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.

April 19, 1999

Catherine Sigmon, Ph.D.
Radian International
Oak Ridge Technical Center Two
1093 Commerce Park Drive
Suite 100
Oak Ridge, Tennessee 37830

Dear Dr. Sigmon:

This letter is in response to your November 19, 1998 request for clarification on the storage of small propane and ether gas cylinders with flammable materials. We apologize for the delay in our response.

In your letter, you stated that "small propane gas cylinders (approximately 3-in. in diameter by 10-in. high) and small gas cylinders of ether ... are sometimes stored with flammable materials inside flammable materials storage cabinets." You indicated that your understanding was that this type of storage was not allowed, based on the Occupational Safety and Health Administration's (OSHA's) standard, 29 CFR 1910.101(b) incorporating the Compressed Gas Association (CGA) Pamphlet P-1.

Regarding the storage of cylinders, the CGA pamphlet states, "do not store cylinders near highly flammable substances such as oil, gasoline, or waste." Similarly, regarding the storage of flammable gases, the pamphlet states "do not store cylinders near highly flammable solvents, combustible waste material and similar substances." Therefore, since the CGA pamphlet is incorporated by reference into OSHA's standard, your interpretation regarding the storage of propane and ether gas cylinders with other flammables is correct. That is, storing these cylinders with other flammables inside flammable materials' storage cabinets would not be in compliance with OSHA's regulations.

Thank you for the opportunity to provide you with this clarification. If you need further assistance, please do not hesitate to contact Alcmene Haloftis in the Office of General Industry Compliance Assistance at 202-693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs