AIHA Submits Comments on Potential PSM Changes
It supports requiring more management system elements and recommends that OSHA include some improvements based on the consensus ANSI/AIHA Z10 standard.
The American Industrial Hygiene Association has filed comments about OSHA's request for information on potential changes to its Process Safety Management standard and related standards. OSHA extended the public comment period to March 31 in response to requests for more time.
The association's comments support requiring more management system elements and recommend that OSHA include some improvements based on the consensus ANSI/AIHA Z10 standard, such as:
- Directing employers to clearly document roles, responsibilities, and lines of authority under the standard.
- Directing them to establish a process for achieving feasible risk reduction based on the hierarchy of controls.
- Directing them to establish a management review process.
AIHA also endorsed including a requirement for facilities to evaluate updates to applicable recognized and generally accepted good engineering practices (RAGAGEP) and determine what reductions in risk result from them. "It is important, however, to be clear that this requirement is focused on the 'evaluation' of the updates and does not require facilities to continuously update their equipment and/or processes with every change in RAGAGEP," the comments stated.
The comments also said the standard should be clarified by including in it a definition of RAGAGEP.
OSHA issued its request in December 2013 in response to President Obama's executive order 13650, which directed the departments of Labor, Homeland Security, and also EPA to work with several other federal agencies on ways to improve chemical facilities' safety and security. The April 2013 explosion of ammonium nitrate at a fertilizer facility in West, Texas, prompted the executive order.
OSHA asked for comments on its PSM standard, potential changes to PSM enforcement policies, and potential updates to its Explosives and Blasting Agents, Flammable Liquids and Spray Finishing standards. For more information, visit http://www.osha.gov/chemicalexecutiveorder/index.html. To submit a written comment, visit http://www.regulations.gov and search for Docket No. OSHA-2013-0020.