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 http://www.osha.gov.

July 23, 1981

Bernard J. Wilkes, III
Wilkes & Wilkes Attorneys at Law
824 City Centre One
P.O. Box 6305
Youngstown, Ohio 44501

Dear Mr. Wilkes:

Mr. Hillenbrand has asked me to respond to your letter of June 29, 1981, regarding a bulk oxygen system at the Southwest Steel Company at Grafton, West Virginia.

A liquid oxygen storage system of 1200-1300 gallons is equivalent to a storage system of more than 130,000 cubic feet at normal temperature and pressure (NTP) and is therefore classified as a bulk oxygen system per 29 CFR 1910.104(b)(1). The requirements of that standard appear to be applicable to your situation.

Since OSHA conducted no inspection of the circumstances in question, we are unable to provide you with further assistance or guidance at this time.

If we may be of further assistance, please call or write.

Sincerely,



John K. Barto Chief,
Division of Occupational Safety Programming