Interpretation on requirements for opening drums in a safe manner.

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.

February 1, 1987

Mr. Owen B. Douglas, Jr., C.I.H.
Manager, Health and Safety
SPER Division
Weston Sper
Weston Way
West Chester, PA 19380

Dear Mr. Owen:

This is in response to your letter of January 20 regarding the Occupational Safety and Health Administration's (OSHA) Interim Final Rule for Hazardous Waste Operations and Emergency Response. You requested an interpretation of section (j) of 29 CFR 1910.120 which addresses "Handling drums and containers."

Application of OSHA's final standard for Hazardous Waste Operations and Emergency Response.

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.

July 28, 1989

Richard F. Boggs, Ph.D
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place N.W.
Washington, D.C. 20036

Dear Dr. Boggs:

This is in response to your inquiry requesting interpretations of OSHA's final standard for Hazardous Waste Operations and Emergency Response (29 CFR 1910.120).

For the sake of clarity, I will enumerate and respond to your questions in the order you raised them: