Last week I posted a June 2016 OSHRC decision in which an Administrative Law Judge (ALJ) sided with OSHA on a number of PSM citations regarding a fatal boiler explosion that occurred within a PSM-covered process. Since that posting, I have received dozens of e-mails asking for more explanation and how I suggest managing this type of situation. PLEASE know that I merely clean-up, edit out names, and make the decision easier to read and post the info as a “for your information” article. I am in no way picking on any industry, company, nor am I 100% in agreement with OSHA or the OSHRC on each decision; those who read all my posting will attest to that. But this decision I fully agree with and yet – that in NO WAY means that every boiler “connected” to a PSM/RMP covered process will be within the battery limits of the covered process. In the OSHRCS case, the boiler was clearly “covered” but for reasons that many other boilers would not be impacted by. Let me explain…