No, the employer is not required to include findings and recommendations from the facility siting study report in the same PHA worksheet or recommendations log to comply with 29 CFR § 1910.119(e)(5) and 29 CFR § 1910.119(e)(7).
29 CFR § 1910.119(e)(3)(v) requires an employer to address facility siting as part of the PHA. When facility siting studies are conducted to supplement a PHA, all findings and recommendations from the facility siting study must be documented and the employer must ensure timely resolution of findings and recommendations as required in 29 CFR § 1910.119(e)(5). Since the PSM standard is performance-based, OSHA does not specify the way an employer documents, compiles, or tracks actions taken on PHAs or facility siting study findings and recommendations. Nevertheless, the employer’s documented findings and recommendations from the facility siting study must be maintained and consistent with the employer’s system to promptly address those findings and recommendations as required in 29 CFR § 1910.119(e)(5) and 29 CFR § 1910.119(e)(7).