U.S. Department of Transportation (DOT) Exemption Which Allow Shipment of Combustible and Flammable Liquids in Polyethylene

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OSHA Instruction STD 1-5.14A October 24, 1980 Office of Compliance Programming

SUBJECT: U.S. Department of Transportation (DOT) Exemptions Which Allow Shipment of Combustible and Flammable Liquids in Polyethylene Containers--Reference: 29 CFR 1910.106(d)(2)(i)

A. Purpose. This instruction permits the use of DOT specification, nonspecification polyethylene, and nonregulated containers for storing COMBUSTIBLE and/or FLAMMABLE liquids at inside storage areas under certain conditions.

B. Scope. This instruction applies OSHA-wide.

Interpretation of 1910.106(d)(2)(i), as it applies to the storage of combustible liquids in polyethylene containers.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

March 9, 1989

Michael Lafond, CIH
Betz Laboratories, Inc.
Somerton Road
Trevose, Pennsylvania 19047

Dear Mr. Lafond:

This is in response to your letter of February 1, 1989, requesting an interpretation of 29 CFR 1910.106(d)(2)(i), as it applies to the storage of combustible liquids in plastic, e.g., polyethylene, containers.

Acceptability of storing Class II combustible liquids in DOT/NRTL approved polyethylene containers.

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.

August 2, 2001

Mr. Seymour G. Epstein
Technical Consultant
900 19th Street, N.W.
Washington, D.C. 20006

Dear Mr. Epstein: