The potential changes of scope 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.
The potential changes to particular provisions of the existing PSM standard that OSHA is considering include:
- Expanding the scope of Paragraph (c) of the existing standard to include enhanced employee participation and stop work authority
- Amending Paragraph (d) of the existing PSM standard to require evaluation of updates to applicable recognized and generally accepted good engineering practices (RAGAGEP)
- Expanding the scope of Paragraph (e) by requiring safer technology and alternatives analysis
- Expanding the scope of Paragraph (j) of the existing PSM standard to cover the mechanical integrity of any critical equipment
- Revising Paragraph (n) of the existing PSM standard to require coordination of emergency planning with local emergency-response authorities
- Amending Paragraph (e) of the existing PSM standard to require formal documentation with management signature(s), approving the actions taken (or lack thereof) in order to
resolve PHA team recommendations - Amending Paragraph (m) of the existing PSM standard to require root cause analysis
- Revising Paragraph (o) of the existing PSM standard to require third-party compliance audits
- Revising the PSM standard to require additional management-system elements
In addition, OSHA is considering several minor modifications which largely codify existing OSHA interpretations of the PSM standard.
| PSM Standard Section | Proposed Change(s) |
| (a) Application |
Clarifying the Atmospheric Storage Tank Exemption Clarify the scope of the retail facilities exemption Adding Oil and Gas Drilling and Servicing Adding Reactive Chemical Hazards Coverage Clarifying threshold quantity coverage of mixtures of covered HHCs Adding dismantling of explosives and pyrotechnics (by amendments to 1910.119(k)) |
| (b) Definitions |
Adding RAGAGEP Definition Adding critical equipment definitions |
| (c) Employee Participation | Stop Work Authority |
| (d) Process Safety Information (PSI) |
Collect Reactive Chemical Hazard Data Assessing Updates to Selected RAGAGEP Continuous Updating of Collected Information |
| (e) Process Hazards Analysis (PHA) |
Assessing Reactive Chemical Hazards Performing Safer Technology and Alternatives Analysis Requiring PHA Teams to Identify “Critical” Equipment Requiring Rationale for PHA Recommendations that are Not Utilized |
| (f) Operating Procedures | N/A |
| (g) Training | N/A |
| (h) Contractors | N/A |
| (i) Pre-startup Safety Review (PSSR) | N/A |
| (j) Mechanical Integrity (MI) |
Adding “Critical” to the List of Covered Equipment Clarifying “Equipment Deficiencies” |
| (k) Hot Work Permit | N/A |
| (l) Management of Change (MOC) | Clarifying Organizational Changes |
| (m) Incident Investigation | Adding Root Cause Analysis Requirement |
| (n) Emergency Planning and Response | Adding Emergency Response Coordination and Training |
| (o) Compliance Audits | Adding Third-Party Audit Requirements |
| (p) Trade Secrets | N/A |
| (q) New Elements | |
| Written PSM Management Systems | |
| Evaluation and Corrective Action | |
| Appendix A List of Covered Chemicals |
Updating the List of Covered Chemicals New Chemicals New Concentrations for Existing Chemicals |