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.

Protect Your Team with Expert Training

When your company commits resources to employee training, you expect results. Interactive, engaging training at is a convenient, effective way to train employees on a number of OSHA safety standards. View a demo of Lion's online training to see how we can help you keep your team safe on the job every day.

Tags: osha, process safety management

Find a Post

Compliance Archives

Lion - Quotes

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops.

Stephanie Gilliam

Material Production/Logistics Manager

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

Download Our Latest Whitepaper

This guide will help you identify 25 of the most -cited errors in RCRA training, recordkeeping, hazardous waste ID, container management, universal waste, and laboratories.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.