Numerous questions related to OSHA's notice to terminate the rulemaking to amend the explosives 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.

April 24, 2012

Mr. Richard Patterson, Managing Director
Sporting Arms and Ammunition Manufacturers Institute, Inc.
Flintlock Ridge Office Center
11 Mile Hill Road
Newtown, CT 06470

Recognized and Generally Accepted Good Engineering Practices in Process Safety Management Enforcement

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 11, 2016

MEMORANDUM FOR:
REGIONAL ADMINISTRATORS
THROUGH:

DOROTHY DOUGHERTY
Deputy Assistant Secretary

FROM:

THOMAS M. GALASSI, Director
Directorate of Enforcement Programs

Process Safety Management of Highly Hazardous Chemicals and Covered Concentrations of Listed Appendix A 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.

July 18, 2016

MEMORANDUM FOR:

REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES

PSM compliance for ammonia refrigeration systems.

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.

***Response 10 updated July 07, 2015***

July 12, 2006

Mr. E. C. Palmer, Jr.
Environmental Attorney/Consultant
LAMB GROUP, LLC.
330 Providence Road
Athens, GA 30606

Dear Mr. Palmer:

Training requirements for mechanics repairing and/or testing pressure relief devices.

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 4, 2013

Mr. Joel Neal
President, Local 931 United Steelworkers
3333 South Oquirlane Street
Magna, Utah 84044

Dear Mr. Neal:

Clarification of the term "hydrocarbon" as used in 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 4, 2013

Mr. Timothy A. Wilkins
Managing Partner
Bracewell & Giuliani LLP
111 Congress Avenue
Suite 2300
Austin, Texas 78701-4061

Dear Mr. Wilkins,

PSM for pharmaceutical 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.

March 5, 2012

Andy Fecht, Associate
Safety Director
Teva Pharmaceuticals, Inc.
North American API Division
5000 Snyder Dr
Mexico, Missouri 65265

Dear Mr. Fecht:

Thank you for your April, 2011, letter to the Occupational Safety and Health Administration (OSHA). Your letter requests an interpretation regarding applicability of 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (PSM), to a process(es) at the Teva Pharmaceutical, Mexico, MO site.

PSM and large batch-mixing tanks

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 19, 2012

Mr. Geoffrey J. Bacci
Principal
Aires Consulting Group, Inc.
1550 Hubbard Avenue
Batavia, Illinois 60510

Dear Mr. Bacci:

Is reassembly of a cylinder valve a mechanical integrity activity?

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 4, 2012

Mr. Daniel Casmey
Executive VP of Safety, Security & Regulatory Compliance
JCI Jones Chemicals, Inc.
2500 Vanderhoof Road
P.O. Box 349
Barberton, Ohio 44203

Dear Mr. Casmey: