Does PSM/RMP standards need a Ultimate Work Authority and Stop Work Authority concepts?

Recently OSHA has “requested information” regarding certain aspects of their Process Safety Management standard. In this effort, OSHA has suggested that the standard is revised to clarify certain aspects and to include some items they feel are needed. In the public posting, OSHA stated they are considering adopting management-system elements from safety standards that other federal agencies promulgated since 1992. For example, the Bureau of Safety and Environmental Enforcement’s (BSEE) Revisions to Safety and Environmental Management Systems (SEMS II) final rule (78 FR 20423; 04/05/2013), which revised a number of requirements in 30 CFR 250, Subpart S, contains management-system elements not included in the PSM standard. BSEE describes two of the main additional elements as follows:

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