OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

June 16, 1982

Machinery and Engineering Group
Mr. Matti Hukki, Chief Metallurgist.,
P.O. Box 267
33101 Tampere 10

Dear Sir:

Your May 4, 1982 letter to Administrator Price of the State of Florida regarding the ASME Pressure Vessel Code was referred to this office for reply.

The Occupational Safety and Health Administration standards for pulp, paper, and paperboard mills are contained in section 29 CFR 1910.261 (copy enclosed), which incorporates by reference the ASME Boiler and Pressure Vessel Code, Section VIII in subparagraph 1910.261(a)(4)(i).

In regards to the point of your letter i.e., whether your pressurized wood grinding machine (PGW) comes under this code, it appears that rule u-l(c)(3), Section VIII, Division I of this code would exclude the PGW from being a pressure vessel and, hence, from being within the scope of the code.

Should you have any further question, please do not hesitate to contact us.


Patrick R. Tyson
Federal Compliance and State Programs