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.

April 19, 1978

Mr. J. J. Kendallv Section Manager
Corporate Safety Department 108G
The Goodyear Tire & Rubber Company
Akron, Ohio 44316

Dear Mr. Kendall:

This is in response to your letter dated March 24, 1978, regarding the modification of a refrigerator or freezer chest to store flammable liquids.

The Occupational Safety and Health Administration has not adopted NFPA-45, and hence these standards, in this sense, are not applicable. The existing OSHA standards covering storage of flammable and/or combustible liquids in cabinets or inside storage rooms in industries where these liquids are used incidental to the principal business are covered by the OSHA standards 29 CFR 1910.106(d)(2), (d)(3), (d)(4), and (e) (copies enclosed). Note that only approved containers shall be used. See 29 CFR 1910.106(a)(35) (copy enclosed) for definition of approved.

Thus, a standard refrigerator with modification would not normally be permissible.

I hope this information will be helpful. Should you have any additional questions, please feel free to contact this office.


Janet H. Sprickman,
Acting Chief Division
of Occupational Safety Programming