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 28, 1992

Mr. Cary Franklin
Senior Process/Project Engineer
Georgia Pacific Resins, Inc.
2883 Miller Road
Decatur, Georgia 30035

Dear Mr. Franklin:

This is in response to your letter of June 24, regarding the Final Rule on Process Safety Management (PSM) of Highly Hazardous Chemicals published in Volume 57, Number 36 of the Federal Register on Monday, February 24, 1992.

In your letter you requested written clarification on what is meant by "Formaldehyde (Formalin)" listed in Appendix A of the PSM standard. This highly hazardous chemical should be listed to read: Formaldehyde (37% by weight or greater). The PSM standard will be revised to reflect this change in the near future. Any amount of mixture of Formaldehyde, less than 37% by weight, in solution would not be covered by the PSM standard.

Presently, the Occupational Safety and Health Administration is developing a directive which will provide interpretative guidance and inspection procedures to our field staff. When the directive is completed in the near future, we will send you a copy to assist you in your stated direction to continue efforts towards employer compliance with the PSM standard.

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


Patricia K. Clark, Director
Directorate of Compliance Programs