Updating process safety information for older pressure vessels

January 30, 2001

Mr. Rick Durham

Boiler & Machinery Consultant

Marsh Risk Consulting

[Recipient address omitted]

Dear Mr. Durham:

Thank you for your October 31, 2000 letter to the Occupational Safety and Health Administrations's (OSHA's) Directorate of Compliance Programs (DCP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had questions regarding OSHA's Process Safety Management of Highly Hazardous Chemicals, Explosives and Blasting Agents Standard (PSM), 29 CFR 1910.119. Your specific question is related to updating process safety information (PSI) with respect to pressure vessels in a PSM-covered process.

Question: If an employer determines that a vessel is suitable (vessel design, construction, maintenance, inspection, testing and operation) for PSM service to a particular American Society of Mechanical Engineers' (ASME) Code, is it required that all of this information be updated periodically or only if there is a change of service?

Response: Based on your letter, your question is related to the PSI portion of OSHA's PSM standard, specifically 29 CFR 1910.119(d)(3)(iii). The intent of this requirement is for the employer to determine and document that PSM-covered equipment that was designed and constructed to comply with codes, standards or practices no longer in general use can continue to operate in a safe manner. After the employer makes the determination required by the standard, it will be the basis for the decision to take the equipment out-of-service or continue operations. If the equipment is to be kept in-service, the determination will be the baseline from which all future operation, inspection, testing and maintenance is conducted.

Generally speaking, OSHA intended for the employer determination and documentation required by 29 CFR 1910.119(d)(3)(iii) to be completed prior to the implementation of the original PHA or startup of a PSM-covered process. Therefore, once an employer is in compliance with this requirement, there is no additional requirement per 29 CFR 1910.119(d)(3)(iii) for future determinations/documentation simply because a code or standard related to the covered equipment has been revised. After the employer has made this baseline determination and documentation, other PSM elements such as management of change, mechanical integrity, PHA-revalidation, pre-startup safety review, etc., are intended to address on-going safe operation and maintenance of PSM-covered equipment.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director

[Directorate of Enforcement Programs]

[Corrected 6/2/2005]