OSHA PSM Standard is up for Change Too
Recently we posted that the EPA’s RMP law was in proposed changed to reflect the changes submitted in the Obama era, and now in the same month it looks to as if OSHA is going to do the same. Public comment on the new OSHA proposed changes will be accepted up to October of 2022.
If you are in need of a class to introduce you to PSM/RMP or a refresher to get caught up on all the new proposed changes, check out our PSM/RMP training schedule at this link. We also offer the PSM/RMP class in an online format.
DEPARTMENT OF LABOR Occupational Safety and Health Administration [Docket No. OSHA–2013–0020]
Process Safety Management (PSM); Stakeholder Meeting. The potential changes to the scope of
the current PSM standard that OSHA is considering include:
1. Clarifying the exemption for atmospheric storage tanks;
2. Expanding the scope to include oil and gas-well drilling and servicing;
3. Resuming enforcement for oil and gas production facilities;
4. Expanding PSM coverage and requirements for reactive chemical hazards;
5. Updating and expanding the list of highly hazardous chemicals in Appendix A;
6. 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;
7. Clarifying the scope of the retail facilities exemption; and
8. Defining the limits of a PSM covered process. The potential changes to particular provisions of the current PSM standard that OSHA is considering include:
1. Amending paragraph (b) to include a definition of RAGAGEP;
2. Amending paragraph (b) to include a definition of critical equipment;
3. Expanding paragraph (c) to strengthen employee participation and include stop work authority;
4. Amending paragraph (d) to require evaluation of updates to applicable recognized and generally accepted as good engineering practices (RAGAGEP);
5. Amending paragraph (d) to require continuous updating of collected information;
6. Amending paragraph (e) to require formal resolution of Process Hazard Analysis team recommendations that are not utilized;
7. Expanding paragraph (e) by requiring safer technology and alternatives analysis;
8. Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in their PSM programs, in response to E.O. 13990;
9. Expanding paragraph (j) to cover the mechanical integrity of any critical equipment;
10. Clarifying paragraph (j) to better explain ‘‘equipment deficiencies’’
11. Clarifying that paragraph (l) covers organizational changes;
12. Amending paragraph (m) to require root cause analysis;
13. Revising paragraph (n) to require coordination of emergency planning local emergency-response
authorities;
14. Amending paragraph (o) to require third-party compliance audits;
15. Including requirements for employers to develop a system for periodic review of and necessary revisions to their PSM management systems (previously referred to as ‘‘Evaluation and Corrective Action’’); and
16. 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’’).
Regardless of attendance at the stakeholder meeting, interested persons may submit written comments
electronically at https://www.regulations.gov, which is the Federal eRulemaking Portal. All comments, attachments, and other material must identify the agency’s name and the docket number for this stakeholder meeting (OSHA–2013–0020). You may supplement electronic submissions by uploading document electronically. All comments and additional materials must be submitted by October 28, 2022.
