900 Oil and Gas Safety Management

Process Safety Management (PSM)

PSM in the Oil and Gas Industry

OSHA's Process Safety Management (PSM) standard 29 CFR 1910.119 applies to oil and gas operations involving highly hazardous chemicals above threshold quantities.

PSM primarily applies to downstream segments such as petroleum refineries, gas processing plants, petrochemical facilities, LNG terminals, and NGL fractionation plants.

A “process” is defined by OSHA in the PSM standard as “any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities.”

The following operations are exemptions to OSHA PSM standard’s scope:

• Retail facilities
• Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical (HHC) covered by the PSM standard
• Flammable liquids with a flashpoint below 100 °F (37.8 °C) stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration. (Note: Atmospheric tanks are storage tanks designed to operate at pressures from atmospheric through 0.5 psig)
• Oil or gas well drilling or servicing operations
• Normally unoccupied remote facilities

Note: PSM does not apply to oil or gas well drilling or servicing operations. This exemption holds regardless of location, including onshore sites, offshore platforms on U.S. navigable waters, or the Outer Continental Shelf. As of December 2025, there have been no regulatory changes to remove this exemption, despite ongoing discussions and proposals since 2022 to potentially expand PSM coverage to include drilling and servicing. The Chemical Safety Board (CSB) has repeatedly urged OSHA to extend PSM to onshore drilling, but no such expansion has occurred as of late 2025.

We will discuss the standard's 14 elements that provide a framework to prevent catastrophic releases of toxic, reactive, or flammable chemicals, such as H₂S. Each element is described with its application in oil and gas, followed by practical examples drawn from industry practices and OSHA guidance.

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