VelocityEHS
MSDSonline - EH&S Compliance Made Simple

OSHA Announces National PSM-Based Directive Impacting Oil, Pyrotechnic Facilities

Jan 27, 2017
Chemical Plant Cropped

Earlier this week, OSHA released a new directive “applicable to all facilities, including petroleum refineries, covered by the PSM standard” intended to “reduce or eliminate workplace hazards associated with the catastrophic release of highly hazardous chemicals.” The new directive renews a National Emphasis Program (NEP) for facilities who manufacture, process or store large amounts of hazardous chemicals, and specifically names refineries and “pyrotechnic manufacturing facilities” as targets for enforcement. The new directive is also notable because, for the first time, OSHA will make use of data and referrals from the Environmental Protection Agency’s (EPA) Risk Management Plan (RMP) Program to inform its targeted enforcement strategies.

OSHA’s Process Safety Management (PSM) standard originally called for certain facilities with threshold quantities of chemicals listed in 1910.119 App A to take steps to minimize the chance of an incident, and to disclose information about onsite chemicals to first responders and local communities. As reported on this blog, many businesses avoided the PSM through what OSHA characterized as a “loophole.” However, when OSHA issued a revised interpretation to close this loophole, industry groups successfully blocked the action in court, arguing that OSHA had not followed required procedure.

Because its PSM-related appeals are now exhausted, this new directive may be OSHA’s way of continuing to pursue enhanced enforcement in this area.

In the text of the new directive, OSHA says it will use four sources when determining who to target for enforcement under this new emphasis program:

The addition of EPA RMP information as a criteria for enforcement is notable and new. The EPA requires businesses with an RMP-covered process to submit information to the EPA which is then posted on a database. The new directive explicitly encourages OSHA inspectors to use this EPA database when considering opening an investigation.

OSHA also seems to hint that enforcement under this new directive may be comparable to enforcement under its now-archived CHEM NEP program. In the text of the directive, OSHA states that: “Since 2010, the Agency [OSHA] has issued 69 significant enforcement cases to chemical facility employers inspected under the CHEM NEP. During the same period, OSHA issued 24 significant enforcement cases to petroleum refinery employers. Petroleum refineries also have experienced numerous fatal and/or catastrophic process-related incidents since 2010. . .”

Thus, we may be able to conclude that OSHA is looking to expand its enforcement and renew a focus on oil and pyrotechnics, as well as the businesses it had hoped to target by closing the PSM loophole.

Remember that a cloud-based chemical management system can help position you for compliance and safety even in the face of sweeping regulatory changes. The MSDSonline HQ Account can allow you to quickly cross reference chemicals against federal, state, and international regulatory lists to easily identify all compliance or reporting obligations. Management of ChangeCompliance Management, and Risk Analysis solutions from VelocityEHS can help you go even further by more effectively managing risks across your locations and facilities to take control of your organizational processes in the face of changing rules and regulations. Whatever the future holds, our solutions help you keep on top of it, and give you powerful tools to help you succeed.

