U.S. Department of Labor | ||||||
Occupational Safety & Health Administration |
Standard Interpretations
07/08/1999 - Storage of gas cylinders on construction sites; clarification of "in storage." |
Standard Interpretations - Table of Contents |
Standard Number: | 1926.350(a)(10) |
July 8, 1999
Steven D. High Re: 1926.350; ANSI 01.1-1967 Dear Mr. High, In your letter dated January 11, 1999, you ask the Occupational Safety and Health Administration (OSHA) to determine when a compressed gas cylinder has to be stored in accordance with 29 CFR 1926.350. You also ask us to comment on how the storage requirements would apply to four specific situations. Section 1926.350(a)(10) requires that oxygen cylinders that are in storage be separated from fuel- gas cylinders and combustible materials. It specifies that the cylinders either be separated by a minimum of 20 feet or have a non-combustible fire wall (with a fire resistance rating of one half hour) at least five feet high. However, the standard does not specify when cylinders are considered to be in storage.
When a gas cylinder is considered to be "in storage" Question (1): A construction company removes the regulators, torch, and gauges from the compressed gas cylinders at the end of today. Valve protection caps are installed and the oxygen and fuel-gas cylinders are left secured and upright on a portable cart. The cart is stored away from sources of ignition and the cylinders will not be used until tomorrow morning, when they will be used again (welding work is planned for the morning and these tanks will be the ones used for that work). Does this violate the storage requirements of §1926.350? The storage requirements of §1926.350 do not apply to this scenario since it is reasonably anticipated that gas will be used within a twenty four hour period from the time today's work is completed (welding work will resume within 24 hours). Question (2): Welding work ends for the day and the regulators, torch, and gauges remain on a burning rig. At what point must you separate and store the oxygen and fuel gas cylinders? As stated above, once the welding ends, the cylinder is considered to be in storage when it is reasonably anticipated that gas will not be drawn from it within the next 24 hours. At that point the employer must meet the storage requirements of §1926.350. However, if it is reasonably anticipated that the cylinders will be used within the next twenty four hours, the storage requirements need not be met. 3. The cylinders are brought to the work site and the valve protection caps are on. The intent is to use them but not immediately. How long can they stay there without having to be stored? The only cylinders not in storage are those anticipated to be used within the next 24 hours. The number of cylinders anticipated to be used in that period will depend on the amount of gas the work is anticipated to require. Any cylinders in excess of that are considered to be in storage, and the storage requirements must be met for them. 4. Would the answers to any of the above questions change in a General Industry setting? This question has been forwarded to the Directorate of Compliance Programs for further comments with respect to general industry.
Please let us know if you need any further clarification on this standard and feel free to contact us
again by writing to: Directorate of Construction- Office of Construction Standards and Compliance
Assistance, Sincerely,
Russell B. Swanson |
Standard Interpretations - Table of Contents |
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