OSHA Defines 'On Site in One Location' for Process Safety Management

OSHA has issued its official interpretation and explanation of the phrase "on site in one location" in the "Application" section of the agency's Process Safety Management (PSM) of Highly Hazardous Chemicals standard.

OSHA interprets "on site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release.

The meaning of "on site in one location" was at issue in a recent case before the Occupational Safety and Health Review Commission (OSHRC) in Secretary of Labor vs. Motiva Enterprises, LLC. (No. 02-2160, 2006). In that decision, the review commission queried whether that language was meant to limit in some way the applicability of the standard to a highly hazardous-chemical process. In the absence of an authoritative interpretation, the review commission decided it could not determine that the cited activities were "on site" and "in one location," and it vacated the citations. Recognizing that OSHA is the policymaking actor under the Occupational Safety and Health Act, the review commission left it to the agency to decide "in the first instance … the meaning of these terms and offer an 'authoritative interpretation.'" OSHRC also stated that any "such subsequent interpretation" would be reviewed in a future case "under 'standard deference principles.'"

The interpretation was published in the June 7 Federal Register, which can be accessed at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=19633.

The review commission's decision can be found at http://www.oshrc.gov/decisions/html_2006/02-2160.html.

For more information on process safety management, visit http://www.osha.gov/SLTC/processsafetymanagement/index.html.

Download Center

HTML - No Current Item Deck
  • Get the Ultimate Guide to OSHA Recordkeeping

    OSHA’s Form 300A posting deadline is February 1! Are you prepared? To help answer your key recordkeeping questions, IndustrySafe put together this guide with critical compliance information.

  • Steps to Conduct a JSA

    We've put together a comprehensive step-by-step guide to help you perform a job safety analysis (JSA), which includes a pre-built, JSA checklist and template, steps of a JSA, list of potential job hazards, and an overview of hazard control hierarchy.

  • Levels of a Risk Matrix

    Risk matrices come in many different shapes and sizes. Understanding the components of a risk matrix will allow you and your organization to manage risk effectively.

  • Free Safety Management Software Demo

    IndustrySafe Safety Management Software helps organizations to improve safety by providing a comprehensive toolset of software modules to help businesses identify trouble spots; reduce claims, lost days, OSHA fines; and more.

  • Industry Safe
TenCate FR Technology

OH&S Digital Edition

  • OHS Magazine Digital Edition - October 2020

    October 2020

    Featuring:

    • FACILITY SECURITY
      EHS Compliance: Make it Personal
    • FOOT PROTECTION
      Choosing the Right Safety Shoe for Your Industry
    • HAND PROTECTION
      A Requirements Checklists for Work Safety Gloves
    • COVID-19 MANAGEMENT
      Contemporary Issues in HSE Management
    View This Issue