Who has jurisdiction? DOT or OSHA/EPA?
Who has jurisdiction? DOT or OSHA/EPA?
(OP)
I am working on a project to develop P&IDs for a pipeline company. They're telling me that OSHA does not have jurisdiction over the pipeline or even the tankfarm facilities. When I checked on DOT documentation they defer pressure relief work and other mechanical integrity tasks to OSHA. When I read OSHA 1910 documents they defere to DOT. The question is, can I get burned by getting caught in the crossfire? Who is (are) ultimately responsible for regulating tankfarm facilities and pipelines?





RE: Who has jurisdiction? DOT or OSHA/EPA?
David
RE: Who has jurisdiction? DOT or OSHA/EPA?
Governmental jurisdiction can be confusing. Your client is right in saying DOT has jurisdiction over pipelines, but I'm pretty sure they're wrong about the tank farm jurisdiction. To my knowledge, DOT has no jurisdiction over tank farms - that's OSHA. If I'm wrong about this, someone please speak up and point out a reference.
DOT has some unique differences from the reg's and standards that we're accustomed to using. For example, DOT allows you to use a special type of shutoff regulator instead of a PSV. The reason is pretty obvious. No one wants to install a PSV out in a public area or on someone's private property.
Here's an excellent reference document that's free. All relief designers ought to have a copy of this. It has a very good section discussing DOT pressure relief regulations. This is one of the best reference documents I've found related to pressure relief design.
<ht
RE: Who has jurisdiction? DOT or OSHA/EPA?