September 5, 1990
MEMORANDUM FOR: JAMES W. LAKE
FROM: PATRICIA K. CLARK DIRECTOR
DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Interpretation of Standards
This is in response to your June 19, 1990, memorandum in which you requested
an interpretation of 29 CFR 1910.252(a)(2)(iii), particularly with respect to
the 20 ft. separation requirement when oxygen and acetylene bottles are in
The answer to your question depends on whether or not the conditions
described in your memorandum constitute "storage" of these bottles within the
meaning of this particular standard.
The generally accepted meaning of the word "storage" contemplates removal of
an object from regular use for an appreciable period of time. Placing an
object aside for a short period of time with the intent of using it again,
would in our opinion not constitute storage of the object. Therefore, the 20
ft. separation requirement would not apply.