IIAR has received clarification from OSHA on an ongoing question surrounding OSHA's requirement for hydrostatic relief for various pieces of equipment, especially evaporative condensers.
OSHA's position on the issue was originally that hydrostatic relief is required when equipment containing liquid refrigerant can be isolated. That position was stated in an interpretation letter commonly known as "the Palmer letter." However, a few years ago, the agency unofficially noted that administrative controls, i.e. the use of trained operators, are acceptable when isolating equipment as outlined in IIAR-2. Nevertheless, OSHA did not officially revise its position and the interpretation remained on the agency's website.
The inconsistency created confusion about OSHA's requirement. Therefore, IIAR pursued OSHA to encourage the agency to make an official decision on the issue. As a result, IIAR has now successfully convinced OSHA to remove its requirement for hydrostatic relief, provided that administrative controls are used for isolation, as outlined in IIAR-2.
To read OSHA's notification on this issue, and its current interpretation of requirements click here.