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• Standard Number: 1910.134(i)(1)(i); 1910.252(b)(2)(ii)
July 14, 1981

Frank J. Niemi, President
Frank Niemi Products, Inc.
3933 W. Ellis Avenue
Gurnee, Illinois 60031

Dear Mr. Niemi:

This is in response to your letter of June 3, 1981, addressed to Mr. John Martonik of my staff, regarding your Cool-View welding helmet.

You relate that one of the helmet's features is that cool, filtered air is blown into it. This feature has ironically led to a reluctance on the part of potential customers to purchase the hood, because they are concerned by the fact that the helmet is not approved as a respiratory by the National Institute for Occupational Safety and Health. You state that your helmet is not a respirator, however, and that you do not try to sell it to replace respirators; neither, you said, do you sell your helmet as a replacement for any system for removing smoke and fumes from the welding area.

You request a clarification as to whether it is permissible to use your Cool-View welding helmet wherever it is acceptable to use a standard welding helmet. There is one requirement that your Cool-View welding helmet must meet, which is not applicable to standard welding helmets. The air blown into it must meet at least the requirements of the specification for Grade D breathing air, as described in Compressed Gas Association Commodity Specification G-7.1-1966. This requirement appears under [29 CFR 1910.134(i)(1)(i-ii)] (copy enclosed) of the standard for respiratory protection.

There are also some requirements that standard welding helmets must meet which your Cool-View welding helmet must also meet. These requirements appear under [29 CFR 1910.252(b)(2)(ii)] (copy enclosed) of the standard for welding, cutting, and brazing.

If the Cool-View welding helmet meets the requirements that I have mentioned, then it is acceptable to use it under any condition where it is acceptable to use a standard welding helmet. That is, the limitations for the Cool-View welding helmet are the same as the limitations for a standard welding helmet. Whenever conditions are such that a respirator would have to be worn underneath a standard welding helmet, then a respirator must be worn underneath a Cool-View welding helmet. By the same token, whenever conditions are such that a respirator would not have to be worn underneath a standard welding helmet, then a respirator does not have to be worn underneath a Cool-View welding helmet. Respirators must be used when an air contaminant concentration just outside the welding helmet exceeds the permissible exposure limit.

I appreciate the opportunity to comment on your concerns. If we can serve you again, we shall be glad to do so.

Sincerely,

Bruce Hillenbrand
Acting Director

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