OSHA Issues Updated PSM Enforcement Guidance

OSHA has recently released a 103-page enforcement document that updates process safety management guidance that went into effect on January 26^th. The enforcement document is primarily designed for OSHA inspectors, providing guidance on the expectations regarding policies and procedures from employers. Structured in a question-and-answer format, the directive draws on OSHA’s interpretation letters dating back to 1992. The document also addresses a wide variety of PSM related issues such as chemical monitoring, storage requirements, and acceptable barriers between liquid storage tanks.

OSHA has indicated that the updated guidance is primarily a change in formatting. The content of the directive is based on existing interpretations and content from the old PSM compliance directive. The intent is to have this document work in tandem with the PSM Covered Chemical Facilities National Emphasis Program (ChemNEP).  Under the new structure, the compliance directive includes PSM interpretations and the ChemNEP provides the inspection methodology.