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.



April 11, 2000



SUBJECT: Enforcement of PSM at Oil and Gas Production Facilities and Withdrawal of December 20, 1999 Memorandum


This memorandum is a follow up to OSHA's December 20, 1999 memorandum to Regional Administrators concerning the applicability of the Process Safety Management (PSM) Standard to oil and gas production wells.

Based on a further examination of the rulemaking record, OSHA has decided to perform an economic analysis with respect to the feasibility of compliance at oil and gas production wells. Pending a feasibility determination, OSHA will not enforce the PSM standard at oil and gas production facilities. In addition, although OSHA believes that its statements in the December 20, 1999 memorandum are legally correct, OSHA has removed this memorandum from its website to avoid confusion during this interim period.

As this memorandum demonstrates, OSHA's re-examination of an issue may result in the clarification or correction of previously stated enforcement guidance. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at 202-693-1850.

[Corrected 08/17/2006]