On January 26, 2024, OSHA published a revised enforcement manual for Process Safety Management of Highly Hazardous Chemicals (“Manual”). The Manual reflect OSHA’s first revisions to its prior directive issued in 1994 which is specifically identified as cancelled and superseded by the Manual.
OSHA highlights significant changes in the Manual as:
• Removal of the Appendix A PQV Audit Checklist in the OSHA Instruction CPL 02-02-045A and
• Incorporating existing PSM enforcement policies into a question and response format
The thrust of the information provided in the Q&A’s cite to prior regulatory interpretations as supporting references.
OSHA notes that the directive is not a standard, regulation, or any other type of substantive rule and that no statement in the Manual should be construed to require the regulated community to adopt any practices, means, methods, operations, or processes beyond those which are already required by the OSH Act or standards and regulations promulgated thereunder. Nonetheless, employers who need to comply with 29 C.F.R. § 1910.119 (“PSM standard”) should be aware of the Manual as it is designed to instruct OSHA enforcement personnel of the agency’s interpretations of those standards.