Hydrochloric acid solutions under the Process Safety Management standard

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 25, 1993

Mr. Ernie P. Woody
Safety Manager
Bekaert Corporation
[Recipient address omitted]
Dear Mr. Woody:

This is in response to your letter of December 1, 1992, requesting written confirmation that the Process Safety Management (PSM) standard at 29 CFR 1910.119 does not apply to solutions of hydrogen chloride in water. For example, a 37 percent concentration of hydrochloric 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. As you indicated in your letter, 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. Solutions of hydrogen chloride gas in water are not listed in Appendix A and therefore, are not considered to be highly hazardous chemicals subject to the PSM standard.

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

Sincerely,
Roger A. Clark,
Director
Directorate of Compliance Programs