The use of natural gas or liquid propane gas used in an after-burner.

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 23, 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 (PSM) of Highly Hazardous Chemicals standards, as it may apply to processes containing 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 22, 1995

The Honorable Richard E. Neal
U.S. House of Representatives
1550 Maine Street Federal Building
Springfield, MA 01103

Dear Congressman Neal:

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.

December 2,1994

Mr. Glynn Rountree
Aerospace Industries Association of America, Inc.
1250 Eye Street, N.W.
Washington, D.C. 20005-3922

Dear Mr. Rountree:

This is in response to your May 25 letter, requesting that the Occupational Safety and Health Administration (OSHA) revisit current OSHA interpretations issued previously on the applicability of the Process Safety Management standard, 29 CFR 1910.119 to the manufacture of explosive devices. Please accept our apology for the delay in responding.

Process Safety Management of Highly Hazardous Chemicals.

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.

 

 

Interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHCs) 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.

November 14, 1994

Mr. Bruce S. Miller Rhone Poulenc Rorer Pharmaceuticals, Inc. Integrated Environmental Services 10 East 6th Avenue Conshohocken, PA 19428

Dear Mr. Miller:

PSM clarification on flammable lubrication in aerosol cans, to prevent foods from sticking to heated cookware

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 4, 1994

Mr. Montfort A. Johnsen President Montfort A. Johnsen and Assoc., Ltd. 26 Sheral Drive Danville, Illinois 61832-1354

Dear Mr. Johnsen:

Process Safety Management of Highly Hazardous Chemicals as it may apply to more than 250 pounds thionyl chloride stored on your work site.

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 27, 1994

Mr. Michael Kohlhauff Director of Quality Systems Sperry - Sun Drilling Services 3000 North Sam Houston Pkway East (77032) P.O. Box 60070 Houston, Texas 77205

Dear Mr. Kohlhauff:

Clarification on whether flammable liquids used to mix (1) inks used in printing on aluminum foil and paper and (2) paint used in coating aluminum sheets are 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.

September 27, 1994

Mr. Bobby J. Sasser
Director of Corporate Safety
Reynolds Metals Company
P.O. Box 27003
Richmond, Virginia 23261-7003

Dear Mr. Sasser:

Voluntary safety and health audits under the Occupational Safety and Health Act

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, 1996

Mr. Frank White
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place, NW
Washington, D.C. 20036

Dear Mr. White:

Thank you for your letter to Secretary Reich concerning voluntary safety and health audits under the Occupational Safety and Health Act (the Act). Secretary Reich has asked me to respond. I appreciate Organization Resource Counselors' (ORC) interest in this issue. ORC's expertise in occupational safety and health issues is well established, and its views merit careful consideration.

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.

August 16, 1996

Mr. Michael V. Marchlik S. Cohen and Associates 143 Pershing Avenue Ridgewood, NJ 07450

Dear Mr. Marchlik:

This is in response to your March 29 letter requesting an interpretation of the process safety management (PSM) of highly hazardous chemicals standard, 29 CFR 1910.119. Please accept our apology for the delay in responding. Your workplace scenario and question and our reply follow.