This week, OSHA once again showed their intent to issue PPE citations during PSM NEP audits. They are very content to issue a citation against 1910.132(a) or (d) when the process contains a flammable liquid and somehow the employer’s PPE Hazard Assessment determined that Flame Retardant Clothing (FRC) is not necessary. But there is another VERY STRONG and DIRECT link between PSM and PPE… Operating Procedures.