Frame grounding of arc welding machines

April 2, 1993

Mr. C. J. Beysselance
Regional Safety Manager
Jacobs Engineering Group, Inc.
[Recipient address omitted]
Dear Mr. Beysselance:

Your June 2 letter to Robert D. Holmes, Occupational Safety and Health Administration (OSHA) Area Director, requesting an interpretation of OSHA's standards addressing frame grounding of arc welding machines (1926.351(c)(5)(iv)) has been referred to the Office of Construction and Maritime Compliance Assistance for response. I apologize for the delay in responding to your inquiry.

As you know, OSHA's construction requirements for frame grounding of arc welding machines at 29 CFR 1926.351(c)(5) do not specifically address engine-driven units. In the absence of a specific grounding requirement and because an engine-driven arc welding machine is basically a portable generator, OSHA would consider compliance with 1926.404(f)(3) as compliance with the welding requirements at 1926.351(c)(5).

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh at (202) 219-8136.

Sincerely,
Roy F. Gurnham, Esq., P.E.
Director
Office of Construction and Maritime
Compliance Assistance

[Attached correspondence reproduced on OSHA page; omitted here.]