OSHA Considering Changes and Updates to the PSM Standard

OSHA has been accepting comments on several proposed changes to its Process Safety Management, or PSM standard. PSM is an OSHA regulation that is concerned with processes at your facility that use highly hazardous chemicals. PSM provides a compliance framework to evaluate each process with the end goal of no spills, fires, explosions, reactions, releases or other incidents arise from their use.

⚡ TL;DR: OSHA is proposing the first major updates to the PSM standard since 1992, including new requirements for employee participation, third-party audits, process hazard analysis, and potential coverage expansion to oil and gas operations. Facilities using highly hazardous chemicals need to understand these changes to ensure continued compliance.

The official standard can be found at 29 CFR 1910.119. PSM hasn’t been updated since its creation in 1992. OSHA has been reevaluating PSM, and EPA has been similarly been reevaluating their Risk Management Plan, or RMP standard since the 2013 West, Texas fertilizer storage facility explosion. Just like the difference between OSHA and EPA, PSM is meant to protect workers while RMP is meant to protect the environment.

⚠️ What’s at stake: Facilities that fail to maintain PSM compliance face serious OSHA citations with penalties ranging from $16,550 for serious violations up to $165,514 for willful violations, plus potential operational shutdowns and increased regulatory scrutiny if a chemical incident occurs.

Potential changes to PSM could include:

Clarifying the exemption for atmospheric storage tanks; Strengthening employee participation and stop work authority; Requiring the development of written procedures for all elements specified in the standard, identification of records required by the standard, and a records retention policy; Including oil-well and gas-well drilling and servicing as part of the standard and resuming enforcement for oil and gas production facilities; Expanding coverage and requirements for reactive chemical hazards; Updating and expanding the list of highly hazardous chemicals in Appendix A; Requiring continuous updating of collected information; Requiring formal resolution of Process Hazard Analysis team recommendations that are not utilized; Better defining what critical equipment means, what equipment deficiencies are, and expanding paragraph (j) to cover the mechanical integrity of critical equipment; Clarifying the scope of the retail facilities exemption; Defining the limits of a PSM-covered process; Better defining recognized and generally accepted as good engineering practices (RAGAGEP) and requiring evaluations of any updates to them; Requiring safer technology and alternatives analysis; Requiring consideration of natural disasters and extreme temperatures; Amending paragraph (k) of the Explosives and Blasting Agents Standard to cover dismantling and disposal of explosives and pyrotechnics; Clarifying that paragraph (l) covers organizational changes; Amending paragraph (m) to require root cause analysis; Requiring coordination of emergency planning with local emergency-response authorities; Requiring third-party compliance audits; and, Including requirements for employers to develop a system for periodic review of and necessary revisions to their PSM management systems.

This action is currently in the comments stage, and stakeholder meetings were held in October 2022 with comments accepted through mid-November 2022. We will keep you updated when anything final is published.

Does your facility’s PSM program align with emerging OSHA standards? iSi’s PSM audit and consulting team helps chemical processors, refineries, and manufacturing facilities conduct compliance gap analyses, develop process hazard analyses, and implement management systems that meet proposed requirements. Get started →

💰 The cost of non-compliance: OSHA serious violations for PSM deficiencies carry penalties up to $16,550 each. Willful violations can result in penalties exceeding $165,514. Beyond fines, incidents from inadequate PSM programs can trigger facility shutdowns, criminal liability, and massive civil litigation costs.

Frequently Asked Questions

Q: What is the OSHA Process Safety Management (PSM) standard and who must comply?

Process Safety Management (PSM) is OSHA regulation 29 CFR 1910.119 that applies to facilities using highly hazardous chemicals in processes. PSM requires a comprehensive management framework to prevent spills, fires, explosions, and releases. The standard applies to chemical manufacturing, processing, and storage facilities that meet threshold chemical quantities specified in the PSM standard’s Appendix A.

Q: Why hasn’t the PSM standard been updated since 1992?

The PSM standard was created in 1992 and remained essentially unchanged for 30 years. OSHA began reevaluating PSM following the 2013 West, Texas fertilizer storage facility explosion to address modern hazards, include emerging chemical processes, and strengthen worker protection and participation requirements in safety management systems.

Q: What is the difference between OSHA’s PSM standard and EPA’s Risk Management Plan (RMP) standard?

OSHA’s PSM standard focuses on protecting workers from process hazards involving highly hazardous chemicals, while EPA’s RMP standard (40 CFR Part 68) focuses on protecting the public and environment from accidental chemical releases. Many facilities must comply with both standards, which have overlapping requirements but different protective objectives.

Q: What are the potential changes to the PSM standard that OSHA is considering?

Proposed changes include strengthening employee participation and stop-work authority, expanding coverage to oil and gas well drilling and servicing, requiring root cause analysis for incidents, requiring safer technology alternatives analysis, addressing reactive chemicals, and requiring coordination with local emergency response authorities. These updates would significantly expand PSM requirements for covered facilities.

Every satisfactory PSM compliance program starts with knowing where the gaps are. iSi Environmental helps industrial and manufacturing facilities with PSM audits, process hazard analysis, mechanical integrity assessments, and management system development. Schedule a compliance review →

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