HHC's as it applies to flammable liquid stored at a worksite.

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 28, 1993

Ms. Carol S. Miller
Safety Coordinator
Exxon
Research and Development Laboratories
P.O. Box 2726
Baton Rouge, Louisiana 70821

Dear Ms. Miller:

This is in response to your March 29 letter requesting clarification on the applicability of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119, to flammable liquid stored on your worksite.

Propane as a fuel for ovens; Chlorine storage exceeding 1500 pounds.

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

Michael D. Zoll
Manager of Safety
Alcan Aluminum Corporation
P.O. Box 6977
Cleveland, Ohio 44101-1977

Dear Mr. Zoll:

This is in response to your February 8 letter requesting interpretations of the Process Safety Management (PSM) of Highly Hazardous Chemicals at 29 CFR 1910.119. Your questions and our responses follow. Please accept our apology for the delay in responding.

Fumigants used to control insects in food plants.

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 3, 1993

Mr. John E. Lee III
Director of Safety and Health
National Oats Company
1515 H. Avenue, N.E.
Cedar Rapids, Iowa 52402

Dear Mr. Lee:

Dimethylamine and Anhydrous Dimethlamine and 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.

July 9, 1993

Mr. Jim Collins
Safety Manager
Helena Chemical Company
Fenn Road, P.O. Box 837
Cordele, Georgia 31015

Dear Mr. Collins:

The purpose of this letter is to correct a misinterpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC's) standard, 29 CFR 1910.119 in the September, 1992 letter to you from Patricia K. Clark, former director of the Directorate of Compliance Programs. The corrected interpretation follows.

Sulfuric acid and 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.

June 24, 1993

Mr. Jon LaRue
Nova Engineering, Inc.
5727 So. Lewis,
Suite 300
Tulsa, Oklahoma 74105

Dear Mr. LaRue:

This is in response to your May 17 letter, requesting an interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119. Specifically, you requested that the Occupational Safety and Health Administration clarify that sulfuric acid is not covered by the PSM standard.

HHCs as it applies to Hydrocarbon fuels used solely for workplace consumption.

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 19, 1993

Mr. Jim R. Orth
Senior Consultant
AIB Safety
1213 Bakers Way
Manhattan, Kansas 66502

Dear Mr. Orth:

Delivery of hydrogen peroxide, 52% by weight or greater.

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 8, 1993

Mr. Lawrence W. Bierlein
Shaw, Pittman, Pott & Trowbridge
2300 N. Street, N.W.
Washington, D.C. 20037-1128

Dear Mr. Bierlein:

This is in further response to your March 24, letter to Mr. Rolland Stroup of my staff requesting clarification on the applicability of the Process Safety Management (PSM) of Highly Hazardous Chemicals Standard, 29 CFR 1910.119 to delivery of hydrogen peroxide, 52% by weight or greater delivered by cargo tank motor vehicles (CTMV'S) which carry 7500 pound (3401.2kg) or greater amounts.

HHCs as it applies to Hydrogen Peroxide delivered from a tank truck.

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

Mr. Gene F. Tappan
Regulatory Affairs Manager
Reskitt & Coleman Inc.
1655 Valley Road
Post Office Box 143
Wayne, New Jersey 07474-0943

Dear Mr. Tappan:

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 December 24, 1992 letter to you. Please disregard and discard the earlier letter of interpretation. The question you asked and our reply with the corrected interpretation follow.

Scheduling and prioritizing on a "worst-first" basis.

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 29, 1993

Mr. Joseph C. Caporossi, Director
Safety, Health & Emergency Response
Cytec Industries
Five Garret Mountain Plaza
West Peterson, N.J. 07424

Dear Mr. Caporossi:

Coating processes 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 20, 1993

Mr. Michael D. Zoll
Manager of Safety
Alcan Aluminum Corporation
100 Erieview
Cleveland, Ohio 44114-1878

Dear Mr. Zoll:

This is in response to your July 30 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. In your letter you requested clarification on whether the PSM standard applies to the process described in the following scenario.