Timing of OSHA's PSM Update
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As our regular readers know, we have published many posts to do with the proposed updates to the OSHA process safety standard. Those posts are summarized in the book The OSHA Process Standard: A 30-Year Update.
People have asked about the timing of these updates. The short answer is that we do not know. The rule making process is described in the post OSHA Rulemaking Process. In that post we suggest that, with regards to this PSM standard, the agency has completed Stage 3: Publishing the Proposed Rule.
So far, all that they have actually published is an agenda for their Stakeholder meeting, so the proposed rule may still be under development. Once the proposed rule is published, there will be a period of public comment. There are also internal processes to follow, such as a review by the Office of Management and Budget. Each of these processes is time-consuming.
Nevertheless, it makes sense for companies to work on the updates at this stage — for three reasons.
The proposed changes are evolutionary, not revolutionary. Their implementation will not require a total overhaul or restructuring of a company’s process safety management system. Therefore, work carried out now will not be wasted.
Implementation now will allow a company to get ahead of the game. This means that it will not be in a rush to implement the changes when they are formalized.
The most important reason of all is that the proposed changes, by and large, make sense. They are the right thing to do — they will help improve safety.
If any our readers can provide insights on the regulatory process, we would love to hear from you.
