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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 http://www.osha.gov.
July 26, 1989
MEMORANDUM FOR: JAMES W. STANLEY Regional Administrator THRU: LEO CAREY, Director Office of Field Programs FROM: PATRICIA K. CLARK, Acting Director Directorate of Compliance Programs SUBJECT: Compressed Gas Cylinder Valve Proctor
This is in response to your memorandum requesting clarification of whether or not a collar type valve protector would fulfill the OSHA requirement for valve protection on compressed gas cylinders.
The collar type valve protector is used extensively in laboratory settings as well as in light industry where frequent valve changes are necessary and service direction varies. Also the cylinders are normally secured to a permanent wall, counter or fixture.
At this time, a "collar" type valve protector is not addressed in either the construction or maritime standards, but is mentioned in the general industry standards in Subpart Q - Welding, Cutting and Brazing, 1910.253(b)(1)(iv). Since this type of valve protector is not specifically prohibited, it should be allowed if the collar protected the valve so that it would not be subjected to a blow if the container is dropped on a flat surface. This requirement would meet the Department of Transportation's standard regarding valve protection (49 CFR 172.301(g)(3)).
The catalog you referenced is primarily directed and distributed to the laboratory community, is recognized in the general industry standards, and, therefore, would not be a violation in that work setting. Because the construction and maritime standards do not recognize or prohibit collar protectors, any violation cited within a specific work setting situation would have to be based on the possibility of valve damage within a specific work setting situation.
Due to the limited application of this type of valve protective device to the construction or maritime industry, issuance of a field directive or information bulletin is not warranted at this time. If you disagree with this decision or have specific evidence to warrant a formal directive to the field offices, please feel free to contact this office at FTS 523-8136.