OSHA does not have any provisions that require the emergency relief devices on PORTABLE TANKS to discharge to the outside of buildings. However, if portable tanks are part of a PSM-covered process, at a minimum, the employer would be required to IDENTIFY, EVALUATE, AND CONTROL [§1910.119(e)(1)] the hazard of discharging flammable and combustible materials through an emergency relief device into the inside of a building.

If this same condition exists for a non-PSM-covered process and employers have NOT properly evaluated and controlled a release inside a building or a room from emergency relief devices on PORTABLE TANKS, the employer may be cited under the General Duty Clause of the OSH Act for not controlling a serious fire/explosion hazard that is likely to cause death or serious physical harm to employees.

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