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.

December 26, 1973

Mr. Lewis C. Barbe, President
Risk Treatment Services Company, Inc.
3200 Wilshire Boulevard
South Tower, Suite 1208
Los Angeles, California 90010

Dear Mr. Barbe:

Your letters to various Occupational Safety and Health Administration offices concerning inspection recordkeeping forms for welding equipment have been forwarded to this office for reply.

There are no OSHA forms maintained or approved for welding equipment inspection recordkeeping. It has been the policy of OSHA to accept any practical recordkeeping method adopted by the employer and maintained available for inspection.

In the event you should desire to pursue standardization of the recordkeeping procedures, it is recommended that you contact the American Welding Society, the Compressed Gas Association, or other referenced organizations as given in 29 CFR 1910.254. Such organizations usually possess suggested accounting and recordkeeping systems which are made available to the membership.

Thank you for your interest in job safety and health.

Sincerely,

Howard J. Schulte
Acting Depute Assistant Secretary of Labor