I got an interesting question this week from one of our sales people.  He told me that a competitor, new to the process safety market, supplied his customer with a list of their users who are compliant with 29CFR1910.119.  He wondered if we had a similar list or a way to neutralize their insinuation that their system was better than ours.  

After I stopped laughing, I sent him the following response:

29CFR1910.119 is not a standard, it is law (CFR = Code of Federal Regulations). It mandates requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. It applies to the following facilities:

A process which involves a chemical at or above the specified threshold quantities listed in Appendix A

A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more except for hydrocarbon fuels used solely for workplace consumption as a fuel….

1910.119 does not include specific information on requirements for safety systems. Rather, it requires that facilities perform a Process Hazard Analysis (PHA) and take measures to mitigate the risks. In reference to Safety Systems the regulation states the following, "The employer shall document that [Safety systems (e.g. interlocks, detection or suppression systems).] equipment complies with recognized and generally accepted good engineering practices."

OSHA has formally acknowledged S84 (ANSI/ISA-S84.00.01-2004 Parts 1-3 (IEC 61511 Mod)) as "recognized and generally accepted good engineering practices for SIS" in a letter from OSHA to ISA dated Nov 29, 2005.  The letter was distributed to all ISA S84 committee members - I have a copy if you are interested. 

It really makes no sense that a safety system supplier would provide a list of their customers that are compliant with 1910.119. It would be about as relevant as a list of their customers that are complaint with the Disabilities Act. To me, this demonstrates their inexperience in process safety. In response, you should ask your customer if they currently implement ANSI/ISA-S84.00.01-2004 in their facilities or have plans to do so in the future. We could advise them that OSHA recognizes S84 as good engineering practice. If they'd like to learn more about implementing S84 we could invite them to participate in one of our Process Safety - Safety Lifecycle Workshops.