In the recent OSHRC decision where the ALJ decided that “tight-fitting” doors for an engine room/machinery room doors were not a PSM requirement since “doors” were not part of the covered process. What is confusing is that the company successfully convinced the ALJ that ASHRAE 15 was not their chosen RAGAGEP (even though they stated it was in their PSI) and that the State’s Revised IMC was the required RAGAGEP. OSHA had, correctly, referenced ASHRAE 15 in both of these citations. So if we throw out ASHARE 15 and use the IMC to understand the importance of “tight-fitting doors” we see the following…