With all the recent attention being paid to EPA and it’s Risk Management Plan amendments and many of those amendments being rescinded by the new administration, I thought it would be a good time to remind those in the PSM/RMP world, that OSHA has their own wish list (my phrase – not theirs) and some of their proposed changes could have MUCH larger impacts on businesses than any of the EPA RMP Amendments. For example, Number 1 on their “wish list” is clarifying the exemption for atmospheric storage tanks. The existing PSM standard applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.” 29 CFR § 1910.119(a)(1)(ii). OSHA is considering changing the language in § 1910.119(a)(1)(ii)(B) to make clear that it applies ONLY to processes in NAICS 4247 Petroleum and Petroleum Products Merchant Wholesalers.
Here are the other 15 items OSHA is working on in regards to their PSM standard: