Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

September 2, 1977

Mr. Donald R. Wedan
Engineering Manager
Tescom Corporation
2600 Niagara Lane North
Minneapolis, Minnesota 55441

Dear Mr. Wedan:

This is in response to your letter of August 3, 1977, concerning replacement tips for torches used in welding operations.

The Occupational Safety and Health Act of 1970 contains no provisions allowing approval or endorsement of equipment. Alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the manufacturer. For this reason, the compliance of equipment or process with OSHA's standards can only be determined by the safety and health professionals observing it actually in use under specific conditions. Also for this reason, OSHA has no long range plans for establishing certification or approval of products.

The welding, cutting and brazing standards as written are interpreted to include tips as a part of the complete assembly of the torch and as such cannot be considered a separate item. We do not interpret 1910.252(a)(1)(iii) to exclude replacement tips when such tips are made to the same specifications as the original tip of the torch at the time of approval by the nationally recognized testing laboratory.

I have enclosed for your information a copy of OSHA Program Directive #100-23 concerning welding tips.

If I may be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational
Safety Programming