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.

March 29, 1983

Mr. C. Daryl Johnson
Division Manager
Safety and Loss Prevention
PPG Industries, Inc.
Rosanna Drive P.O. Box 9
Allison Park, Pennsylvania 15101

Dear Mr. Johnson:

Thank you for your letter of March 1, 1983, concerning the storage of paint thinner in plastic one-gallon containers in a retail store.

According to Table H-12 of 29 CFR 1910.106(d)(2), paint thinner with a flash point of 105 F, being a Class II combustible, would be permitted to be stored in approved plastic one-gallon containers. In any case, when being retailed, paint thinner would be considered a common consumer item, and according to the note below Table H-12, would be exempt when packaged in approved plastic containers.

Other possible items to be considered as common consumer items would have to be individually evaluated.

Should you have any further questions, please do not hesitate to contact me.


Bruce Hllenbrand
Acting Director, Federal Compliance
and State Programs