Valve Protection Caps? Answer at Bottom.
I thought I read somewhere that OSHA required gas bottles to have valve protection caps on the tanks if they were not in use for over twenty-four hours. However, I cannot find that requirement. When I tried to research the exact OSHA reference (in 1910) to use, I found an old OSHA Letter of Interpretation from 1980 that says something about valve caps are to be used when the tanks are not in use and cites 1910.252(a)(i)(d). However, when I look it up in my 2021 edition of 1910, there is no (d). 1910.252(a)(i) does not talk anywhere about valve caps, only “Combustible Materials”. Must be a really old Letter, 1980 seems like yesterday to me!
https://www.osha.gov/laws-regs/standardinterpretations/1980-10-22
I found a reference at 1910.253(b)(2)(iv) that says:
“Valve protection caps, where cylinder is designed to accept a cap, shall always be in place, hand-tight, except when cylinders are in use or connected for use.”
Finally, I found, 1910.253(b)(5)(ii)(D):
“Unless cylinders are secured on a special truck, regulators shall be removed and valve-protection caps, when provided for, shall be put in place before cylinders are moved.”
So I take from all this that gas cylinders must have a cap or connected for use and if connected for use, must be on a special truck. I have not clue where I got the 24-Hours from. This sound about right to all of you? The gas cylinder in the picture needs a Valve Protection Cap, right?
PS What is a "special truck"? Would a two-handed cart with a cradle and chain be satisfactory?
https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-Q/section-1910.253
Comments (10)
As usual my hero Drew! Thanks!
So Drew has pegged it correctly. OSHA says in the last Letter of Interpretation above:
https://www.osha.gov/laws-regs/standardinterpretations/2006-05-08
OSHA would consider single cylinders of O2 and acetylene on a cylinder cart to be de minimis violation if:
#1 No more than a single cylinders of O2 and acetylene are on the cart., The cart must be designed for this purpose and the cylinders must be secured. Both cylinders are secured to the cart via chain or straps.
#2 The cart is on a firm level surface.
#3 The cart cannot be in an area where it could be struck by equipment and vehicles.
#4 Both cylinders have valves closed and protection valve caps or properly functioning regulators.
The Letter clearly says the above applies to General Industry (1910) and Construction (1926).
As far as the picture above I am not sure I see a cart and I do not see it secured. If this is true this one would be subject to violations, no valve caps, not secured, and the gas in the tanks not identified.