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November 14, 1983
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MEMORANDUM FOR:
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PERRY JONES Area Director, Charleston
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ATTENTION:
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EUGENE FORD, CSHO
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FROM:
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LINDA R. ANKU Regional Administrator
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SUBJECT:
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Interpretation of 29 CFR 1910.106(c)(1)(i)
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This memorandum was prepared in response to your written request of October
28, 1983 for interpretation of 1910.106(c)(1)(i) as stated in the written
inquiry (copy attached) of Union Carbide Corporation dated October 25, 1983.
The specific question referred to compliance with the applicable provisions
of Pressure Piping, ANSI B31 and "the provisions of this paragraph" as
indication of prima facie evidence of compliance with the foregoing
provisions, specifically 1910.106(b)(7) on testing.
Our interpretation is in general agreement with the position of CSHO Eugene
Ford; i.e., all piping, valves, and fittings meeting the design requirements
of ANSI B31 and the provisions of 1910.106(c)(1)(i) will by implication meet
the testing requirements of 1910.106(b)(7) and all other applicable
provisions of 1910.106(b) on tank storage.
Questions on this memorandum may be directed to Bill Thomas in the Technical
Support group of this office.
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