February 8, 2024

OSHA Updates Enforcement Document for Process Safety Management Standard

A new OSHA directive outlines the agency’s enforcement policy for its standard on the process safety management of highly hazardous chemicals. The document is primarily intended to help OSHA personnel understand the agency’s technical interpretations of the standard and is not a regulation or substantive rule. The new instruction, which became effective on Jan. 26, cancels and supersedes the previous enforcement directive from 1994. According to OSHA, significant updates to the enforcement document include the removal of an inspection checklist and the addition of a question-and-answer format outlining existing OSHA policies on process safety management. These updates are based on suggestions stemming from OSHA’s “lookback review” of its process safety management standard. Lookback reviews are intended to help OSHA “determine whether [existing] standards should be maintained without change, rescinded or modified.”

The questions and responses in the new OSHA instruction include references to applicable letters of interpretation or standard interpretations as well as current agency compliance guidance. OSHA addresses topics such as process hazard analysis, training, contractors, and mechanical integrity. Hot work permits, management of change, emergency planning and response, and compliance audits are also discussed.

The new OSHA directive is available as a PDF.

In 2022, OSHA announced that it was considering changes to the scope and provisions of its process safety management standard, but according to the regulatory agenda for the Department of Labor, the rulemaking remains in the pre-rule stage. Potential changes include resuming enforcement for oil and gas production facilities; expanding requirements for reactive chemical hazards; updating the standard’s list of highly hazardous chemicals; and expanding the scope of the standard to include oil- and gas-well drilling and servicing. Other changes could strengthen employee participation, require safer technology and alternatives analysis, and cover the mechanical integrity of critical equipment. A stakeholder meeting on this topic took place in October 2022, and recordings of the meeting are available from OSHA’s process safety management page.

Related: An article published in the October 2021 issue of The Synergist examines OSHA's process safety management standard, which establishes a roadmap for occupational and environmental health and safety professionals to ensure the safety of workers and communities.