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• Standard Number: 1910.110(b)(6)(ii)

April 10, 1991

MEMORANDUM FOR:     FRANK STRASHEIM
                   REGIONAL ADMINISTRATOR

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

SUBJECT:            Interpretation of 29 CFR 1910.110(b)(6)(ii)
This is in response to your memorandum of January 30, in which you requested an interpretation of 29 CFR 1910.110(b)(6)(ii) with respect to the separation of LPG containers from--and a definition of--"important buildings", and whether or not OSHA can use table H-23 of the above mentioned standard to cite distances between LPG containers.

First, "important building", as used by OSHA and NFPA, does not have a singular meaning. According to Ted Lemoss, NFPA's Gases Engineer and technical expert for LPG, value is the basic criteria for defining an important building. Value can range from the building's contents to its importance in firefighting. OSHA defines "important building" as any building where employees may be exposed to potential or actual hazards.

Second, the spacing of the containers with regard to each other should not be cited under our .110(b)(6)(ii) standard due to the ambiguity of Table H-23, but instead should be cited as a 5(a)(1) violation based on the clarified language of NFPA 59-25, 1986 Edition, Section 3-2.2.2. The language of our current OSHA standard, taken from NFPA 58, 1969, the most current standard at the time of OSHA's adoption, is not clear enough to use as a basis for citing under .110 of the standard. A copy of the 1986 Edition is attached for your information.

If additional information is needed, please let me know.


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