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HAZWOPER coverage for removal of petroleum storage tanks

Summary A contractor asked whether HAZWOPER applies to removal of underground tanks that contain or once contained petroleum products. OSHA said petroleum products count as hazardous substances under the rule, so tank removal may be covered. It distinguished tank closures and corrective actions, covered by paragraphs (b) through (o), from other removals with emergency potential, which may trigger paragraph (q).
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-03-30
Date issued
March 30, 1990
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazardous Waste Petroleum
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

MAR 30 1990

Jay P. Koch
President
United Science Industries, Inc.
[Recipient address omitted]

Dear Mr. Koch:

This is in response to your letter of March 12 requesting an interpretation of the application of 29 CFR 1910.120 to the removal of underground storage tanks.

Petroleum products are included in the definition of hazardous substance under 29 CFR 1910.120. Thus, this standard could apply to contractors removing underground storage tanks that contain or have contained petroleum products. Section (b) through (o) of the standard apply to closures and corrective actions involving the removal of underground storage tanks and (q) would apply to any other type of removal activity where there is a potential for an emergency involving hazardous substances.

I hope this information is helpful.

Sincerely,

Patricia K. Clark
Director Designate
Directorate of Compliance Programs

[Forwarding correspondence and requester letter reproduced on OSHA's page; omitted here.]

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