This article appears in the Spring 2026 issue of Tanks and Terminals magazine, a copyrighted publication of Palladian Publications.
The US Department of Labor’s Occupational Safety and Health Administration (OSHA) oversees enforcement and compliance of diverse standards geared at safeguarding worker protection, safety, and health across a variety of industry sectors. In general, OSHA’s regulations applicable to the tanks and terminals sector are compiled in the OSHA General Industry Standards.
As part of its efforts, OSHA has instituted the National Emphasis Program (NEP). These are temporary programmes that focus OSHA’s resources on particular hazards and high-hazard industries. Existing and potential new emphasis programmes are evaluated using inspection data, injury, and illness data, National Institute for Occupational Safety and Health (NIOSH) reports, peer-reviewed literature, analysis of inspection findings, and other available information sources. The Process Safety Management and fall protection/work at heights standards are among the current NEPs.
OSHA also maintains a list of Regional and Local Emphasis Programs (REP/LEP) that target hazards or industries with specific risks to workers in that area. For example, the Kansas City OSHA office has developed REPs for work conducted after severe weather events. On the other hand, the San Francisco office (which oversees western states including Iowa, a unionised state) has developed an LEP applicable to floating seafood processors.
In addition to the above, there are other programmes well known for their susceptibility to create high risk situations. These include entries into confined spaces, lockout/tagout of hazardous energy sources (including line breaking), and electrical hazards.
OSHA and the tank and terminals sector
During the period from October 2024 to September 2025, OSHA issued 15 citations and conducted six inspections at petroleum bulk stations and terminals. The highest number of citations (four) were issued for violations to process safety management standards; fall protection and hazard communication accounted for two violations each. Penalties for the period totalled just over US$75 000.
This article will explore some of the programmes highlighted in OSHA inspections, as well as some high-risk activities.
Process safety management (PSM)
PSM is a critical tool in the safe operation of terminal processes due to the potential presence of large quantities of highly hazardous chemicals. The industry has experienced catastrophic events such as major fires, explosions, and toxic releases at bulk storage facilities that underscore the importance of strong PSM implementation. Although all 14 elements of the OSHA PSM standard are important for a robust programme, several critical elements are routinely identified in inspections as deficiencies throughout this industry.
Process hazard analysis (PHA)
PHA in storage facilities and terminals must evaluate the unique hazards present by the movement and storage of the highly hazardous chemicals present, such as incompatible mixing, storage temperature stability, and scrubber operations where applicable. Common gaps include incomplete PHA and failure to consider interconnected systems and external events like flooding or hurricanes, leaving risks unaddressed.
Mechanical integrity
OSHA often cites inadequate inspection and maintenance of critical equipment such as pumps, valves, and emergency isolation systems, which can lead to leaks or overfills. Facilities must identify the appropriate codes and standards for each piece of equipment or system to ensure the correct inspection and maintenance is being performed.
Operating procedures and training
Outdated or poorly implemented procedures and insufficient training can increase human error during transfers and emergency response. Maintenance and contractor training is also frequently overlooked, creating compliance and safety gaps.
Management of change (MOC)
Changes in tank configurations or product types without hazard review introduce unmitigated risks. Missing documentation and inadequate communication of changes are frequently identified issues.
Emergency planning and response
In this industry, incidents can escalate rapidly due to large inventories of flammable or toxic chemicals, so a well-developed plan is critical. Common pitfalls include outdated plans that fail to reflect current tank configurations, chemical inventories, or site layout, insufficient drills and training, and lack of coordination with external responders resulting in delayed or ineffective response.
For storage and terminals facilities, robust PSM implementation is more than just regulatory compliance: it is essential for preventing catastrophic fires, explosions, and toxic releases that threaten workers, communities, and the environment.
Confined space
Across the tanks and terminals sector, confined space entry continues to present significant operational risk. OSHA’s permit-required confined space (PRCS) standard requires employers to evaluate spaces, determine which are permit-required spaces, implement written entry procedures, and assign responsibilities for entrants, attendants, and entry supervisors. However, inspections often show that the practical implementation of these requirements does not consistently match written expectations. Recent OSHA fatality investigations have also highlighted deficiencies in atmospheric monitoring (including proper calibration of monitoring equipment), training, and rescue readiness during confined space entry.
A frequent issue identified during inspections is an incomplete or poorly implemented PRCS programme. While most facilities have written confined space procedures, inspectors often find missing or unclear supporting elements, such as how spaces are classified, how hazards are evaluated, or how responsibilities are communicated and carried out. In many cases, there is a noticeable disconnect between what is written in the procedure and the steps employees actually follow during an entry.
Atmospheric testing is another common weakness. The standard requires testing the atmosphere before entry, and when conditions may change, there should be continuous monitoring. In tank environments, atmospheric conditions can shift quickly due to factors such as product residues, connected piping, ventilation changes, or the opening of manways during preparation. OSHA’s tank-entry guidance and industry standards like NFPA 326 emphasise the need for thorough initial testing and ongoing verification, yet inspections routinely uncover incomplete pre-entry testing, inconsistent calibration or bump-testing practices, or the absence of continuous monitoring when conditions are likely to vary. In some cases, testing equipment is present but not used in accordance with manufacturer or provider guidance, a trend that is highlighted in multiple recent OSHA investigations involving tank entries.
Isolation of hazardous energy is also a recurring concern during confined space operations. The PRCS standard requires isolating the space from all hazards, and in tank environments this often involves multiple valves, pumps, and transfer lines. Inspections frequently reveal missing verification steps, unclear isolation methods, or inconsistent coordination between operators and contractors, particularly during non-routine tasks such as tank cleaning or product changeovers.
Rescue preparedness is another area where deficiencies are consistently identified. The standard requires employers to ensure that rescue services can respond in a timely manner, and that rescue equipment is available, maintained, and appropriate for the space. Inspections often find generic or outdated rescue plans, limited coordination with off-site rescue services, or rescue equipment that has not been maintained but is still staged for use. Several recent OSHA cases involving tank entries have emphasised the consequences of inadequate rescue planning and equipment.
These trends demonstrate that confined space risks in terminal operations often arise from incomplete implementation, unclear responsibilities, or inconsistent field execution. Strengthening coordination, improving how procedures are carried out, and providing detailed site-specific training can significantly improve employee safety and overall performance during inspections.
Fall protection
Working at heights at storage facilities and terminals requires task hazard assessments to determine if existing equipment (e.g. fixed ladders, walkways, or scaffolding) provide adequate fall protection or whether personal protective equipment (PPE) will be required. Worker training is required before exposure to a fall hazard for understanding of proper use of personal fall protection systems, including proper harness fit, anchoring, and tie off techniques.
Worker training for fall hazards must be delivered by a qualified person, which is defined by 29 CFR 1926.32(m) as: “Qualified means on who, by possession of a recognised degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated ability to solve or resolve problems relating to the subject matter, the work, or the project.”
A combination of task demonstration, discussion, and document review should be considered to ensure that training is fully understood by the employee(s).
