- Standard Number:
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 9, 1996
Mr. David Crockett Packaging Engineer Wolverine Metal Specialties 1013 Thorrez Road, P.O. Box 744 Jackson, MI 49204-0744
Dear Mr. Crockett:
Thank you for your letter of August 21, to John Miles, Director of the Directorate of Compliance Programs, requesting confirmation that the Occupational Safety and Health Administration (OSHA) does not have standards on quantities of corrugated storage and plastic returnable packaging storage in a metal stamping plant.
OSHA does not have standards that apply to corrugated storage and plastic returnable packaging storage for fire protection purposes. However, General Industry Standard 29 CFR 1910.176(b) governs the secure storage of all materials.
In addition, 29 CFR 1910 Subpart L governs employees' fire protection systems and 29 CFR 1910.38 governs employee and fire prevention plans. Copies of these standards are enclosed.
As you may be aware, the State of Michigan administers its own occupational safety and health program under the State Plan provisions of the Occupational Safety and Health Act of 1970. As part of that program, the State is responsible for the enforcement of occupational safety standards in Michigan, subject to monitoring by Federal OSHA. The State does not have to have standards identical to Federal Standards. State standards, however, must be "at least as effective" as the Federal Standards. If you are doing business in Michigan, you should contact the following Michigan State designees:
Kathleen M. Wilbur, Director Michigan Department of Consumer and Industry Services 4th Floor, Law Building P.O. Box 30004 Lansing, Michigan 48909 Phone: (517) 373-7230 Fax: (517) 373-7230
Douglas R. Earle, Program Director Michigan Department of Consumer and Industry Services 4th Floor, Law Building P.O. Box 30004 Lansing, Michigan 48909 Phone: (517) 322-1814 Fax: (517) 322-1775
We appreciate your interest in Occupational Safety and Health. If you have further questions on this response please contact Mr. Arthur Buchanan in the Office of Safety Compliance Assistance at (202)219-8031.
Raymond E. Donnelly, Director Office of Safety Compliance Assistance
August 21, 1996
Mr. John Miles Director of Office of Compliance OSHA U.S. Department of Labor Washington D.C., 20210
Dear Mr. Jones,
I am writing you to obtain confirmation that OSHA does not have standards on quantities of corrugated storage in a metal stamping plant. I also would like to have confirmation on plastic returnable packaging storage in the plant. This storage is to pertain to any fire codes that OSHA regulations might have.
I called Don Barkway at the safety regulations department and I was told to write you for confirmation notice. I need this as proof to show the management of Textron Automotive Company.
Thank you for your time and consideration in this matter.
Very truly yours,
David Crockett Packaging Engineer