Process hazard analysis deadlines with one or two covered processes

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 3, 1993

Ms. Shelly Howard
Tyson Foods, Inc.
[Recipient address omitted]
Dear Ms. Howard:

This is in response to the February 12 letter from Tyson Foods, Inc., signed by Ms. Shannon Weather, to Mr. James F. Foster, Director Office of Information and Consumer Affairs of the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Compliance Programs for response. In the April 27 telephone call between you and Mr. Ronald Davies of my staff, you disclosed that Ms. Weather no longer is employed by Tyson Foods, Inc., and you asked that this response be addressed to you. Please accept our apology for the delay in responding.

In the February 12 letter, clarification was requested on the 1910.119(e) deadlines for completion of process hazard analysis (PHA's). Specifically, does the percentage requirement pertain even if one or two processes are present at a worksite? Also, should 100% of the PHA be completed by May 26, 1994, if one process is present?

Normally, if only one process (covered by the PSM standard) is present, the PHA for the covered process must be completed in its entirety as soon as possible but no later than May 26, 1994. If there are only two covered processes then a PHA on the higher priority process must be completed in its entirety as soon as possible but not later than May 26, 1994, and a PHA on the second process must be completed in its entirety as soon as possible but no later than May 26, 1995.

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

Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs