![]() Process Safety Management.ġSecretary of Labor v. This memorandum should be filed with CPL 2-2.45. Employers inquiring about coverage of stored flammables under PSM should be informed that OSHA is following the decision in Meer, pending possible revisions to the standard to resolve the ambiguity, but that citations may be issued under 5(a)(1) if circumstances warrant.įor further information, contact the Office of General Industry Compliance Assistance (Ray Donnelly or Alcmene Haloftis on 20 or Mike Marshall on 20, x112). Since such citations will in all likelihood be litigated, early involvement of the Solicitor in such cases is mandatory, to ensure that the basis for citation has legal clearance. In other cases where stored flammable liquids subject to the exemption are connected to a process, and a documentable hazard exists which involves a serious risk to workers, 5(a)(1) citations may be issued. storage not atmospheric, storage relies on refrigeration, quantities not actually in storage).Ĭitations for 1910.106 may apply to situations where flammable liquids are stored. Citations under 1910.119 will continue to be issued when the quantity of flammables in the process, not counting atmospheric storage, exceeds 10,000 pounds, or where the quantities in storage do not fall within the exception for other reasons (i.e. Until the standard is revised, however, OSHA will abide by the Meer decision, and will not cite 1910.119 under circumstances when coverage of the process would be based partly or solely on the quantity of flammable liquid in connected atmospheric storage tanks, that would otherwise qualify for the 1910.119(a)(1)(ii)(B) exemption. We have asked the Directorate of Safety Standards Programs to consider developing amendments to the standard which would clearly state our intention to cover flammables stored in atmospheric tanks when they are connected to a covered process, or when they are located such that there is a reasonable probability that they could be involved in the release of a covered highly hazardous chemical. Any highly hazardous chemical (HHC) listed on. The exemption does not apply to Appendix A materials. However, there are four important points to keep in mind before applying it to your process. However, the decision will not be appealed because it is based on problems in the text of the standard itself, which support the judge's decision. Flammable liquids are hazardous, even when in storage, but the atmospheric flammable storage exemption still exists for PSM. Idmg flammable liquid exemption download#Image is large in size, windows users right click to download file and choose Save Target As, Mac users Option-click (or right click with a two button mouse) and choose Download Link to Disk. Idmg flammable liquid exemption code#This is contrary to consistent OSHA interpretations of the standard. Below is a decision tree to see whether a vehicle powered by flammable liquid is dangerous goods or not under the provisions of IMDG Code 35-10. In a recent decision, 1 the judge ruled that coverage under OSHA's Process Safety Management Standard (1910.119) does not extend to stored flammables in "atmospheric tanks," even if they were connected to a "process" within the definition of the standard. Subject: Coverage of Stored Flammables Under the Process Safety ![]()
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