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 https://www.osha.gov.

January 24, 1980

Mr. D. T. Steadman
Senior Section Engineer
Project and Development Section
British Standards Institute
Maylands Avenue
Hemel Hempstead
Herts HP2 4SQ

Dear Mr. Steadman:

This is in response to your inquiry concerning OSHA's technical requirements for off highway vehicles being exported from the UK to the USA. Your letter addressed to Mr. Dave Hadden was forwarded to this office for response.

29 CFR 1910.169 is not intended to apply to compressed air machinery and equipment used on transportation vehicles such as steam railroad cars, electric railway cars, and automotive equipment. It applies to compressed air receivers, and other equipment used in providing and utilizing compressed air for performing operations such as cleaning, drilling, hoisting, and chipping.

In addition to the above boilers and piping systems which are a part of or used with pile driving equipment, shall meet the applicable requirements in 29 CFR 1926.603. Also, the American Society of Mechanical Engineers Pressure Vessel Code and the Department of Transportation, Bureau of Motor Carrier Safety regulations may be used to support alleged violations of Section 5(a)(1) of the Act (copy enclosed).

The sections you identified from the Code of the Federal Register as being relevant to OSHA's technical requirements for equipment manufacturers are accurate with the exception of 29 CFR 1910.169.

If we may be of any further assistance, please feel free to call or write.


Grover C. Wrenn Director,
Federal Compliance and State Programs