Is “dispersal of inventory” an accepted method to maintain inventories BELOW PSM/RMP Thresholds?
The simple and short answer is YES. In fact, OSHA covers “dispersal of inventory” in their 1994 Compliance Directive: 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals — Compliance Guidelines and Enforcement Procedures. In this directive OSHA asks and answers the following questions regarding “dispersal of inventory”: Can an employer who keeps threshold…...