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.



September 9, 1993

Mr. Kenneth J. Yotz
Health and Safety Consultant
Environmental, Management
And Training Systems, Inc.
Five South Andover Lane
Geneva, Illinois 60134-1806

Dear Mr. Yotz:

This is a further response to your letter of June 21, in which you requested an interpretation of the Occupational Safety and Health Administration's (OSHA's) 29 CFR 1910.253(b)(2)(iv), Oxygen-fuel gas welding and cutting, standard. Specifically, you requested whether the safe movement of the compressed gas cylinders with the regulators installed comply with the "in use" or the "connected for use" requirements of the above-mentioned standard, and whether the "special truck" requirement of 1910.253(b)(5)(ii)(D) implies any specific design criteria of the truck.

Compressed gas cylinders with the regulators installed are considered by OSHA to be "connected for use." A "special truck" is a vehicle or cart used for the specific purpose of transporting the aforementioned "connected for use" compressed gas cylinders in the workplace. The "special truck" must be designed so that the following conditions can be met: 1) when cylinders are on the special trucks, they must be held in an erect or nearly erect position; and 2) protection of the cylinder valves and regulators must be provided.

Based on the information in your letter, we believe that the procedure or practice described in your letter meets the intent of 1910.253(b)(2)(iv). The intervals at which the unit is used is not the main consideration. The critical factor that distinguishes cylinders in storage [where valve protection caps are required] from those not in storage is those not in storage must be in use or connected for use, with provisions made to protect the regulator and the valve. Also, in accordance with the requirement of 1910.253(b)(5)(ii)(G), cylinder valves must be closed when work is finished.

If we may be of further assistance, please feel free to contact [the Office of General Industry Enforcement at (202) 693-1850].


Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance

[Corrected 5/19/2006]