OSHA Interpretation on Connected System 29 CF 1910.119(b)

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, 2017

Mr. Ken Fegley
Process Safety Engineer
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown, Pennsylvania 18195-1501

Dear Mr. Fegley:

Production facilities that recover natural gas liquids may have enforceable PSM-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.

December 19, 2018

Mr. Darren J. Hunter
Rooney, Ripple & Ratnaswamy, LLP
Kingsbury Center, Suite 600
350 W. Hubbard St.
Chicago, IL 60654

Dear Mr. Hunter:

PSM applicability to warehousing flammable liquids and other 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.

February 1, 2002

Donald L. Olesen, P.E., C.S.P.
Vice President
J&H Marsh & McLennan
Risk Control Consulting
200 Clarendon Street
Boston, MA 02116

Dear Mr. Olesen:

Evaluation of scenarios regarding PSM requirements related to normally unoccupied remote facilities and natural gas processing plants (gas 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.

February 16, 2005

Mr. Ty J. Smith
Lesair Environmental, Inc.
10394 W. Chatfield Ave., Ste. 100
Littleton, CO 80127

Dear Mr. Smith:

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:

Extent of OSHA's jurisdiction over worksites involving geological and underground storage facilities for gas and hazardous liquids.

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.


October 7, 2008

Ms. Joanne B. Linhard
Consultant
ORC Worldwide, Suite 810
1800 K Street, NW
Washington, DC 20006

Dear Ms. Linhard:

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: