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.

January 21, 1993

Mr. Ernie P. Woody
Safety Manager
Bekaert Corporation
P. O. Box 1205
Rome, Georgia 30162-1205

Dear Mr. Woody:

This is in response to your letter of December 1, 1992, requesting written confirmation that the Process Safety Management (PSM) standard at 29 CFR 1910.119 does not apply to solutions of hydrogen chloride in water, for example, a 37 percent concentration of hydrochloric acid.

The chemical names "hydrogen chloride" (HCL) and "anhydrous hydrochloric acid" are included in the highly hazardous chemicals listing in Appendix A of the PSM standard. Anhydrous, without water, hydrochloric acid is hydrogen chloride. As you indicated in your letter, both hydrogen chloride and anhydrous hydrochloric acid are identified by the same Chemical Abstract Service (CAS) Number 7647-01-0, as denoted in Appendix A. Solutions of hydrogen chloride gas in water are not listed in Appendix A and therefore, are not considered to be highly hazardous chemicals subject to the PSM standard.

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


Roger A. Clark,
Directorate of Compliance Programs