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.
February 4, 1993
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THROUGH: LEO CAREY Director Office of Field Programs
FROM: PATRICIA K. CLARK Director Directorate of Technical Support
SUBJECT: Repair of Cahn Balances and Canon Camcorders, and Maintenance of Air Cyclinders
The Office of Science and Technology Assessment (OSTA) has renewed the service contract with Cahn Instruments, Inc. to repair electrobalances when such repair is proven to be cost effective.
In addition, OSTA is currently establishing a maintenance contract with Canon USA, Jamesburg, N.J., authorizing you to directly send Canon camcorders for repair. The procedure will be similar to that of the current Cahn Electrobalance maintenance contract. As in the past, to assure that repair is cost effective and funds are available, please contact Deborah Gabry prior to authorizing a repair. Ms. Gabry will make a determination based on the current DOL policy.
Regarding the maintenance of air cylinders used with SCBAs, currently OSHA has two types of cylinders, composite cylinders and steel or aluminum cylinders. Composite cylinders have a service life of 15 years and must be hydrostatically tested every three years. Steel and aluminum cylinders require hydrostatic testing every 5 years and have a permanent service life as long as they meet the hydrostatic testing requirements.
Cylinder testing must be performed by a Department of Transportation (DOT) authorized retester. To assist in compliance with this requirement, we have attached a list of the authorized centers in your region. The list is current as of November 23, 1992. If you want an updated list please contact Ms. Mech of the DOT at the following address and telephone number:
U.S. Department of Transportation Research and Special Programs Administration Office of Hazardous Materials Planning and Analysis, DHM-63 400 7th Street, SW Washington, D.C. 20590 TELE: (202) 366-4518
We have no plan to process a service contract for testing cylinders used with the SCBAs. Therefore, we request that you ensure compliance with the testing requirements as described in this memorandum.
If you have any questions regarding the above information, please contact Deborah Gabry of my staff at (202) 219-7065.