PSM Battery Limit Scenario w/ gas cylinders stored within the same building w/ NO passive fire barrier separation (OSHA LOI)
I found this latest Letter of Interpretation regarding PSM Battery Limits an interesting read. The scenario is VERY COMMON and I am so glad OSHA wrote this letter! OSHA reminds us that cylinders stored in the same fire area (e.g. a fire has no passive control(s) to prevent its spread) that ALL of the cylinders that could be impacted by the same fire MUST BE AGGREGATED to determine if the threshold has been exceeded. NOTE: the person asking the question appears to be wanting to lay claim that each individual cylinder (DOT 3AA-2400) will be adequate "separation". This letter hits the following key topics: |
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Also I have found this LOI which speaks to a Flammable Storage area that is adjacent to process piping in which OSHA states that it is part of the covered process..??? Understood the co-location but wouldn't that be similar to people using the "Exemption" to not cover connected atmospheric storage as one could say that it meets the exemption?
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=interpretations&p_id=21705
An employer is exempt from the requirements of PSM when a threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration (29 C.F.R. 1910.119(a)(1)(ii)(B)). This exemption would also apply to your storage of flammable liquids in small containers, even if an aggregate TQ or greater amount is stored in the engineered storage vaults.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24328
FYI... if OSHA has their way, this atmospheric tank exemption will be removed from the standard when it is revised.
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