Compressed gas cylinder safety

The employer is responsible for determining compressed gas cylinders under their control are safe by performing visual inspections to the extent hazards can be identified visually. Under 1910.101(a), employers must ensure cylinders are checked by visual and other inspections prescribed by the Department of Transportation (49 CFR parts 171–179 and 14 CFR part 103) or, when those DOT rules do not apply, by the Compressed Gas Association pamphlets C-6-1968 and C-8-1962 (incorporated by reference via 1910.6).

• Do a visual check for dents, corrosion, leaks, damaged valves, or missing markings.
• Follow DOT inspection schedules and procedures when those regulations apply; otherwise follow the cited CGA pamphlets for guidance.
• Keep records and take cylinders out of service if visual defects indicate they are unsafe.

Use the DOT Hazardous Materials Regulations for visual and other inspections whenever those DOT regulations apply to the cylinder or the operation. 1910.101(a) requires inspections “as prescribed in the Hazardous Materials Regulations of the Department of Transportation (49 CFR parts 171–179 and 14 CFR part 103).”

• If the cylinder is transported or otherwise covered by DOT rules, follow DOT inspection, marking, testing, and retest schedules.
• If DOT rules do not apply (for example, certain in-plant permanent installations), follow the Compressed Gas Association pamphlets referenced in 1910.101(a) via 1910.6.

When DOT regulations do not apply, employers must conduct inspections in accordance with Compressed Gas Association Pamphlets C-6-1968 and C-8-1962, as incorporated by reference through 1910.6. 1910.101(a) explicitly directs employers to use those CGA pamphlets if the DOT Hazardous Materials Regulations are not applicable.

• Obtain the referenced CGA pamphlets for the detailed visual and other inspection procedures.
• Use those pamphlets’ acceptance/rejection criteria and inspection intervals when DOT rules aren’t in force.

Employers must follow the Compressed Gas Association Pamphlet P-1-1965 for in-plant handling, storage, and utilization of compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks. 1910.101(b) requires P-1-1965, which is incorporated by reference through 1910.6.

• Use P-1-1965 guidance for safe storage spacing, segregation of incompatible gases, cylinder securing, valve protection, and handling methods.
• If your operation involves cylinders plus portable tanks or transport tanks on-site, P-1-1965 covers those in-plant practices as cited by 1910.101(b).

Safety relief devices must be installed and maintained in accordance with Compressed Gas Association Pamphlets S-1.1-1963 (and its 1965 addenda) and S-1.2-1963, as incorporated by reference by 1910.101(c) through 1910.6.

• Ensure each cylinder, portable tank, and cargo tank has an appropriate pressure relief device sized, set, and maintained per the cited CGA pamphlets.
• Follow the CGA guidance for inspection, testing, and replacement of relief devices to prevent overpressurization hazards.

No—OSHA’s 1910.101 requires employers to follow the DOT Hazardous Materials Regulations when they apply, and otherwise to follow the specific Compressed Gas Association pamphlets incorporated by reference; it does not replace those requirements. 1910.101(a),(b),(c) directs employers to comply with DOT rules or the named CGA pamphlets, and 1910.6 provides the legal mechanism for incorporation by reference.

• Treat DOT and CGA requirements as the required technical sources cited by OSHA for inspection, handling, storage, and relief-device practices.
• Where both OSHA and DOT/CGAs apply, follow the more specific or applicable provisions to ensure safety and compliance.

If a visual inspection reveals damage such as severe corrosion, dents, gouges, bulges, fire damage, valve damage, or leaks, the cylinder must be removed from service and handled per DOT or CGA guidance. 1910.101(a) requires visual inspections and references the DOT Hazardous Materials Regulations and CGA pamphlets for acceptance/rejection criteria.

• Tag or segregate the cylinder so it cannot be used until evaluated by qualified personnel.
• Follow DOT 49 CFR acceptance/rejection criteria when DOT applies, or the CGA pamphlets C-6-1968/C-8-1962 when DOT does not apply, for repair, requalification, or disposal decisions.

Yes. 1910.101(b) requires that the in-plant handling, storage, and utilization of compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks be performed in accordance with Compressed Gas Association Pamphlet P-1-1965 (incorporated by reference via 1910.6).

• Use the P-1-1965 practices for securing, grounding/bonding if required, segregation of incompatible gases, and safe transfer procedures for all listed container types.
• Recognize that the CGA pamphlet provides tailored guidance for different container types even though 1910.101(b) groups them together for the reference.

‘Incorporated by reference’ means OSHA requires compliance with the specified external documents (Compressed Gas Association pamphlets) as if they were written into the standard, and that incorporation authority is established in 1910.6. The specific CGA pamphlets named in 1910.101(a),(b),(c) become mandatory guidance for employers under OSHA.

• Obtain the cited CGA documents (C-6-1968, C-8-1962, P-1-1965, S-1.1-1963 and addenda, S-1.2-1963) and follow their procedures.
• If you rely on these external documents, maintain access to them so workplace programs and inspections reflect the referenced requirements.

Yes—1910.101(c) requires that compressed gas cylinders, portable tanks, and cargo tanks have pressure relief devices installed and maintained in accordance with the Compressed Gas Association Pamphlets S-1.1-1963 (and 1965 addenda) and S-1.2-1963 (as incorporated by reference via 1910.6).

• Confirm appropriate relief devices are present and sized for the gas and container in question per CGA guidance.
• Maintain, inspect, and replace relief devices following the CGA procedures to prevent overpressure events.

Although 1910.101(b) does not list specific segregation distances, it requires employers to follow Compressed Gas Association Pamphlet P-1-1965 for handling and storage, and that pamphlet provides guidance on segregation of incompatible gases. 1910.101(b) incorporates P-1-1965 by reference via 1910.6.

• Use P-1-1965’s tables and recommendations to separate oxidizers from flammables, corrosives from reactives, and to set safe aisle, valve-protection, and distance requirements.
• If local code or DOT rules give different requirements that apply to your operation, follow the applicable regulation that provides the required protection.

1910.101(a) requires employers to determine cylinders are in a safe condition by visual inspection and to follow DOT or CGA inspection procedures, which implies inspections should be done by trained or qualified personnel familiar with the applicable DOT rules or CGA acceptance/rejection criteria. 1910.101(a) and the referenced DOT and CGA documents set the technical criteria.

• Train employees to recognize dents, corrosion, heat damage, valve defects, and other visually detectable defects listed in DOT or CGA guidance.
• Document who is authorized to perform inspections and ensure they have access to the applicable DOT/CGA procedures used to make disposition decisions.

No—employers must determine cylinders under their control are in a safe condition by performing their own visual inspections to the extent hazards are detectable visually; supplier certificates do not replace the employer’s obligation under 1910.101(a).

• Supplier test or requalification certificates are important, but employers should still perform on‑site visual checks for damage, leaks, or improper valves when receiving or before using cylinders.
• Follow DOT or CGA inspection steps for acceptance/rejection as required by 1910.101(a).

Compressed-gas storage can trigger OSHA’s Process Safety Management (PSM) Standard if the stored gas is a covered highly hazardous chemical present on site in one location at or above the PSM threshold quantity. OSHA’s PSM interpretation explains that a process involving a Category 1 flammable gas stored on-site in one location can be PSM-covered if the aggregate quantity exceeds the threshold; this principle applies to pre-charged cylinders and tanks stored in a warehouse. See 1910.101(b) for storage references and the PSM interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 for aggregation and coverage guidance.

• If the total amount of a Category 1 flammable gas (per 29 CFR 1910.1200 definitions) stored in one location is at or above the PSM threshold (10,000 pounds for many flammables), PSM 1910.119 may apply—plan for process hazard analysis, operating procedures, and other PSM elements.
• Coordinate compliance between 1910.101 storage practices (CGA P-1-1965) and PSM requirements when both apply (see the PSM LOI for how OSHA views aggregation and storage).

While 1910.101 itself directs employers to perform inspections and maintain relief devices per DOT or CGA requirements, employers should follow the recordkeeping provisions of the applicable DOT regulations or the referenced CGA pamphlets for documentation. 1910.101(a),(c) direct employers to those sources for inspection and relief-device maintenance requirements, and 1910.6 incorporates them by reference.

• Retain DOT-required test and requalification records when DOT rules apply.
• When using CGA guidance because DOT does not apply, follow the CGA pamphlets’ recommendations for recordkeeping and retain evidence of routine visual inspections and maintenance actions as part of your safety program.

If a pressure relief device has activated or shows signs of failure, the employer must take the container out of service and follow the inspection, repair, or requalification procedures in the Compressed Gas Association pamphlets S-1.1/S-1.2 or the applicable DOT regulations per 1910.101(c).

• Segregate and tag the affected container and prevent its use until a qualified person evaluates it.
• Repair or replace relief devices only in accordance with the CGA pamphlets or DOT requirements, and document the action as required by those guidance documents.

Yes—employers should treat empty cylinders carefully and in many cases the DOT regulations and CGA guidance still apply because residual gas, pressure, or hazards may remain. 1910.101(a),(b) refer to inspection and handling practices from DOT and CGA documents that address both filled and empty cylinders.

• Follow DOT markings and handling rules for ‘empty’ cylinders where DOT applies (some DOT rules require specific markings and treat ‘‘empty’’ in defined ways).
• Use CGA P-1-1965 and C-6/C-8 pamphlet guidance for proper valve protection, transportation, storage, and inspection of empty cylinders in the workplace.

When cylinders are in motor vehicle cargo tanks, rail tankcars, portable tanks, or transported on-site, employers must follow the handling, storage, and utilization practices set out in Compressed Gas Association Pamphlet P-1-1965 as required by 1910.101(b), and must also comply with Department of Transportation rules when DOT regulations apply as referenced in 1910.101(a).

• Secure cylinders during transport, protect valves, and segregate incompatible gases per P-1-1965 and DOT requirements.
• Ensure operators and handlers are trained in safe transfer and emergency procedures consistent with the referenced guidance.

Employers must follow the in-plant handling and storage rules of Compressed Gas Association Pamphlet P-1-1965 as required by 1910.101(b) and applicable DOT requirements for transport and inspection in 1910.101(a). Those documents address segregation from ignition sources, ventilation, bonding/grounding where needed, and maximum quantities in storage areas.

• Store flammable gases away from oxidizers and ignition sources and follow the CGA’s recommendations for ventilation and area classification.
• If storage quantities trigger other OSHA programs (for example, PSM as discussed in the PSM LOI at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06), implement the required additional safeguards.

OSHA expects employers to follow Compressed Gas Association Pamphlet P-1-1965 for valve protection, securing cylinders, and safe transportation methods inside a facility as required by 1910.101(b). If DOT regulations apply to the movement, follow those specific DOT provisions per 1910.101(a).

• Keep cylinder valves capped or protected during movement, secure cylinders from tipping, and use appropriate carts or mechanical handling equipment recommended by P-1-1965.
• Train employees on correct transport practices and inspect valve protection devices regularly.