Typical processes in a paint manufacturing facility.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 1, 1992

Mr. Kevin S. Sall
Manager, Hazardous Materials
National Paint & Coatings Association
1500 Rhode Island Avenue, N.W.
Washington, D.C. 20005-5597

Dear Mr. Sall:

This is in response to your letter of June 16, addressed to Mr. Thomas Seymour, Deputy Director of Safety Standards Programs, requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard, 29 CFR 1910.119. Please accept our apology for the lateness of this reply.

Storage of Pentane in excess of 10,000 pounds.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 3, 1992

Mr. David A. Day
107 Barley Mill Drive
Greer, South Carolina 29651

Dear Mr. Day:

This is in response to your July 14 letter to Mr. Rolland Stroup, a member of my staff requesting interpretations of the Occupational Safety and Health Administration (OSHA's) standard on Process Safety Management (PSM) of Highly Hazardous Chemicals. Please accept our apologies for the delay in responding.

Flammable liquid processes and the Process Safety Management standard.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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. Gregory E. Thompson
Law Offices of Daniel R. Thompson, P.C.
1620 "I" Street, N.W.
Suite 925
Washington, D.C. 20006

Dear Mr. Thompson:

Solutions of hydrogen chloride in water.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 25, 1993

Mr. Ernie P. Woody
Safety Manager
Bekaert Corporation
P.O. Box 1205
Rome, Georgia 30162-1205

Dear Mr. Woody:

This is in response to your letter of December 1, 1992, requesting written confirmation that the Process Safety Management (PSM) standard at 29 CFR 1910.119 does not apply to solutions of hydrogen chloride in water. For example, a 37 percent concentration of hydrochloric acid.

HHCs as it applies to how high must the percentage of a chemical be to require compliance.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

April 14, 1993

Mr. Shari Roney
Health and Safety Officer
Landlaw Environmental Services, Inc.
208 Watlington, Industrial Drive
Readsville, N.C. 27320

Dear Mr. Roney:

This is in response to your February 8 letter requesting interpretations 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 questions and our responses follow:

Spray painting operations and the process safety management standard.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 6, 1993

Mr. Martin R. Kohne
Senior Safety Engineer
Donaldson Company, Inc.
1400 West 94th Street
Minneapolis, Minnesota 55440

Dear Mr. Kohne:

PSM Chemicals, unless specified, commercial grades less than 99 percent purity.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 22, 1993

Mr. F. L. Lambert
Environmental and
Technical Division
Westvaco-Chemical Division
Box 70848
Charleston Heights, S.C. 29415-0848

Dear Mr. Lambert:

Processes involving flammable liquids and gases.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 9, 1993

Ms. Charlotte Uram
Landels, Ripley & Diamond Attorneys
Hills Plaza 350 Steuart Street
San Francisco, CA 94105-1250

Dear Ms. Uram:

This is in response to your November 3, 1992 letter, which posed questions and projected answers with respect to the Process Safety Management standard, 29 CFR 1910.119, as it applies to workplace processes involving flammable liquids and gases. Please accept our apology for the delay in responding.

Process safety information for ventilation system design.

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 22, 2003

Mr. Stephen Barker
Senior Engineer
Williams
One Williams Center
Post Office Box 21628
Tulsa, OK 74121

Dear Mr. Barker:

Documentation establishing the boiling points or the 10 percent points of distillation.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 20, 1993

Mr. David L. Smith
Constangy, Brooks & Smith
Attorneys At Law
Suite 2400
Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Smith:

This is in response to your August 3 letter, requesting 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 questions and our responses follow.