Who has jurisdiction? DOT or OSHA/EPA?

[rocketscientist]

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?

 

[zdas04]

What difference does it make? At the end of the day, the facility must comply with OSHA, DOT, EPA, State Environmental Boards, State Health and Safety departments, and local codes. None of them always have primacy. I've never found the requirements of the codes to be in conflict (mostly they deal with different facets of the design and construction). Occasionally, something will be acceptable to one of the agencies and not acceptable to another, but if you turn it over and coply with the most restrictive code then the less restrictive codes are satisfied.

David

 

[don1980]

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.

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http://www.tycovalves-usa.com/getlit.asp?lit=ld/Tech

Sem Manual.pdf>

 

[rocketscientist]

I think I found a simple explanation. It stems from a 1971 agreement between the DOT and EPA. Basically it says that if it's moving or about to move jurisdiction belongs to the DOT. If it is not moving, as in a tankfarm then it is EPA. Where there is overlap, then both agencies have regulation dominion.