Update to OSHA's PSM Regulation. Part 3: Open Feedback
We continue our review of OSHA’s proposed update to the Process Safety Management (PSM) standard. In the first part of this series we looked at the Background to the proposed changes. In particular, we looked at the performance-based nature of the standard, and at 14 management elements that provided the core of the original regulation.
In this post we look at the section entitled ‘II. Stakeholder Meeting’ (we have already provided some thoughts to do with this the topics to be discussed here). Of this meeting, OSHA says,
The meeting will feature a brief presentation from OSHA on the background of the PSM standard and some of the issues outlined in this notice. After the presentation, there will be time for registered commenters to provide verbal comments. PSM rulemaking topics are outlined in the lists below, but commenters may provide feedback on additional PSM-related issues.
< my emphasis >
OSHA is looking for feedback on about 26 specific items that we will look at in future posts. But the emphasized section of the above statement shows that any topic or idea can be suggested. The world is a very different place from what it was all those years ago when process safety was new. No is the time to make suggestions.
As I have already said, I intend to make a comment to do with the relationship between Process Safety Management and ‘Net Zero by 2050’ programs, and how PSM can be linked to the SEC’s proposed Climate-disclosure rule.
Index of Posts
For a list of the posts that we have published to do with OSHA’s proposed updates, please visit Update to OSHA’s Process Safety Management Regulation: An Index.
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