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Standard Interpretations
06/16/1994 - Clarifications of the OSHA standards 1910.109 and 1910.119. |
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Standard Number: | 1910.109; 1910.119 |
June 16, 1994
Mr. Curtis W. Rankins Dear Mr. Rankins: This is in response to your May 9 letter to Roger Clark, former Director of the Directorate of Compliance Programs. In your letter, you requested clarifications of the OSHA standards, 29 CFR 1910.109 and 29 CFR 1910.119. In the following, please find your specific questions and our answers. Question 1. Should our facility have to comply with 1910.119 when addressing the 1910.109(k)(1-3) standard for a hazardous waste facility permitted to handle explosives? In my opinion, 109(k) deals with a facility manufacturing explosives, our facility stores and disposes of explosives. Reply. In order for OSHA to state clearly whether your
facility would be covered by 1910.119, we need the following information: Question 2. We operate facilities that recover natural landfill gases and generate electricity (no storage tanks are utilized); will this process fall under the exemption of 29 CFR 1910.119(a)(1)(ii)(A), (a)(2)(ii)? Reply. According to the information that you have provided, it appears that your facility would fall under the exception of 29 CFR 1910.119(a)(1)(ii)(A) and (a)(2)(ii). However, OSHA needs further information as to what other processes, if any, are located relative to the gas recovering process, in order to clearly determine whether your facility would be excepted from standard 1910.119 (please see the definition of "process" in this standard). Please note, for your information that these facilities would be covered under the Electric Power Generation, Transmission, and Distribution Standard. A copy is enclosed for your use. We appreciate your interest in occupational safety and health.
Sincerely,
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