On October 12th, 2022, OSHA held a virtual informal stakeholder meeting to give the public a chance to provide testimony regarding several potential changes and provisions to the current Process Safety Management (PSM) Standard (29 CFR 1910.119).
Potential changes could include:
- Clarifying the exemption for atmospheric storage tanks;
- Expanding the scope to include oil- and gas-well drilling and servicing;
- Resuming enforcement for oil and gas production facilities;
- Expanding PSM coverage and requirements for reactive chemical hazards;
- Updating and expanding the list of highly hazardous chemicals in Appendix A;
- Amending paragraph (k) of the Explosives and Blasting Agents Standard (§ 1910.109) to extend PSM requirements to cover dismantling and disposal of explosives and pyrotechnics;
- Clarifying the scope of the retail facilities exemption; and
- Defining the limits of a PSM-covered process.
Amendments to the standard could include:
- A definition of “recognized and generally accepted as good engineering practices” (RAGAGEP);
- A definition of critical equipment;
- Strengthening employee participation and including stop-work authority;
- Requiring evaluation of updates to applicable RAGAGEP;
- Requiring continuous updating of collected information;
- Requiring formal resolution of process hazard analysis team recommendations that are not utilized;
- Requiring safer technology and alternatives analysis;
- Clarifying requirements for considering natural disasters and extreme temperatures in employers’ PSM programs;
- Expanding coverage of the mechanical integrity of any critical equipment;
- Better explaining the definition of “equipment deficiencies”;
- Clarifying the coverage of organizational changes;
- Requiring root cause analysis;
- Requiring coordination of emergency planning with local emergency response authorities;
- Requiring third-party compliance audits;
- Requiring that employers develop a system for periodic review of their PSM systems and the need for any revisions (previously referred to as “Evaluation and Corrective Action”); and
- Requiring the development of written procedures for all elements specified in the standard and to identify records required by the standard, along with a records retention policy (previously referred to as “Written PSM Management Systems”).
The official notice released by the department of labor can be found at the link below:
