"Applicability of the PSM standard's mechanical intergrity requirements to refinery structures."

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, 2010

The Honorable David Vitter
United States Senate
Washington, DC 20510

Dear Senator Vitter:

Extent of OSHA's jurisdiction over worksites involving geological and underground storage facilities for gas and hazardous liquids.

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 7, 2008

Ms. Joanne B. Linhard
Consultant
ORC Worldwide, Suite 810
1800 K Street, NW
Washington, DC 20006

Dear Ms. Linhard:

Flame-resistant and flame-retardant treated clothing for oil and gas well drilling, servicing, and production-related operations

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 31, 2011

Mr. Kenny Jordan
Executive Director
The Association of Energy Service Companies
14531 FM 529, Suite 250
Houston, TX 77095

Dear Mr. Jordan:

Determining when a mixture would exceed the threshold quantity 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.

May 21, 2009

Mr. Mark R. Kaster
Dorsey & Whitney LLP
50 South Sixth Street, Suite 1500
Minneapolis, MN  55402-1498

Dear Mr. Kaster:

Clarification of term "Active Hydrocarbon Zone" as it relates to the oil and gas well drilling operations; and the need to use FRC when performing drilling operations

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 19, 2010

Dr. Lee Hunt, President
International Association of Drilling Contractors
10370 Richmond Ave., Suite 760
Houston, Texas 77402

Dear Dr. Hunt:

Management of Organizational Change

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.

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March 31, 2009
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
 
THROUGH: DONALD G. SHALHOUB

Interpretation of the process safety management of highly hazardous chemicals 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.

December 12, 1995

Mr. Bry Roberson
EMPE Inc.
Plaza 1, Suite 410
220 Athens Way
Nashville, TN 37228

Dear Mr. Roberson:

Process Safety Management (PSM) at work sites.

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 11, 1996

Mr. James A.J. Connell
USA Engineering, Inc.
500 Ellis Avenue
Colwyn, PA 19023

Dear Mr. Connell:

This is in response to your May 26, 1994, letter requesting an interpretation of the process safety management (PSM) of highly hazardous chemicals (HHCs) standard, 29 CFR 1910.119. Process scenarios at work sites and associated questions are noted below. Our corresponding replies follow. Please accept our apology for the delay in responding.

Process Safety Management (PSM) of Highly Hazardous Chemicals.

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 16, 1996

Mr. K.S. Dreux
McDermott, Will & Emery
1850 K Street, N.W.
Washington, DC 20006-2296

Dear Mr. Dreux:

This is response to your letter of August 25, 1995 requesting interpretation of the 29 CFR 1910.119, Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC's) standard. Your process scenario and question and our reply follow.

Clarification of the Process Safety Management of Highly Hazardous Chemicals 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.

February 7, 1996

Mr. David A. Berg
GATX Terminals Corporation
500 West Monroe Street
Chicago, IL 60661-3678

Dear Mr. Berg: