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.

October 29, 1986

Mr. Lucas A. Seeman
Senior Vice President
Ozalid Corporation
P.O. Box 2000
Binghamton, New York 13902-2000

Dear Mr. Seeman:

This is in response to your letter of September 16, concerning your desire for a directive which would clarify the Occupational Safety and Health Administration (OSHA) requirements relative to the use of anhydrous ammonia in Diazo Reproduction machines. An OSHA directive is unnecessary, since this letter clarifies the situation and provides an official interpretation relative to the matter.

Portable D.O.T. containers (cylinder) of anhydrous ammonia which are in-use and/or manifolded to an approved and listed blueprint reproduction machine, such as the Diazo Reproduction machine manufactured by OZALID, are not regulated under the storage requirements specified at 29 CFR 1910.111(b). Therefore, there is no OSHA requirement that employers provide gas masks, water, or showers in the vicinity of such reproduction machines. However, properly manifolded D.O.T. cylinders connected to in-use reproduction machines shall comply with the requirements of 29 CFR 1910.111(e).

It is acknowledged that due to the repugnant odor of ammonia, reproduction machines which develop slight leaks would cause operators and clerical staff to shut down such defective equipment and leave the area before levels of 10 PPM were attained. Since the standards at 29 CFR 1910.1000, table Z-1, require exposure levels to be less than 50 PPM T.W.A., it is unlikely that employee exposure in excess of the OSHA standard would result from the use of an approved and listed blueprint reproduction machine.

If we may be of further assistance, please contact us.


John B. Miles, Jr.,
Directorate of Field Operations