For those of you that follow my ramblings have heard me rant on about ASME A13.1 and how pipe labeling begins LONG BEFORE a process becomes a PSM/RMP covered process. ALL Hazardous Materials piping has to be labeled! And yes I am well aware of OSHA’s position on pipe labeling and their Globally Harmonized System for Hazardous Communications…
Container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are NOT considered to be containers.
But the standard also says…