OSHA 3909-03 2017

Process Safety 

Management for 

Storage Facilities
Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions 

for working men and women; by authorizing 

enforcement of the standards developed under 

the Act; by assisting and encouraging the States 

in their efforts to assure safe and healthful 

working conditions; by providing for research, 

information, education, and training in the field of 

occupational safety and health.”

This guidance document is not a standard 

or regulation, and it creates no new legal 

obligations. It contains recommendations as well 

as descriptions of mandatory safety and health 

standards. The recommendations are advisory 

in nature, informational in content, and are 

intended to assist employers in providing a safe 

and healthful workplace. The Occupational Safety 

and Health Act requires employers to comply 

with safety and health standards and regulations 

promulgated by OSHA or by a state with an 

OSHA‐approved state plan. In addition, the Act’s 

General Duty Clause, Section 5(a)(1), requires 

employers to provide their employees with a 

workplace free from recognized hazards likely to 

cause death or serious physical harm.

Material contained in this publication is in the 

public domain and may be reproduced, fully or 

partially, without permission. Source credit is 

requested but not required.

This information will be made available to 

sensory-impaired individuals upon request.

Voice phone: (202) 693-1999; teletypewriter

(TTY) number: 1-877-889-562
Process Safety Management 

for Storage Facilities

U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3909-03 201
Contents

Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Employee Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Process Safety Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Information on Highly Hazardous Chemicals. 

Information on Process Technology  

Information on the Process Equipment  

Process Hazard Analysis (PHA) . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Operating Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Mechanical Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Emergency Planning and Response . . . . . . . . . . . . . . . . . . . . . 15

APPENDIX: Misconceptions and 

Frequently Asked Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Workers’ Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

OSHA Assistance, Services and Programs . . . . . . . . . . . . . . . 21

Establishing a Safety and Health Program. .

Compliance Assistance Specialists. .

Free On-site Safety and Health Consultation Services

for Small Business. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Cooperative Programs. .

Occupational Safety and Health Training Courses. .

OSHA Educational Materials. .

OSHA Regional Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

How to Contact OSHA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  2
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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Purpose

This document does not cover the entire Process Safety 

Management (PSM) standard, but only focuses on aspects of 

the standard particularly relevant to storage facilities. For a 

full compliance guide to PSM, please refer to OSHA 31321 or 

the full text of the standard at www.osha.gov.

2 Although all 

elements of the PSM standard apply to a PSM-covered storage

facility, the following elements of the standard are most 

relevant to hazards associated with storage facilities:

■ Employee Participation

■ Process Safety Information (PSI)

■ Process Hazard Analysis

■ Operating Procedures

■ Training

■ Mechanical Integrity (MI)

■ Emergency Planning and Response

PSM is critically important to facilities that store highly 

hazardous chemicals. Implementing the required safety 

programs help prevent fires, explosions, large chemical spills, 

toxic gas releases, runaway chemical reactions, and other 

major incidents. This will ensure that employees, contractors, 

facility visitors and emergency responders are safe from these 

hazards. Compliance will also benefit employers by minimizing 

damage to facility equipment and neighboring structures in the 

event of an HHC release. 

Between 1997 and 2013, there have been numerous incidents 

at storage facilities that have caused serious injuries and 

fatalities to employees. Several examples are included below:

■ In 2013, a facility that stored and distributed compressed 

propane gas was largely destroyed by a series of fires and 

explosions. After receiving spent propane gas cylinders, 

employees would “bleed” any remaining gas into the air 

1. www.osha.gov/Publications/osha3132.pdf

2. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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before the cylinders were cleaned and reused. On the 

night of the incident, investigators believe, this practice 

resulted in a cloud of flammable propane gas at the facility, 

which was ignited by a spark from a forklift operating in 

the area. The resulting explosions and fires injured several 

employees—four critically. 

■ In 2008, a nearly 90-year-old storage tank catastrophicall

failed and released approximately 2.1 million gallons of 

liquid fertilizer. The collapsing tank seriously injured two 

employees, and the chemicals flowed over containment 

berms. Investigators determined that defective welds likely 

caused the tank failure, and inspectors condemned another 

tank at the same facility that presented an “imminent 

danger” of failure. Major contributing factors were the 

inadequacy of tank weld inspections and overestimates 

of the maximum liquid levels that the tank could safely 

accommodate. Further, some tank inspection and testing 

activities did not follow recognized and generally accepted 

good engineering practices. This is a recurring category 

of incident: between 1995 and 2008, 16 tanks at other 

facilities catastrophically failed, killing one employee and 

hospitalizing four others. Faulty welding caused 11 of these 

tank failures (CSB, 2009).

■ In 2005, a fire and subsequent explosion(s) destroyed a 

facility that stored and distributed compressed gas, and 

propelled debris and projectiles. The incident was traced 

back to propylene gas cylinders in the facility’s storage area 

that were directly exposed to sunlight. High temperatures 

from the sunlight exposure increased cylinder pressure 

enough to cause flammable vapors to leak from the 

cylinders and catch fire. Heat from the initial fire caused 

other cylinders to leak gas. The fire spread throughout 

the storage area and eventually consumed nearly 8,000 

cylinders of compressed gas. 

■ In 2003, an industrial facility that stores and distributes 

chlorine received a routine railcar shipment of liquid 

chlorine. The chlorine was transferred to a bulk trailer, 

a procedure that the facility had conducted for many 
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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years without serious incident. The loading process was 

equipped with a scrubber, which was designed to control 

chlorine vapors displaced during trailer filling. On the day of 

the incident, chlorine vapors overwhelmed the scrubbers’ 

capacity, and up to 1,920 pounds of chlorine escaped 

into the air. This incident occurred in a process for which 

a process hazard analysis had already been conducted. 

However, investigators found that the process hazard 

analysis failed to consider the consequences of chlorine 

gases overloading the scrubbers (CSB, 2007).

■ In 1999, a truck driver was killed and an employee injured 

when a chemical shipment was inadvertently loaded into 

the wrong tank. Due to this error, incompatible chemicals 

came into contact, reacted, and released a cloud of toxic 

gas containing lethal levels of hydrogen sulfide. In this case, 

the employer’s failure to have adequate process safety 

information on chemical incompatibilities, its inadequate 

chemical unloading procedures, and its failure to implement 

appropriate controls all contributed to the incident (NTSB, 

2001). Other similar incidents have been recorded. A 

1998 incident investigated by the National Transportation 

Safety Board (NTSB) occurred when inadvertent mixing of 

incompatible chemicals at a facility’s loading dock released 

toxic gases. That incident injured seven people—including 

two first responders—and caused 3,000 workers to be 

evacuated or instructed to shelter in place (NTSB, 2000).

■ In 1997, three firefighters were killed by flying debris from 

an explosion in the storage area of a pesticide distribution 

facility. Investigators concluded that the explosion was most 

likely caused by a sack of thermally unstable material that 

had been placed too close to a hot compressor discharge 

pipe. The heat from the pipe caused the material to 

decompose and release flammable vapors, which eventually 

ignited and exploded. The investigators recommended that 

safety programs to review hazards should be implemented 

at all facilities that store, manufacture, handle, or use 

hazardous chemicals (EPA 1999).
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Applicability 

The Process Safety Management standard covers processes 

which involve a chemical at or above the specified threshold 

quantity (TQ) listed in Appendix A of the PSM standard3, 

unless another Federal Agency has jurisdiction.4 The PSM 

standard is also applicable to processes containing a 

Category 1 flammable gas (as defined in 1910.1200(c)) or a 

flammable liquid with a flashpoint below 100 °F (37.8 °C) on 

site in one location, in a quantity of 10,000 pounds (4535.9 kg) 

or more. A “process” is defined by OSHA in the PSM standard 

as “any activity involving a highly hazardous chemical 

including any use, storage, manufacturing, handling, or the 

on-site movement of such chemicals, or combination of these

activities.”5 The standard also states that any group of vessels 

which are interconnected and separate vessels that are located 

such that a highly hazardous chemical could be involved in a 

potential release, shall be considered a single process.

The following operations are excepted from the PSM 

standard’s scope, which may apply to some storage facilities:

■ Retail facilities

■ Hydrocarbon fuels used solely for workplace consumption 

as a fuel (e.g., propane used for comfort heating, gasoline 

for vehicle refueling), if such fuels are not a part of a 

process containing another highly hazardous chemical 

(HHC) covered by the PSM standard

■ Flammable liquids with a flashpoint below 100 °F (37.8 °C) 

stored in atmospheric tanks or transferred which are kept 

below their normal boiling point without benefit of chilling 

or refrigeration. (Note: Atmospheric tanks are storage 

tanks designed to operate at pressures from atmospheric 

through 0.5 psig)

3. Calculation of TQ for mixtures is explained in an OSHA Letter of Interpretation at www.osha.gov/

pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=30848

4. Section 4(b)(1) of the OSH Act, 29 U.S.C. 653(b)(1), provides that OSHA has no authority to regulate 

a working condition if another federal agency exercises statutory authority to prescribe or enforce 

a standard or regulation addressing that working condition. Thus, except as noted, if another 

federal agency has or enforces a standard or regulation addressing accidental releases of regulated 

substances, the OSH Act does not apply to that working condition. 

5. 29 CFR 1910.119.
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■ Oil or gas well drilling or servicing operations6

■ Normally unoccupied remote facilities7

All storage facilities that do not fit under one of these 

exemptions should determine whether they fall under the 

OSHA PSM standard and comply with the standard if they do. 

