Standard Interpretations - Table of Contents
• Standard Number: 1910.119(a)(1)(ii)(A)

December 8, 2000

Mr. Edwin G. Foulke, Esq.
Jackson, Lewis, Schnitzler & Krupman
2100 Daniel Building
301 North Main Street
Greenville, SC 29601-2122

Dear Mr. Foulke:

We are writing in response to correspondence received from your client, Thomas Industrial Gases, Inc. (Thomas), concerning an issue arising under the Occupational Safety and Health Administration's (OSHA's) rule on Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents, (PSM), 29 CFR §1910.119. Thomas requested an interpretation which would include its MAPP gas glass mold lubrication system within an exemption from the requirements of OSHA's PSM rule.

MAPP gas is a flammable gas made from a mixture of methyl acetylene and propadiene. We understand Thomas' customers are storing quantities of MAPP gas in amounts greater than the threshold quantity (TQ) of 10,000 pounds, which would trigger application of the PSM requirements. We have reviewed and considered a number of letters from you and your client to OSHA staff providing information in connection with Thomas' interpretive request. The letters are dated from December 20, 1999 through November 8, 2000.

It appears that your client's concerns were spurred by a prior OSHA interpretation letter to Mr. Steven Lee, Libbey Glass, Inc., dated November 23, 1999. Libbey Glass, Inc. is one of Thomas' primary users of this process. In this letter, OSHA concluded that Libbey's use of Thomas' MAPP gas process to lubricate glass molds did not meet the hydrocarbon fuels exemption set forth in PSM [29 CFR