Process Safety Management

Stakeholder Meeting

October 12, 2022

Presentation outline

 What is PSM?
 History of this rulemaking?
 Why do we need rulemaking?
 What are the issues?
 Rulemaking process and what’s next?
 OSHA’s PSM Standard

 Scope and Application

– Process containing a threshold quantity of a highly hazardous chemical (HHC)
• “Process” - activity that includes use, storage, manufacturing, handling, or the on-site movement of highly
hazardous chemicals
• Flammable liquids and gasses
• Appendix A – list chemicals with threshold quantities
– Manufacture of explosives and pyrotechnics regardless of quantities by reference in 1910.109
– Several exemptions and exceptions
 Requirements
– Performance-based standard with some specification requirements
– Requires a management system with 14 specific elements

OSHA PSM Standard 1910.119: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.119

OSHA PSM Website: https://www.osha.gov/process-safety-management
Significant Events and OSHA Actions
Significant Events and OSHA Actions
EPA Rulemaking

 PSM and RMP come from Clean Air Act Amendments of 1990
 Mostly identical with some additional RMP outside the fence line requirements
 CAAA requires agency coordination
 2017 RMP Amendments Rule
 2019 RMP Reconsideration Rule – rescinded most of the 2017 amendments
 2017/2019 Rule Litigation
 RMP Safer Communities by Chemical Accident Prevention Rule
 January 2021 - EO 13990 – Protecting Public Health and the Environment and Restoring Science To Tackle
the Climate Crisis
 June/July 2021 - Public Listening Sessions
 August 2022 - NPRM
 STAA, RCA, RAGAGEP updates, 3rd Party Audits, Define retail, Natural hazards emphasized
What are the Issues?

Scope and Application

 Clarifying
• The atmospheric storage tank exemption
• The retail facilities exemption
• Threshold quantities for mixtures of Appendix A substances
 Consider adding coverage for
• Oil and gas well drilling and servicing operations
• Reactive chemical hazards
• Dismantling of explosives and pyrotechnics
 Economic analysis for oil and gas production facilities
 Consider updates to Appendix A
• New chemicals, including AN
• New concentrations
What are the Issues?
Requirement changes being considered:
 Defining RAGAGEP
 Mechanical integrity for all “critical” equipment
 Stop work authority
 Collecting & assessing reactive hazard data
 Assessing updates to RAGAGEP
 Safer Technology and Alternatives
 Rationale for PHA recommendations that are
not adopted
 Clarifying equipment “deficiencies”
 Clarifying management of organizational
change
 Root cause investigation
 Emergency response coordination
 Third party audits
 Written PSM management systems
 Evaluation and corrective action
 Codifying major interpretations
 PHA consideration of natural disasters and
extreme temperatures (E.O. 13990)
 Our Next Steps
 Continue research
and data/comment evaluation
 ​Work toward a proposed rule
 Continue to coordinate with the
EPA
Opportunities for Public Comment
 Already completed
– Comments in response to the RFI
– Comments during EO 13650
– Comments in response to the SBAR Panel
– Stakeholder Meeting
 Future
– Comments on Proposed Rule
– Possible Public Hearings