Special trucks for moving compressed-gas cylinders

October 24, 1988

Mr. B. C. Griffin
GrifTan, Inc.
[Recipient address omitted]
Dear Mr. Griffin:

This is in response to your letter of July 21, 1988, concerning a "safety cap" designed by you and intended for use on portable DOT compressed gas cylinders. Please excuse the delay in response.

Your specific request was for an interpretation of "special trucks" as identified at 29 CFR 1910.253(b)(5)(ii)(D), copy enclosed The Occupational Safety and Health Administration (OSHA) provides the following:

A "special truck" is a vehicle or cart which provides for stable support of vertical standing DOT portable gas cylinders during movement and at various work locations.

There is provision in the OSHA regulations for the use of a device, such as your safety cap, beyond that required to protect compressed gas cylinder valves as defined by DOT shipping requirements. The movement of compressed gas cylinders with a regulator attached is only permitted while the cylinder is mounted on a special truck. In the workplace, concern is for the protection of the regulator as well as the protection of the cylinder valve. Should a regulator become damaged it is possible for its parts to be ejected with great velocity thereby presenting a significant hazard to workers. For this reason, movement of a compressed gas cylinder with regulator installed may only be accomplished when the cylinder valve and regulator are assured of protection from damage and the cylinder is moved in an erect or nearly erect position on a special truck. Installation of your safety shield does not alter the requirement for a special truck, because the GrifTan Safety Cap does not provide for protection of the regulator.

Use of the GrifTan Safety Cap in place of the DOT one piece safety cap for all situations in which installed caps are required by OSHA regulations is acceptable, if the caps are listed by UL as indicated by your letter. The cap may be used with a regulator installed providing the procedures used assure compliance with the regulations.

If we may be of further assistance, please contact us.

Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
Enclosure

[Requester letter reproduced on OSHA page; omitted here.]