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Standard Interpretations
01/21/1993 - Solutions of hydrogen chloride in water do not apply to Process Safety Management Standard. |
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Standard Number: | 1910.119 |
January 21, 1993
Mr. Ernie P. Woody Dear Mr. Woody: This is in response to your letter of December 1, 1992, requesting written confirmation that the Process Safety Management (PSM) standard at 29 CFR 1910.119 does not apply to solutions of hydrogen chloride in water, for example, a 37 percent concentration of hydrochloric acid. The chemical names "hydrogen chloride" (HCL) and "anhydrous hydrochloric acid" are included in the highly hazardous chemicals listing in Appendix A of the PSM standard. Anhydrous, without water, hydrochloric acid is hydrogen chloride. As you indicated in your letter, both hydrogen chloride and anhydrous hydrochloric acid are identified by the same Chemical Abstract Service (CAS) Number 7647-01-0, as denoted in Appendix A. Solutions of hydrogen chloride gas in water are not listed in Appendix A and therefore, are not considered to be highly hazardous chemicals subject to the PSM standard. Thank you for your interest in occupational safety and health. If we can be of further assistance, please contact us.
Sincerely,
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