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OSHA Interpretations: Coverage of Utilities |
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In 1995, a company with PSM covered processes at one of its facilities requested guidance on how to treat utility systems that interface with covered processes. OSHA responded that utilities that serve a covered process are considered part of the process where they can impact on, or affect a release of the highly hazardous chemical in the process. Utility system failure such as loss of instrument air, heating and cooling mediums, and electric have been a major cause of upset conditions in chemical processes. These utility systems would be subject to all of the provisions of the PSM standard until such point where a failure in component of the system can no longer affect a potential release of a covered chemical, or where the utility leaves the control of the employer. In practical terms, the PSM boundaries of covered processes must be extended into utility and support systems until redundancy is found. For example, if a covered process is served by a single loop cooling water system, and the loss of the cooling water could contribute to a catastrophic release in the covered process, then the entire cooling water system would have to be included in the PSM program. If, on the other hand, the cooling water loop has a backup city water supply which automatically initiates flow if the normal cooling water pressure reduces below the city water pressure, then only the backup supply and the piping and heat removal equipment that actually interfaces with the covered process equipment might need to be covered. The remainder of the cooling water loop (including pumps, cooling tower, fans, and associated piping) might be exempt from PSM coverage. For more information on this particular interpretation, see OSHA letter of interpretation dated September 14, 1995. To go back to Part 1: OSHA Interpretations, click here. Otherwise, click here for AcuSafe.
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