440342 PSM Legal Update

Monday, April 11, 2016
Exhibit Hall E (George R. Brown )
Mark Dreux, Arent Fox LLP, Washington DC, WA

Over the last year, there have been many changes to the PSM Standard. There have been two court cases explaining key terms in the PSM Standard such  as “change,” “process,” and “process equipment” and discussing key issues such as the time to implement PHA and audit findings. In addition, OSHA has issued four memoranda expanding the boundaries of PSM  by defining  RAGAGEP, creating a new mixture rule for Appendix A substances, completely revising the retail exemption and defining  “proximate” for the purpose of establishing the boundaries of a process.  OSHA issued a  Request for Information to gather information for 14 potential changes to the PSM Standard to modernize it. After reviewing all of the responses to the RFI,  OSHA has just  initiated the review process under the  Small Business Regulatory Enforcement Fairness Act (SBREFA) in which a draft rule with the proposed changes to the PSM Standard will be published and small business will have an opportunity to comment on it.   The SBRFA process will provide a framework for additional changes being developed for the PSM Standard.  This presentation will provide an overview of the key changes in the PSM Standard  that OSHA has implemented and a summary of the changes being considered by OSHA. 

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