CONSAD Research Corporation

Occupational Safety and Health

TECHNICAL RULEMAKING SUPPORT AND DATA GATHERING FOR AN ANALYSIS OF COSTS, TECHNOLOGICAL FEASIBILITY, AND BENEFITS OF A PROPOSED REVISION TO THE OSHA PROCESS SAFETY MANAGEMENT STANDARD

U.S. Department of Labor, Occupational Safety and Health Administration,

In 1992, OSHA promulgated a final rule for a process safety management (PSM) standard for general industry [29 CFR 1910.119]. This rule was published in the Federal Register on February 24, 1992, at 57 FR 6356. On June 20, 1996, the EPA promulgated its risk management program (RMP) rule (61 FR 31668), designed to prevent accidental releases of regulated chemicals and reduce the severity of those releases that do occur. Following the promulgation of the EPA RMP rule, OSHA was requested by several stakeholders (e.g., trade associations) to bring its chemical list into closer alignment with the chemical list in EPA's RMP rule. Therefore, OSHA is considering proposing to revise the PSM standard by adding the following nine EPA chemicals to its list of highly hazardous chemicals: arsenous trichloride, boron trifluoride with methyl ether, chloroform, hydrazine, isopropyl chloroformate, methyl thiocyanate, tetranitromethane, titanium tetrachloride, and toluene diisocyanate. In addition, the proposed threshold quantities would be at least as stringent as those specified by the EPA rule. Furthermore, OSHA is considering proposing to correct, clarify, or technically amend certain entries in the Appendix A toxic and reactive list of the PSM standard, as well as to make corrections and additions to Appendix C of the PSM standard.

The purpose of this study was to provide technical and analytical support for the forthcoming OSHA PSM rulemaking and to assist in data gathering for a preliminary technological feasibility and economic analysis of proposed revisions to the process safety management standard. More specifically, the tasks that were performed include:

• review of regulatory requirements,
• development of an industry profile,
• assessment of technological feasibility,
• estimation of safety benefits and cost savings,
• estimation of compliance costs, and
• assessment of economic impacts including impacts on small business.

The results of this work were presented in a Final Report submitted to OSHA by CONSAD.