OSHA’s original guidance on PSM and “dispersal of inventory”

Several months ago I posted an article OSHA publishes DRAFT “Process Safety Management for Small Business Compliance” and how it offered some guidance on how facilities could disperse their inventories of Highly Hazardous Chemicals (HHC) and stay out of or get out of PSM.  I have received many e-mails questioning the validity of the material in the DRAFT publication “Process Safety Management for Small Business Compliance” and asking how reliable the instructions are seeing how it was a DRAFT publication.  But long before OSHA published their DRAFT document, they offered up the same advice in a much more “official” document…

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