Storage facilities typically have considerably less complex 

process safety issues than facilities with large chemical 

manufacturing operations, which may make compliance easier 

and less costly. Some organizations and trade associations 

provide PSM compliance resources for their members. Those that 

may address storage activities include, but are not limited to: 

■ Insurance companies

■ Local fire officials

■ National Association of Chemical Distributors (NACD)

■ Center for Chemical Process Safety (CCPS)

■ Agricultural Retailers Association (ARA)

■ American Chemistry Council (ACC)

■ Society of Chemical Manufacturers and Affiliates (SOCMA)

■ American Petroleum Institute (API)

■ The Fertilizer Institute (TFI)

■ Compressed Gas Association (CGA)

■ National Fire Protection Association (NFPA)

■ International Warehouse Logistics Association (IWLA)

Small businesses may contact OSHA’s free On-site

Consultation Program for help with identifying and mitigating 

workplace hazards. OSHA’s On-site Consultation Program

offers free and confidential occupational safety and health 

services to small and medium-sized businesses in all states

and several territories, with priority given to high-hazard

worksites. On-site Consultation services are separate from

enforcement and do not result in penalties or citations. 

6. Letter of Interpretation: www.osha.gov/pls/oshaweb/owadisp.show_document?p_

table=INTERPRETATIONS&p_id=23727

7. Letter of Interpretation: www.osha.gov/pls/oshaweb/owadisp.show_document?p_

table=INTERPRETATIONS&p_id=22592
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Consultants from state agencies or universities work with 

employers to identify workplace hazards, provide advice on 

compliance with OSHA standards, and assist in establishing 

and improving safety and health programs. To locate the 

OSHA On-site Consultation Program nearest you, call 1-8

321-6742 (OSHA) or visit www.osha.gov/consultation

Although all elements of the PSM standard apply to a 

PSM‐covered storage facility, the following elements of the 

PSM standard are particularly relevant to hazards associated 

with storage facilities: 

Employee Participation

Employees with experience in hazard identification and 

prevention are vital to workplace safety. Workplace safety 

is taken seriously if employees are committed to following 

health and safety procedures and have a sincere interest in 

developing them. 

The PSM standard requires that employers covered under 

the standard:

■ Develop a written plan of action regarding how they will 

implement employee participation.

■ Consult their employees and their representatives regarding 

conducting and developing process hazard analysis (PHAs) 

and other elements of process safety management. 

■ Ensure that their employees and their representatives have 

access to PHAs and all other information required to be 

developed by the PSM standard. 

Process Safety Information

Employers are required to compile written process safety 

information (PSI). The compilation of written process safety 

information will help the employer and the workers involved in 

operating the process to identify and understand the hazards 
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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involved in their processes. Process safety information must 

include information on the hazards of the highly hazardous 

chemicals used or produced by the process, information 

on the technology of the process, and information on the 

equipment used in the process. Process safety information 

for the storage of highly hazardous chemicals will usually 

be considerably less extensive than that required for the 

manufacture or use of such chemicals.

Information on Highly Hazardous Chemicals

For every highly hazardous chemical, PSM requires that 

employers compile information on chemical toxicity, permissible 

exposure limits, physical data, reactivity data, corrosivity data, 

thermal and chemical stability data, and hazardous effects 

associated with inadvertent mixing of chemicals that may 

occur. Facilities are required by OSHA’s Hazard Communication 

standard to have Safety Data Sheets (SDSs) for hazardous 

chemicals in their workplaces, which often contain some of this 

information. If an employer does not already have an SDS, it 

must obtain it from its chemical suppliers. 

Storage facilities should be aware of reactivity hazards 

including unstable substances or incompatibility issues. The 

Center for Chemical Process Safety (CCPS) provides basic 

guidance on chemical reactivity, which facilities can consult on 

the CCPS webpage.8

The NOAA/EPA/CCPS Chemical Reactivity Worksheet9 is available 

to aid in identifying potentially incompatible chemicals. 

Information on Process Technology 

Process technology is likely much less complicated when 

the employer only stores chemicals, rather than processing, 

mixing, or deliberately reacting them. 

8. www.aiche.org/ccps/topics/process-safety-technical-areas/chemical-reactivity-hazards/rea

material-hazard

9. www.aiche.org/ccps/resources/chemical-reactivity-worksheet
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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Process technology information must include:

■ Diagrams (Block, Process Flow) – an example of which is 

shown in non-mandatory Appendix B of the PSM standard,

■ Maximum inventory levels for all chemicals in the PSM

covered process,

■ Safe upper and lower process limits for such items as 

temperatures, pressures, flows or compositions, and

■ An evaluation of the consequences of deviation, including 

those affecting the safety and health of employees, that 

could occur if operating beyond the established process 

limits. 

Information on the Process Equipment 

Many storage facilities may have minimal process equipment. 

Nevertheless, facilities must collect information on equipment 

that is part of the PSM-covered process. Typical equipment

may include: storage tanks, piping, pumps, containers, 

pressure relief systems, dikes, ventilation equipment, alarms, 

controls, process safeguards and monitoring equipment.

Employers are required to collect equipment information on 

materials of construction, piping and instrument diagrams 

(P&IDs), electrical classifications, relief system design 

and design basis, ventilation system designs, and safety 

systems. For facilities using packaged storage systems, the 

manufacturer will provide most, if not all, of this information.

