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OSHA's updated PSM enforcement directive - are you prepared?

 

August 22, 2024

 

The Occupational Safety and Health Administration (OSHA) issued an updated enforcement directive for its Process Safety Management (PSM) standard. This new directive, which became effective on January 26, 2024, replaces the previous guidance from 1994 and aims to provide more uniform enforcement of the PSM standard across industries.

 

Key changes in the updated directive include:

• Removal of the Appendix A Program Quality Verification (PQV) Audit Checklist

• Incorporation of existing OSHA PSM enforcement policies into a question-and-answer format

• Compilation of prior guidance documents, instructions, and standard interpretations into a section-by-section index

 

Important dates and actions

• Effective Date: January 26, 2024

• State Plan Notice of Intent: Was due within 60 days of the effective date (March 26, 2024)

• State Plan Adoption: To be completed within 6 months of the effective date (July 26, 2024)

 

What this means for employers

 

While the directive does not introduce new regulations, it signals OSHA's continued focus on process safety management. Companies regulated by PSM should:

 

1. Review the updated directive promptly and refresh yourself with it

2. Ensure compliance with key PSM elements, including:

    - Employee participation

    - Process hazard analysis

    - Detailed operating procedures

    - Comprehensive training programs

    - Regular pre-startup safety reviews

    - Management of change procedures

3. Prepare for potential increased scrutiny during inspections

 

What's next?

 

OSHA has indicated that it continues to consider revisions to the PSM standard itself. Stay tuned for potential updates to the regulation in the future.