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 https://www.osha.gov.

January 19, 1977

Mr. John W. Thiele,
Manager Occupational Safety and Health
Bristol Myers Company
P. O. Box 182
Easy Syracuse, New York 13057

Dear Mr. Thiele:

This is in reply to your letter of November 23, 1976, concerning the storage of flammable and combustible liquids. This letter will also confirm a recent telephone conversation with a member of this staff.

29 CFR 1910.106(d)(5)(v) "...material creating no fire exposure hazard to flammable and combustible liquids may be stored in the same area". This is interpreted to mean it may be stored in the same room and not on top of the flammable liquids. However, if your storage areas have little or no employee exposure other than the placing or withdrawal of stock with sufficient aisles and fire exits, it may be permissible to stack non-flammable products on storage racks above the allowable stacking height for flammables. The reason for racking is to preclude the possibility of rupturing the bottom containers of flammable liquids with a superimposed load.

Hopefully, this will help you in the storage of your products and materials.

Sincerely,

John K. Barto,
Chief Division of
Occupational Safety Programming