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Standard Number: 1910.119
June 4, 1992
Mr. Joseph G. Gerard
Vice President of Government Affairs
American Furniture Manufacturers Association
Suite 402
918 16th Street, N.W.
Washington, D.C. 20006
Dear Mr. Gerard:
Thank you for your letter of May 22, addressed to Ms. Dorothy L. Strunk, Acting Assistant Secretary of the Occupational Safety and Health Administration (OSHA), concerning the OSHA standard for Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119). Your letter has been referred to the Directorate of Safety Standards Programs for response.
You requested a clarification of the application of the standard with respect to the storage of flammable liquids. The standard applies to a process (including storage) which involves a flammable liquid in quantities of 10,000 pounds or more. As you correctly noted, however, there is an exception. The standard does not apply to flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration (1910.119(a)(1)(ii)(B)).
Containers such as 55-gallon drums are considered to be atmospheric tanks. Therefore, storage of flammable liquids in such containers, even if the quantity exceeds 10,000 pounds, would not be covered by the standard. However, such storage would have to meet the requirements contained in the OSHA standard for flammable and combustible liquids (1910.106).
I hope this information will be of assistance to you.
Sincerely,
Roger A.Clark Director,
Directorate of Safety Standards Program
[Corrected 6/21/2007]