PSM standard: OSHA issues interim enforcement policy for Appendix A chemicals

Washington – OSHA has established an interim citation policy regarding concentrations of chemicals listed in Appendix A of the Process Safety Management Standard, according to a recent memorandum issued to regional administrators and State Plan designees.

The July 18 memorandum rescinds and replaces a memo from June 2015. It details the agency’s enforcement policy on “the concentration of a chemical that must be present in a process for the purpose of determining whether the chemical is at or above the threshold quantity listed in Appendix A” of the PSM standard, Thomas M. Galassi, director of OSHA’s Directorate of Enforcement Programs, states in the memo.

Previously, OSHA analyzed chemicals in a mixture by analyzing their maximum commercial grade. The July 18 memorandum states that OSHA reviewed the policy because of concerns that any of the 137 chemicals in Appendix A “may retain their hazardous characteristics even at relatively low concentrations.”

In response, OSHA adopted the “1 percent test,” instructing employers to calculate the total weight of a chemical in a process at a concentration of at least 1 percent when no specific concentration for that chemical is defined in Appendix A.

OSHA will not cite employers through March 31, 2017, for violations of the PSM standard related to the memo. Through March 31, 2018, the agency will “make it a top priority” for compliance assistance specialists to help employers comply with changes to the standard.