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 21, 1980

Ms. Geogi St. John
Assistant Manager
Safety and Regulatory Affairs
Oakite Products
50 Valley Road
Berkeley Heights, New Jersey 07922

Dear Ms. St. John:

This is in response to your recent letter to the Occupational Safety and Health Administration's New York Regional Office concerning storage of combustible liquids.

The Department of Transportation does not specifically regulate packaging of combustible liquids in quantities of 110 gallons or less. However, use of any metal container which meets DOT specifications for use with flammable liquids and which is no larger than 60 gallons satisfies 29 CFR 1910.106(d)(2) and Table H-12, with regard to the requirement for use of metal drums made to DOT specifications.

Thank you for your interest in occupational safety and health. If I may be of further assistance, please contact me.


Grover C. Wrenn
Director, Federal Compliance
and State Programs