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OSHA Issues Revised Chemical Concentrations Enforcement Memorandum

Prepared for the Katten Safety Advisory Group
Advisory | August 10, 2016

The Occupational Safety and Health Administration ("OSHA") recently published a revised version of its guidance memorandum "Process Safety Management of Highly Hazardous Chemicals and Covered Concentrations of Listed Appendix A Chemicals" (the "Chemical Concentrations Memorandum"). Media reports indicate that the revised memorandum, which was released on July 18, 2016, was issued as a part of a settlement to resolve industry challenges to the validity of the original version of the Chemical Concentrations Memorandum. The original Chemical Concentrations Memorandum, which was published on June 5, 2015, was one of three PSM enforcement memoranda issued by OSHA last year in its effort to comply with President Obama's Executive Order 13650, Improving Chemical Facility Safety and Security. All three memoranda prompted legal challenges from the chemical and agricultural sectors. As previously alerted, OSHA has already issued a revised version of one of the other guidance memoranda, "RAGAGEP in Process Safety Management Enforcement," as a part of a similar settlement to resolve industry challenges. See KSAG Alert 2016-18....

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