19 comments

Leave a comment
  1. Frankie | May 19, 2017
    Simply choose your categories of interest and press the save button. ilovesharewares.com You should have received an email from EF Tours with a link to your trip's TourLink.
  2. afreen nazi | May 19, 2017
    Awesome post I might want to thank you for the endeavors you have made in composing this fascinating and learned article.Visit here.
  3. Blake | May 16, 2017
    While this app does not directly detail first aid treatment for your pet, it may help you figure out if what your cat or dog ate is poisonous or not. budurmarket.over-blog.com Meditation has been a remedy for thousands of years, not only in eastern religions.
  4. Ollie | May 15, 2017
    Logic has 10 geometric forms which help your child to learn shapes. download pdf You can tap on any word for a dictionary definition.
  5. afreen nazi | May 15, 2017
    I was very pleased to find this site.I wanted to thank you for this great read!! I definitely enjoying every little bit of it and I have you bookmarked to check out new stuff you post Visit here
  6. Charles | May 07, 2017
    Olive is a United Methodist congregation that began in 2005. downloadbestsoftwaresite.ru Together the book and the software are a great way to start your study of Chinese.
  7. a10 | May 02, 2017
    You’ve written nice post, I am gonna bookmark this page, thanks for info. I actually appreciate your own position and I will be sure to come back here. animal jam, a10, color switch
  8. Luke | May 02, 2017
    These are included in the app itself and do not require network or wifi. download ebooks Your mission was to identify the source of the signature, rumored to be source of an infinite energy source, before the Banshee does.
  9. nikhil sharma | Apr 30, 2017
    good morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for hergood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for girlfriendgood morning quotes for himgood morning quotes for himgood morning quotes for himgood morning quotes for himgood morning quotes for himgood morning quotes for himgood morning quotes for himgood morning quotes for himgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for friendsgood morning quotes for boyfriendgood morning quotes for boyfriendgood morning quotes for boyfriendgood morning quotes for boyfriendgood morning quotes for boyfriendgood morning quotes for boyfriendgood morning quotes for boyfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for girlfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for boyfriendhappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for friendshappy birthday wishes for herhappy birthday wishes for herhappy birthday wishes for herhappy birthday wishes for herhappy birthday wishes for himhappy birthday wishes for himhappy birthday wishes for himhappy birthday wishes for himhappy birthday wishes for himhouston medical centerhouston medical centerhouston medical centerhouston medical centerhouston medical centerhouston hospitalshouston hospitalshouston hospitalshouston hospitalshouston hospitalsnew york hospitalnew york hospitalnew york hospitalnew york hospitalnew york hospitalchicago hospitalschicago hospitalschicago hospitalschicago hospitalschicago hospitalschicago hospitalschicago hospitalschicago hospitalschicago hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsboston hospitalsaustin hospitalsaustin hospitalsaustin hospitalsaustin hospitalsaustin hospitalsaustin hospitalsaustin hospitalsaustin hospitalsaustin hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalsseattle hospitalshospitals in philadelphiahospitals in philadelphiahospitals in philadelphiahospitals in philadelphiahospitals in philadelphiaphoenix hospitalsphoenix hospitalsphoenix hospitalsphoenix hospitalsphoenix hospitalsphoenix hospitalshospital los angeleshospital los angeleshospital los angeleshospital los angeleshospital los angeleshospital los angelesdetroit hospitalsdetroit hospitalsdetroit hospitalsdetroit hospitalsdetroit hospitalsdetroit hospitalsportland hospitalportland hospitalportland hospitalportland hospitalportland hospitalportland hospitalportland hospitalwashington dc hospitalswashington dc hospitalswashington dc hospitalswashington dc hospitalscharlotte hospitalscharlotte hospitalscharlotte hospitalscharlotte hospitalscharlotte hospitals
  10. blogcomment backlinks | Apr 30, 2017
    This is a great inspiring article. I am pretty much pleased with your good work. You put really very helpful information. Keep it up. Keep blogging. Looking to reading your next post blogcomment backlinks
  11. FOREX ASLI | Apr 29, 2017
    Obat Forex Asli  Is a natural herbal remedy that has a high quality that can overcome the problem of male vitality naturally without any side effects at all. Genuine Forex Drugs are made from high quality herbal ingredients and have been clinically tested by DOCTOR INDONESIA so get the license Berstatus BPOM. Forex Strong Drugs Made From The Natural Herbal High Quality Blend Of Both Domestic And Foreign Affairs So Can Be Able To Overcome Some Male Problems Like:EFFECT DISCRETIONWEAKNESS ELEVENIMPOTENCEPREMATURE EJACULATIONhttp://vimaxaslifarma.com/HERBAL FOREX has been through various studies that have been done by Adult  health physician and survey some people who have done in men aged 30-65 years, can conclude that the intensity of their relationships decreased and even weakened as in the above problems. The Case Above Most Happens Because Our Own Mistakes That Can Not Maintain Healthy Lifestyle Everyday So That Tiredness Too That Makes Us Fatigue When Connect And Shahwat In Lost Release Because Our Thoughts And Stamina Begin To Lost. Above Problems Can Also Happen Because Our Thoughts Stress With Our Natural Condition, So Want To Do Anything Became Lazy.DRUG FOREX WHITE HORSE WHITE IS A Lifestyle Choice For Men Who Want The Return Of Stamina And Body Power To Maximize The Power Of Stamina Gedor And Older Lasting Erections In Sexsual Affairs. Forex Asli  useful and efficacious for maintaining and restoring male stamina in response to the needs of men who want to always look excellent, strong and mighty with couples in order to maintain the harmony of the household.Specially formulated from selected natural sources and mixed naturally without using Drug Chemicals (BKO) so it is safe for daily consumption.Make Obat Forex  as a natural solution to restore your stamina and vitality. Avoid a variety of potentially harmful drugs that can damage internal organs and can disrupt and weaken the heart.In addition to maintaining and improving male stamina, Natural Penis Enlargement Drugs are also able to work double by improving and improving the health of all body functions, and strengthen the heart, kidneys, and spleen.
  12. heyr | Apr 26, 2017
    Quality articles is the important to attract the people to pay a visit the website, that's what this web site is providing truetablets
  13. PUSAT OBAT KUAT PEMBESAR PENIS DAN KOSMETIK | Apr 24, 2017
  14. alex | Apr 24, 2017
  15. jackbi | Apr 24, 2017
    Thank you for your blog post.I admire the valuable information you offer in your articles. Thanks for posting it, again! Really looking forward to read more. Awesome. happy wheels geometry dash 2.1 happy wheels demo
  16. Zachary | Apr 20, 2017
    I really enjoyed reading on this article.  this site.
  17. jake | Apr 19, 2017
    thanks for the information. if you need a great massage in columbia sc, then columbia massage sc is your place. 
  18. Vivek | Apr 14, 2017
  19. muneer | Apr 13, 2017
    Many homework on the continual hunt along with offstage on the road to winning. Definitely not attached, simple to-fall as a result of wayside; And not investigation, afterward into a path travel toward the black. 8 ball pool game

    Leave a comment

    Follow Us

    Testimonials

    “Flexible, convenient, easy to use and explain to the employees. Great time saver over the old paper system that had.  I am very happy with the experience; from building the file to the roll out to the employees.”

    Mike Fergurson, Cope Plastics, Inc