October 6, 1986

In response to your request the following clarification is provided as discussed with Benton Nicholas.

OSHA Instruction STD 1-5.14A, dated October 24, 1980, permits storage and use of flammable and combustible liquids in DOT specification polyethylene containers. However, since these containers are not equipped with a means for electrical grounding, provisions for the safe transfer of Class IA liquids requires clarification.

The transfer of Class IA liquids from polyethylene drums and containers may be safety accomplished and is deemed to comply with the intent of the standards at 29 CFR 1910.106(e)(6)(ii) and (h)(7)(i)(b) when:

1.    A polyethylene drum is equipped with an approved metallic suction pump and draw tube for taking liquid through the top of the drum and the pump is electrically grounded, or

2.    The drum or container is provided with a metallic self closing faucet which is electrically grounded.