April 5, 2005

Mr. Thomas J. Davies
Corporate Safety Manager
The Herrick Corporation
P.O. Box 9125
Pleasanton, CA 94566

Dear Mr. Davies:

Thank you for your December 11, 2003 letter to the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA). Your letter was referred to OSHA's Directorate of Enforcement Programs (DEP) for review and response. This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any question(s) and/or scenario not delineated within your original correspondence. You had specific questions regarding the use of welding leads in General Industry. We apologize for the delay in responding to your request.

Scenario: You have been informed by OSHA officials that the General Industry standard does not allow for repair to welding leads. Even if the repair is further than 10 feet down the lead from the holder and the repair is equivalent insulation, it still cannot be used because the standard does not allow for repair. The language in the standard states "replace" and, therefore, the lead cannot be repaired.

Question: Can welding leads be repaired in General Industry, or do they have to be replaced whenever damage occurs?

Reply: OSHA's General Industry standard requires that the welding leads be replaced. 29 CFR 1910.254(d)(9)(iii) is a result of the reorganization and renumbering of Subpart Q, Welding, Cutting, and Brazing, Final Rule, April 11, 1990. (The standard was previously numbered §1910.252(b)(4)(ix)(C).) The standard, which was adopted from ANSI Z49.1-1967, Safety in Welding and Cutting, clearly states that cables with damaged insulation or exposed bare conductors shall be replaced. Although repair of cables is mentioned in the more recent ANSI standard Z49.1-1999, OSHA has not adopted this standard.

Additionally, you stated that you had been informed by OSHA officials that repairing welding leads is "ok" in the Construction Industry, specifically, under §1926.351(b)(4). This standard allows for the repair of cables beyond 10 feet from the cable end and, "...protected by means of rubber and friction tape or other equivalent insulation." This provision does not apply to the cable lead referred to in §1926.351(b)(2) which may only be replaced and not repaired.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.


Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs