Powered by GoogleTranslate
Standard Interpretations - Table of Contents
• Standard Number: 1910.120

MAR 30 1990

Jay P. Koch United Science Industries, Inc. President Post Office 21 Carlyle, Illinois 62231

Dear Mr. Koch:

This is in response to your letter of March 12 requesting an interpretation of the application of 29 CFR 1910.120 to the removal of underground storage tanks.

Petroleum products are included in the definition of hazardous substance under 29 CFR 1910.120. Thus, this standard could apply to contractors removing underground storage tanks that contain or have contained petroleum products. Section (b) through (o) of the standard apply to closures and corrective actions involving the removal of underground storage tanks and (q) would apply to any other type of removal activity where there is a potential for an emergency involving hazardous substances.

I hope this information is helpful.

Sincerely,

Patricia K. Clark Director Designate Directorate of Compliance Programs

U.S. Department of Labor Occupational Safety and Health Administration

Washington, D.C. 20210

Reply to the Attention of:

Jay P. Koch United Science Industries, Inc. President P.O. Box 21 Carlyle, Illinois 62231

Dear Mr. Koch:

I am responding to your letter of March 12, 1990 requesting an OSHA interpretation of the training requirements in 29 CFR 1910.120 paragraph (e) for removal of underground petroleum storage tanks.

OSHA policy requires written interpretations to be issued through our Office of Compliance Programs. I have therefore forwarded your request to that office for reply. You should hear from them soon.

If you should not hear from them in a reasonable amount of time, please contact me and I will follow up on your request.

Sincerely,

Michael B. Moore Safety Engineer

March 12, 1990

U.S. Department of Labor O.S.H.A. Frances Perkins Building 200 Constitution Avenue Northwest Room N-34-63 Directorate of Compliance Programs Washington. D.C. 20210

Dear Sir or Madam:

In January of 1990 I spoke with a representative of Federal OSHA about the applicability of the regulations found in 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response) to contractors removing underground storage tanks that contain, or have contained petroleum products. At that time, the representative of OSHA that I spoke with informed me that the standard applied to contractors removing underground storage tanks that contain or have contained petroleum products since under the final rule for 29 CFR 1910.120 OSHA included petroleum products in their definition of hazardous substances.

Since my conversations with the OSHA representative, I have heard rumors to the effect that the regulations found in 29 CFR 1910.120 do not apply to contractors removing underground storage tanks that contain or have contained petroleum products.

I ask that you clarify this situation for me. Please send me a letter describing OSHA's position on this matter. Thank you.

Sincerely,

Jay P. Koch President

bp


Standard Interpretations - Table of Contents

Thank You for Visiting Our Website

You are exiting the Department of Labor's Web server.

The Department of Labor does not endorse, takes no responsibility for, and exercises no control over the linked organization or its views, or contents, nor does it vouch for the accuracy or accessibility of the information contained on the destination server. The Department of Labor also cannot authorize the use of copyrighted materials contained in linked Web sites. Users must request such authorization from the sponsor of the linked Web site. Thank you for visiting our site. Please click the button below to continue.

Close