I received a great question and answer to this question that I wanted to share with the EE365 Level group. The engineer with a major oil and gas producer was tasked with performing a gap analysis and ultimately a gap closure for some of their facilities to ensure compliance with API 2350. He had a question about the scope of the standard and how to interpret it. He shared this highlighted excerpt in question directly from API 2350.
1.1 ScopeThe scope of this standard is intended for storage tanks associated with marketing, refining, pipeline and terminalscontaining Class I or Class II petroleum liquids. Use is recommended for Class III petroleum liquids. This standarddoes not apply to:
This standard recommends application of PEI Recommended Practice 600 Recommended Practices for OverfillPrevention for Shop-Fabricated Aboveground Tanks for overfill protection where applicable for aboveground tanksfalling outside the scope of this document.
His question was, "is this a typographical error, or are 'tanks covered by OSHA' really excluded from the standard? This seems contradictory to the intent of the document. What does 'tanks covered by OSHA…' even mean? OSHA 29 CFR 1910.119 doesn’t dictate tank specifications, and the minimal references it does make about tanks are not very normative."
Lance Berry, a member of the API2350 committee reached out to the chair of the API2350 Rev 4 for scope clarification. Here's the response he received back:
The scope was written so as not to overlap with small tank standards such as PEI, or containers that are not really petroleum receiving tanks. We did not want nor is 2350 applicable to pressure vessels. We did not want to overlap with the OSHA codes since there are chemicals and non petroleum related chemicals in that code. Hope this helps.
The email thread has some follow up Q&A which I wanted to share:
Q: Just to clarify, API 2350 does not supersede OSHA 1910.119; so what does OSHA specify in their codes in regards to tanks, and specifically tank overfill, that would take precedent over API 2350? It seems like OSHA concedes specificity to industry standards and practices.
A: The OSHA codes seems to be a smattering of tidbits of other API standards. Not sure why nothing is said about tank overfilling... To directly answer, there is nothing in OSHA that supersedes 2350.I think if you are developing an internal standard or a guideline, it would be best to build it upon the industry standards. Then have a disclaimer than anytime there is a conflict between regulatory standards and internal standards that the regulatory shall take precedence. This allows you to have your cake and eat it too (both industry practice and legal). I would not work from the basis of compliance if you want to get your operations working properly...