Not unlike the response to the interpretation letter concerning at-home workplace safety that made front-page news, OSHA apparently modified the original letter  in response to the suggestions from the American Petroleum Institute and Organization Resources Counselors. A new letter dated 11/20/99 was posted on the letters database on 12/20/99. Only the one sentence was removed (“OSHA does not, however, consider daily visits, regardless of duration, to constitute ‘periodic’ visits for the purposes of this exception."). Both letters are available on AcuSafe by clicking on the links highlighted above.

The API is still concerned that the interpretation letter expands the scope of the PSM standard into operations not previously covered. OSHA may be out of bounds because the original economic studies done on the impact of the PSM standard did not include the SIC (now NIACS) codes for oil production operations. According to oil production insiders who were involved with the original RMP rulemaking, it was the intent of OSHA to eventually make special rules for oil production operations. That was never done. This turn of events may force OSHA to reopen the rule for formal coverage of simple oil production operations.

It is believed that the interpretation letter was driven by the fact that OSHA had to rescind citations issued to Sonat Exploration after their significant incident in Pitkin, Louisiana in March 1998, which killed 4 workers. This prompted national attention and was one of the early investigations conducted by the Chemical Safety Board.