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Storage of corrugated and plastic packaging in a stamping plant

Summary OSHA found no federal standard limiting quantities of corrugated or returnable plastic packaging for fire protection in the described plant. It identified 29 CFR 1910.176(b) for secure storage, Subpart L for fire protection, and 1910.38 for emergency and fire prevention plans; Michigan state-plan rules may differ.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-09-09-0
Date issued
September 9, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 9, 1996

Mr. David Crockett
Packaging Engineer
Wolverine Metal Specialties
[Recipient address omitted]
Dear Mr. Crockett:

Thank you for your letter of August 21, to John Miles, Director of the Directorate of Compliance Programs, requesting confirmation that the Occupational Safety and Health Administration (OSHA) does not have standards on quantities of corrugated storage and plastic returnable packaging storage in a metal stamping plant.

OSHA does not have standards that apply to corrugated storage and plastic returnable packaging storage for fire protection purposes. However, General Industry Standard 29 CFR 1910.176(b) governs the secure storage of all materials.

In addition, 29 CFR 1910 Subpart L governs employees' fire protection systems and 29 CFR 1910.38 governs employee and fire prevention plans. Copies of these standards are enclosed.

As you may be aware, the State of Michigan administers its own occupational safety and health program under the State Plan provisions of the Occupational Safety and Health Act of 1970. As part of that program, the State is responsible for the enforcement of occupational safety standards in Michigan, subject to monitoring by Federal OSHA. The State does not have to have standards identical to Federal Standards. State standards, however, must be "at least as effective" as the Federal Standards. If you are doing business in Michigan, you should contact the following Michigan State designees:

Kathleen M. Wilbur, Director Michigan Department of Consumer and Industry Services 4th Floor, Law Building P.O. Box 30004 Lansing, Michigan 48909 Phone: (517) 373-7230 Fax: (517) 373-7230

Douglas R. Earle, Program Director Michigan Department of Consumer and Industry Services 4th Floor, Law Building P.O. Box 30004 Lansing, Michigan 48909 Phone: (517) 322-1814 Fax: (517) 322-1775

We appreciate your interest in Occupational Safety and Health. If you have further questions on this response please contact Mr. Arthur Buchanan in the Office of Safety Compliance Assistance at (202)219-8031.

Sincerely,

Raymond E. Donnelly, Director Office of Safety Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]

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