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.

February 24, 1995

Mr. Dean H. DeGhetto, Senior Associate
Environmental Risk Limited
1373 Broad Street
Clifton, NJ 07013

Dear Mr. DeGhetto:

This is in response to your letter of January 17, regarding Section (o) "Compliance Audits" of the Process Safety Management for Highly Hazardous Chemical Standard, 29 CFR 1910.119.

Your letter inquired whether pursuant to Section (o), paragraphs (1) and (4), deficiencies should be corrected within a three year timeframe, or promptly after the audit is conducted.

OSHA believes that a compliance safety audit provides an important function in assuring that an effective process safety management system is in place and working. If deficiencies are discovered, it is imperative that corrective actions be initiated immediately, so that corrective measures can be implemented as soon as possible.

Thank you for your interest in occupational safety and health.

Sincerely yours,



John B. Miles, Jr., Director
Directorate of Compliance Programs