OSHA is preparing to release a rulemaking that seeks comments on its Process Safety Management rules. This is not one that industry can afford to ignore. The announcement is here and you can click here to read the full rulemaking document. The PSM standard is now more than 20 years old and was a pretty revolutionary concept for its time. It could probably use a review right about now.
However, OSHA is directly tying this review to four pretty horrific accidents, including the ammonium nitrate explosion this year in West, Texas, killed at least 15 people. As a rule of thumb, when a federal agency ties a rulemaking process to a tragedy, the result will be more and not less regulation. It appears that OSHA is looking at a very expansive laundry list of changes. The document says OSHA wants to open up PSM in 17 different categories.
The oil and gas upstream industry has special reason to pay attention to this rulemaking. Ever since SEMS came to the offshore world, industry has wondered if it would come on-shore. OSHA says with this rulemaking that it wants comments on whether PSM should apply to drilling and production. So there it is – a proposal to apply a SEMS-like system to E&P. There are other provisions that could also affect upstream operations and these will take a careful reading.
The proposal still needs to be published in the Federal Register, but once it is, the public will have 90 days to comment.