Pressure piping compliance under flammable-liquid rules
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November 14, 1983
MEMORANDUM FOR: PERRY JONES
Area Director, Charleston
ATTENTION: EUGENE FORD, CSHO
FROM: LINDA R. ANKU
Regional Administrator
SUBJECT: Interpretation of 29 CFR 1910.106(c)(1)(i)
This memorandum was prepared in response to your written request of October 28, 1983 for interpretation of 1910.106(c)(1)(i) as stated in the written inquiry (copy attached) of Union Carbide Corporation dated October 25, 1983. The specific question referred to compliance with the applicable provisions of Pressure Piping, ANSI B31 and "the provisions of this paragraph" as indication of prima facie evidence of compliance with the foregoing provisions, specifically 1910.106(b)(7) on testing.
Our interpretation is in general agreement with the position of CSHO Eugene Ford; i.e., all piping, valves, and fittings meeting the design requirements of ANSI B31 and the provisions of 1910.106(c)(1)(i) will by implication meet the testing requirements of 1910.106(b)(7) and all other applicable provisions of 1910.106(b) on tank storage.
Questions on this memorandum may be directed to Bill Thomas in the Technical Support group of this office.
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