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Are pipelines subject to 311 and 312?

Pipelines and similar transport systems are covered under the OSHA Hazard Communication Standard (HCS) (August 24, 1987).  Must the "storage" of materials in these facilities be reported under Sections 311 and 312?

Materials in pipelines are included in the general exemption for substances in transportation from all requirements under Title III except Section 304 release reporting.  Therefore, despite the coverage of these facilities under OSHA, the materials in pipelines are not subject 311 and 312.