Global Workplace Insider - A Norton Rose Fulbright Blog

The U.S. Department of Labor’s Occupational Safety and Health Administration is contemplating several, and extensive, changes to its existing Process Safety Management (PSM) standard, and will be seeking public comments.

Broadly speaking, the PSM standard requires employers to implement safety programs that identify, evaluate and control highly hazardous chemicals.

Contemplated changes to the current PSM standard will:

  • Clarify the exemption for atmospheric storage tanks;
  • Expand the scope of the standard to include oil- and gas-well drilling and servicing;
  • Resume enforcement for oil and gas production facilities;
  • Expand PSM coverage and requirements for reactive chemical hazards;
  • Update and expand the list of what are considered as highly hazardous chemicals;
  • Amend the Explosives and Blasting Agents Standard (§ 1910.109) to extend PSM requirements to cover dismantling and disposal of explosives and pyrotechnics;
  • Clarify the scope of the retail facilities exemption; and,
  • Define the limits of a PSM-covered process.

Modifications and amendments to multiple provisions of the current PSM standard are also contemplated, including:

  • Adding a definition of “Recognized And Generally Accepted Good Engineering Practices” (RAGAGEP);
  • Defining “critical equipment”;
  • Strengthening employee participation and stop work authority; and,
  • Requiring, among others, the following:
    • Evaluation of updates to applicable RAGAGEP;
    • Continuous updating of collected information;
    • Formal resolution of Process Hazard Analysis team recommendations that are not utilized;
    • Carrying out safer technology and alternatives analyses;
    • Consideration of natural disasters and extreme temperatures in PSM programs;
    • Carrying out root cause analyses;
    • Coordination of emergency planning with local emergency-response authorities;
    • Carrying out third-party compliance audits;
    • Developing a system for periodic review of, and necessary revisions to, employers’ PSM management systems; and,
    • Developing written procedures for all elements specified in the PSM standard, and identifying records required by the standard along with a records retention policy.

Interested stakeholders may participate in a meeting that will be held virtually from 10 a.m. to 4 p.m. ET on Wednesday, October 12, 2022. Registration is online at​process-safety-management/​background/​2022stakeholdermtg. Those wishing to make comments in the meeting, which are limited to three minutes, must so indicate at the time of registration.

Stakeholders may also submit written comments electronically at, which is the Federal eRulemaking Portal. Any comments or materials submitted must identify OSHA’s docket number for the stakeholder meeting (OSHA-2013-0020). Comments are due no later than November 14, 2022. Comments submitted may be made publicly available, so OSHA cautions against submitting personal information.

More detailed information about the upcoming stakeholder meeting and related issues may be found at :

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