Facilities without piping such as those that store small containers 

only, typically will not have P&IDs. Questions on applicability of 

specific PSM requirements pertaining to unique situations should 

be referred to OSHA’s Directorate of Enforcement Programs or 

the appropriate OSHA Consultation Program Office.

Employers must document that all equipment complies with 

recognized and generally accepted good engineering practices 

(RAGAGEP). OSHA has published guidance10 clarifying 

10. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=30785
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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RAGAGEP requirements and identifying potential sources of 

RAGAGEP. In all cases, the RAGAGEP must be both “recognized 

and generally accepted” and “good engineering practices”. 

In addition, depending on the classification of the stored 

contents, storage tanks may bear a marking identifying 

compliance with the appropriate codes or standards under 

which the container is constructed, such as the ASME Boiler 

and Pressure Vessel Code. Other markings may also be 

required by the National Board of Boiler and Pressure Vessel 

Inspectors. Typical information on storage tanks may include 

this information as well as manufacturer name, installation 

date, materials of construction (to ensure compatibility with 

the commodity being stored), pressure rating, wall thickness 

and volume. If the compliance traceability of the storage tank 

design is unknown, most applicable RAGAGEP states that 

the tank cannot be used until inspected and certified by an 

appropriate certifying authority. For pressure vessels with no 

“traceability,” such as those with no nameplate and minimal 

or no design or construction documentation, the employer 

should verify the fitness-for-operations integrity of the vessel

by utilizing the procedure contained in API 510, Section 6.7 or 

other appropriately recognized standard. Employers should 

also collect data on transfer hoses, vapor control systems, 

pressure relief systems, level controls, spill control and 

containment mechanisms, and other equipment associated 

with the process. 

Process Hazard Analysis (PHA)

A process hazard analysis is an organized and systematic 

effort to identify and analyze the significance of potential 

hazards associated with the processing and handling of highly 

hazardous chemicals. A PHA team must be comprised of 

personnel that are knowledgeable in engineering and process 

operations, at least one employee familiar with the process 

being evaluated, and at least one employee knowledgeable in 

the specific process hazard analysis methodology being used. 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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The team analyzes potential causes and consequences of fires, 

explosions, releases of toxic or flammable chemicals, and 

major spills of hazardous chemicals. The team conducting the 

PHA must make recommendations for additional safeguards 

to adequately control identified hazards or to mitigate their 

effects. Safeguards may include inherently safer or passive 

approaches to hazard control, or suggesting new engineering 

controls (e.g., improved fire detection and suppression 

systems at facilities that store heat-sensitive chemicals) or

administrative controls (e.g., new operating procedures, 

inventory control measures, separation of highly hazardous 

chemicals into different storage areas).

Employers that operate more than one storage facility with 

identical equipment and processes may be able to develop just 

one hazard analysis and then customize it based on the specific 

hazards present at each facility.

Process hazard analyses must be reviewed and revalidated at 

least every five years.

Employers must develop systems to promptly address hazards 

identified and the process hazard analyses’ findings and 

recommendations, document how each item was resolved, 

and inform affected employees of any process changes made. 

Specific items storage facilities may consider when conducting 

a PHA include:

■ Making sure incompatible materials are separated, e.g., 

oxidizers and combustible/flammable materials

■ Siting hazards – such as vehicle impact and appropriate 

separation of occupied buildings

■ Temperature hazards – are you storing materials with 

temperature stability limits?

■ Toxic hazards – ventilation issues

■ Potential impacts of on-site accidental release

■ Fire zone separation
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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The PSM standard allows PHAs to be conducted by many 

different methodologies, enabling facilities to address their 

unique process safety challenges in a manner that is most 

appropriate and cost-effective for them. Typically, storage

facilities should be able to use less sophisticated techniques 

such as What-if, Checklists, or a combination of accepted

methods. Additional guidance can be found on OSHA’s Hazard 

Identification and Assessment, and Hazard Prevention and 

Control webpages.11, 12

Operating Procedures 

Employers are required to develop and implement written 

operating procedures that provide clear instructions for safely 

conducting activities involved in each covered process consistent 

with the process safety information. Operating procedures must 

cover not only normal operations, but also other situations such 

as startup, temporary operations, and emergency shutdown. 

Important safety information, including the basic hazards 

encountered or that could be encountered in the process, shall be 

included in the operating procedures. The procedures need to be 

available to all operators, and be accurate and current. Employers 

should check the date of the operating procedure(s) being used 

be checked prior to each use to verify that only the most current 

version is being used before proceeding. The operation may need 

to be placed on hold if an out-of-date procedure is discovere

or an error affecting form, fit, or function in the process is 

noted, unless the facility has developed and implemented 

a Management of Change (MOC) procedure to address the 

situation. Employers must certify annually that their operating 

procedures are current and accurate.

Helpful resources to consult in developing effective 

written operating procedures include input from 

equipment manufacturers or designers, facility employees 

with unique insights into operations, chemical suppliers, or 

external references. 

