Summary
On October 12, 2022, the Occupational Safety and Health Administration (OSHA) held a Stakeholder Meeting to discuss possible updates to the Process Safety Management (PSM) rule. Their aim is to enhance protections for workers and communities. These updates, many of which align with the recent SCCAP changes to the EPA's RMP rule, aim to modernize the PSM standard, address gaps, and respond to lessons learned from past incidents. Proposed changes include new requirements for stop work authority, expanded definitions, updates to mechanical integrity protocols, and additional measures for
employee participation and emergency response coordination.
History
The PSM standard, originally issued in 1992, underwent several enforcement efforts, including National Emphasis Programs for refineries and chemical facilities. Despite these measures, the frequency of incidents involving hazardous chemicals has persisted, highlighting a need for further regulation updates. The current rulemaking effort, which began in response to Executive Order 13650 and the EPA's revisions to the RMP rule, is now taking shape, emphasizing areas where further improvements can be made.
Potential Changes
While we await the official proposed rule, here are some of the potential changes based on the 2022 stakeholder meeting:
Stop Work Authority: Selected employees may be given authority to stop a process when an imminent hazard is identified. This empowers workers to act immediately in the interest of safety.
Root Cause Analysis for Incidents: Incident investigations would require a defined root cause analysis, aiming to identify and correct fundamental management system failures.
Third-Party Compliance Audits: Similar to the SCCAP Rule, facilities with qualifying incidents in the last five years may be required to conduct compliance audits through independent third-party auditors.
Management of Organizational Changes: PSM is likely to formally recognize changes in staffing levels, shifts, or structural changes in organizations as potential hazards needing management.
Employee Participation and Anonymous Reporting: Provisions may expand to include anonymous reporting mechanisms for safety concerns and stronger requirements for employee access to PSM information.
RAGAGEP Requirements: The term "recognized and generally accepted good engineering practices" (RAGAGEP) is expected to be defined clearly within the regulation, with requirements to review and update practices to the latest standards.
Expanded Scope for Reactive Chemicals: Coverage of reactive chemical hazards is likely to expand, closing known gaps that have led to significant incidents in the past.
Written PSM Management Systems: New language may require a fully documented PSM management system, making program accountability and transparency more consistent across all covered facilities.
Conclusion
These changes are still under review, and the formal rulemaking process will include further opportunities for public comment. It is anticipated that the proposed rule may be published soon, after which there will likely be a multi-year compliance timeline.
As with the SCCAP Rule, these potential changes represent a significant shift in how PSM-regulated facilities must operate, making it crucial to start preparing your teams for enhanced compliance measures.
Stay tuned for more detailed breakdowns as these changes develop. Subscribe to keep updated on how these updates might impact your PSM program.
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