Response regarding the application of the OSHA Process Safety Management Standard to utility LPG distribution facilities.

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.

November 19, 1996

Mr. Randy Nicholls, CIH
Employee and Public Safety Dept.
Montana Power Company
40 East Broadway
Butte, Montana 59701

Dear Mr. Nicholls:

This is in response to your inquiry of June 4, addressed to Ms. Joanne Slattery regarding the application of the Occupational Safety and Health Administration's (OSHA's) Process Safety Management Standard, 29 CFR 1910.119 to utility LPG distribution facilities. Please excuse the delay in our response.

Highly Hazardous Chemicals as it applies to threshold quantity (TQ) of HHCs.

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.

April 22, 1994

Mr. Luc Hamelin
IVACO Inc.
Place Mercantile
777 Rue Sherbrooke Quest
Montreal (Quebec) Canada H3A 1G1

Dear Mr. Hamelin:

Highly Hazardous Chemicals standard, Tertiary Butyl Hydroperoxide (TBHP).

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.

March 31, 1994

Ms. Doris S. Reid, Manager
Environmental Health & Safety Services
Delta Environmental Consultants, Inc.
6701 Carmel Road
Suite 200
Charlotte, N.C. 28226-3901

Dear Ms. Reid:

1910.119 does not apply to public displays of flame effects.

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.

May 16, 1997

Mr. Henry Renfrew
Compliance and Response Management, Inc.
1842 Meriden-Waterbury Road
Milldale, CT 06467-0794

Dear Mr. Renfrew:

This is in response to your letter of September 25, 1996, regarding the applicability of 29 CFR 1910.119 to public displays of flame effects. Please excuse the delay in our response.

Highly Hazardous Chemicals as it applies to flammable liquid from a stationary tank.

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.

March 16, 1994

Ms. Charlotte Uram
Landels, Ripley & Diamond Attorneys
Hills Plaza
350 Steuart Street
San Francisco, CA 94105-1250

Dear Ms. Uram:

The purpose of this letter is to correct an interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals, 29 CFR 1910.119, standard in the September 9, 1993 letter to you. Question 6 posed in your November 3, 1992 letter and our correction follow. Please replace our original reply to Question 6 with the reply below.

Question 6:

Highly Hazardous Chemicals as it applies to a covered process.

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.

March 10, 1994

Mr. Lynton D. Barnett
Corporate Manager Equipment & Maintenance
American Cyanamid Company
One Cyanamid Plaza
Wayne, N.J. 07470-8426

Dear Mr. Barnett:

This is in response to your July 1st, letter requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC's) standard, 29 CFR 1910.119. Specifically, you requested clarification on whether the PSM standard applies to the following scenarios.

Highly Hazardous Chemicals as it applies to operating procedures and certify on an annual basis.

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.

 

 

Remote distance, close proximity and other PSM questions.

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.

February 15, 1994

Mr. John Anicello
Technical Manager, Regulatory Affairs
Airco Gases
1588 Doolittle Drive
P.O. Box 2033
San Leandra, California 94577

Dear Mr. Anicello:

This is in response to your December 11, 1992 letter requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119. Please accept our apology for the delay in responding. Your questions and our responses follow.

Clarification of the Process Safety Management standard with regard to material and energy balances.

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.

September 25, 1995

Don C. Wobser
MTI Corporation
2 Smiley Drive
St. Albans, WV 25177-8221

Dear Mr. Wobser:

This is in response to your March 31, 1995 letter requesting clarification of the Process Safety Management standard (PSM), 29 CFR 1910.119, with regard to material and energy balances as required by paragraph 1910.119(d)(3)(i)(G). The work place scenario you describe concerns modifications to existing facilities, built significantly before the effective date of the standard, to raise the capacity 150% above original.

Three scenarios and questions regarding on-site natural gas in pipe lines used as a fuel and as a feed stock.

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.

September 14, 1995

Mr. J. B. Evans
Union Carbide Corporation
39 Old Ridgebury Road, K3
Danbury, Connecticut 06817-001

Dear Mr. Evans: