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.


November 11, 1976

Mr. Jack A. Hager
Gas Inspector
City of Rice Lake
Rice Lake, Wisconsin 54868

In re: Your letter dated November 1, 1976 1910.110 liquified Petroleum Gases

Dear Mr. Hager:

Your letter posed the following question:

Does foot note 1 in Table H-23 pertain only to containers of less than 125 gallons, or does it pertain to all sizes of containers listed in Table H-23?

Our Answer:

The foot note applies to multi-container installations of any size of container.

You also asked:

Does this entire code pertain to installations that were in existence prior to the adoption of this code or just the new installations?

Our Answer:

The standard applies to all installations subject to OSHA jurisdiction and as detailed in 1910.110(i). We suggest that you again review this part of the standard and particularly note the final two paragraphs dealing with retroactivity. Existing installations which were in compliance with the current provisions of NFPA Pamphlet No. 58 at the time of installation may be continued in use if such continued use does not constitute a recognized hazard that is causing or is likely to cause death or serious physical harm to employees.

Please contact us if we can be of further service. You may call us toll-free at 800-621-0523.

Very truly yours,

Regional Administrator for
Occupational Safety and Health Administration

cc: National Office