OSHA Memos Clarify PSM Enforcement Policies

Posted on 6/11/2015 by Roger Marks

On June 8, OSHA issued two memos for regional administrators and State plan designees that address enforcement of the Process Safety Management standards. (Read more about what’s required under OSHA’s PSM rules here.)

Memo 1: RAGAGEP and PSM

The first memo addresses the use of Recognized and General Accepted Good Engineering Practices (RAGAGEP).

While RAGAGEP is not defined in OSHA’s PSM requirements, the term refers to “generally approved ways to perform specific engineering, inspection, or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve.”

Under OSHA PSM rules, RAGAGEP applies to equipment design, installation, operation and maintenance, as well as inspection and test practices and frequency. The memo details how OSHA bases its RAGAGEP standards on published codes, industry consensus standards including NFPA Codes, ASME/NASI/ISO standards, and other safety documents from recognized expert sources.

New OSHA enforcement policy for PSM chemical concentration

“Shall” vs. “Should”

Among other things, the memo clarifies the differences between the use of the words “shall” and “should” within the OSHA PSM rules. In general, “shall” reflects a mandatory minimum requirement, whereas “should” reflects an acceptable or preferred approach. The memo provides important guidance and should be viewed by those interested in PSM requirements. Read the full memo here: RAGAGEP in Process Safety Management Enforcement.

Memo 2: New OSHA Enforcement Policy for High-hazardous Chemicals (HHCs)

Because the previous enforcement method used by OSHA for highly hazardous chemicals and Appendix A chemicals were ambiguous with respect to the concentration of a given chemical meets the threshold for these requirements, OSHA has revised its enforcement policy.

The memo lays out a history of the previous enforcement policy, including issues raised by an unclear policy toward chemical concentration. It also lays out a number of formulas industry can use to calculate whether the concentration of a given chemical will meet the threshold for PSM.

OSHA’s New Enforcement Policy: the One Percent Test

To make it more clear which concentrations of which chemicals fall under the scope of these rules, OSHA had dropped “maximum commercial grade” and “ commercial grade” as measures of chemical concentration with respect to PSM enforcement. Now, OSHA states:
“In determining whether a process involves a chemical (whether pure or in a mixture) at or above the specified threshold quantities listed in Appendix A, the employer shall calculate:
  1. (a) the total weight of any chemical in the process at a concentration that meets or exceeds the concentration listed for that chemical in Appendix A, and
  2. (b) with respect to chemicals for which no concentration is specified in Appendix A, the total weight of the chemical in the process at a concentration of one percent or greater. However, the employer need not include the weight of such chemicals in any portion of the process in which the partial pressure of the chemical in the vapor space under handling or storage conditions is less than 10 millimeters of mercury (mm Hg). The employer shall document this partial pressure determination.”
Read the full memo here: PSM of High-hazardous Chemicals and Covered Concentrations of Listed Appendix A Chemicals.

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