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 https://www.osha.gov.



March 9, 1994

Ms. Joanne B. Linhard
Organization Resources Counselors, Inc.
1910 Sunderland Place, N.W.
Washington, D.C. 20036

Dear Ms. Linhard:

This is in response to your September 9 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals, 29 CFR 1910.119 standard. We apologize for the delay in response. Your question and our response follow.

Question: May an employer, who has developed and reviewed an initially accurate set of operating procedures and who has effective management of change procedures in place (in compliance with 1910.119(l)), certify on an annual basis thereafter that the operating procedures are current and accurate without actually performing a review of the procedures each year after the initial review?

Reply: Yes. The standard states that operating procedures must be reviewed as often as necessary to assure that they reflect current operating practice. If an employer determines that modifications resulting from management of change are incorporated into operating procedures and determines that no other changes occur, then the employer could certify that the procedures are current and accurate and have been reviewed as often as necessary. While 1910.119(p)(3)(f)(3) requires annual certification that operating procedures are current and accurate, there is no requirement for an annual review, as such.

Thank you for your interest in occupational safety & health. If we may be of further assistance please contact us.


H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs

[Corrected on 11/11/2005]