Liquefied petroleum gas in underground construction

May 20, 1992

MEMORANDUM FOR: GABRIEL J. GILLOTTI
ASSISTANT REGIONAL ADMINISTRATOR
OFFICE OF TECHNICAL SUPPORT

FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Use of LPG Underground

Your January 30 memorandum to Roger A. Clark requesting an interpretation of underground construction regulations addressing the use of liquified petroleum gas (LPG) has been referred to the Office of Construction and Maritime Compliance Assistance for response. I apologize for the delay in responding to you.

Paragraph 1926.800(m)(5)(ii) specifically allows the use of LPG underground only for purposes of welding, cutting or other hot work. This practice was proposed in the August 8, 1983, NPRM (48 FR 35774) and was discussed in the preamble to the final rule published on June 2, 1989 (54 FR 23824). In the final rulemaking, OSHA received comments similar to the professional tunnel engineer's comment mentioned in your memorandum and found "....the evidence insufficient to warrant changing the proposal. OSHA believes that the risks that may be associated with the use of fuel gases will continue to be effectively controlled by compliance with the paragraphs referred to in the rule; namely, 29 CFR Part 1926, Subpart J and paragraphs (j), (k), (m) and (n) of this section."