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Standard Interpretations
12/31/2002 - Use of double-walled tanks as the only form of protection from collision damage. |
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Standard Number: | 1926.152; 1926.152(e); 1926.152(e)(4) |
December 31, 2002 Patricia H. Falls Firstline Safety Management, Inc. P.O Box 3069 Winchester, VA 22604 Re: Whether use of double-walled tanks meets the requirement in §1926.152(e) that tanks be protected from collision damage Dear Ms. Falls, This is in response to your April 29, 2002, letter to the Occupational Safety and Health Administration (OSHA). You ask that we further clarify our April 26, 2002, response to you concerning the use of double-walled tanks; we apologize for the delay in responding. In our April 26 letter, we stated the question and answer as follows: Question: Section 1926.152(e)(4) provides that, with respect to dispensing flammable and combustible liquids, "The dispensing units shall be protected against collision damage." If a fuel tank has double walls, are barriers or other devices required to meet the requirements of this provision?Follow-up question In your April 29 follow-up letter, you ask us to more definitively state whether the use of a double-walled tank supplants a need for any additional measures, such as barricades, for preventing collision damage. Answer In general, the fact that a tank is double-walled would not, by itself, be sufficient to meet the requirements of §1926.152(e)(4), for the reasons stated in our previous letter. The extent of other measures required depends on factors such as the proximity of the tank to high volume or high-speed traffic, as previously discussed. Other factors such as whether vehicles back up to the tank (posing a higher collision risk) are also relevant. Typically, where collision risk is very low (such as a separate refueling area in which: traffic is limited to refueling vehicles, there is plenty of maneuvering room, there is low traffic volume and speed, and backing-up to the tank is not necessary), some form of visual warning that marks an approach boundary would be required, irrespective of whether the tank was double-walled. Where collision risk is higher, more substantial measures would be required. In sum, the fact that a tank is double-walled typically would be insufficient by itself to meet the requirement in §1926.152(e)(4) for protection against collision damage.1 Please let us know if you need any further clarification on this subject and feel free to contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, [Office of Construction Standards and Guidance], fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. Sincerely, Russell B. Swanson Director 1This interpretation applies only to states covered by Federal OSHA. States with an approved State OSHA program may have additional standards or standards that are more stringent then the Federal standards. If you are interested in how a comparable requirement is interpreted in the State of Virginia or other State program, please contact that State. [back to text] |
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