Highly Hazardous Chemicals, methanol stored in an atmospheric tank.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

November 18, 1993

Mr. Thomas J. Lukish, Director
Occupational Safety & Health Services
P.O. Box 2218
Richmond, Virginia 23217

Dear Mr. Lukish,

Documentation methods used to comply with the qualitative evaluation of a range of possible safety/health effects of "failure of controls" requirement of 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.

February 1, 2005

Mr. Roygene Harmon
Industrial Consultants
10470 W. Devils Den Road
Winslow, AR 72959

Dear Mr. Harmon:

Evaluation of scenarios regarding PSM requirements related to normally unoccupied remote facilities and natural gas processing plants (gas plant).

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 16, 2005

Mr. Ty J. Smith
Lesair Environmental, Inc.
10394 W. Chatfield Ave., Ste. 100
Littleton, CO 80127

Dear Mr. Smith:

Highly Hazardous Chemicals as it applies to toxic or reactive chemical mixtures which are not explosive and which are not flammable liquids or 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.

January 31, 1994

Mr. Donald J. Connelley
Process Safety Specialist
Central Engineering Department
AKZO Chemicals Inc.
9 Livingstone Avenue
Dobbs Ferry, New York 10522-3409

Dear Mr. Connelley:

The purpose of this letter is to correct a misinterpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119 in our September 9 letter to you. The corrected interpretation follows.

Requirement for flame-resistant clothing in petrochemical plant covered by PSM.

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 7, 2006

Mr. Joseph P. Zemen
Ashland Specialty Chemical Company
Special Polymers and Adhesives Division
Calumet City, IL 60109

Dear Mr. Zemen:

Use of ANSI/ISA S84.00.01-2004 Parts 1-3 (IEC 61511 MOD) to comply with OSHA's 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.

November 29, 2005

Ms. Lois M. Ferson
Manager of Standards Services
ISA
67 Alexandria Drive
P.O. Box 12277
Research Triangle Park, NC 27709

Dear Ms. Ferson:

Highly Hazardous Chemicals, hydrochloric acid.

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.

March 21, 1994

Mr. David B. Smith
Central Soya Company, Inc.
1946 Westcook Road
P.O. Box 2507
Fort Wayne, Indiana 46801-2507

Dear Mr. Smith:

This is in response to your November 24, 1993 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals, 29 CFR 1910.119, standard. Please accept our apology for the delay in responding. Your questions and our responses follow.

Question 1:

Is 35 percent hydrochloric acid covered by the PSM standard?

Reply:

Highly Hazardous Chemicals, hydrocarbon fuels.

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 7, 1994

Mr. Don L. Hudnall
Bell Helicopter Textron Inc.
Post Office Box 482
Fort Worth, Texas 76101

Dear Mr. Hudnall:

This is in response to your February 28 letter, requesting clarification on whether the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119 applies to the following workplace application.

HHC's as it applies to hydrochloric acid, hydrofluoric acid, hydrogen sulfide, hydrogen cyanide.

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 9, 1994

Mr. Gary F. Lindgreen
Vice President, Environmental Compliance
Heritage Environmental Services, Inc.
7901 West Morris Street
Indianapolis, Indiana 46231

Dear Mr. Lindgreen:

This is in response to your January 26 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHCs) standard, 29 CFR 1910.119. Please accept our apology for the delay in responding. Your questions and our response follow:

Scenario: The following HHCs are listed in Appendix A of the PSM standard

HHC's as it applies to wood digestion process containing multiple toxic and flammable liquid HHCs.

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.

"This document was published prior to the publication of OSHA's final rule on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and therefore does not necessarily address or reflect the provisions set forth in the final standard."


July 7, 1994

Mr. Jerry T. Fields
Director, Safety & Health
Boise Cascade Corporation
One Jefferson Square
Boise, Idaho 83728

Dear Mr. Fields: