Are hydrogen systems holding more than 10,000 lb (4500 kg) of hydrogen for use as a fuel required to comply with OSHA PSM requirements described in 49 CFR 1910.119?

Fuels like gasoline are exempt from OSHA process safety management (PSM) requirements. When asked about the applicability for hydrogen storage larger than 10,000 lb (4500 kg) being used as a fuel, OSHA responded with an interpretation that can be found at https://www.osha.gov/laws-regs/standardinterpretations/2013-02-04-0.

 The interpretation says in part “…processes containing a threshold quantity of hydrogen used as a fuel must meet all requirements of PSM.”