Update to OSHA’s Process Safety Management Regulation. Part 27: Written Procedures for All Elements

Amending OSHA’s PSM Standard

The United States Occupational Safety and Health Administration (OSHA) is proposing to update its Process Safety Management (PSM) standard. We are publishing a series of posts that review the proposed changes. (This is the final post in the series.)

The topics covered by OSHA are listed below. (For a full list of the indexed posts please refer to Update to OSHA’s Process Safety Management Regulation: An Index.) The topic of this post — Written Procedures for All Elements — is highlighted.

1. Background

2. Stakeholder Meeting

3. Open Feedback

4. Atmospheric Storage Tanks

5. Oil and Gas-Well Drilling

6. Oil and Gas Production Facilities

7. Reactive Chemical Hazards

8. Highly Hazardous Chemicals

9. Explosives and Blasting Agents

10. Clarifying the scope of the retail facilities exemption

11. Defining the limits of a PSM-covered process

12. Definition of RAGAGEP

13. Definition of Critical Equipment

14. Employee Participation and Stop Work Authority

15. Updates to RAGAGEP

16. Updating Collected Information

17. Formal Resolution of PHA recommendations

18. Safer Technology

19. Natural Disasters

20. Mechanical Integrity of Critical Equipment

21. Equipment Deficiencies

22. Organizational Changes

23. Root Cause Analysis

24. Local Emergency Response

25. Third-Party Compliance Audits

26. Review of PSM Management Systems

27. Written Procedures for All Elements

The Regulation

Currently, there is no general requirement in the standard for written procedures for all the management elements. (There are, however, some specific requirements in this area, for example to do with the updating of operating procedures.)