Industry is struggling with an issue: how does it,in an effective and feasible way,fulfill the facility siting requirements in OSHA'S Process Safety Management Standard,29 C.F.R.1910.119.This issue is very complex,involving various industry guidance documents,good engineering practices,and the exercise of professional judgment.Many facets of the issue are unresolved and subject to continuous debate within the Industry.For example,should qualitative or quantitative risk analysis be used; should credible or worst case scenarios be used; should occupancy criteria be 200 or 400 man hours per week; or should control rooms be moved or reinforced? Since the PSM Standard is a performance standard,individual employers and their Industry have a great deal of discretion in resolving these issues.
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