During an opening conference, CSHOs can (FOM states “SHALL”) request a list of the chemicals on-site and their respective maximum intended inventories. CSHOs shall review the list of chemicals and quantities, and determine if there are highly hazardous chemicals (HHCs) listed in §1910.119, Appendix A or flammable liquids or gases at or above the specified threshold quantity. CSHOs may ask questions, conduct interviews, and/or conduct a walkaround to confirm the information on the list of chemicals and maximum intended inventories. If there is an HHC present at or above threshold quantities, CSHOs shall use the following criteria to determine if any exemptions apply:
- CSHOs shall confirm that the facility is not: a retail facility; oil or gas well drilling or servicing operation; or a normally unoccupied remote facility (§1910.119(a)(2)). If the facility is one of these types of establishments, PSM does not apply.
- If management believes that the process is exempt, CSHOs shall ask the employer to provide DOCUMENTATION or OTHER INFORMATION to support that claim.
According to §1910.119 (a)(1)(ii), a process may be exempt if the employer can demonstrate that the covered chemical(s) are:
- Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by the standard, or
- Flammable liquids with a flashpoint below 100 ºF (37.8ºC) stored in atmospheric tanks or transferred, which are kept below their normal boiling point without the benefit of chilling or refrigeration.
NOTE: Current agency policies for applying exemptions can be found on the OSHA website. See CPL 03-00-010, Petroleum Refinery Process Safety
Management National Emphasis Program, August 18, 2009.
Source: Page 3-10 of the 2015 FOM (CPL 02-00-159)CPL 02-00-159)