Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

March 15, 1990

Mr. Ray Graham Navistar
International Transportation Co.
5565 Brookville
Road Indianapolis, Indiana 46219

Dear Mr. Graham:

This is in response to your letter addressed to me regarding the proper handling of compressed gas cylinders and particularly with reference to the moving of cylinders from place to place by means of rolling the cylinder on its lower edge.

Your general question may be answered by the publication C.G.A. P-1-1984, Safe Handling of Compressed Gases In Containers. (copy enclosed). An answer to your specific question will be found in subsection 3.4.1, on page 8 of the above mentioned publication.

Since Safe Handling of Compressed Gases (C.G.A. P-1 1984) has been adopted by reference into 29 CFR 1910.101 of OSHA's General Industry Standards, the position of the Compressed Gas Association against moving compressed gas cylinders by rolling them would also be OSHA's position on this subject.

I hope the above will be of help to you, but should you have any further questions, please do not hesitate to contact this office.



Patricia K. Clark
Director Designate
Directorate of Compliance Programs