Ezel / Labor Guidance / US
Back to Federal guidance

Interim PSM enforcement at oil and gas production facilities

Summary OSHA told regional administrators it would not enforce the process safety management standard at oil and gas production facilities while it studied feasibility. The memo expressly withdrew its December 20, 1999 memorandum from the website. The posted page does not say when the interim pause ended, so its current status is uncertain.
Document
Federal guidance
Agency
Occupational Safety and Health Administration (OSHA)
Document number
2000-04-11-1
Date issued
April 11, 2000
Status
Unknown
The memo states an interim enforcement position pending economic analysis; OSHA does not state on this page whether that interim position remains operative. It expressly withdrew the December 20, 1999 memorandum.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Process Safety Oil Gas
Source
View the official document

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

The current status of this document is unclear
The memo states an interim enforcement position pending economic analysis; OSHA does not state on this page whether that interim position remains operative. It expressly withdrew the December 20, 1999 memorandum. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

April 11, 2000

MEMORANDUM FOR:
REGIONAL ADMINISTRATORS

FROM:
RICHARD FAIRFAX, Director

DIRECTORATE OF COMPLIANCE PROGRAMS

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]

Related guidance

Permanently labeled locks for electrical lockout Opinion Letter · August 17, 2026 Helmet selection for lateral head-impact hazards Opinion Letter · August 17, 2026 Asbestos precautions when restoring drywall after flood damage Opinion Letter · May 7, 2026 Enforcement policy for recording and reporting COVID-19 cases Guidance · March 31, 2026

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace