Scenario 1: The first scenario you described has the following attributes:
Your firm is engaged in the design and construction of a manufacturing (processing) facility which includes OSHA Category 2, 3, and 4 flammable liquids as raw materials and processing intermediates.
- The Food and Drug Administration and countries in Europe, the Middle East, and Africa regulate the facility due to the manufacture of injectable biologics and pharmaceuticals. The facility must meet strict cleaning and contamination-prevention regulations.
- The facility uses PD pumps for transferring flammable liquids from storage to processing units and from process vessels to other process vessels or processing equipment.
- Flammable liquids are handled at temperatures below their flash points and boiling points.
- Quantities of flammable liquid in storage exceed 10,000 pounds as do quantities of flammable liquid outside of storage (i.e., downstream of storage processs(es)).
Question 1A: Does OSHA consider a transfer pump used to transfer flammable liquids from a storage tank to a process unit to be a process pump or a storage pump? Does OSHA view the two types of pumps differently?