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OSHA 1910.119AppD

Further information sources

Subpart H

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.119AppD, is Appendix D mandatory for employers to follow when implementing Process Safety Management (PSM)?

No, Appendix D is nonmandatory guidance that employers may use for additional information. Appendix D is titled "Sources of Further Information (Nonmandatory)" and lists books, industry standards, and government publications that can help with PSM topics but does not create additional legal obligations beyond the PSM standard itself. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory) and the PSM regulation at 1910.119.

Under 1910.119AppD, can an employer rely solely on one of the listed sources (for example CCPS guidance) to demonstrate compliance with the requirements of 1910.119?

No, relying solely on a listed source in Appendix D does not automatically demonstrate compliance with 1910.119. Appendix D provides helpful references but the employer remains responsible for meeting the specific requirements of the PSM standard itself. Employers should use the listed guidance to inform their programs but must ensure their procedures, analyses, and practices meet the legal requirements in 1910.119.

Under 1910.119AppD, what kinds of publications does OSHA list as sources of further information for process safety?

Appendix D lists industry guidance, technical textbooks, and government reports that address hazard evaluation, process safety management, emergency planning, and related topics. Examples include the Center for Chemical Process Safety (CCPS) publications, American Institute of Chemical Engineers guidelines, API recommended practices (for example API RP 750), Chemical Manufacturers Association guidance, and OSHA publications such as "Safety and Health Program Management Guidelines" and "Safety and Health Guide for the Chemical Industry". See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory) and the PSM standard at 1910.119.

Under 1910.119AppD, does listing API Recommended Practice 750 (API RP 750) mean employers must follow API RP 750 to comply with 1910.119?

No. Listing API RP 750 in Appendix D identifies it as a useful reference but does not make it a mandatory requirement. Employers may consult API RP 750 for guidance on management of process hazards, but they must still ensure their written programs meet the specific elements and performance expectations in 1910.119.

Under 1910.119AppD, how should employers use OSHA publications listed in the appendix (for example OSHA 3091)?

Employers should treat OSHA publications listed in Appendix D as practical guidance that explains and clarifies safety topics but not as additional mandatory rules. Such documents (for example "Safety and Health Guide for the Chemical Industry" (OSHA 3091)) can help employers design their PSM elements, but compliance must be judged against the text of 1910.119 itself.

Under 1910.119AppD, which resources does OSHA recommend for guidance on hazard evaluation procedures?

Appendix D explicitly lists the American Institute of Chemical Engineers' "Guidelines for Hazard Evaluation Procedures" and similar CCPS materials as recommended references for hazard evaluation. Employers can consult those resources for methodologies and examples when conducting process hazard analyses, while still ensuring the PHA meets the legal requirements in 1910.119. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory).

Under 1910.119AppD, what emergency planning sources does OSHA list that PSM programs can consult?

Appendix D lists several emergency-planning resources, including an EPA/FEMA/DOT technical guidance titled "Technical Guidance for Hazards Analysis, Emergency Planning for Extremely Hazardous Substances" and an EPA report "Review of Emergency Systems." Employers may use those documents to develop or improve emergency response and coordination plans, while ensuring overall compliance with 1910.119 and applicable local requirements. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory).

Under 1910.119 and relevant OSHA interpretations, is storage of pre-charged air conditioners with refrigerant considered a "process" subject to PSM when the aggregate refrigerant exceeds the threshold quantity?

Yes, storage of pre-charged air conditioners or heat pumps that together contain a Category 1 flammable gas on site in one location and in an aggregate amount at or above the 10,000 pound threshold can be a PSM-covered "process." OSHA has explained that "process" includes storage and on-site movement, so a warehouse storing many pre-charged units may meet the PSM coverage criteria. See the PSM standard at 1910.119 and OSHA's interpretation on this topic at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

Under 1910.119AppD, how can an employer obtain the non-OSHA books and industry documents listed (for example works by Lees or CCPS)?

Appendix D provides the titles, publishers, and contact information (addresses and phone numbers) for the listed books and industry publications so employers can order or locate them through the publishers or professional organizations. Employers should use the citation information in Appendix D to 1910.119 – Sources of Further Information (Nonmandatory) to contact the appropriate organization or search library and publisher catalogs.

Under 1910.119AppD, is the Center for Chemical Process Safety (CCPS) specifically listed as an information source and how might its guidance be used?

Yes, Appendix D lists the Center for Chemical Process Safety (CCPS) and specific CCPS documents as recommended sources. Employers can use CCPS guidance for practical tools, methodologies, and examples for hazard evaluation, management systems, and technical process safety practices, but must still ensure their programs comply with the mandatory elements of 1910.119. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory).

Under 1910.119AppD, does inclusion of contractor-safety guidance (for example API RP 2220 or Business Roundtable Report A-3) mean OSHA requires those contractor evaluation criteria be used?

No, inclusion of contractor-safety guidance in Appendix D identifies useful references for improving contractor selection and oversight but does not require employers to use a specific publication. Employers should apply the mandatory contractor-related obligations in 1910.119 and may adopt practices from the listed sources (for example API RP 2220 or the Business Roundtable report) to strengthen their contractor management programs. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory).

Under 1910.119AppD, if an employer in a State with an OSHA-approved State Plan uses guidance from the appendix, do they need to check with the State for differences?

Yes. While Appendix D is federal nonmandatory guidance, employers in States with OSHA-approved State Plans should confirm whether their State plan has additional or different guidance or enforcement policies. OSHA has noted in interpretation letters that State plans may be more stringent and employers must follow State requirements in those jurisdictions. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory) and the discussion of State-plan differences found in OSHA interpretation letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01.

Under 1910.119AppD, can the industry textbooks listed (for example "Loss Prevention in the Process Industries" by Lees) be used to support Process Hazard Analysis (PHA) methods?

Yes, industry textbooks like Lees' "Loss Prevention in the Process Industries" are listed in Appendix D as useful technical references and can be used to inform PHA methods and analyses. Employers may draw on the practices and technical explanations in such texts when performing PHAs, but they must ensure the chosen PHA method and its execution meet the PSM requirements in 1910.119. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory).

Under 1910.119AppD, what is the role of government agency reports listed in Appendix D (for example EPA and FEMA guidance) for emergency systems and response planning?

Government agency reports listed in Appendix D, such as EPA/FEMA/DOT technical guidance and the EPA "Review of Emergency Systems," are recommended references to help employers design emergency systems, coordinate with local authorities, and plan responses for chemical incidents. These reports provide practical approaches and considerations that employers can incorporate into their emergency response plans while ensuring they meet the PSM requirements in 1910.119. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory).

Under 1910.119AppD, if a company wants to use a consensus standard or an "alternative method," does Appendix D make that alternative acceptable to OSHA?

No, Appendix D does not automatically make a consensus standard or alternative method acceptable to OSHA. Appendix D lists consensus documents that may help design safe systems, but acceptance of an alternative method depends on whether it meets the performance and specific requirements of the mandatory standard. OSHA has explained in other interpretations (for example about alternative methods in lockout/tagout) that it values consensus standards but has not automatically adopted all alternative-method definitions. See Appendix D to 1910.119 – Sources of Further Information (Nonmandatory) and OSHA's discussion of alternative methods in the lockout/tagout interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.