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Muriatic acid and process safety management listing

Summary A chemical company asked if 32 percent muriatic acid was covered by OSHA's process safety management rule. OSHA said Appendix A listed hydrogen chloride and anhydrous hydrochloric acid, but did not list hydrochloric acid dissolved in water. It therefore said the muriatic acid solution was not subject to that listing.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1992-06-24-2
Date issued
June 24, 1992
Status
Active
Status last verified October 9, 2026

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June 24, 1992

Mr. Frank R. Samartinov
Process Safety Engineer
Hoechst Celanese
[Recipient address omitted]
Dear Mr. Samartino:

This is in response to your May 11 letter, requesting written confirmation that the Final Rule on Process Safety Management (PSM) of Highly Hazardous Chemicals published in Volume 57, Number 35 of the Federal Register on Monday, February 24, 1992 does not apply to muriatic (32% HCL) acid.

The chemical names: hydrogen chloride (HCL) and anhydrous hydrochloric acid are included in the highly hazardous chemicals listing in Appendix A of the PSM standard. Anhydrous (without water) hydrochloric acid is hydrogen chloride. Both hydrogen chloride and anhydrous hydrochloric acid are identified by the same Chemical Abstract Service (CAS) Number 7647-01-0, as denoted in Appendix A. Hydrochloric acid (muriatic acid), that is, a solution of hydrogen chloride gas in water, is not listed in Appendix A and therefore, is not considered to be a highly hazardous chemical subject to the PSM standard.

Thank you for your interest in occupational safety and health. If we may be of further assistance, please contact us.

Sincerely,

Patricia K. Clark, Director
Directorate of Compliance Programs

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