OSHA Interpretation of PSM Applicability to Oil & Gas Processes
August 26, 1992
Dr. Harry H. West
Consulting Chemical Engineer
1415 North Loop West #1130
Houston, Texas 77008
Dear Mr. West:
This is in response to your May 11, letter to Mr. Gilbert J. Saulter, Dallas Regional Administrator for the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Compliance Programs for response.
In your letter you requested an interpretation of the Final Rule on Process Safety Management (PSM) of Highly Hazardous Chemicals published in Volume 57, Number 35 of the Federal Register on Monday, February 24, 1992. In particular, you questioned whether single well processing facilities with equipment including separators, heat-treaters and storage tanks used in gas production (from non-H(2)S containing petroleum fluids) operations would be exempt from employer compliance with the PSM standard within the context of 1910.119(a)(2)(ii), which excludes oil and gas well drilling and servicing operations.
The 1910.119(a)(ii) exemption of oil or gas well drilling or servicing operations is intended to cover all drilling operations and any well servicing operation including acidizing. Additionally, water separation facilities adjacent to or near the well (including tanks used primarily for water separation in conjunction with oil or gas well production) are not covered by the PSM Standard.
The following processes, when they involve at least threshold quantities of oil or gas, are covered by the PSM standard. Oil or gas well production fluids from several wells are processed by heating the fluids and physically separating the water from the gas or oil. The water is returned to the ground via a "down hole well" for disposal return to the strata from which it came. But if these oil or gas well drilling operations take place at "normally unoccupied remote facilities", then according to 1910.119(a)(2)(iii), they are exempt from PSM standard coverage.
OSHA is developing a directive which will provide interpretive guidance and inspection procedures to our field staff. We will send you a copy of the directive when it is completed in the near future. Please refer to that directive for additional PSM standard interpretations and clarifications, for example, on what constitutes a normally unoccupied remote facility.
Thank you for your interest in occupational safety and health. If we may be of further assistance, please do not hesitate to contact us.
Patricia K. Clark, Director
Directorate of Compliance Programs