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 https://www.osha.gov.

APR 1 1991

Mr. Brent S. Ehmke
Explosion Protection Group
Fenwal Safety Systems Inc.
700 Nickerson Road
Marlborough, Massachusetts 01752

Dear Mr. Ehmke:

This is in response to your letter of February 14, requesting a clarification of the Occupational Safety and Health Administration (OSHA) standard 29 CFR 1910.272(p)(8)(i).

In your letter you gave a description of one of your products, X-Pac, which you described as an assembly containing a suppression agent and as an explosion suppression system capable of detecting and suppressing a potential explosion.

The OSHA standard at 1910.272(p)(8) states "Paragraphs (p)(4), (p)(5), and (p)(6) do not apply to the following: (i) Bucket elevators which are equipped with an operational fire and explosion suppression system capable of protecting at least the head and boot section of the bucket elevator."

We interpret the above standard to mean that the suppression systems must be functional and capable of detecting and suppressing an imminent explosion.

We want to inform you that our knowledge of your product, X-Pac, is limited to the information you provided in your letter. We have no direct knowledge of your product. Since X-Pac as you described can detect and suppress an explosion in a rapid manner, we consider that your product would meet the intent of the OSHA standard at 1910.272(p)(8)(i), provided it is installed and maintained in a manner prescribed by your company.

As you may know, OSHA does not approve or endorse any product since the products may be misapplied or misused during installation or usage. Therefore, you should not treat this letter as an approval of your product.

Thank you for your interest in safety and health. If we may be of further assistance, please contact us.


Patricia K. Clark, Director
Directorate of Compliance Programs