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.


June 4, 1992

Mr. Joseph G. Gerard
Vice President of Government Affairs
American Furniture Manufacturers Association
Suite 402
918 16th Street, N.W.
Washington, D.C. 20006

Dear Mr. Gerard:

Thank you for your letter of May 22, addressed to Ms. Dorothy L. Strunk, Acting Assistant Secretary of the Occupational Safety and Health Administration (OSHA), concerning the OSHA standard for Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119). Your letter has been referred to the Directorate of Safety Standards Programs for response.

You requested a clarification of the application of the standard with respect to the storage of flammable liquids. The standard applies to a process (including storage) which involves a flammable liquid in quantities of 10,000 pounds or more. As you correctly noted, however, there is an exception. The standard does not apply to flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration (1910.119(a)(1)(ii)(B)).

Containers such as 55-gallon drums are considered to be atmospheric tanks. Therefore, storage of flammable liquids in such containers, even if the quantity exceeds 10,000 pounds, would not be covered by the standard. However, such storage would have to meet the requirements contained in the OSHA standard for flammable and combustible liquids (1910.106).

I hope this information will be of assistance to you.


Roger A.Clark Director,
Directorate of Safety Standards Program

[Corrected 6/21/2007]