OSHA’s Interim PSM Enforcement Policy (December 23, 2015)

OSHA’s Process Safety Management (PSM) Standard states that its requirements do not apply to “retail facilities.” 29 CFR 1910.119(a)(2)(i).  On July 22, 2015, OSHA issued a memorandum entitled “Process Safety Management of Highly Hazardous Chemicals and Application of the Retail Exemption (29 CFR 1910.119(a)(2)(i))” (Memorandum). In the Memorandum, OSHA interpreted the term “retail,” as used...