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Blast-cap tester batteries under OSHA and mining rules

Summary A manufacturer asked about power sources for testing electric blast caps. The Department of Labor's occupational safety counsel said the silver-chloride dry-cell requirement appeared in OSHA's construction rule but not its general-industry rule, and mining hazards under the mining agency's jurisdiction were outside OSHA's standard. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1977-11-18
Date issued
November 18, 1977
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 18, 1977

Mr. Howard Lawrence
E.I.T. Corporation
[Recipient address omitted]
Dear Mr. Lawrence:

Your letter to the Federal Trade Commission dated August 31, 1977 has been referred to me for a response.

As Mr. Barto, Chief, Division of Occupational Safety Programming indicated in his October 12, 1977 letter, only OSHA construction standards (29 CFR 1926.906(9)) specifically require the use of silver chloride dry cells as a power source for testing electric blast caps. OSHA General Industry Standards (29 CFR 1910.109(e)(4)(vii)) do not contain such a requirement. Moreover, to the extent that the Mining Enforcement and Safety Administration (MESA) has exercised jurisdiction in mines over the hazards which you have addressed, OSHA standards would not apply.

I am forwarding this letter to Dr. Bingham's office so that it will be made part of the record on the petition to amend the relevant construction standard.

Let me assure you that your comments will be carefully considered before any decision on this matter is reached.

Sincerely,
Benjamin W. Mintz
Associate Solicitor
for Occupational Safety and Health

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