PSM Standard does not apply to 10,000 pounds of hydrocarbon fuel on site used solely as a fuel for a furnace.

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 22, 1992

Mr. Richard H. Cole, Jr.
Senior Chemical Information Officer
Ball Corporation
345 South High Street
Muncie, Indiana 47305-2326

Dear Mr. Cole:

Heat-treating process (using methanol) and the applicability 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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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.

July 28, 1995

Ms. Kimberly J. Wasson
Davis & Floyd, Inc.
PO Drawer 428
Greenwood, SC 29648

Dear Ms. Wasson:

This is in response to your letter of June 6, regarding your client's heat-treating process (using methanol) and the applicability of the Process Safety Management of Highly Hazardous Chemicals Standard, 29 CFR 1910.119.

The (PSM) for Highly Hazardous Chemicals Standard and its applicability to the specific scenarios outlined.

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 25, 1995

Sam Mannan, Ph.D, PE, CSP
Division Director
Process Safety and Risk Assessment
RMT/Jones & Neuse, Inc.
912 Capital of Texas
Highway South
Suite 300
Austin, Texas 78746-6163

Dear Dr. Mannan:

Challenge Testing as a Substitute for Annual Refresher Training.

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.

November 27, 1995

MEMORANDUM FOR:     R. DAVIS LAYNE
                   Regional Administrator

FROM:               JOHN B. MILES, Director 
                   Directorate of Compliance Programs

SUBJECT:            Challenge Testing as a Substitute for Annual Refresher
                   Training

This is in response to your letter of April 10, forwarding Florida Power Corporation's request for comments regarding their tentative plans to initiate challenge testing as a substitute for mandatory annual refresher training.

Interpretation of 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.

February 3, 1993

Mr. Michael Townley, Manager
Safety and Regulatory Affairs
Fuji Hunt Photographic Chemicals, Inc.
900 Carnegie Street
Rolling Meadows, Illinois 60008

Dear Mr. Townley:

This is in response to your October 19, 1992, letter requesting an interpretation of the Process Safety Management (PSM) standard at 29 CFR 1910.119. Please accept our apologies for the delay in responding.

Your question was:

Carburization process and the applicability of Process Safety Management for Highly Hazardous 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.

November 28, 1995

Mr. Don L. Hudnall
Industrial Hygienist
Bell Helicopter
Textron Dept. H8, Safety
P.O. Box 482
Fort Worth, TX 76101

Dear Mr. Hudnall:

This is in response to your letter of August 11, regarding your carburization process and the applicability of 29 CFR 1910.119, Process Safety Management (PSM) for Highly Hazardous Chemicals. We apologize for the delay in responding to you.

Outer Continental Shelf lands--OSHA and the U.S. Coast Guard.

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 2, 1993

(Name Withheld)

Dear (Name Withheld):

OSHA's Standard Process Safety Management of Highly Hazardous 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.

December 7, 1995

Mr. J.B. Evans
Associate Director
Operational Safety and Risk Management
Union Carbide Corporation
39 Old Ridgebury Road, Section K3
Danbury, CT 06817-0001

Dear Mr. Evans:

Solutions of hydrogen chloride in water do not apply to 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.

January 21, 1993

Mr. Ernie P. Woody
Safety Manager
Bekaert Corporation
P. O. Box 1205
Rome, Georgia 30162-1205

Dear Mr. Woody:

This is in response to your letter of December 1, 1992, requesting written confirmation that the Process Safety Management (PSM) standard at 29 CFR 1910.119 does not apply to solutions of hydrogen chloride in water, for example, a 37 percent concentration of hydrochloric acid.

When steam boilers fired by flammable liquids or natural gas are subject to 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.

January 18, 1993

Mr. Garry Stubblefield
Senior Technician
Petrocon Engineering, Inc.
P.O. Box 20397
Beaumont, Texas 77720-0397

Dear Mr. Stubblefield:

This is in response to your letter of June 18, to Mr. Gilbert J. Saulter, Dallas Regional Administrator for the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Compliance Programs for response. Please accept our apology for the delay in responding.