Defending OSHA facility siting citations: Issues and recommendations



Since the Process Safety Management Standard was promulgated, industry has struggled with how to effectively and feasibly comply with the facility siting provision of the Standard. This issue is very complex and involves various industry guidance documents, good engineering practices, and the exercise of professional judgment. Many facets of the issue are evolving and subject to continuous debate within industry. For example, should qualitative or quantitative risk analysis be used? Should credible or worst-case scenarios be used? Should occupancy criteria be 200 or 400 man hours per week? Should control rooms be moved or reinforced? Because the PSM Standard is a performance standard, industry and individual employers have a great deal of discretion in resolving these issues. This editorial discusses these issues from a lawyer's perspective and includes recommendations. © 2005 American Institute of Chemical Engineers Process Saf Prog, 2005