Update to OSHA's PSM Regulation. Part 2: Stakeholder Meeting
Update to OSHA's PSM Regulation. Part 2: Stakeholder Meeting
Yesterday we started a series of posts to do with changes to OSHA’s PSM regulation (and the corresponding RMP rule from the EPA). As mentioned in that post, the Stakeholder Meeting has been postponed from September 28th 2022 to an unspecified date.
Open for General Comments
The following is from the notice to do with the Stakeholder Meeting.
OSHA has continued to work on the PSM standard rulemaking and PSM was placed back on the Unified Agenda in the spring of 2021. OSHA is holding this stakeholder meeting to reengage stakeholders and solicit comments on the modernization topics mentioned in the RFI and SBAR panel report, as well as any additional PSM-related issues stakeholders would like to raise.
< my emphasis >
In other words, the standard is open for change for the first time in thirty years. This means that we all have an opportunity to make suggestions to do with changes that we would like to see. (For example, I recall that, when the standard was first introduced, there was considerable input from the Steelworkers Union.)
My guess is that this time around OSHA will receive many comments from environmental and climate groups. (One of those comments will be from me.) There will be pressure on OSHA to modify the standard such that safety is achieved while achieving Net Zero goals. Related to this comment, the revised standard will need to consider the wide varieties of new technologies that companies in the energy and process industries are now implementing.
Postscript
This post was written on September 21, 2022. There have not been many comments. Indeed, the proposed updates have not drawn much attention from the stakeholder community.
The comment period is now closed.
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.