Yes. When OSHA enacted the PSM requirement, it did so in an effort to eliminate or minimize catastrophic incidents involving highly hazardous chemicals. PSM programs are risk reduction strategies. When implemented correctly, reducing storage inventories of highly hazardous chemicals and isolating stored quantities in distinct facility areas are acceptable risk reduction strategies.
Employers at storage facilities may, therefore, choose to safely alter their storage practices to reduce chemical risks—and fall below PSM applicability criteria—instead of complying with PSM. However, such facilities must still comply with other applicable OSHA standards and section (5)(a)(1) of the OSH Act, the “General Duty Clause” (which requires that employers provide workplaces free from recognized hazards that are likely to cause death or serious physical harm).
CLICK HERE for the recently released DRAFT FAQs
CLICK HERE for the OSHA Publication Process Safety Management for Storage Facilities