News & Analysis as of

Hazardous Substances Process Safety Management

Ogletree, Deakins, Nash, Smoak & Stewart,...

OSHA Updates Its Process Safety Management of Highly Hazardous Chemicals Instruction

On January 26, 2024, the Occupational Safety and Health Administration (OSHA) issued its updated Process Safety Management of Highly Hazardous Chemicals Instruction, providing enforcement guidance related to compliance with...more

Cozen O'Connor

OSHA Updates Process Safety Management Enforcement Manual

Cozen O'Connor on

On January 26, 2024, OSHA published a revised enforcement manual for Process Safety Management of Highly Hazardous Chemicals (“Manual”). The Manual reflect OSHA’s first revisions to its prior directive issued in 1994 which is...more

Bracewell LLP

10th Circuit expands PSM coverage

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The Tenth Circuit Court of Appeals (covering Oklahoma, Kansas, New Mexico, Colorado, Wyoming, and Utah) issued an opinion on Tuesday (10/27/2020) that expands the applicability of OSHA’s process-safety-management standard to...more

Seyfarth Shaw LLP

OSHA Releases PSM Guidance for Explosives and Pyrotechnics Manufacturing and for Storage Facilities

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Seyfarth Synopsis: New OSHA guidance documents may provide employers in these industries with another tool for carefully measuring compliance with the PSM standards....more

Seyfarth Shaw LLP

DC Circuit Finds OSHA “Interpretation” Narrowing Retail Exemption Under the Process Safety Management Standard Really a...

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Seyfarth Synopsis: In a challenge brought by trade associations for the farm supply and fertilizer industries, the D.C. Circuit vacates OSHA memorandum narrowing the retail exemption from the PSM standard. The U.S....more

BakerHostetler

Regulated Industry Successfully Challenges New OSHA Process Safety Management Enforcement Policies

BakerHostetler on

On September 23, 2016, the D.C. Court of Appeals ruled that the Occupational Safety and Health Administration (OSHA) wrongfully adopted new safety requirements for fertilizer dealers who have to comply with the Process Safety...more

Conn Maciel Carey LLP

OSHA Settles Legal Challenge to Process Safety Management Chemical Mixtures Enforcement Memo

Conn Maciel Carey LLP on

In March 2015, the U.S. Supreme Court issued its decision in the closely watched Perez v. Mortgage Bankers. The Court’s decision killed a longstanding doctrine, set by the D.C. Circuit, that changes to federal agency rules,...more

Seyfarth Shaw LLP

OSHA Enforcement Memo and Interim Policy on the Process Safety Management Retail Exemption

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The Occupational Safety and Health Administration issued yesterday an enforcement memo (Memo) and an interim policy (Policy) on the PSM retail exemption. Tho Memo revised OSHA’s interpretation of the exemption of retail...more

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