11. www.osha.gov/shpguidelines/hazard-Identification.htm

12. www.osha.gov/shpguidelines/hazard-prevention.htm
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Although storage facilities typically have relatively few 

procedures, when highly hazardous chemicals are involved, it 

is still critically important that these procedures are thorough, 

clear, and communicated effectively to employees. Operating 

procedures must be covered in training courses for employees 

involved in the process and reviewed during mandatory three

year PSM compliance audits. Employers must ensure that 

employees both understand and routinely follow the procedures. 

Examples of storage facility operating procedures include:

■ Container transfer/storage procedures – including proper 

handling of the container to avoid loss of containment; 

appropriate locations for stored chemicals; and signs of 

damaged storage containers

■ Storage tank loading/unloading procedures – including 

proper connection/valve operating sequence, maximum 

intended inventory, maximum intended pressure, and 

receiving documentation procedures

■ Administrative procedures – including limited personnel 

access to toxic or flammable storage areas, restrictions for 

forklift access or ignition source introduction

■ Emergency operations – including loss of containment, fire 

response, and evacuation procedures

Training 

Employers must provide initial and refresher training to 

every employee involved in operating a PSM-covered

process. Training must also cover the facility’s procedures for 

emergency operations, such as loss of containment scenarios. 

The level of training may vary for each employee. For example, 

those who work in the area or operate the equipment will 

receive more extensive training than visitors or other non

operational personnel, which would require awareness 

training. Employers must also train contractors or temporary 

employees on known potential fire, explosion, or toxic release 

hazards associated with their work and the processes. 
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Depending on the facility, training required for employees at 

storage facilities may include instructions on how employees 

handle storage containers, including proper operation and 

correct grounding during storage and transfer. For instance, 

even though some containers may be small and may appear 

non-threatening, it is important to inform workers of the

dangers of the chemicals they contain. Storage facility training 

must also focus on any administrative rules followed in the 

facility, such as designation of hazard areas, temporary access 

locations, and designated smoking areas. Training must 

also include loss of containment scenarios. Some chemical 

releases at storage facilities may appear small and seemingly 

not highly dangerous, but employees need to be trained to 

recognize the dangers posed by even small releases and how 

to appropriately respond to them. In addition, various other 

OSHA standards (e.g., Hazard Communication, Hazardous 

Waste Operations and Emergency Response, Personal 

Protective Equipment, and Powered Industrial Trucks) have 

training requirements that may apply to storage facility 

employees. In addition to initial training, refresher training in 

accordance with the PSM standard shall be provided at least 

every three years, and more often if deemed necessary in 

consultation with employees. 

Mechanical Integrity 

Mechanical Integrity requires storage facilities to implement 

written procedures that ensure that critical process equipment are 

properly fabricated, tested, inspected, repaired, and maintained. 

Mechanical integrity programs must address pressure vessels, 

storage tanks, piping systems (including piping components such 

as valves), pumps, relief or vent systems and devices, emergency 

shutdown systems, and controls (including monitoring devices 

and sensors, alarms, and interlocks). While large chemical 

manufacturing facilities and petroleum refineries sometimes 

have hundreds—or even thousands—of such components, 

storage facilities with PSM-covered processes typically have less

equipment to maintain, making compliance less challenging, 

although no less important. 
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A starting point for creating a mechanical integrity program 

is listing all equipment, instruments, and components that 

need to be considered. In many cases, the equipment that 

is part of the MI program will have inspection and testing 

recommendations from the manufacturer. If the covered 

equipment does not have any MI related manufacturers 

recommendations, then employers should look for applicable 

codes/standards or industry best practices. Inspections 

and tests must follow Recognized and Generally Accepted 

Good Engineering Practices (RAGAGEP), and inspection 

and test frequency must be consistent with manufacturer’s 

recommendations and good engineering practices, or more 

frequently if indicated by operating experience. If employers 

and employees are unfamiliar with these RAGAGEP references, 

they should consult with others as needed to understand 

the RAGAGEP. Consultation with local fire officials may also 

provide references for appropriate fire codes.

Employers must train each employee involved in the 

maintenance of the integrity of equipment used in an ongoing 

process. These employees must be provided an overview of 

the process, its hazards, and the procedures they must follow 

in their assigned tasks to ensure they can perform the tasks 

in a safe manner. This is important because maintenance 

employees may not be fully versed in process hazards—

particularly in cases where storage facilities contract out much 

of their inspection, testing, maintenance, and repair duties. 

Each inspection and test to verify current equipment integrity 

must be documented. This documentation serves as proof 

of compliance, and the records can also be used to assess 

trends in longer-term equipment degradation which is then

used to determine if inspection and testing frequencies should 

be adjusted. Any deficiencies identified during inspections 

and tests must be addressed before further use, or in a safe 

and timely manner when actions are taken to assure safe 

operation pending repairs. When equipment is determined to 

be deficient, a management of change (MOC) procedure must 

be established and implemented prior to continuing operation 

of the deficient equipment outside of established operating 
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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limits. The MOC procedure must include a determination of 

the safety and health impacts of continued operation of the 

deficient equipment.

The final element of mechanical integrity programs is quality 

assurance. PSM-covered facilities must ensure that equipment

for newly constructed operations is suitable for the intended 

application and that equipment in existing processes is 

properly installed and consistent with design specifications. 

Quality assurance requirements also apply to maintenance 

materials and spare parts to ensure compatibility with the 

equipment and the process.

Emergency Planning and Response 

The PSM emergency planning and response requirements 

largely refer to other OSHA standards, particularly the 

Emergency Action Plan standard13 which requires an 

emergency action plan, employee alarm system, employee 

training on the plan, and provisions for reviewing the plan; 

employers may also be covered under the Hazardous Waste 

Operations and Emergency Response standard.14 Chemical 

storage facilities with a PSM-covered process should already

be complying with these standards. Storage facilities should 

consider addressing:

■ Procedures for reporting emergencies

■ Procedures for handling small releases

■ Emergency evacuation procedures

■ Procedures for employees who must implement critical 

operations before evacuating

■ Procedures for accounting for all evacuated employees

■ Procedures for employees who perform rescue or 

medical duties

■ A list of contacts for employees with specific duties and 

responsibilities in emergencies

13. 29 CFR 1910.38

14. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765 
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Storage tanks must be properly labeled with their contents as 

required by OSHA’s Hazard Communication standard (29 CFR 

1910.1200). This enables first-responders to recognize the

hazards of stored commodities and implement appropriate 

emergency actions. While not required, OSHA recommends 

that facilities keep track of the location of portable containers 

of highly hazardous chemicals so that emergency responders 

can be accurately directed to their location in the event of an 

incident. In order to facilitate a successful response effort, OSHA 

encourages facilities to coordinate with their local emergency 

responders and to perform practice drills whenever possible.

Storage facilities with PSM-covered processes should also

ensure that contractors and visitors who may be present 

at the storage facility understand how to respond during 

emergencies. Employers can assign hosts, escorts, or 

evacuation wardens when visitors first enter the premise, and 

provide visitors with evacuation procedures and emergency 

response information. 

OSHA has developed a short checklist that employers are 

encouraged to review which offers additional tips for developing 

effective emergency response plans at PSM-covered facilities.1

Additional resources include NFPA 1600, Standard on Disaster/

Emergency Management and Business Continuity/Continuity of 

Operations Programs; NFPA 1616, Standard for Mass Evacuation 

and Sheltering (to be published at end of 2016); and NFPA 1620, 

Standard for Pre-Incident Planning. 

15. www.osha.gov/SLTC/etools/evacuation/checklists/eap.html
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APPENDIX: Misconceptions and 

Frequently Asked Questions

This appendix documents many PSM-related questions that

storage facilities commonly ask of OSHA. These questions are 

meant to provide storage facility owners with responses that 

will help with PSM compliance.

“A major incident will not occur at a facility that only stores 

hazardous chemicals...” The mere presence of large quantities 

of highly hazardous chemicals at storage facilities creates a 

risk of a catastrophic incident. There are many examples of 

incidents where stored chemicals have leaked, decomposed, 

polymerized, combusted, or exploded. With a proper PSM 

program in place, employers at storage facilities can fully 

evaluate hazards and implement measures that prevent life

threatening incidents.

“Aren’t PSM programs extremely expensive for storage 

facilities?” PSM compliance costs are directly related to the 

complexity of the covered processes. PSM compliance for 

storage purposes are usually less complex than formulation or 

reaction processes, resulting in lower costs. PSM compliance 

costs are small when compared to the very significant costs 

caused by catastrophic incidents. Employers are encouraged 

to view the time and resources devoted to PSM programs as 

worthwhile investments and not as burdens. PSM programs 

benefit all facilities that store highly hazardous chemicals, even 

those facilities that store hazardous chemicals in quantities that 

do not trigger mandatory PSM compliance. Many employers 

have found that implementing a comprehensive safety 

management program, as required under PSM, translates into 

more efficient operations and increased profits.16

“My facility has stored chemicals for decades without 

incident...” This is a common reaction in the field of process 

safety. Catastrophic chemical-related incidents do not occur

often, and it is not unusual for a facility to have incident-free

operations for many years before tragedy strikes. In fact, 

16. www.aiche.org/ccps/about/business-cas
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for most of the case studies referenced in this guidance, 

the facilities in question had no previous records of major 

incidents. Employers should be aware of the dangers of 

operating on a false sense of security based on an incident

free past. Maintaining a sense of vulnerability is essential to 

ensuring that process hazards are adequately controlled. 

“My facility already has effective safety programs...” Many 

facilities that store highly hazardous chemicals may already 

have safety programs that address specific issues, like 

confined space entry, hot work, emergency response, and fire 

protection. Some facilities might also have specialized safety 

programs recommended by their insurance underwriters. 

While these programs address certain hazards associated 

with storing and handling highly hazardous chemicals, they 

may not provide the comprehensive safety assessment 

required under PSM. The good news is that, if your facility’s 

safety program is comprehensive enough, it may already be 

in compliance with PSM storage requirements or need only 

minor revisions to be compliant. 

“How complex must a PSM program be?” An employer’s PSM 

program must reflect the complexity of the covered processes 

and its hazards. Storage facilities, which generally do not 

conduct chemical reactions or have complex, interconnected 

processes, are expected to have considerably less complex 

process safety issues than those found at refineries and large 

chemical manufacturing operations. 

“How much time does it take to develop a new PSM 

program?” What makes a PSM program effective is the 

extent to which it identifies, evaluates, and controls hazards—

not the amount of time an employer spends developing 

it. Implementing PSM at storage facilities, with their lack 

of manufacturing or processing activities, should not be a 

burdensome process. Some employers who are concerned 

about resources or proper implementation can hire consultants 

to help, as discussed further below. 
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“Can employers use consultants to develop PSM programs?”

Yes. Many employers originally implemented and continue 

to run their PSM programs entirely on their own. Others seek 

outside assistance, typically by hiring consultants. This is not 

uncommon for businesses run by managers with limited or 

no engineering background. Either approach is acceptable, 

provided the PSM program focuses on and comprehensively 

addresses the facility-specific hazards, equipment, and 

operating procedures—and is not based on generic checklists, 

boilerplate language, or other resources that do not focus on 

the facility’s hazards. However, keep in mind that ultimately the 

employer is responsible for PSM compliance! 

“Must employers inform OSHA if the standard applies to 

them?” No. Unlike various other environmental, health, 

and safety regulations, the PSM standard does not have 

notification or reporting requirements. This means employers 

do not need to inform OSHA whether or not they meet the 

PSM applicability criteria. They need only ensure that they 

fully comply with the mandatory PSM requirements for all 

processes that meet the applicability criteria. Out of caution, 

some employers may choose to implement these elements in 

processes that use highly hazardous chemicals in quantities 

that do not exceed the applicability criteria—but this is not 

required.

“What should employers do if they realize their processes 

have met the applicability criteria for many years?” For any 

non-exempted process that meets the regulation’s applicability

criteria, employers should immediately take steps to comply 

with all PSM requirements, regardless of whether the process 

met the applicability criteria for decades or just recently did so. 

“Can a facility alter its highly hazardous chemical storage 

practices to avoid PSM?” Yes. When OSHA enacted 

the PSM standard, it did so in an effort to eliminate or 

minimize catastrophic incidents involving highly hazardous 

chemicals. PSM programs are risk reduction strategies. 

When implemented correctly, reducing storage inventories of 
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highly hazardous chemicals and isolating stored quantities in 

distinct facility areas are acceptable risk reduction strategies. 

Employers at storage facilities may therefore choose to safely 

alter their storage practices to reduce chemical risks—and fall 

below PSM applicability criteria—instead of complying with 

PSM. However, such facilities must still comply with other 

applicable OSHA standards and section (5)(a)(1) of the OSH 

Act, the “General Duty Clause” (which requires that employers 

provide workplaces free from recognized hazards that are likely 

to cause death or serious physical harm).

“Who should I contact for any other questions about PSM 

applicability? “ Employers who have read the requirements 

of the standard and still have questions about whether the 

standard applies to their processes should either:

■ Contact a local OSHA area office. Refer to OSHA’s website 

(www.osha.gov/html/RAmap.html) for locations and 

contact information; or

■ Request an official interpretation by writing to: 

U.S. Department of Labor

Occupational Safety and Health Administration

Directorate of Enforcement Programs

200 Constitution Ave., NW

Washington DC 20210
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Workers’ Rights

Under federal law, workers are entitled to working conditions 

that do not pose a risk of serious harm. 

For more information on how to assure a safe and healthful 

workplace, see OSHA’s Workers page.

OSHA Assistance, Services and Programs 

OSHA has a great deal of information to assist employers 

in complying with their responsibilities under OSHA law. 

Several OSHA programs and services can help employers 

identify and correct job hazards, as well as improve their 

safety and health program.

Establishing a Safety and Health Program

Safety and health programs are systems that can substantially 

reduce the number and severity of workplace injuries and 

illnesses, while reducing costs to employers. 

Visit www.osha.gov/shpguidelines for more information.

Compliance Assistance Specialists

OSHA Compliance assistance specialists can provide 

information to employers and workers about OSHA standards, 

short educational programs on specific hazards or OSHA rights 

and responsibilities, and information on additional compliance 

assistance resources. 

