EHS Topic of the Month: Storing Compressed Gas Cylinders

Editor's Note: The following is language taken from the OSHA Letter of Interpretation dated May 23, 2008 regarding questions concerning standards applicable to the storage and use of compressed gas cylinders. 

OSHA's requirements for the storage of compressed gas cylinders can be found in OSHA standard 29 CFR §1910.101(b). The standard states that “the in-plant handling, storage, and utilization of all compressed gases in cylinders...shall be in accordance with Compressed Gas Association (CGA) Pamphlet P-1-1965.” We note that there are more recent version of the industry consensus standards that are referenced in §1910.101. If the more recent consensus standards address hazards associated with compressed gases that are not addressed in the CGA pamphlets referenced in the standard, §1910.101, §1910.1200, or any other applicable OSHA standard, the more recent consensus standards may provide support for a citation.

The cited pamphlet states:
3.3.1 Cylinders should be stored in accordance with all local, state and municipal regulations and in accordance with appropriate standards of the Compressed Gas Association and the National Fire Protection Association.
3.3.2 Cylinder storage areas should be prominently posted (sic) with the names of the gases to be stored.
3.3.3 Where gases of different types are stored at the same location, cylinders should be grouped by types
of gas, and the groups arranged to take into account the gases contained, e.g. flammable gases should not
be stored near oxidizing gases.
3.3.4 Charged and empty cylinders should be stored separately with the storage layout so planned that cylinders comprising old stock can be removed first with a minimum handling of other cylinders.

Additional language from OSHA regarding letters of interpretation: 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.