In an interpretation letter dated October 27, 2010, OSHA clarified their policies related to Vendor-owned and operated systems of process safety management (PSM)-covered chemical supply systems on industrial sites.  Such sites are relatively common in the semiconductor and pharmaceutical industries where a chemical supplier owns and operates a gas or chemical supply system to a production process that is owned by the host company.

A copy of the original request letter and the OSHA interpretation letter is available on the Resources page of our website at http://www.specialtytechnicalconsultants.com/resources/.  If you have further questions on these issues or wish help interpreting shared roles between suppliers and hosts for PSM systems, please contact Barb Ruble or 410-625-1952.