Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1910.166|
October 14, 1976
Mr. Arlen C. Bell
Technical Services Department
Fred S. James & Company
55 Water Street
New York, New York 10041
Dear Mr. Bell:
Assistant Secretary of Labor Morton Corn has asked me to respond to your letter of September 23, 1976, concerning low-pressure cylinders which are subject to hydrostatic testing.
A review of the material contained in both the Occupational Safety and Health Administration's (OSHA) standard 29 CFR 1910.166 and the referenced 1968 edition of the Compressed Gas Association's (CGA) C-6 standard has been completed. Section 3.2.1(a) of the CGA standard as well as OSHA's 29 CFR 1910.166(c)(3)(i)(a) address the five percent tare weight loss. The requirements for physical testing of low-pressure cylinders subject to hydrostatic testing is spelled out in paragraphs (c) and (d) of 29 CFR 1910.166.
Based on the above, the five percent figure for loss of original tare weight applies to all low-pressure cylinders as stated in both OSHA and CGA C-6 standards, and they must be destroyed. While the high-pressure cylinders, 900 p.s.i. or higher, have definite guidelines set down in the standard regarding physical internal and external inspections, additional information regarding high and low-pressure cylinders can be located in the CGA C-6 pamphlet. However, a good safe work practice "rule of thumb" for all cylinders, either high or low-pressure, is to physically destroy all cylinders that have reached the five percent loss of tare weight.
If you wish to pursue the problem any further, it is suggested that you contact the expert in the field for compressed gas cylinders. He is Mr. Robert Lanyard, Managing Director for CGA. His local New York telephone number is : (212) 354-1130.
Barry J. White
Associate Assistant Secretary
for Regional Programs
|Standard Interpretations - (Archived) Table of Contents|