PSM Changes Considered by OSHA

Dec 10th, 2013 | By | Category: Health and Safety

EHS Journal - Bridge in the Night by Michal Zacharzewski

The U.S. Occupational Safety and Health Administration (OSHA) is requesting information and comments to address possible changes and updates in the

  • Process Safety Management (PSM) standard;
  • Explosives and Blasting Agents standard;
  • Flammable Liquids standard; and
  • Spray Finishing standard.

OSHA is also considering changes to its PSM enforcement policies.


Possible PSM Changes

According to the Request for Information (RFI) document, OSHA is considering changes in the following areas:

1. Clarifying the PSM exemption for atmospheric storage tanks (to include these tanks in the definition of PSM-covered tanks);

2. Oil and Gas Well Drilling and Servicing (to include oil and gas well drilling as covered processes);

3. Oil and Gas Production Facilities (to include oil and gas production facilities as covered processes);

4. Expanding PSM coverage and requirements for reactivity hazards;

5. Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard;

6. Revising the PSM Standard to require additional management system elements;

7. Amending paragraph (d) of the PSM Standard to require evaluation of updates to applicable recognized and generally accepted good engineering practices (RAGAGEP);

8. Clarifying the PSM Standard by adding a definition for RAGAGEP;

9. Expanding the Scope of Paragraph (j) of the PSM Standard to cover the mechanical integrity of any safety-critical equipment;

10. Clarifying paragraph (l) of the PSM Standard with an explicit requirement that employers manage organizational changes;

11. Revising paragraph (n) of the PSM Standard to require coordination of emergency planning with local emergency-response authorities;

12. Revising Paragraph (o) of the PSM Standard to require third-party compliance audits;

13. Expanding the Requirements of §1910.109 to cover dismantling and disposal of explosives, blasting agents, and pyrotechnics;

14. Updating §§1910.106 and 1910.107 based on the latest applicable consensus standards;

15. Updating the regulations addressing the storage, handling, and management of ammonium nitrate;

16. Changing the enforcement policy of the PSM exemption for retail facilities; and

17. Changing the enforcement policy for Highly Hazardous Chemicals listed in Appendix A of the PSM Standard without specific concentrations.


Additional Information

OSHA made the RFI available to the public pending its publication in the Federal Register. Until the date of publication, the RFI can be found at

After publication, the RFI can be accessed from or through the Federal Register.


About the Author

Michael Bittner, CPEA, is the Director of post-merger integration (PMI) services at Ramboll Environment & Health, a leading global environmental and health sciences consulting firm. Michael leads a team of consultants that provides clients and legal counsel with the strategic advice, technical assistance, and temporary staffing needed to overcome the EHS challenges associated with mergers, acquisitions, divestitures, and spin-offs. He has published several articles on the challenges of post-merger integration, is a former member of the Auditing Roundtable’s board of directors, and also serves as editor of the EHS Journal, an on-line magazine for EHS professionals.

Photograph: Bridge in the Night by Michal Zacharzewski, Warsaw, Poland.


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