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.

September 5, 1992

Mr. Michael Townley, Manager
Safety and Regulatory Affairs
Fuji Hunt Photographic Chemicals, Inc.
900 Carnegie Street
Rolling Meadows, Illinois 60008

Dear Mr. Townley:

This is in response to your October 19, 1992, letter requesting an interpretation of the Process Safety Management (PSM) standard at 29 CFR 1910.119. Please accept our apologies for the delay in responding.

Your question was:

With respect to the chemical listed in Appendix A as "Ammonia solutions (>44% ammonia by weight):" Does this listing include solutions of ammonium compounds such as ammonium chloride or ammonium bisulfite solutions, or does it refer only to ammonia- water solutions?

Our answer is:

The referenced listing includes only ammonia-water solutions and does not apply to ammonium chloride or ammonium bisulfite solutions.

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

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs