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.
The following information on PSM clarifications and interpretations will be the first in a continuing series in order to provide wider distribution of this information. We welcome your feedback on this feature of the AcuSafe newsletter, and also welcome any clarification and interpretation information that you might have discovered for inclusion in a future issue.
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.
To see a specific letter or other interpretive document published by OSHA, visit OSHA's website at
http://www.osha-slc.gov/OshDoc/toc_interps.html. As a service to our client and readers,
AcuSafe has included many of these documents, including the two documents discussed above, in a
continuous Word® file. This file allows for easier searching for keywords that might be of interest and
makes it easier to determine if an interpretative document has been published on a particular topic or
if any of them address a specific PSM-related issue. This file may be found at
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, ©2002, All Rights Reserved