Review of NASA hydrogen safety manual

December 10, 1984

Mr. Haggai Cohen
Acting Director, Safety Division
National Aeronautics and
Space Administration
[Recipient address omitted]
Dear Mr. Cohen:

This is in response to your October 25 letter requesting general comments on the hydrogen safety manual in time for your Review Committee meeting on December 11 and 12. Because of the time constraints our review was limited to the manual's general organizational structure and obvious conflicts with OSHA's standards.

Our preliminary comments were provided by the Directors of Health Standards and Safety Standards and are as follows:

1. Control measures not required by OSHA but included in the document are: certification of operators, use of a two-barrier safety feature (at least two simultaneous mishaps must occur before an incident/accident takes place), and maintaining negative pressure (relative to communication rooms) for uncontained systems.

2. It is suggested that the manual list cross references from OSHA's regulations to other regulations, e.g., 29 CFR 1910.103(b)(1)(iii) should be cross referenced to ANSI B31.1-1967 and B31.1-1969 addenda.

3. "Should" is used instead of "shall". Examples are paragraphs 3.3.2.a.4, 3.3.2.b.1, and 3.3.4.d (first should).

4. Section 1910.103 contains specific provisions on vaporizers; we were unable to locate similar language in the manual.

5. 29 CFR Part 1910 is listed in Appendix C, Transportation Codes; OSHA's standard is not a transportation standard and this should be clearly indicated.

We hope these general comments will be helpful.

We will try to have comments of both a technical and general nature completed and transmitted to you by the January 18, 1985, date that you requested in your letter.

Sincerely,
John B. Miles, Jr.
Director
Directorate of Field Operations

[Requester letter reproduced on OSHA page; omitted here.]