OSHA has started its Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA’s Process Safety Management Program (PSM) standard. The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA’s 2013 Request for Information and lessons learned from accidents involving highly hazardous chemicals. Topics to be considered by the Small Business Panel include:
- Clarifying the PSM Exemption for Atmospheric Storage Tanks
- Oil and Gas-Well Drilling and Servicing
- Oil and Gas-Production Facilities
- Expanding PSM Coverage and Requirements for Reactivity Hazards
- Expanding the scope of Paragraph (e) by requiring safer technology and alternatives analysis
- Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard
- Revising the PSM Standard To Require Additional Management-System Elements
- Amending Paragraph (d) of the PSM Standard To Require Evaluation of Updates to Applicable RAGAGEP
- Clarifying the PSM Standard by Adding a Definition for RAGAGEP
- Expanding the Scope of Paragraph (j) of the PSM Standard To Cover the Mechanical Integrity of Any Safety-Critical Equipment
- Revising Paragraph (n) of the PSM Standard To Require Coordination of Emergency Planning With Local Emergency-Response Authorities
- Amending Paragraph (m) of the existing PSM standard to require root cause analysis
- Revising Paragraph (o) of the PSM Standard To Require Third-Party Compliance Audits
- Expanding the Requirements of § 1910.109 To Cover Dismantling and Disposal of Explosives, Blasting Agents, and Pyrotechnics
- Several additional minor modifications which largely codify existing OSHA interpretations of the PSM standard
- Solicit feedback on any similar provision of EPA’s RMP rule and the PSM standard that could be streamlined.
CLICK HERE for more on the Small Business Advocacy Review Panel.