Highly Hazardous Chemicals as it applies to solid propellant rocket motors.

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

L. Dave McLean
Strategic Operations
Thiokol Corporation
P.O. Box 689, M/S DOO
Brigham City, Utah 84302-0689

Dear Mr. McLean:

This is in response to your September 28 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. Your questions and our responses follow.

Question 1: Is the manufacture of solid propellant rocket motors covered by 1910.119?

PSM threshold quantity; EPA regulated and permitted RCRA Hazardous waste treatment.

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 21, 1992

Mr. David L. Walker
Division of Environmental Quality
State of Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, Missouri 65102

Dear Mr. Walker:

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 19, 1994

The Honorable Richard E. Neal Member, U.S. House of Representatives Federal Building 1550 Maine Street Springfield, MA. 01103

Dear Congressman Neal:

We have received your July 25 letter regarding the request for assistance by Ms. Catherine Benjamin, Safety Coordinator for Flexcon Company, Inc. Ms. Benjamin requested an interpretation and clarification of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHCs) standard, 29 CFR 1910.119 as it may apply to processes containing HHCs at one of her company's work sites.

OSHA's policy for inspections related to the Process Safety Management 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.

July 18, 1994

Mr. P. J. Bellomo
Senior Consultant
Arthur D. Little, Inc.
1001 Fannin Street, Suite 2050
Houston, Texas 77002-6778

Dear Mr. Bellomo:

This is in response to your letter dated February 28, which you resubmitted to us on June 15, by telefax. We apparently misplaced the original mailing and apologize for the delay in responding.

In your letter you described your understanding of OSHA's policy for inspections related to the Process Safety Management (PSM) standard as follows:

Process Safety Management - Threshold quantity is determined on the amount of HHC in the 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.

July 18, 1994

Ms. Susan Kunst
Boushell Law Offices of McKenna and Cuneo
1575 Eye Street, N.W.
Washington, D.C. 20005

Dear Ms. Boushel:

This is in response to your May 3 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 response. In your letter you asked for confirmation that a threshold quantity (TQ) is determined on the amount of HHC in the process at any one point in time and not aggregated over a period of time.

The Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC) 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 11, 1994

Mr. Joseph R. Schneider
Professional Development Chairman
Central Florida Section
American Institute of Chemical Engineer
2510 Twelve Point Drive
Lakeland, Florida 33811

Dear Mr. Schneider:

This is in response to your March 22 letter, requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC) standard, 29 CFR 1910.119. Please accept our apology for the delay in response. Your questions and our responses follow.

Question #1:

HHC's as it applies to employer obligation to obtain and evaluate information regarding the contract employer's safety performance and programs

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 29, 1994

Mr. Jeffrey D. Jefferson
Nordstrom Steele & Jefferson
215 Fidalgo Avenue, Suite 201
Kenai, Alaska 99611

Dear Mr. Jefferson:

This is in response to your letter of May 11 and follow-up to a telephone conference with you on June 9 initiated by Rolland Stroup of our staff, regarding the applicability and requirements of the Process Safety Management of Highly Hazardous Chemicals (PSM) standard, 29 CFR 1910.119.

Process Safety Management Standard (PSM) of Highly Hazardous Chemicals (HHCs) 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.

June 24, 1994

Mr. Gavin Burdge
Industrial Hygienist
Laidlaw Environmental Services
407 Burton Road
Lexington, SC 29072

Dear Mr. Burdge:

This is in response to your May 19 letter to Roger Clark, former Director of Compliance Programs. In your letter, you requested an interpretation of the Process Safety Management Standard (PSM) of Highly Hazardous Chemicals (HHCs) standard, 29 CFR 1910.119.

Clarification on whether the ozone process described is 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.

October 12, 1995

Ms. Janis A. Morelli
Elizabethtown Water Company
600 South Avenue
Westfield, NJ 07091-0788

Dear Ms. Morelli:

This is in response to your September 28 letter requesting interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119. Specifically, you requested clarification on whether the ozone process described in your letter is covered by the PSM standard.

Interpretation of the Process Safety Management of Highly Hazardous Chemicals 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 27, 1995

Mr. J. B. Evans Union Carbide Corporation 39 Old Ridgebury Road, K3 Danbury, CT 06817-0001

Dear Mr. Evans:

This is in response to your June 1, 1994 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 replies follow: