The quick and easy answer is YES and before the changing of Presidential administrations the wheels were in motion, even after several court set-backs. But some would like to accuse me of being a “consultant” and spreading fear to drum up business. I used to laugh off these comments and accusations, but today I received a call on my way home from a great day of training that had me thinking… I wonder if my other clients believe me when I tell them that OSHA has a “wish list” of items they want to see changed? This is not some kind of insider information; this is publically available information. Now whether or not OSHA is successful in getting these changes thru is debatable. What’s not debatable is this is OSHA’s wish list, not some “Haywood list” that some consultant is planting “into your head to scare you so you’ll call him back” (paraphrasing). So what are the items on OSHA’s PSM Wishlist:
NOTE: for those who have been following the RMP Amendments mess, you will see a lot of similar ideas!
The potential changes in the scope of the standard include:
- Clarifying the EXEMPTION for ATMOSPHERIC STORAGE TANKS
- Expanding the scope to include OIL- AND GAS-WELL DRILLING AND SERVICING
- RESUMING ENFORCEMENT for Oil and Gas Production Facilities
- Expanding PSM coverage and requirements for REACTIVITY HAZARDS
- Updating and EXPANDING THE LIST OF HHCS IN APPENDIX A of the existing PSM standard
- Amending Paragraph (k) of the Explosives and Blasting Standard to cover dismantling and disposal of explosives and pyrotechnics under the requirements of PSM.