Visit www.osha.gov/dcsp/compliance_assistance/cas.html or 

call 1-800-321-OSHA (6742) to contact your local OSHA offi

Free On-site Safety and Health Consultation 

Services for Small Business

OSHA’s On-site Consultation Program offers free and confidential

advice to small and medium-sized businesses in all states across

the country, with priority given to high-hazard worksites. On-sit

consultation services are separate from enforcement and do not 

result in penalties or citations. 
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For more information or to find the local On-site Consultation

office in your state, visit www.osha.gov/consultation, or call 

1-800-321-OSHA (674

Under the consultation program, certain exemplary 

employers may request participation in OSHA’s Safety 

and Health Achievement Recognition Program (SHARP). 

Worksites that receive SHARP recognition are exempt from 

programmed inspections during the period that the SHARP 

certification is valid.

Cooperative Programs

OSHA offers cooperative programs under which businesses, 

labor groups and other organizations can work cooperatively 

with OSHA. To find out more about any of the following 

programs, visit www.osha.gov/cooperativeprograms.

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP) provide the opportunity 

for OSHA to partner with employers, workers, professional or 

trade associations, labor organizations, and/or other interested 

stakeholders. Through the Alliance Program, OSHA works with 

groups to develop compliance assistance tools and resources 

to share with workers and employers, and educate workers and 

employers about their rights and responsibilities.

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers in private industry 

and federal agencies who have implemented effective safety and 

health management programs and maintain injury and illness 

rates below the national average for their respective industries.
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Occupational Safety and Health Training Courses

The OSHA Training Institute partners with 27 OSHA Training 

Institute Education Centers at 42 locations throughout the United 

States to deliver courses on OSHA standards and occupational 

safety and health topics to thousands of students a year. For more 

information on training courses, visit www.osha.gov/otiec.

OSHA Educational Materials

OSHA has many types of educational materials to assist employers 

and workers in finding and preventing workplace hazards. 

All OSHA publications are free at www.osha.gov/publications and 

www.osha.gov/ebooks. You can also call 1-800-321-OSHA (674

to order publications.

Employers and safety and health professionals can sign-up for

QuickTakes, OSHA’s free, twice-monthly online newsletter with

the latest news about OSHA initiatives and products to assist 

in finding and preventing workplace hazards. To sign up visit 

www.osha.gov/quicktakes.
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OSHA Regional Offices

Region I

Boston Regional Office

(CT*, ME, MA, NH, RI, VT*) 

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860 (617) 565-9827 Fa

Region II

New York Regional Office

(NJ*, NY*, PR*, VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378 (212) 337-2371 F

Region III

Philadelphia Regional Office

(DE, DC, MD*, PA, VA*, WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-330

(215) 861-4900 (215) 861-4904 F

Region IV 

Atlanta Regional Office

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(678) 237-0400 (678) 237-0447 F

 

Region V

Chicago Regional Office

(IL*, IN*, MI*, MN*, OH, WI)

230 South Dearborn Street 

Room 3244

Chicago, IL 60604

(312) 353-2220 (312) 353-7774 F
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Region VI

Dallas Regional Office

(AR, LA, NM*, OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145 (972) 850-4149 F

(972) 850-4150 FSO Fa

Region VII

Kansas City Regional Office

(IA*, KS, MO, NE)

Two Pershing Square Building

2300 Main Street, Suite 1010

Kansas City, MO 64108-241

(816) 283-8745 (816) 283-0547 F

Region VIII

Denver Regional Office

(CO, MT, ND, SD, UT*, WY*)

Cesar Chavez Memorial Building

1244 Speer Boulevard, Suite 551

Denver, CO 80204

(720) 264-6550 (720) 264-6585 F

Region IX 

San Francisco Regional Office

(AZ*, CA*, HI*, NV*, and American Samoa, 

Guam and the Northern Mariana Islands)

90 7th Street, Suite 18100

San Francisco, CA 94103

(415) 625-2547 (415) 625-2534 F

Region X

Seattle Regional Office

(AK*, ID, OR*, WA*)

300 Fifth Avenue, Suite 1280

Seattle, WA 98104

(206) 757-6700 (206) 757-6705 F
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* These states and territories operate their own OSHA

approved job safety and health plans and cover state and local 

government employees as well as private sector employees. 

The Connecticut, Illinois, New Jersey, New York and Virgin 

Islands programs cover public employees only. (Private sector 

workers in these states are covered by Federal OSHA). States 

with approved programs must have standards that are identical 

to, or at least as effective as, the Federal OSHA standards.

Note: To get contact information for OSHA area offices, OSHA

approved state plans and OSHA consultation projects, please visit 

us online at www.osha.gov or call us at 1-800-321-OSHA (674
PROCESS SAFETY MANAGEMENT FOR STORAGE FACILITIES

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How to Contact OSHA

For questions or to get information or advice, to report an 

emergency, fatality, inpatient hospitalization, amputation, 

or loss of an eye, or to file a confidential complaint, contact 

your nearest OSHA office, visit www.osha.gov or call OSHA 

at 1-800-321-OSHA (6742), TTY 1-877-889

For assistance, contact us

We are OSHA. We can hel
For more information:

Occupational

Safety and Health

Administration

www.osha.gov (800) 321-OSHA (6742)

U.S. Department of Lab