Update to OSHA’s PSM Regulation. Part 6: Oil and Gas Production Facilities
The United States Occupational and Health Administration (OSHA) is proposing to update its Process Safety Management (PSM) standard. This post is the sixth in a series in which we discuss some of the proposed changes. OSHA’s proposal document is Process Safety Management (PSM): Stakeholder Meeting. (
The item we consider in this post is:
Resuming enforcement for oil and gas production facilities
Broadly speaking, the PSM standard applies to two types of facility. The first type consists of processes that handle highly hazardous chemicals. As we point out in the first post in this series, it was the appalling chemical release at Bhopal in the 1984 that was a trigger for process safety standards worldwide.
The second type of facility is one that handles “10,000 pounds or more of flammable liquids or flammable gases”. Oil and gas production would be placed in this category. For reference, a typical gasoline tanker truck contains around 30,000 pounds of fuel. Hence, the 10,000 lb. threshold represents a very low threshold.
OSHA published an archive document to do with this issue. Because it is archived the document “may no longer represent OSHA policy.” Nevertheless, it is useful to see what the agency had to say in the year 1999. The following is from that document.
Does the PSM standard (29 CFR 1910.119) apply to oil and gas production facilities, including oil, gas, and water separation facilities operating in conjunction with the producing well?
If at least 10,000 pounds or more of flammable liquids or flammable gases are contained in an oil and gas production process, the production facilities described above are covered by the PSM standard. Covered production activities that are included in the term process can include, but are not limited to:
the handling and on-site movement of flammable gas or flammable liquids through interconnected equipment;
the separation of oil, gas or water by means including, but not limited to:
high and low pressure separators;
gravity water separation conducted inside in-process tanks; and
the compression of the flammable gas from a lower to higher pressure; and
the other chemical and physical processing activities which are interconnected with, or proximate to, the covered process.
OSHA has stated in previous interpretation letters that production facilities, including related oil, gas, and water separation facilities, are excluded from PSM coverage under the oil and gas well drilling and servicing exemption, 29 C.F.R. §1910.119(a)(2)(ii). Several factors, however, demonstrate that the conclusions reached in these letters are erroneous. As a result, these letters are hereby rescinded.
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