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.

July 26, 1995

Mr. Michael Rataj, CIH
Manager, Environmental Health/Hygiene
Sandoz Agro, Inc.
1300 East Touhy Avenue
Des Plaines, Illinois 60018-3300

Dear Mr. Rataj:

Thank you for your letter of May 8, in which you requested OSHA's approval of the Zurich Hazard Analysis, as an appropriate method for conducting the process hazard analysis which is required by 1910.119(e)(2).

As you are aware, 1910.119(e)(2) gives the employer the choice of using one or more of the listed methodologies for evaluating the hazards of the process. In this regard, 1910.119(e)(2)(viii) gives the employer the option to choose "an appropriate equivalent methodology."

It is the employer's responsibility to assess and evaluate the "equivalent methodology." Further, so long as the chosen "equivalent methodology" permits and achieves compliance with the remaining provisions of the standard, and accomplishes the objective and the intended goal of the standard, the employer would be regarded as being in compliance.

We appreciate the opportunity of reviewing the Zurich Methodology, and your interest in the health and safety of the American workers. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.


John B. Miles, Jr., Director
Directorate of Compliance Programs