A process safety professional in Houston asked OSHA whether recommendations from a facility siting study report must be included on the process hazard analysis (PHA) worksheet itself to comply with 29 CFR 1910.119(e)(5) and 1910.119(e)(7) of the Process Safety Management standard.
OSHA answered no. Employers are not required to fold facility siting study findings and recommendations into the same PHA worksheet or recommendations log. That said, 29 CFR 1910.119(e)(3)(v) still mandates that facility siting be addressed within the PHA framework. When facility siting studies are used to supplement a PHA, OSHA stated that 'all findings and recommendations from the facility siting study must be documented and the employer must ensure timely resolution.'
Because the PSM standard operates on performance-based principles, OSHA does not mandate a specific documentation method. The key obligation is substantive, not formatting: 'the employer's documented findings and recommendations from the facility siting study must be maintained and consistent with the employer's system to promptly address those findings and recommendations as required in 29 CFR 1910.119(e)(5) and 29 CFR 1910.119(e)(7).' In practice, you can keep siting study recommendations in a separate tracking system, as long as they are documented, tracked, and resolved on the same footing as PHA recommendations.