OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
June 7, 1993
Ms. Christine W. Reiter
Manager, Government Relations
Synthetic Organic Chemical Manufacturers
1330 Connecticut Avenue, N.W.
Washington, D.C. 20036-1791
Dear Ms. Reiter:
Thank you for your letter of April 22, requesting that the Synthetic Organic Chemical Manufacturers Association's (SOCMA) Chemical Process Operator Certification Training Program be included as a resource in the next update of the compliance directive for the Process Safety Management (PSM) standard. Please accept our apologies for the delay in this response.
The Occupational Safety and Health Administration (OSHA) plans to include a reference to SOCMA's program in Appendix D of the forthcoming update of the directive, OSHA Instruction CPL 2-2.45A CH-1. We believe SOCMA's program is a useful resource for compliance with the PSM standard's training requirements.
The updated directive should be published in about one month. We will be happy to provide you with a copy when it is available. If you have any further questions, please feel free to contact Mr. Rolland Stroup at 202-219-8031.
Roger A. Clark, Director
Directorate of Compliance Programs