The explosion in West, Texas, prompted President Obama

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.

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.

  • Everything You Need to Know about Incident investigations

    Need some tips for conducting an incident investigation at work after there’s been an occupational injury or illness, or maybe even a near miss? This guide presents a comprehensive overview of methods of performing incident investigations to lead you through your next steps.

  • 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

OH&S Digital Edition

  • OHS Magazine Digital Edition - November December 2020

    November December 2020

    Featuring:

    • COLD STRESS
      Managing Cold Stress
    • TRAINING: FALL PROTECTION
      Providing Training for Fall Protection
    • PPE: HEARING PROTECTION
      Eight Tips for Hearing Testing Day
    • FACILITY SECURITY
      Incorporating COVID-19 Protections into Safety Programs
    View This Issue