Steam boilers fired by flammable liquids or natural gas and the PSM standard.

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 8, 1993

Mr. Garry Stubblefield
Senior Technician
Petrocon Engineering, Inc.
P.O. Box 20397
Beaumont, Texas 77720-0397

Dear Mr. Stubblefield:

This is in response to your letter of June 18, to Mr. Gilbert J. Saulter, Dallas Regional Administrator for the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Compliance Programs for response. Please accept our apology for the delay in responding.

Employee participation requirements of the Process safety management standard.

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 8, 1993

Mr. Randall Osborne
Oil, Chemical and Atomic Workers International,
AFL-CIO
P.O. Box 1298
El Dorado, Kansas 67042

Dear Mr. Osborne:

This is in response to your August 28 letter which requested an interpretation of the Occupational Safety and Health Administration (OSHA's) standard on Process Safety Management (PSM) of Highly Hazardous Chemicals as it pertains to employee participation. Please accept our apologies for the delay in responding.

Process safety management at what point a work site change would no longer be considered a modification but a new facility.

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 11, 1996

Ms. Susan Tolley
Chevron Research and Technology Center
1003 West Cutting Boulevard
Post Office Box 4054
Richmond, California 94804-0054

Dear Ms. Tolley:

OSHA's approval of the Zurich Hazard Analysis, as an appropriate method for conductiong the process hazard analysis which is required by 1910.119.

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.

July 26, 1995

Mr. Michael Rataj, CIH
Manager, Environmental Health/Hygiene
Sandoz Agro, Inc.
1300 East Touhy Avenue
Des Plaines, Illinois 60018-3300

Dear Mr. Rataj:

Thank you for your letter of May 8, in which you requested OSHA's approval of the Zurich Hazard Analysis, as an appropriate method for conducting the process hazard analysis which is required by 1910.119(e)(2).

Clarification on how OSHA would address the use of natural gas or liquid propane gas used in an after-burner to remove volatile organic carbon (VOC) air contaminants.

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 13, 1995

Mr. Steve Neville
Safety and Health Program Development
Analyst Steve Neville Associates
144 Ocean Terrace
Indialantic, FL 32903

Dear Mr. Neville:

This is in response to your letter of November 18, 1994, in which you have requested clarification on how the Occupational Safety and Health Administration (OSHA) would address the use of natural gas or liquid propane gas used in an after-burner to remove volatile organic carbon (VOC) air contaminants.

Process Safety Management Program required by OSHA.

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 6, 1995

U. S. Dept. Of Labor OSHA
200 Constitution Avenue N.W.
Room N3107 Washington D. C. 20210
Attention: Mr. Ron Davies

Dear Ron:

Interpretation of the Process Safety Management of Highly Hazardous Chemicals Standard.

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 23, 1995

[Name Withheld]

Dear [Name Withheld]:

This is in response to your December 24, 1994 letter, requesting interpretation of the Process Safety Management of Highly Hazardous Chemicals Standard, 29 CFR 1910.119.

In your letter, you have indicated that your client stores formalin (37%) in fifty five gallon drums, approximately one hundred yards from his mixing area, and only one to two drums are moved to the process area to make a product. Your specific questions and our responses follow.

Compliance Audits.

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 5, 1995

Mr. Mike McDonald Safety Coordinator
Nisseki Chemical Texas Inc.
10500 Bay Area Blvd.
Pasadena, Texas 77507

Dear Mr. McDonald:

Thank you for your letter of November 23, in which you have requested the interpretation of the Process Safety Management Standard, 29 CFR 1910.119, specifically, paragraph (o) "Compliance Audits".

Process Safety Management of Highly Hazardous Chemicals and process hazard analyses.

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 31, 1996

Mr. Michael J. Hazzan, P.E.
Vice President and Technical Director
PrimaTech Inc.
5 Vaughn Drive, Suite 309
Princeton, NJ 08540

Dear Mr. Hazzan:

This is in response to your letter of February 6, 1995, addressed to Mr. Roger Clark, former Director of Compliance Programs, regarding the Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119, and process hazard analyses (PHA). Please excuse the delay in our response.

Please find in the following, your specific questions and our responses.

Akzo-Nobel Chemicals - Limits of a 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.

February 28, 1997