Processes involving workplace explosive.

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 30, 1993

Mr. Steven E. Roberts
Director of Health Services
Alliant Techsystems Inc.
5901 Lincoln Drive
Edina, Minnesota 55436

Dear Mr. Roberts:

Highly Hazardous Chemical's anhydrous ammonia (NH(3)).

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 2, 1994

Mr. Jim Dykes
Director of Safety Education
American Institute of Baking
1213 Bakers Way
Manhattan, Kansas 66502

Dear Mr. Dykes:

HHC's as it applies to exterior, interior 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.

June 3, 1994

Mr. Kenneth W. Clarfield
Director - Member Services
Private Label Manufacturers Association
369 Lexington Avenue
New York, New York 10017

Dear Mr. Clarfield:

Clarifications of the OSHA standards 1910.109 and 1910.119.

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 16, 1994

Mr. Curtis W. Rankins
Director of Health and Safety
Laidlaw Environmental Services
407 Burton Road
Lexington, South Carolina 29072

Dear Mr. Rankins:

This is in response to your May 9 letter to Roger Clark, former Director of the Directorate of Compliance Programs. In your letter, you requested clarifications of the OSHA standards, 29 CFR 1910.109 and 29 CFR 1910.119.

In the following, please find your specific questions and our answers.

Question 1.

HHC's as it applies to pulp and paper industry processes that contain chlorine dioxide

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, 1994

Mr. Thomas J. Lukish
James River Corporation
P.O. Box 2218
Richmond, Virginia 23217

Dear Mr. Lukish:

This is in response to your January 31 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119. Specifically, you requested clarification as to whether processes used in the pulp and paper industry are covered by the PSM standard because the processes contain chlorine dioxide (ClO(2)). Please accept our apology for the delay in responding.

Highly Hazardous Chemicals, types of hardware that see contact with explosives.

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 25, 1994

Mr. Sam Mannan
Jones and Neuse, Inc.
Suite 300
912 Capitol of Texas Highway
South Austin, Texas 78746

Dear Mr. Mannan:

Cellulose nitrate 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 20, 1992

Highly Hazardous Chemicals as it applies to aqueous solutions of hydrofluoric acid.

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 18, 1994

Mr. Robert A. Rusczek, President
Envirocomp
264 Cottage Street
Springfield, MA 01104-3240

Dear Mr. Rusczek:

This is in response to your letter of April 13, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals, 29 CFR 1910.119 standard. Specifically, you requested clarification as to whether the PSM standard applies to aqueous solutions of hydrofluoric acid.

Highly Hazardous Chemicals as it applies to what constitutes the boundaries of a 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.

April 28, 1994

Mr. Grahame Barker
Baker Performance Chemicals Incorporated
3920 Essex Lane
Houston, Texas 77027

Dear Mr. Barker:

This is in response to your March 23 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119. Specifically, you requested clarification on what constitutes the boundaries of a process. Your question and our replies follow.

Question 1:

Formaldehyde (37% by weight or greater) in the 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.

June 28, 1992

Mr. Cary Franklin
Senior Process/Project Engineer
Georgia Pacific Resins, Inc.
2883 Miller Road
Decatur, Georgia 30035

Dear Mr. Franklin:

This is in response to your letter of June 24, regarding the Final Rule on Process Safety Management (PSM) of Highly Hazardous Chemicals published in Volume 57, Number 36 of the Federal Register on Monday, February 24, 1992.