PSM coverage of utility systems; whether 1910.269 preempts the PSM standard for power generation facilities that serve covered processes.

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.


January 31, 2008

Mr. Howard J. Feldman
Director, Regulatory Analysis and Scientific Affairs
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005-4070

Dear Mr. Feldman:

Determining when a mixture would exceed the threshold quantity in 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.

May 21, 2009

Mr. Mark R. Kaster
Dorsey & Whitney LLP
50 South Sixth Street, Suite 1500
Minneapolis, MN  55402-1498

Dear Mr. Kaster:

PSM for pharmaceutical plant

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 5, 2012

Andy Fecht, Associate
Safety Director
Teva Pharmaceuticals, Inc.
North American API Division
5000 Snyder Dr
Mexico, Missouri 65265

Dear Mr. Fecht:

Thank you for your April, 2011, letter to the Occupational Safety and Health Administration (OSHA). Your letter requests an interpretation regarding applicability of 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (PSM), to a process(es) at the Teva Pharmaceutical, Mexico, MO site.