OSHA to Modernize the PSM Standard

Pursuant to Executive Order (EO) 13650 “Improving Chemical Facility Safety and Security”, OSHA was directed to modernize their Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 CFR 1910.119). OSHA has issued potential revisions to the standard and convened a Small Business Advocacy Review (SBAR) Panel earlier this year. The Small Business Regulatory Enforcement Fairness Act (SBREFA) Panels were conducted back in June 2016, with the completed report placed in the federal docket on August 1, 2016.

From the documents available on Regulations.gov for Docket ID: OSHA-2013-0020 (https://www.regulations.gov/docket?D=OSHA-2013-0020), OSHA’s Pre-Rule potential revisions include the following:

  • Atmospheric storage tanks exemption for flammable liquids to be applied only to petroleum products wholesalers.
  • Increasing coverage for chemicals with reactive hazards.
  • Require a review of potentially safer alternatives and technology.
  • Add additional chemicals to the Appendix A list of covered chemicals.
  • Require periodic review of current RAGAGEP and implementation.
  • Expand Mechanical Integrity element to include all equipment deemed “critical”.
  • Emergency planning to require coordination with local responders.
  • Require independent third party to complete the three year compliance audits.
  • Implement a Stop Work Authority (SWA) Program for operators to shutdown processes in imminent risk situations.
  • Require root cause analysis in Incident Investigations.
  • Require management sign off on the Process Hazard Analysis (PHA).

127 comments were received during the commenting period, covering the proposed changes and potential costs to implement the standard with those proposed changes. OSHA is still in the Pre-Rule stage and will take the comments from the SBREFA Panel to prepare a proposed rule.

A separate docket (Docket ID: OSHA-2016-0021) has been established with draft guidance documents for PSM compliance for small businesses, storage facilities, and explosives and pyrotechnics manufacturing.


More information on the PSM standard can be found OSHA’s website: https://www.osha.gov/SLTC/processsafetymanagement/ and https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760

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