May 21, 2012

Bill Howell
FAX:  610-744-2855

Dear Mr. Howell:

Thank you for your January 10, 2011 fax to OSHA's Directorate of Construction.  We apologize for the delay in our reply.  Your fax raises a specific question regarding OSHA's standard for storing compressed gas cylinders used in construction work.

Question: Does 29 CFR § 1926.350(a)(9) permit compressed gas cylinders to be stored horizontally in commercial cylinder holders designed for horizontal storage?

Response:  No.  Section 1926.350(a)(9) provides:

Compressed gas cylinders shall be secured in an upright position at all times except, if necessary, for short periods of time while cylinders are actually being hoisted or carried.

Section 1926.350(a)(9) clearly provides that compressed gas cylinders must be stored in an upright position when they are not being hoisted or carried.  Therefore, storing cylinders horizontally is not permissible under the standard.

Thank you for your interest in occupational safety and health.  We hope you find this information helpful.  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.  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.  If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,



James G. Maddux, Director
Directorate of Construction