I have already written on this blog about OSHA’s efforts to extend its Process Safety Management (PSM) rules to oil and gas drilling and production. It is part of a much larger effort to revise and expand PSM to a number of industries. In the case of oil and gas, this would be similar to implementing the offshore SEMS rules to landside operations.
Now you have a chance to learn more and have your voice heard. OSHA and other agencies are holding a “listening session” on a White House initiative called Improving Chemical Facility Safety and Security (Executive Order 13650) in Houston on January 24.
You have the option of attending in person or listening in on a teleconference, but you must register here to participate.
In my experience in dealing with the regulatory and public policy process, when the government proposes something as large as this initiative, two outcomes are real possibilities. One is that the proposal is too big for the agencies to get their arms around and it doesn’t succeed.
However, the other possibility is that there are so many moving parts to the proposal that it is difficult for any one industry to successfully argue that is shouldn’t be included or that there is a better way to address its concerns. In that case, the industry tends to get swept up in the proposal without being able to make its case. The upstream oil and gas industry has successfully argued that PSM is a bad fit for its operations in the past, but if it wants to continue to stay outside the PSM regulations, it will need to make sure its voice is heard above the noise that this proposal is producing.