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Washington State: Fire Water Utility System is Not Subject to MI, PHA Regulations

Prepared for the Katten Safety Advisory Group
Advisory | October 17, 2018

On September 26, 2018, the Washington Board of Industrial Insurance Appeals ("BIIA") affirmed a May 11, 2018, administrative law judge ("ALJ") order that vacated several citations issued against a Washington Refinery. BIAA specifically ruled that fire water systems are not "process equipment" subject to the mechanical integrity and process hazard analysis ("PHA") regulations of the Washington process safety management ("PSM") rule. The Washington PSM Rule is identical to the federal OSHA PSM Standard (29 C.F.R. 1910.119).

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