PHMSA vs OSHA for Hydrocarbon Facilities
by Michael Hurley, 11/12/2025 Be the first to commentTags: Mechanical Integrity Process Safety Management Regulation
Hydrocarbon facilities in the U.S. frequently face overlapping regulation from the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Occupational Safety and Health Administration (OSHA). While PHMSA primarily governs transportation safety via pipelines (49 CFR 190-199), OSHA focuses on worker safety and health within facilities, including Process Safety Management (PSM). This post clarifies their distinct scopes, common jurisdictional boundaries (e.g., at the first valve inside a facility), and provides tips for operators to integrate their compliance programs.
Hydrocarbon facilities in the U.S. - such as refineries, gas plants, terminals, and pipelines - often fall under both PHMSA and OSHA jurisdiction, but for different reasons. Their scopes overlap in some areas (especially process safety), yet each agency enforces distinct regulations. Let's take a deeper dive into the PHMSA and OSHA in-service integrity regulations.
1. Primary Regulatory Focus
Both organizations are focused on integrity, but the principal question for companies in these sectors to ponder is whether these facilities fall under the OSHA Process Safety Management regulation. The table below presents each organization's primary responsibilities:
| Agency | Full Name | Core Focus |
|---|---|---|
| PHMSA | Pipeline and Hazardous Materials Safety Administration (part of the U.S. Department of Transportation, DOT) | Transportation and storage of hazardous materials and energy products via pipelines and containers |
| OSHA | Occupational Safety and Health Administration (part of the U.S. Department of Labor) | Worker safety and health inside workplaces and facilities |
2. Jurisdiction
A PHMSA draft notification document was issued in 2020 to help clear up where PHMSA jurisdiction ends and OSHA begins. After researching this document and reviewing other announcements/articles, the table below summarizes AOC's understanding
| Area | PHMSA | OSHA |
|---|---|---|
| Pipelines (transmission, gathering, distribution) | ✅ Yes - primary authority under 49 CFR Parts 190–199 | ❌ No - (PHMSA preempts OSHA for most pipeline operations) |
| Pipeline terminals and compressor stations | ✅ Yes - Applies up to certain facility boundaries | ✅ Yes - May also apply inside buildings or where employees work |
| Refineries, gas processing plants, chemical plants | ❌ No - Typically not covered by PHMSA (except pipeline connections) | ✅ Yes - Fully covered under 29 CFR 1910, including PSM (Process Safety Management) |
| Storage (tanks, spheres, caverns) | ✅ Yes - If integrated with pipeline systems | ✅ Yes - If within facility boundaries or employee work areas |
| Transportation (trucks, railcars) | ✅ Yes - For the hazardous materials transport itself | ✅ Yes - For worker safety during loading/unloading |
3. Key Regulations
The regulations below are where the confusion lies.
| Regulation | Agency | Purpose |
|---|---|---|
| 49 CFR Parts 190–199 (1) | PHMSA | Reporting, integrity management, and enforcement |
| 29 CFR 1910.119 (2) | OSHA | Process Safety Management (PSM) of Highly Hazardous Chemicals |
4. Overlap and Coordination
PHMSA jurisdiction typically ends at the first valve inside a refinery, tank farm, or process facility; beyond that, OSHA takes over. To clear this up, the announcement defined Midstream Facilities as:
"A processing facility that receives products being transported by PHMSA-jurisdictional pipelines and reinjects those products for continued transportation by pipeline. In other words, a midstream processing facility is a processing facility with piping or storage that is engaged in the transportation of gas or hazardous liquids by pipeline, and is therefore a pipeline facility subject to PHMSA jurisdiction. The pipeline systems within or associated with midstream processing facilities may be subject to regulation by one or more Federal agencies, depending on the facility's purpose and configuration. PHMSA regulates the safety of transportation-related pipeline systems associated with midstream processing facilities in 49 CFR parts 190–199, while OSHA regulates safety within midstream processing facilities using the Process Safety Management (PSM) regulations (29 CFR 1910.119)." (3)
5. Examples
Below are some specific examples to help your understanding of the boundaries of the regulations.
| Scenario | PHMSA Applies? | OSHA Applies? |
|---|---|---|
| Crude oil transmission pipeline between fields | ✅ Yes | ❌ No |
| Compressor station building | ✅ Yes | ❌ No |
| Refinery distillation unit | ❌ No | ✅ Yes |
| Midstream Processing Facility | ❌ No | ✅ Yes |
| LNG terminal (marine offloading) | ✅ Yes | ✅ Yes |
| Truck rack loading at a terminal | ✅ Yes | ✅ Yes |
6. Integration Tip for Operators
To stay compliant and efficient:
- Map jurisdictional boundaries clearly in your documentation and drawings
- Align Mechanical Integrity (MI) and Risk-Based Inspection (RBI) programs so they meet both OSHA PSM and PHMSA IMP expectations
- Cross-reference PSM, RMP, and PHMSA IMP requirements to avoid duplicate work and inconsistent risk management.
If your organization needs help aligning your MI programs to comply with both organizations, please contact us or reach out to me directly.
REFERENCES
- "Pipeline Safety Regulations (Annotated)", U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) https://www.phmsa.dot.gov/training/pipeline/annotated-regulations
- "Process Safety Management (PSM) of Highly Hazardous Chemicals", Occupational Safety and Health Administration (OSHA), https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.119
- "Pipeline Safety: Midstream Facilities Frequently Asked Questions", U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), November 4, 2020 https://www.phmsa.dot.gov/regulations/federal-register-documents/2020-24011.
- "Pipeline safety update - Issue No. 161", Van Ness Feldman, LLP., November 13, 2020, https://www.vnf.com/pipeline-safety-update-issue-no-161.
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