Replacement torch tips under welding standards

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 2, 1977
Mr. Donald R. Wedan
Engineering Manager
Tescom Corporation
[Recipient address omitted]
Dear Mr. Wedan:
This is in response to your letter of August 3, 1977, concerning replacement tips for torches used in welding operations.
The Occupational Safety and Health Act of 1970 contains no provisions allowing approval or endorsement of equipment. Alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the manufacturer. For this reason, the compliance of equipment or process with OSHA's standards can only be determined by the safety and health professionals observing it actually in use under specific conditions. Also for this reason, OSHA has no long range plans for establishing certification or approval of products.
The welding, cutting and brazing standards as written are interpreted to include tips as a part of the complete assembly of the torch and as such cannot be considered a separate item. We do not interpret 1910.252(a)(1)(iii) to exclude replacement tips when such tips are made to the same specifications as the original tip of the torch at the time of approval by the nationally recognized testing laboratory.
I have enclosed for your information a copy of OSHA Program Directive #100-23 concerning welding tips.
If I may be of any further assistance, please feel free to contact me.
Sincerely,
John K. Barto, Chief
Division of Occupational
Safety Programming