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.

June 24, 1992

Mr. Robert L. Hoskinson Manager,
Safety, Health and Environmental Affairs
GenCorp Automotive
350 Springside Drive
Akron, Ohio 44333-2475

Dear Mr. Hoskinson:

Thank you for your letter of May 12, addressed to Acting Assistant Secretary Dorothy L. Strunk, requesting a clarification of the intent of the Occupational Safety and Health Administration's (OSHA) standard for Process Safety Management of Highly Hazardous Chemicals (1910.119).

In a recent conversation you had with Mr. Thomas Seymour of my staff, he indicated that 10,000 pounds of flammable liquids stored in 55-gallon storage containers which are stored in an inside storage room would not fall under the process safety management standard since the containers are not pressurized and are not connected to a process (see the exemption of atmospheric tanks and the definition of process in 1910.119). The storage situation you describe is fully covered under OSHA's standard for flammable and combustible liquids, 1910.106, and as indicated by Mr. Seymour, is not covered by the process safety management standard.

I hope this information is helpful.


Roger A. Clark Director,
Directorate of Safety Standards Programs