OSHA to host small business panel on chemical safety improvements

Board to review potential revisions to PSM standard

Posted June 2, 2016

OSHA is initiating a Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA's Process Safety Management Program (PSM) standard.

This effort arises from the President's Executive Order 13650, “Improving Chemical Facility Safety and Security,” which charged the Agency to “identify issues related to modernization of the PSM Standard and related standards necessary to meet the goal of preventing major chemical accidents.”

The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA's 2013 Request for Information, and lessons learned from accidents involving highly hazardous chemicals.

Topics to be considered by the Small Business Panel include:

  • Clarifying the PSM exemption for atmospheric storage tanks
  • Oil and gas-well drilling and servicing
  • Oil and gas-production facilities
  • Expanding PSM coverage and requirements for reactivity hazards
  • Expanding the scope of paragraph (e) by requiring safer technology and alternatives analysis
  • Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM standard
  • Revising the PSM standard to require additional management-system elements
  • Amending Paragraph (d) of the PSM Standard To Require Evaluation of Updates to Applicable RAGAGEP
  • Clarifying the PSM Standard by adding a definition for RAGAGEP
  • Expanding the scope of paragraph (j) of the PSM standard to cover the mechanical integrity of any safety-critical equipment
  • Revising paragraph (n) of the PSM standard to require coordination of emergency planning with local emergency-response authorities
  • Amending paragraph (m) of the existing PSM standard to require root cause analysis
  • Revising paragraph (o) of the PSM standard to require third-party compliance audits
  • Expanding the requirements of §1910.109 to cover dismantling and disposal of explosives, blasting agents, and pyrotechnics
  • Several additional minor modifications which largely codify existing OSHA interpretations of the PSM standard
  • Solicit feedback on any similar provision of EPA's RMP rule and the PSM standard that could be streamlined

PSM Small Business Regulatory Enforcement Fairness Act (SBREFA) Schedule

  • June 2 - Convene SBREFA panel
  • Teleconferences with SERs
    • June 21 1:30pm - 4:30pm
    • June 22 1:30pm - 4:30pm
    • June 28 9:30am - 12:30pm
    • June 29 9:30am - 12:30pm
  • July 8 - all written comments from SERs due
  • August 1 - Complete panel, and report placed in docket

1910 OSHA GuideOSHA Rules for General Industry: 1910 and Other Essential Regulations puts OSHA’s workplace safety regulations in a reader-friendly format.


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