1926 - Safety and Health Regulations for Construction
December 4, 1995
Mr. Aldo M. Gonzalez
Dear Mr. Gonzalez:
This is in response to your letter of October 25 to the Occupational Safety and Health Administration (OSHA) in which you request an interpretation of 29 CFR 1926.352(c). Specifically, you asked what the standard means by the phrase "presence of other flammable compounds."
As you point out in your letter, although the subject standard does not specify a minimum separation distance between flammable compounds and sources of ignition, other OSHA standards related to fire protection require a minimum separation distance of 20 to 25 feet. We have reviewed those standards and believe that the appropriate minimum separation distance for application of Section 1926.352(c) is also 20 feet (measured horizontally). However, this distance may be insufficient if the source of ignition is at a lower elevation than a heavier-than-air flammable compound and vapors can flow to the ignition source.
If you require further assistance, please do not hesitate to contact either myself or Mr. Dale Cavanaugh of my staff at (202) 219-8136.
Roy F. Gurnham, P.E., J.D.