Application cont'd - hdbk11010027

DOE-HDBK-1101-96

What is meant by the manufacture of explosives?

20.

OSHA considers the manufacture of explosives to mean mixing, blending, extruding, synthe-

sizing, assembling, disassembling, and other activities involved in the making of a product or

device which is intended to explode.

21.

Are flammable liquid and gas separation vessels associated with oil and gas well drilling

and servicing operations exempt?

Yes; however, these operations are often closely associated with a variety of vessels used to

separate and treat the flammable liquids and gases produced by the wells. Some oil and gas

production vessels may be excluded from coverage under the Rule by the atmospheric storage

and transfer exemption. However, other vessels associated with oil and gas are covered if the

flammable materials are stored above atmospheric pressure and meet the 10,000-lb TQ require-

ment.

Please clarify the definition for the exemption of a normally unoccupied remote facility?

22.

What does normally unoccupied mean? How remote is remote?

Normally unoccupied means that employees are not permanently stationed at the remote

location. This includes those sites where employees make periodic, scheduled visits (e.g., for

preventive maintenance, sample collection, equipment calibration, or inspections). Facilities

meeting this definition are not contiguous with and must be geographically remote from all

other buildings, processes, or persons. There is no minimum distance specified to define

remote. DOE contractors should review each situation and document their technical bases for

determining whether a process is exempt. No accident at a remote location should have the

potential to injure people at locations which are normally occupied.

23.

What documentation is needed, if any, to support a DOE contractor's judgement that a

particular site, facility, or process is not covered?

No specific documentation is required by the PSM Rule concerning the establishment of

covered processes. However, DOE contractors should maintain a list of covered processes and

document the technical basis for any decision to exclude a process from coverage where the

PSM Rule is subject to interpretation.

24.

Single containers used to store a specific HHC, each containing less than the TQ amount,

are located at several distinct, widely-separated locations in a plant. Is the storage and

handling of this HHC covered under the Rule if the combined amount of two or more

containers exceeds the TQ for the HHC?

If the containers are not connected and are not in one location, then each container and its

associated process should be evaluated separately. On the other hand, if widely separated

containers are connected by process piping, and a loss of containment in one section could

cause an HHC to be released from more than one container, then coverage should be evaluated

on the basis of the total amount of HHC in all of the connected containers. A similar argument

applies if these separate containers, although unconnected, are all stored in one location where

a single, common event could release the HHC from two or more containers.