July 2018, Vol. 245, No. 7


Lines Between Regulators Still Blurry for Midstream Processors

By Robert Nichols and Kevin Ewing, Bracewell LLP, Houston and Washington The Pipeline and Hazardous Materials Safety Administration (PHMSA) began an effort in 2014 to help businesses engaged in midstream oil and gas processing operations determine where the lines fall between applicability of PHMSA safety rules and Occupational Safety and Health Administration (OSHA) regulation, particularly OSHA’s process safety management (PSM) standard.  As a result, a working group of PHMSA and industry representatives offered proposed guidance in August 2015 in the form of FAQs.  Although PHMSA has never published the guidance as official agency policy, while cautioning it does not carry the force of

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