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• Standard Number: 1910.252

September 5, 1990 

MEMORANDUM FOR:     JAMES W. LAKE
                   REGIONAL ADMINISTRATOR

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 storage.

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.

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