On Jan. 29, OSHA revealed an unexpected update that overhauls process safety management (PSM) guidance. The federal worker safety enforcement directive for facilities with significant chemical quantities, such as refineries and chemical plants, is housed in a 103-page document primarily intended for OSHA inspectors. The directive outlines expectations for employers and incorporates updated advice since the last revision in 1994. It is based on OSHA's interpretation letters from 1992 to the present, addressing compliance triggers, chemical monitoring, storage barriers and interconnectivity of operations.
“OSHA’s release of the 103-page enforcement guidance is a welcome update to the 1994 PSM guidance,” according to Chemical Processing compliance columnist and attorney Lynn Bergeson. “While directed at OSHA enforcement personnel, the document provides much-needed direction on OSHA’s interpretation of the PSM standard. It is presented in an easy-to-follow Q&A format. The content is based on OSHA’s interpretation letters dating back to issuance of the original standard. While not everyone will agree with guidance content, it is a useful basis for discussion on enforcement issues and provides OSHA’s “take” on key PSM compliance matters.”