Pipe labeling is essential for every facility that contains pipes, no matter if the pipe just contains potable water or if it contains hazardous chemicals such as anhydrous ammonia. Simply stating that pipe marking “should” be done in these kinds of facilities is often not enough. For that reason, OSHA does require and enforce the voluntary pipe marking standards created by ANSI and ASME.
OSHA does this by using what’s called incorporation by reference. Many business owners may already recognize the ANSI/ASME A13.1 pipe marking standard as the best practice method for keeping employees safe via visual communication efforts. However, OSHA has gone a step further to ensure that employers follow this voluntary standard and has done so by directly referencing this standard within part 1910 of the Occupational Safety and Health Standards regulations.
Section 1910.6(a)(3) of the “Incorporation by Reference” standard specifies the following, “The standards listed in this section are incorporated by reference into this part with the approval of the Director of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51.” Specifically, in 1910.6(e)(6) the standard states, “ANSI/ASME 13.1-56 Scheme for the Identification of piping Systems, IBR approved for §§1910.253(d)(4)(ii); 1910.261(a)(3)(iii); 1910.262(c)(7).” These three sections within part 1910 of the Occupational Safety and Health Standards regulations are where ANSI’s A13.1 standard are specifically referenced by OSHA, making the voluntary best practice method for pipe marking into a regulation that facilities must follow to stay in compliance with OSHA regulations.
Notice that the regulation references ANSI/ASME 13.1-56 rather than the most recent revision put out in 2020. Theoretically, employers only need to follow OSHA standards as they are a government regulated body in comparison to ANSI and ASME’s voluntary status. However, OSHA has another trick up their sleeve called the General Duty Clause. This exception has the ability to come back and bite the employer because OSHA can claim that they didn’t take other courses of action available at the time to fully protect their employees. For this reason, following the most recently updated pipe marking, or other incorporated voluntary standards, is highly recommended. It will not only protect the employers from citation, but more importantly it will ensure the safety of employees even more so than if older outdated standards are used.
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