To answer the question of whether pipe labeling is required by law, the simplest reply is yes, they are required. The way they are required, however, is a little different than most other workplace safety regulations, and it is important to understand this in order to remain in compliance.
As with most safety regulations like this, it is OSHA that is making them requirements. Unlike most safety regulations, OSHA didn’t actually write or modify the requirements that they say must be followed. Instead, OSHA simply referenced the ANSI/AMSE A13.1 standards and said that companies need to follow them in order to remain in compliance.
Most OSHA regulations only apply to companies that are of a certain size, or have a certain number of employees. This is true of the pipe labeling requirements as well. Given the fact that installing pipe markings is a very easy and affordable process, however, it just makes sense for all facilities to make the effort to follow the established guidelines. Small companies that follow these standards will also benefit because if they grow to the point where it is required by OSHA, they wouldn’t have to make any changes or be at risk of a citation.
If you are looking at starting, or improving, your pipe labeling system in the workplace, it may be tempting to look directly at the ANSI/AMSE A13.1 standards to see what to do. While this would make sense initially, you need to know what ANSI/AMSE has actually updated their standards since OSHA last made their demands.
In 2007, ANSI/AMSE updated their pipe labeling recommendations in a variety of ways. So far, OSHA hasn’t updated their regulations to demand that companies are in compliance with these updated standards. This is likely because OSHA wants to give companies sufficient time to voluntarily update their labeling practices to reflect the new standards.
The new standards do meet (and exceed) the requirements listed by OSHA, so it just makes sense for all companies working on their pipe labeling to follow the new and improved standards. Virtually all experts believe that OSHA will, at some point, update their regulations to reflect the updated standards. Companies that have already moved to these standards will already be in compliance and won’t have to make any changes.