OSHA may use their General Duty Clause (GDC) to enforce their desire for employers to have Oxygen monitor(s) in areas where inert cryogenics are stored and used. But I like to use codes/standards (e.g. RAGAGEPs) to drive my safety engineering of these hazardous processes, even though they are not PSM/RMP covered processes. To do this I turn to the Internation Fire Code (IFC) that is applicable to the state I’m in. Here is the language from the IFC regarding Inert Cryogenics, but this code directs us to the code/standard where the actual requirement resides…