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.

July 28, 1995

Ms. Kimberly J. Wasson
Davis & Floyd, Inc.
PO Drawer 428
Greenwood, SC 29648

Dear Ms. Wasson:

This is in response to your letter of June 6, regarding your client's heat-treating process (using methanol) and the applicability of the Process Safety Management of Highly Hazardous Chemicals Standard, 29 CFR 1910.119.

Please be advised that the exemption cited under 1910.119(a)(1)(ii)(B) pertains only to storage facilities and transfer conduits. If the storage tanks and the transfer conduits are interconnected to a process, however, such as the one indicated in your letter, then the total facility (i.e. atmospheric storage tanks, transfer conduits/piping and the process) would fall under 1910.119, whenever the threshold quantities are exceeded.

Thank you for your interest in occupational safety and health. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.

Sincerely,



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