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Rolling compressed gas cylinders on their lower edge

Summary A transportation company asked whether workers could move compressed gas cylinders by rolling them on their lower edge. OSHA said the incorporated Compressed Gas Association handling standard opposed that method and that OSHA followed the same position. OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-03-15-0
Date issued
March 15, 1990
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Compressed Gas
Source
View the official document

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The current status of this document is unclear
OSHA archives this letter and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 15, 1990

Mr. Ray Graham Navistar
International Transportation Co.
[Recipient address omitted]
Dear Mr. Graham:

This is in response to your letter addressed to me regarding the proper handling of compressed gas cylinders and particularly with reference to the moving of cylinders from place to place by means of rolling the cylinder on its lower edge.

Your general question may be answered by the publication C.G.A. P-1-1984, Safe Handling of Compressed Gases In Containers. (copy enclosed). An answer to your specific question will be found in subsection 3.4.1, on page 8 of the above mentioned publication.

Since Safe Handling of Compressed Gases (C.G.A. P-1 1984) has been adopted by reference into 29 CFR 1910.101 of OSHA's General Industry Standards, the position of the Compressed Gas Association against moving compressed gas cylinders by rolling them would also be OSHA's position on this subject.

I hope the above will be of help to you, but should you have any further questions, please do not hesitate to contact this office.

Enclosure

Sincerely,

Patricia K. Clark
Director Designate
Directorate of Compliance Programs

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