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: