Ongoing AcuSafe Feature: OSHA Interpretations
In recent PSM audit work, it has come to attention that the body of written and verbal information issued by OSHA since the inception of the PSM Standard has not received wide dissemination. These clarifications and interpretations are not mandatory, and covered facilities cannot be held legally responsible for not being aware of their existence, however, they do represent OSHA's official (written) and unofficial (verbal) guidance on what they expect in a PSM program.
Note to our readers who have downloaded or used the interpretations file in the past: This file has been updated and now includes interpretations from the OSHA regulations that form the requirements for an emergency response plan, including alarm system and HAZWOPER training requirements. The updated file may be found at http://www.acusafe.com/psm/process-safety-management-interp_letters.html
Most of the letters of interpretation issued by OSHA over the years have dealt with PSM applicability issues. This newsletter will focus on written interpretations that have widespread implications for the applicability of PSM programs at covered facilities.
June 2002 (Reissued!):
This feature is meant for informational use only by AcuSafe users and should not be construed as official regulatory information. OSHA, EPA, nor any other regulatory agency has sanctioned or support this feature.
This AcuSafe feature is prepared by Michael Hazzan, Senior Principal Engineer, Acutech Consulting Group.
If you have an interpretation that you would like to share with AcuSafe or feedback about this feature, please email us at firstname.lastname@example.org.
AcuSafe is a presentation of AcuTech Consulting, ©2003, All Rights Reserved