Potential PSM scope items:
- Clarifying the exemption for atmospheric storage tanks
- Removing the exemption for Oil- and Gas-Well Drilling and Servicing
- Resuming Enforcement for Oil and Gas Production Facilities
- Covering reactive chemical hazards
- Updating and expanding the list of HHCs in Appendix A of the existing PSM standard
- Covering dismantling and disposal of explosives and pyrotechnics under the requirements of PSM (through an amendment to 1910.109 Explosives and Blasting Agents).
Potential PSM Requirement Changes:
- Adding management-system elements
- Requiring a written PSM program and records retention policy
- Requiring a system for evaluation and corrective action
- Expanding employee participation elements to include a system for employee input and stop work authority
- Requiring evaluation, through the Process Hazard Analysis requirements of 29 CFR 1910.119(e), of updates to applicable recognized and generally accepted good engineering practices (RAGAGEP)
- Requiring safer technology and alternatives analysis during the process hazard analysis (PHA)
- Requiring management sign-off on when PHA recommendations are rejected
- Expanding the types of equipment covered by the Mechanical Integrity provisions of 29 CFR 1910.119(j)
- Clarifying existing employer requirements to manage organizational changes
- Requiring root causes analysis for incident investigation
- Requiring coordination of emergency planning and coordination with local emergency-response authorities
- Requiring third-party compliance audits