OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 25, 1975

John Pirong
Clement and Co., Inc.
2020 Lemoyne Street
Syracuse, New York 13211

Dear Mr. Pirong:

This is in response to your letter requesting clarification of the OSHA Standard 1910.106(b)(5)(ii), page 23614 of Federal Register dated June 27, 1974.

A saddle has been described as a support device curved to fit the tank contour which may or may not be attached to legs. The measurement of the saddle to its lowest point would come in the middle of the curve. If it exceeds twelve inches to the ground or surface, the Standard requires that it be protected with a coating of fire resistive materials. Such coating is not required if the distance is less than twelve inches.

Please feel free to contract us if there are further questions about OSHA.


Alfred Barden
Assistant Regional Director
Occupational Safety and Health