The term "interconnection" as it would apply to utilities, steam and electric, used 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.

September 14, 1995

James B. Evans
Union Carbide Corporation
39 Old Ridgebury Road, K3
Danbury, Connecticut 06817-0001

Dear Mr. Evans:

This is in response to your June 1, 1994 letter requesting interpretation of the Process Safety Management standard 29 CFR 1910.119. Your question concerns the term "interconnection" as it would apply to utilities, steam and electric, used in a covered process.

Storage of flammable liquids and the applicability to 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.

September 11, 1995

Richard H. LaLumondier
Technical Director, ILTA
1133 15th Street, N.W., Suite 650
Washington, D.C. 20005

Dear Mr. LaLumondier:

This letter is to confirm the phone conversation between yourself and Mr. Ron Davies of my staff regarding storage of flammable liquids and the applicability to the Process Safety Management standard (PSM), 29 CFR 1910.119. The discussion concerned elected rather than required refrigeration of flammable liquids in storage and the exception at 29 CFR 1910.119(a)(1)(ii)(B).

The Ciba Self-Medication, Inc. (CSM) facility and the application of OSHA's PSM 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.

September 7, 1995

Mr. William J. Kessack, Jr.
Project Manager
IES Incorporated
10 East 6th Avenue
Conshohocken, PA 19428

Dear Mr. Kessack:

This is in response to your letter of April 19, addressed to Mr. Ron Davies with respect to the Ciba Self-Medication, Inc. (CSM) facility and the application of OSHA's Process Safety Management (PSM) of Highly Hazardous Chemicals Standard, 29 CFR 1910.119.

Sodium Azide as Used in the Manufacturing Process of Automobile Air Bags.

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.

June 30, 1997

Chlorine storage facility plan and the applicability of the Process Safety Management (PSM) 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.

August 15, 1995

Mr. George W. Goodman
Cummins, Goodman, Fish & Peterson, P.C.
P.O. Box 17
434 N. Evans Street
McMinnville, Oregon 97128

Dear Mr. Goodman:

Thank you for your letter of May 16, addressed to Deputy Assistant Secretary, James W. Stanley, regarding your client's chlorine storage facility plan and the applicability of the Process Safety Management (PSM) of Highly Hazardous Chemicals Standard, 29 CFR 1910.119. Your letter was forwarded to our office for response.

Clarification on the time allowed for completion of the initial process hazard analysis (PHA) as it may apply to a hypothetical case involving four different work sites of an employer.

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.

June 1, 1995

Mr. Stephen Z. Short
Bob Short & Associates, Inc.
4849 Greenville Avenue
Suite 1670
Dallas, TX 75206

Dear Mr. Short:

Confirmation that mixing of liquefied butane, transferred by a CTMV, with gasoline stored in atmospheric tanks at terminals is not covered by 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.

May 17, 1995

Mr. Larry D. Mattingly
President
Mid-Continent Company, Inc.
P.O. Box 395
Lake Monroe, Florida 32747

Dear Mr. Mattingly:

Coverage under 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.

March 22, 1995

Mr. Robert M. Bachman
System Safety Engineer
P.O. Box 250
Independence, MO 84051-0250

Dear Mr. Bachman:

Thank you for your letter of February 7, 1995, in which you expressed some concerns regarding OSHA's response to Mr. Douglas H. Delsemme's inquiry of May 25, 1994, regarding coverage under the Process Safety Management Standard. We apologize for the delay in responding to you.

"Compliance Audits" 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.

March 21, 1995

Mr. John C. Stoney Manager,
Process Safety Albright and Wilson Americas, Inc.
2151 King Street Ext.
Charleston, SC 29405-8339

Dear Mr. Stoney:

This is in response to your letter of February 2, 1995, regarding paragraph (o), "Compliance Audits" of the Process Safety Management of Highly Hazardous Chemicals Standard, 29 CFR 1910.119.

Regarding "Compliance Audits" of the Process Safety Management for 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.

February 24, 1995

Mr. Dean H. DeGhetto, Senior Associate
Environmental Risk Limited
1373 Broad Street
Clifton, NJ 07013

Dear Mr. DeGhetto:

This is in response to your letter of January 17, regarding Section (o) "Compliance Audits" of the Process Safety Management for Highly Hazardous Chemical Standard, 29 CFR 1910.119.

Your letter inquired whether pursuant to Section (o), paragraphs (1) and (4), deficiencies should be corrected within a three year timeframe, or promptly after the audit is conducted.