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.

January 26, 1977

Mr. George R. Lacina
Regional Field Engineer
Hilti Fastening Systems Inc.
1427 Centre Circle Drive
Downers Grove, Illinois 60515

Dear Mr. Lacina:

Your letter of August 17, 1976, has been referred to the National Office of the Occupational Safety and Health Administration (OSHA) for reply. Your letter requested guidance in relation to rules and regulations governing warehousing and transportation of powder-actuated tool cartridges. This letter will also confirm a recent telephone conversation between you and a staff member.

OSHA rules and regulations governing warehousing and transportation of powder-actuated tool cartridges are addressed in 29 CFR 1910.109. A review of the standard agrees in part with the data in your letter. Besides 1910.109(a)(3); Sections (13), (14) & (15) are relevant. Your attention is also called to 1910.109(b), under miscellaneous provision. While 1910.109(c)(1)(ix)(a) eliminates the type of magazines for the storage of propellant-actuated power cartridges, 1910.109(j), which addresses storage conditions for small arms ammunition, should be reviewed for compliance.

In addition to OSHA's rules and regulations it is recommended that you investigate the rules and regulations promulgated by both the Department of Transportation and the Treasury Department in order to assure yourself that you are in total compliance with all agencies having jurisdiction.

Thank you for your interest and concern in occupational safety and health.


Richard P. Wilson
Deputy Director,
Federal Compliance and State Programs