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Standard Interpretations - Table of Contents |
| • Standard Number: | 1926.351 |
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April 2, 1993
Mr. C. J. Beysselance Dear Mr. Beysselance: Your June 2 letter to Robert D. Holmes, Occupational Safety and Health Administration (OSHA) Area Director, requesting an interpretation of OSHA's standards addressing frame grounding of arc welding machines (1926.351(c)(5)(iv)) has been referred to the Office of Construction and Maritime Compliance Assistance for response. I apologize for the delay in responding to your inquiry. As you know, OSHA's construction requirements for frame grounding of arc welding machines at 29 CFR 1926.351(c)(5) do not specifically address engine-driven units. In the absence of a specific grounding requirement and because an engine-driven arc welding machine is basically a portable generator, OSHA would consider compliance with 1926.404(f)(3) as compliance with the welding requirements at 1926.351(c)(5). If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh at (202) 219-8136.
Sincerely,
MEMORANDUM FOR: PATRICIA K. CLARK
Director
Directorate of Compliance Programs
THROUGH: LEO CAREY
Director
Office of Field Programs
SUBJECT: Requests for Interpretation Re: 29 CFR 1910.254(c)(2)(i)
and 29 CFR 1926.351(c)(5)(iv)
The attached request for subject interpretations was received by our Baton
Rouge Area Office from Jacobs Engineering Group, Inc, Baton Rouge, Louisiana.
This inquiry is forwarded for your review and response since the interpretations could have national implication for consistency in enforcement activities.
Please provide a copy of your response to Jerry Bailey, Assistant Regional
Administrator for Technical Support.
Attachments
Mr. C. J. Beysselance Dear Mr. Beysselance: This refers to your letter of June 2, 1992, addressed to our Baton Rouge Area Office, concerning clarification of OSHA safety standards [29 CFR 1910.254(c)(2)(i) and 29 CFR 1926(c)(5)(iv)]. Your inquiry has been referred to the Directorate of Compliance Programs, Washington, D. C., for response at that level. Please accept our apology for the delay in responding to your request.
Sincerely,
U. S. DEPARTMENT OF LABOR
MEMORANDUM FOR: Gilbert J. Saulter
Regional Administrator
ATTENTION: Jerry D. Bailey
ARA/TS
SUBJECT: Request for Interpretation/Clarification of 29 CFR
1910.254(c)(2)(i) and 29 CFR 1926.351(c)(5)(iv)
Re: Jacobs Engineering Group, Inc. Baton Rouge, LA
A recent inquiry (copy attached) received from Jacobs Engineering Group,
Inc., a Louisiana firm engaged in both construction work and contract
maintenance work in chemical plants/refineries, requested a clarification of
when grounding of the frame or case of arc-welding machines is required.
1910.254(c)(2)(i) requires grounding of welding machine frames, but exempts
engine-driven machines. 1926.351(c)(5)(iv) requires the frames of all are
welding and cutting machines to be grounded, either through a third wire in
the power cable or through a separate wire grounded at the source of the
current, but this paragraph seems to apply to welding machines connected to
an electrical supply system and not engine-driven machines.
ANSI/ASC Z 49.1 - 1983, Article 11.4.3 "Machine Frame Grounding" stated "....special attention shall be given to safety grounding connections of portable machines per NFPA 70-Art. 250 "grounding". ANSI C33.2 - 1972, paragraph 14.2 "transformer type arc-welding machines" states "....An arc-welding machine which is not provided with a flexible cord or cable and is not designed for the connection of wiring system shall be provided with a suitable pressure wire connection for attachment of the grounding conductor". Article 630 (C) of the National Electric Code "Motor-Generator Arc-Welders" does not mention machine frame grounding. Since the OSHA standards are worded rather confusingly, we would appreciate your help in clarifying when "machine frame grounding" of arc-welding machines is required. Specifically, what types of portable welding machines require the machine to be grounded and are engine-driven machines exempt from this requirement?
We look forward to you rapid response to the technical questions so we may
provide competent guidance to our field personnel. If you have a questions
concerning this request, please contact W.A. Womack, Safety Supervisor, in
the Baton Rouge Area Office.
Attachments
Dear Mr. Holmes, I am writing to request your assistance in applying current OSHA safety standards to the use of portable welding machines. Specifically, is the frame of a portable engine driven welding machine required to be earth grounded? Standard 1910.254(c)(2)(i) requires grounding of welding machines but exempts engine-driven machines. Standard 1910.254(d)(3) requires grounding of welding machines frames to be checked and mandates special attention to the "ground connections of portable machines." Standard 1926.351(c)(5) discusses grounding of ARC welding machine frames but is worded rather confusing and I have gotten various interpretation from several electrical experts. Finally, I have a manufacturer's manual (attached) which states that their portable welding machines do not require the machine frame to be grounded. Your help in clarifying this rather confusing issue is greatly appreciated. If any further information would be helpful, please don't hesitate to call me at 768-5123.
Your friend in safety,
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Standard Interpretations - Table of Contents |