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.

November 14, 1983

Area Director, Charleston
Regional Administrator
SUBJECT: Interpretation of 29 CFR 1910.106(c)(1)(i)

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.