Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

August 11, 1995

Joe Hudman, Ph.D, CHMM
Hudman & Associates, Inc.
P.O. Box 1506
Conroe, Texas 77305

Dear Mr. Hudman:

This is in response to your April 7, 1995 letter requesting interpretation of the Process Safety Management (PSM) standard 29 CFR 1910.119. Specifically, you requested clarification regarding the applicability of PSM to chemical distributors that merely store, transfer, and/or non mechanically blend flammable liquids.

The PSM standard applies to those processes containing 10,000 pounds or more of flammable liquids, with certain exceptions. Flammable liquids are defined as those liquids having flash points below 100 degrees fahrenheit.

The operations described in your letter appear to involve nothing more than storage of flammable liquids with subsequent transfer to other storage, including non mechanical, (agitation or stirring), blending. You further indicate that there is no chemical change or unit physical process such as distillation, mixing, filtering, evaporation, or drying. Under these circumstances, the operations you described, are not covered by the PSM standard. Please note that the exception at 29 CFR 1910.119(a)(1)(ii)(B), applies to those processes that only involve storage and associated transfer.

We appreciate your interest in occupational safety and health. If we can be of further assistance, please contact Ron Davies at (202)219-8041.


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