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.

May 15, 1996

William C. Rhoten, Director
of Safety and Health, United Association
of Journeymen and Apprentices
of Plumbing and Pipe Fitting Industry
of the United States and Canada
901 Mass. Avenue, N.W.
Washington, D.C. 20001.

Dear Mr. Rhoten:

This is in response to your April 17 letter to Mr. Jim E. Lapping, referencing a question concerning whether there is "... any Federal Occupational Safety and Health Administration (OSHA) requirement that addresses the use of compressed air to test for leaks in gas lines?"

There is no Federal OSHA requirement specifically addressing the use of compressed air to test for leaks in gas lines. There are several applicable general industry and construction standards addressing the hazards of compressed gases. In the construction standard, Subpart J, Welding and cutting, §1926.350.(c)(2) and (3) require that:


(2) "No one shall use a cylinder's contents for purposes other than those intended by the supplier. All cylinders used shall meet the Department of Transportation requirements published in 49 CFR part 178, subpart C, Specifications for cylinders."

(3) "No damaged or defective cylinders shall be used."

If compressed gas cylinders or containers are used for purposes of pressure testing, the containers and their use must meet the applicable DOT requirements. Also, as you are aware, where there is no specific standard covering an industry recognized hazard, Section 5(a)(1) of the OSH Act requires the duty of employers to "... furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." In such cases, the hazard must be recognized as a serious hazard by the industry and by the employer and there must be feasible means of abatement. For Section 5(a)(1) to be applicable, of course, employees must be exposed to potential injury or illness as a result of the hazard.

We trust this is responsive to your inquiry and thank you for your interest in occupational safety and health.

Gerald P. Reidy, Director
Office of Construction and
Compliance Assistance