Standard Interpretations - Table of Contents
• Standard Number: 1910.119(e)(6); 1910.119(e)(3); 1926.64(e)(6); 1926.64(e)(3)

June 22, 1998

Mr. Baruch A. Fellner
Gibson, Dunn & Crutcher, LLP
1050 Connecticut Avenue, N.W.
Washington, DC 20036-5306

Dear Mr. Fellner:

The following response is in reference to your letter dated April 7, 1997, to me, related to employer requirements under OSHA's (Process Safety Management of Highly Hazardous Chemicals, Explosives and Blasting Agents [PSM]) standard for updating and revalidating process hazard analyses [PHA](29 CFR 1910.119(e)(6)). We apologize for the delay in our response.

You asked that OSHA review a list of procedures to determine if they meet requirements of the 29 CFR 1910.119(e)(6). The subject standard is a performance oriented standard and therefore, it would not be appropriate for OSHA to evaluate your set of specific procedures to determine if they apply to all workplaces covered by the PSM standard. The only requirements OSHA specifies in the subject standard is that the PHA update and revalidation be conducted at least every five years by a team which meets the requirements of 1910.119(e)(4).

Even though OSHA does not specify other requirements for this standard, 1910.119(e)(6), OSHA does require employers to insure that PHAs are current and accurately reflect covered processes. To determine if a PHA can be revalidated and updated, employers must make evaluations of existing PHAs using the specific requirements to be addressed in a PHA as defined in 29 CFR 1910.119(e)(3). After employers evaluate existing PHAs using the 29 CFR 1910.119(e)(3) criteria and have made updates when necessary, then employers may revalidate their respective PHAs as being