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Commercial-grade hydroxylamine under process safety rules

Summary A manufacturer asked whether a 50% hydroxylamine solution was covered by process safety management requirements. OSHA said the listed chemical without a concentration limit was covered at commercial-grade strength; on its stated assumption a purchased 50% liquid solution was not covered, but commercial-grade material later diluted onsite could be if the threshold quantity was present. OSHA now labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-09-11-3
Date issued
September 11, 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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Hazardous Chemicals
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 11, 1995

Mr. Jeffrey O. Brown
Howard Hall Division R.W.
Greeff & Co., Inc.
[Recipient address omitted]
Dear Mr. Brown:

This is in response to your March 20, 1995 letter requesting an interpretation regarding the applicability of Process Safety Management standard, 29 CFR 1910.119, to a 50% solution of Hydroxylamine (CAS #7803-49-8).

The substances listed in Appendix A of the standard without specified concentration limits, such as Hydroxylamine, are intended to be covered by the PSM standard at commercial grade percentages. OSHA defines "commercial grade" as a typical maximum concentration of the chemical that is commercially available and shipped. Hydroxylamine comes as both a liquid and a solid. Assuming the commercial grade of the liquid form is near a 99% concentration, a 50% solution would not be covered by the standard. However, if your company receives a commercial grade concentration, either liquid or solid, and dilutes the chemical on-site, the undiluted quantity would be subject to the PSM standard should the 2,500 pound threshold quantity be available.

We appreciate your interest in occupational safety and health. If we can be of further assistance, please contact Ron Davies at (202)219-8041.

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

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