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.

August 28, 1992

Mr. Charles G. Marvin, Chairman
c/o The Refractories Institute
500 Wood Street, Suite 326
Pittsburgh, PA 15222

Dear Mr. Marvin:

This is in response to your letter of July 15 to Mr. James F. Foster, Director of the Office of Information and Consumer Affairs for the Occupational Safety and Health Administration (OSHA), 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. Your letter was forwarded to the Directorate of Compliance Programs for response.

In your letter you asked whether the PSM standard applies to ceramic manufacturing facilities utilizing propane in amounts exceeding 10,000 pounds as the fuel for firing ceramic ware in a process which does not involve any other highly hazardous chemicals. The PSM standard would not apply to such a situation.

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

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs