SGIA attended the Small Business Labor Safety Roundtable hosted by the Occupational Safety and Health Administration (OSHA) and the Mine Safety and Health Administration (MSHA) on Friday, July 17, 2015 at the U.S. Small Business Administration building in Washington, DC. The agenda was primarily focused on the impact OSHA’s Process Safety Management (PSM) and EPA’s Risk Management Program (RMP) will have on small businesses in various industries.
Bruce Lundegren, Assistant Chief Counsel at the SBA Office of Advocacy, led the meeting, and started off with a brief overview of the Small Business Regulatory Enforcement Fairness Act, or SBREFA, process. Lundegren reported that both OSHA and EPA plan to convene SBREFA panels for their related PSM and RMP programs in 2015.
Mark S. Dreux of Arent Fox, LLP presented an overview of OSHA’s PSM and EPA’s RMP, discussing the similarities and differences of the two programs from a small business perspective. Dreux stated that both programs are related to chemical facility safety: EPA’s program is designed to protect human health and the environment from hazards associated with chemical releases, while OSHA’s program is focused on employee safety from similar hazards.
The final presentation was a panel discussion on how EPA’s RMP program and OSHA’s PSM rule impact small businesses across several distinct industries. Lowell Randel of the Global Gold Chain Alliance spoke about the refrigeration and cold storage transport industry. Theresa Forbes from the National Association of Chemical Distributors gave an in-depth look at how the chemical distributor industry works and how RMP and PSM rules affect this industry. James W. Conrad Jr., representing the Society of Chemical Manufacturers and Affiliates, discussed the topic of chemical batch, custom, and specialty producers industry. All of the presenters agreed on key points – that third party audits are expensive and not practicable for small businesses, and that the requirements of these two policies are not always feasible within these industries.