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Permanent installation of a Bullard free-air pump

Summary An engineering firm asked whether a Bullard breathing-air pump had to remain portable. OSHA said permanently installing it should not itself create a safety or health hazard, while four compliance conditions from a 1985 memo still applied. The letter did not restate those conditions.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-04-18-0
Date issued
April 18, 1996
Status
Active
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Respiratory Protection
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

April 18, 1996

Ms. Jeni Leberknight
Rapley Engineering Services, Inc.
[Recipient address omitted]
Dear Ms. Leberknight:

Thank you for your letter of March 11, requesting an interpretation of the use of the Bullard "Free Air" Pump.

This is to confirm, per your phone conversation with Doug Ray of my staff, that the issue raised by our field offices concerning the portability of the unit was not addressed in our memorandum dated January 25, 1985, to our Regional Administrators. The portability of the unit should not have any bearing on safety and health. Therefore, permanently installing the units in a facility should not create a safety or health hazard. Also please bear in mind that the four compliance requirements for the use of the Bullard "Free Air" Pump, as addressed in the memorandum of January 25, an attachment to your letter, are still in effect.

Any additional questions regarding this matter can be addressed by Doug Ray at (202) 219-8036.

Sincerely,

Ruth McCully, Director
Office of Health Compliance

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

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