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.

September 5, 1990

MEMORANDUM FOR:     JAMES W. LAKE
                   REGIONAL ADMINISTRATOR

FROM:               PATRICIA K. CLARK DIRECTOR
                   DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:            Interpretation of Standards

This is in response to your June 19, 1990, memorandum in which you requested an interpretation of 29 CFR 1910.252(a)(2)(iii), particularly with respect to the 20 ft. separation requirement when oxygen and acetylene bottles are in storage.

The answer to your question depends on whether or not the conditions described in your memorandum constitute "storage" of these bottles within the meaning of this particular standard.

The generally accepted meaning of the word "storage" contemplates removal of an object from regular use for an appreciable period of time. Placing an object aside for a short period of time with the intent of using it again, would in our opinion not constitute storage of the object. Therefore, the 20 ft. separation requirement would not apply.