On May 11, 2016, the Occupational Safety and Health Administration (“OSHA”) issued a Standard Interpretation on the topic of Recognized and Generally Accepted Good Engineering Practices (“RAGAGEP”) in Process Safety Management (“PSM”) Enforcement. This new interpretation replaces an interpretation of the same title dated June 5, 2015. In replacing it though, OSHA does not make any substantive changes to the PSM regulatory requirements; standard interpretations cannot do so.
OSHA’s PSM regulations generally contain requirements for managing hazards associated with processes for highly hazardous chemicals. A “process” is any activity involving highly hazardous chemicals, including using, storing, manufacturing, handling, and/or on-site moving. 29 C.F.R. § 1910.119(b). PSM requirements apply to certain toxic and reactive chemicals at or above threshold levels and certain flammable gases and liquids. 29 C.F.R. § 1910.119(a)(1).
The PSM standard is multifaceted. At a high level, it requires employers, among… Continue Reading