OSHA's PSM standard excludes highly hazardous chemicals used in normally unoccupied remote facilities, a narrow exemption originally intended for oil and gas production sites and similar isolated installations where worker exposure is limited. These letters clarify what normally unoccupied and remote mean in practice. A facility that is periodically staffed, that has nearby occupied buildings, or that is part of a larger facility complex generally will not qualify. OSHA has been restrictive in applying this exemption, and these letters show the analysis OSHA applies on a case-by-case basis.

What OSHA Has Said

Feb 16, 2005
Normally Unoccupied Remote Facility Exemption Staffed for Maintenance
OSHA addresses whether periodic entry for maintenance and inspection defeats the normally unoccupied status. OSHA position: occasional entry by trained personnel does not by itself render a facility occupied, but regular shifts do.
Read OSHA Letter ↗
May 29, 1998
Remote Facility Exemption and Proximity to Populated Areas
OSHA clarifies what remote means for the exemption. A facility adjacent to a plant boundary, near public roads, or close to residential areas is unlikely to qualify as remote even if employees are seldom present.
Read OSHA Letter ↗

⚡ Key Compliance Takeaway

The normally unoccupied remote facility exemption is narrow. If workers enter on any regular schedule, evaluate whether operations have become occupied. Proximity to other occupied facilities or public areas weighs heavily against the exemption.