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PT Notes

Changes to OSHA's PSM Standard

PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.

On August 30, 2022, OSHA published a notice in the Federal Register (87 FR 53020) announcing a stakeholder meeting regarding changes to OSHA's Process Safety Management (PSM) standard and inviting comments on the potential changes being considered.

Originally, the meeting was scheduled for September 28, 2022 but has been postponed to a later date to be announced.

The potential changes to the scope of the current PSM standard that OSHA is considering 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

  • Defining the limits of a PSM-covered process

Potential changes to particular provisions of the current PSM standard that OSHA is considering include:

  • Amending paragraph (b) to include a definition of RAGAGEP

  • Amending paragraph (b) to include a definition of critical equipment

  • Expanding paragraph (c) to strengthen employee participation and include stop work authority

  • Amending paragraph (d) to require evaluation of updates to applicable recognized and generally accepted good engineering practices (RAGAGEP)

  • Amending paragraph (d) to require continuous updating of collected information

  • Amending paragraph (e) to require formal resolution of Process Hazard Analysis (PHA) team recommendations that are not utilized

  • Expanding paragraph (e) by requiring safer technology and alternatives analysis (STAA)

  • Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in PSM programs, in response to Executive Order 13990

  • Expanding paragraph (j) to cover the mechanical integrity of any critical equipment

  • Clarifying paragraph (j) to better explain ''equipment deficiencies''

  • Clarifying that paragraph (l) covers organizational changes

  • Amending paragraph (m) to require root cause analysis

  • Revising paragraph (n) to require coordination of emergency planning with local emergency response authorities

  • Amending paragraph (o) to require third-party compliance audits

  • 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'')

  • 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'')

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