Clarification of the requirements under the OSHA Standard 1910.166(c)(3)(i)(a) as opposed to the requirement of 1910.166(d)(1). | OSHA.gov | Occupational Safety and Health Administration

Standard Number:

1910.166

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 24, 1976

Mr. Arlen C. Bell
Fred S. James & Co.
of New York, Inc.
55 Water Street
New York, New York 10041

Dear Mr. Bell:

This is in response to your letter requesting clarification of the requirements under the OSHA Standard 1910.166(c)(3)(i)(a) as opposed to the requirement of 1910.166(d)(1).

In reading 1910.166(d)(1), we note that in the third sentence it says, "Defect limits for the external examination are prescribed in paragraph (c)". Upon examination we discover that paragraph (c) consists of three parts (1)(2)(3) and in (3) it is subdivided into paragraphing identified with the Roman numerals i, ii, iii, etc. and these in turn are broken down into subparts a, b, c, etc. We further note that the paragraphing quoted in your letter should be identified as 1910.166(c)(3)(i)(a). However, this ignores all of the other subparagraphs of paragraph 3 dealing with the physical conditions of the cylinder. Such items as the remaining wall thickness in the area having isolated pitting or a cylinder shall be rejected when the line corrosion on the cylinder is 3 inches in length or over, or a cylinder shall be rejected when the remaining wall thickness in an area of general corrosion is less than one half of the minimal allowable wall thickness. These are the physical conditions revealed by the external examination and dealt with under Paragraph (d)(1) third sentence. Since the Standard does not differentiate between the older and newer types of cylinders, the physical condition evident by an examination of the external parts of the cylinder would be the controlling factor. Another factor is the 5% weight loss of a low pressure cylinder which would be a controlling factor for determining rejection or acceptance of a cylinder.

We have mailed under separate cover several OSHA brochures including a copy of the Federal Register containing the current OSHA Standards dealing with this subject. Please note under 1910.166 the specific requirement for cylinders. Please feel free to contact us if there are further questions about OSHA.

Sincerely,

Alfred Barden
Regional Administrator
Occupational Safety and Health