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.

March 30, 2004

Mr. Chris Smith
Via E-mail

Re: 29 CFR 1926.350(a)(6); hoisting compressed gas cylinders on a wheeled cart.

Dear Mr. Smith:

This is in response to your e-mail submitted March 2, 2004, to the Occupational Safety and Health Administration (OSHA). You ask for an interpretation of §1926.350, Gas Welding and Cutting.

We have paraphrased your question as follows:

Question: Does §1926.350(a) require that all regulators be removed, and replaced with valve-protection caps each time the compressed gas cylinders are hoisted in a wheeled cart by a crane?


Section 1926.350(a)(6) requires that when compressed gas cylinders are transported, moved and stored:

Unless cylinders are firmly secured on a special carrier intended for this purpose, regulators shall be removed and valve protection caps put in place before cylinders are moved.

You describe a situation where you use a crane to hoist oxygen and acetylene tanks strapped to a wheeled cart. The tanks are secured to the cart with tank clamps which can be tightened down around both tanks. There is also an arm with a closed loop to attach the rigging.

The standard states that before moving cylinders, the regulators must be removed and valve protection caps put on, unless "on a special carrier intended for this purpose." In your scenario, the wheeled cart is a special carrier designed to safely support and move oxygen and acetylene tanks on the ground. The cart was not designed or intended to protect tanks from damage when moved by crane; the cart does not include any feature that would protect the regulators in the event they struck against an object while being hoisted. Therefore, the requirement that regulators be removed and valve protection caps be put in place before the cylinders are moved applies.

If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction