The Occupational Safety and Health Administration issued last December a request for information (RFI) that signaled the agency’s intent to make major changes to its Process Safety Management (PMS) standard for manufacturing facilities. In comments filed last week, IDFA questioned the need for the suggested changes, saying they would add new burdens to an already overly complex rule and add “exorbitant additional costs” for employers.

The PSM standard is a comprehensive management program for highly hazardous chemicals that integrates technologies, procedures and management practices to help assure safe workplaces. Dairy manufacturing companies are covered by the standard because they use anhydrous ammonia for refrigeration. Issuing an RFI is usually a federal agency’s first step in the rulemaking process. 

In the RFI, OSHA acknowledged that the PSM standard has been effective in improving process safety and protecting workers from many hazards, but expressed concern that “major incidents have continued to occur.” IDFA responded, saying “There are no notable incidents, catastrophic or otherwise, that indicate a need for a change in the application of PSM in dairy processing facilities. Making changes or adding elements for change’s sake does not enhance worker safety.”

In the comments, IDFA responded to a variety of questions raised by OSHA, reinforcing the industry’s positive track record and emphasizing the need to avoid ambiguity or vague terms that would allow differences of opinion and uneven enforcement.

• Read IDFA’s point-by-point response in the comments.
• Read OSHA’s request for information on “Process Safety Management and Prevention of Major Chemical Accidents.”

For more information, contact Clay Detlefsen, IDFA vice president of regulatory affairs, at cdetlefsen@idfa.org.