The future of the OSHA PSM standard

The significance of the proposed PSM changes could be to greatly expand coverage of processes in order to include many not currently covered by the PSM regulation. New chemicals will likely be added to Appendix A, and reactive chemicals (a definition will be needed) also may be covered. What exactly will be the definition of a reactive chemical is unclear at this time, although definitions used in New Jersey in the TCPA Act may guide OSHA. It is likely that atmospheric storage of flammable liquids will be included more specifically and the exemption of these tanks eliminated. In applying RAGAGEP, sites may be required to apply the most recent codes and standards to covered processes, perhaps at the time of PHA auditing: A narrowing of the PSM exemption for retail facilities could bring many of them under the PSM regulation at some level. Process safety management practices should be applied to all facilities that store and process hazardous materials that have fire, explosion, reactivity, and toxic properties. If changes are made to the PSM regulation, many new sites will be covered and will need to formally adopt PSM as defined in the OSHA regulation. The addition of reactive chemicals to the PSM regulation will greatly expand the number of processes covered by the regulation. Keeping up with the most current codes, standards, and legislative changes is a daunting task that may require the support of specialists. The results of the proposed legislation will be an increase in the level of process safety excellence throughout the chemical industries.