Public Comments on OSHA PSM ANPRM – 03-22-14

This is part of a continuing look at the public comments that have been posted to the docket for the OSHA Process Safety Management program advance notice of proposed rulemaking. Earlier posts in the series include:

• Public Comments on OSHA PSM ANPRM – 03-09-14

• Public Comments on OSHA PSM ANPRM – 03-09-14

• ICS and OSHA PSM

There were only three comments posted to the docket during the last week and one of those came from me; a copy of my post listed above on ICS and OSHA PSM. Those comments came from:

• The International Dairy Foods Association (IDFA)

• McLane Company Inc.

• Chemical Facility Security News (Blog)

Many of the negative comments in seen in previous comments were repeated here. There were some interesting new additions.

Retrospective Rules Analysis

A commentor asked if OSHA will be publishing results of their retrospective analysis of their regulations as part of the PSM update process. Section 6 of EO 13563 requires agencies to perform this analysis to find regulations that may be “outmoded, ineffective, insufficient, or excessively burdensome, and to modify, streamline, expand, or repeal them in accordance with what has been learned”.

LEPC’s

A commentor responded to questions about providing additional information to LEPCs by noting that some of these organizations are small, underfunded. They suggested that any expansion of LEPC requirements also provide some sort of funding stream for LEPCs.

End Approaches

There are only 9 days left in the extended comment period. This means that there will probably be just two more blog posts in this series.