ILTA Group Reviews OSHA Efforts on Process Safety Management Program
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Michael Stroud
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ILTA Group Reviews OSHA Efforts on Process Safety Management Program

ILTA has offered to serve as a resource to OSHA as it considers revisions to the PSM standard, which has not been updated since 1992.   ILTA formed a working group to provide member insights and guidance about the OSHA PSM (and the EPA Risk Management Program, see also the article following). The working group met and discussed ILTA's members interests in the two safety programs. The consensus from the group was to offer ILTA insights and guidance to help shape any prospective OSHA-proposed rule that would impact ILTA members. ILTA continues to remain engaged in the OSHA PSM process and will look to work with the working group and other ILTA members.

On August 30, OSHA issued a Federal Register notice requesting informal stakeholder engagement on the OSHA Process Safety Management ("OSHA PSM" or "PSM"). The notice indicated that OSHA wanted to reengage on the PSM standards and was doing so via an initial stakeholder meeting. OSHA held a stakeholder meeting on October 12, 2022. ILTA presented at the stakeholder meeting.   OSHA's intention with the stakeholder meeting is to gather information about specific questions about revisions to the PSM standard. OSHA requested stakeholders to provide information about changes to the PSM standard in the areas of:

-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 reactive chemical hazards;

-Updating and expanding the list of highly hazardous chemicals in Appendix A;

And many other topics, detailed in the Federal Register notice 2022-20261.pdf ( (linked here).

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