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.

May 12, 1992

Mr. Steven R. Brenske
Manager - Safety Services
International Paper
International Place
I 6400 Poplar Avenue
Memphis, Tennessee 38197

Dear Mr. Brenske:

Thank you for your inquiry of March 31, requesting an interpretation of the scope of ANSI B31.1, Power Piping, and ANSI B31.2, Fuel Gas Piping, which are incorporated by reference in the Occupational Safety and Health Administration (OSHA) standard at 29 CFR 1910.261.

Your interpretation that ANSI B31.1, and ANSI B31.2 only apply to the safe design, construction and installation of new piping, as specified in the introductory paragraph of both ANSI standards, is correct.

However, OSHA standard 29 CFR 1910.261(g)(12)(iii), Blowoff valves and piping, goes beyond the safe design, construction and installation of new piping by requiring that heavy-duty pipe, valves and fittings be used between digesters and blow pits and be inspected at least semiannually to determine the degree of deterioration for purposes of repair or replacement when necessary.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.


Raymond Donnelly, Director
Office of General Industry
Compliance Assistance