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.

 

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 http://www.osha.gov.

 


June 29, 1988

Mr. Nicholas Delagi
4336 Grace Court
Rohnert Park, California 94928-1526


Dear Mr. Delagi:

This is in response to your letter of May 4, 1988, concerning safe distance as it applies to fire protection regarding battery charging areas outlined in 29 CFR 1910.178(g)(10) and (g)(11).

29 CFR 1910.178(a) addresses some of the concerns expressed in your letter. 29 CFR 1910.178(a)(1) specifies that: "This section contains safety requirements relating to fire protection, design, maintenance ---;" and 29 CFR 1910.178(a)(2) specifies: "All new powered industrial trucks acquired and used by an employer after the effective date specified in paragraph (b) of 1910.182 shall meet the design and construction requirements for powered industrial trucks established in the American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969, except for vehicles intended primarily for earth moving or over-the-road hauling. Paragraph (b) of 1910.182 specifies that 29 CFR 1910.178(a)(2) became effective on February 15, 1972.

[29 CFR 1910.178(g)(1)] and ANSI B56.1-1969 (portions attached) specify that battery charging installations be located and designated for that purpose. Facilities shall be provided to include fire protection and adequate ventilation based on the amount of batteries to be charged and/or stored. The safe distance thus would be outside of this special designated area.

Precautions to prevent open flames, sparks or electrical area in the battery charging area are based on the concern for the amounts of hydrogen and oxygen which are given off from the batteries while being charged. Dispersal and dilution of these gases is a critical consideration as is also the potential accumulation of hydrogen in unventilated floor to ceiling areas of the designated facility.

OSHA standard 29 CFR 1910.151(b) does not specify whether first aid supplies can be locked up or not. The standard does require the supplies to be "readily available". Positive control measures may be taken providing the supplies are at hand, ready for use, and can be obtained easily and quickly. Normally the employer will establish procedures for the use of the first aid supplies after consultation with the consulting physician.

If we may be of further assistance, please contact [the Office of General Industry Enforcement at 202 693-1850].

Sincerely,



Thomas J. Shepich, Director
[Directorate of Enforcement Programs]


[Corrected 11/5/02]