In response to the health and safety concern presented by the coronavirus in essential industries, OSHA
and the EPA
have both published enforcement discretion notices that are meant to add some breathing room for facilities juggling regulatory compliance with personal safety. However, the stipulations put in place for facilities to lean on these temporary enforcement policies, especially with regard to the OSHA PSM and EPA RMP standards, are vague as to what facilities must do to qualify for leniency in compliance.
Facilities must demonstrate “good faith efforts”, but what does that really mean with regard to PSM/RPM program elements?Read more