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.
April 24, 1980
Mr. Robert Lewis
Sales Representative
Sealed Air Corporation
Old Sherman Turnpike
Danbury, Connecticut 06810
Dear Mr. Lewis;
This is response to your inquiry concerning the pressurization of 55 gallon drums for use with urethane foam dispensing equipment.
The Occupational Safety and Health Administration's General Industry Safety and Health Standards do not specifically address the pressurization of 55 gallon drums. However, because pressurized 55 gallon drums can be dangerous to exposed employees, the general duty clause, (section 5 (a)(1)) of the Occupational Safety and Health Act (copy enclosed) can be used to protect employees from injuries from a ruptured drum. It is, therefore, recommended that you contact the manufacturer of the drum to determine whether or not the drum will withstand the prescribed working pressure.
Current and valid certification by an insurance company or regulatory authority could be deemed as acceptable evidence of safe installation, inspection and testing of pressurized drums provided by the employer.
If I may be of further assistance, please feel free to call or write.
Sincerely,
Grover C. Wrenn, Director
[Directorate of Cooperative and State Programs]
[Corrected 10/22/2004]