Standard Interpretations - Table of Contents
• Standard Number: 1910.106(f)(3)(i)

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

July 7, 2000

Mr. Rafael E. Romero, P.E.
Galloway, Romero & Associates
5350 DTC Parkway
Englewood, Colorado 80111-3006

Dear Mr. Romero,

Thank you for your letters dated December 7,1999, and February 14, 2000, to the Occupational Safety and Health Administration's (OSHA's) Regional Office in Denver, Colorado. Your letters have been referred to the Directorate of Compliance Programs.

You requested an interpretation of 29 CFR 1910.106, Flammable and Combustible Liquids, and a possible reduction in the minimum separation distance for above ground tanks, warehouses, and other plant buildings. You also requested approval to reduce the separation distance for Class I liquids from the 25 foot requirement to 12.5 feet based on your double-wall tank design. You stated in your letter that the local fire department gave you a permit for a reduction in distance from 25 feet to 20 feet.

Based on the information we received, at this time we cannot approve a reduction of the minimum safety distance described in 1910.106(f)(3)(i). We referenced the m