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Connected methanol storage under process safety rules

Summary A company asked whether atmospheric methanol storage tanks were exempt from OSHA’s process safety management rule. OSHA said the storage exemption applied to storage facilities and transfer conduits alone; tanks and lines connected to a process were included when threshold quantities were exceeded. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-07-28
Date issued
July 28, 1995
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Process Safety Chemical Safety
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 28, 1995

Ms. Kimberly J. Wasson
Davis & Floyd, Inc.
[Recipient address omitted]
Dear Ms. Wasson:

This is in response to your letter of June 6, regarding your client's heat-treating process (using methanol) and the applicability of the Process Safety Management of Highly Hazardous Chemicals Standard, 29 CFR 1910.119.

Please be advised that the exemption cited under 1910.119(a)(1)(ii)(B) pertains only to storage facilities and transfer conduits. If the storage tanks and the transfer conduits are interconnected to a process, however, such as the one indicated in your letter, then the total facility (i.e. atmospheric storage tanks, transfer conduits/piping and the process) would fall under 1910.119, whenever the threshold quantities are exceeded.

Thank you for your interest in occupational safety and health. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.

Sincerely,
John B. Miles, Jr.
Director
Directorate of Compliance Programs

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