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OSHA 1910.102

Acetylene handling requirements

1910 Subpart H

16 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.102(a), which standard must employers follow for in-plant transfer, handling, storage, and use of acetylene in cylinders?

Employers must follow the Compressed Gas Association's CGA Pamphlet G-1-2009 requirements as incorporated by reference in 1910.102(a). The standard text says employers must ensure that in-plant transfer, handling, storage, and use of acetylene in cylinders comply with CGA Pamphlet G-1-2009; see 1910.102(a) and note the incorporation-by-reference authority at 1910.6.

  • Follow CGA G-1-2009 for cylinder labeling, valve and regulator use, secure storage, segregation, caps/guards, transport, and leak control.
  • If CGA G-1-2009 contains specific procedures (e.g., filling limits, valve protection), implement them in your operations to be compliant with 1910.102(a).

Under 1910.102(a), can an employer adopt more protective practices than CGA G-1-2009 for acetylene cylinders?

Yes — employers may adopt more protective practices than CGA G-1-2009, but they must at minimum meet the requirements incorporated by reference in 1910.102(a). The rule requires compliance with CGA Pamphlet G-1-2009 as set out in 1910.102(a) and recognizes incorporation under 1910.6.

  • Practical step: document any additional or more protective procedures (e.g., stricter storage separation, extra leak detection) so you can demonstrate you meet or exceed the incorporated requirements.
  • If you choose different methods, ensure they provide equal or greater protection than the referenced CGA provisions.

Under 1910.102(b)(1), which standard governs acetylene piping systems installed under current requirements?

Acetylene piped systems must comply with Chapter 9 (“Acetylene Piping”) of NFPA 51A-2006 as required by 1910.102(b)(1).

  • Use NFPA 51A-2006 Chapter 9 for design, materials, installation, and safety controls for acetylene piping.
  • For details about which NFPA edition applies to installations, see 1910.102(b)(2)–(b)(3).

Under 1910.102(b)(2) and (b)(3), when may employers use the older NFPA 51A-2001 piping provisions instead of NFPA 51A-2006?

Employers may use Chapter 7 of NFPA 51A-2001 when they can demonstrate the facilities, equipment, structures, or installations used to generate or charge acetylene cylinders were installed prior to February 16, 2006, or were approved for construction before that date even if constructed later, per 1910.102(b)(2) and 1910.102(b)(3).

  • To use the older edition, be prepared to document installation dates or permit/approval dates showing the facility or equipment predates the February 16, 2006 cutoff.
  • If you cannot demonstrate pre‑2006 installation or approval, you must follow NFPA 51A-2006 as required by 1910.102(b)(1).

Under 1910.102(b)(4), where can employers find additional guidance on acetylene piping systems?

OSHA points employers to CGA G-1.2-2006 Part 3 (“Acetylene piping”) for additional information on acetylene piping systems as stated in 1910.102(b)(4).

  • Consider reviewing CGA G-1.2-2006 for practical details on piping materials, fittings, installation practices, and maintenance that supplement NFPA guidance.
  • Remember that following these consensus documents helps demonstrate compliance with the OSHA requirement in 1910.102(b).

Under 1910.102(c)(1), which standard applies to acetylene generators and facilities that fill (charge) acetylene cylinders?

Facilities, equipment, structures, or installations used to generate acetylene or to charge acetylene cylinders must comply with NFPA 51A-2006 as required by 1910.102(c)(1).

  • NFPA 51A-2006 sets requirements for site layout, generator design, ventilation, fire protection, and safe filling operations for acetylene charging plants.
  • If your facility was constructed or approved before February 16, 2006, see 1910.102(c)(2)–(c)(3) about possible applicability of the 2001 edition.

Under 1910.102(c)(2) and (c)(3), when may NFPA 51A-2001 be used for generators and cylinder filling operations?

You may use NFPA 51A-2001 for generators and filling operations when you can demonstrate the facilities, equipment, structures, or installations were constructed or installed prior to February 16, 2006, or were approved for construction before that date even if actually built on or after that date, per 1910.102(c)(2) and 1910.102(c)(3).

  • Keep records of construction or approval dates to document eligibility for the older NFPA edition.
  • If you cannot demonstrate pre‑2006 status, follow NFPA 51A-2006 as required by 1910.102(c)(1).

Under 1910.102, what's the practical difference between the rules for acetylene cylinders, piped systems, and generators/filling?

The standard divides responsibilities by application: cylinders (in-plant handling/storage/use) are governed by CGA G-1-2009 under 1910.102(a); piped systems are covered by NFPA 51A Chapter 9 (typically NFPA 51A-2006) under 1910.102(b); and generators/charging plants that produce or fill acetylene cylinders are governed by NFPA 51A-2006 under 1910.102(c).

  • You must apply the specific referenced consensus document for the activity type: cylinder handling (CGA), fixed piped distribution (NFPA piping chapter), or generation/filling (NFPA charging plant chapters).
  • For older installations, the standard explains when earlier NFPA editions may be used; see 1910.102(b)(2)–(b)(3).

Under 1910.102, do employers need to keep documents showing which edition of NFPA or CGA they followed?

The standard requires employers to ensure compliance with the incorporated consensus documents; while 1910.102 does not list a specific recordkeeping requirement for which edition you used, you should retain documentation that demonstrates compliance (installation dates, approvals, and policies) to show that you applied the correct edition per 1910.102(b)(2)–(b)(3) and 1910.102(c)(2)–(c)(3).

  • Practical documents to keep: dated construction/installation approvals, vendor certificates, piping diagrams, maintenance records, and written procedures showing application of CGA G-1-2009 or the applicable NFPA edition.
  • The incorporation-by-reference authority at 1910.6 supports that meeting the referenced standard satisfies the OSHA requirement.

Under 1910.102, what should an employer do if an acetylene piping installation was approved before Feb 16, 2006 but actually built after that date?

If the installation was approved for construction prior to February 16, 2006, the employer may comply with the provisions of the older NFPA 51A-2001 per 1910.102(b)(3) for piping and 1910.102(c)(3) for generators/filling.

  • Keep and be ready to present approval records showing the date the facility or equipment was approved for construction.
  • If you cannot show pre‑2006 approval, follow the current NFPA 51A-2006 requirements as specified in 1910.102(b)(1) and 1910.102(c)(1).

Under 1910.102, are acetylene-charging plants subject to specific NFPA requirements for ventilation and fire protection?

Yes — acetylene charging plants must meet the applicable NFPA 51A-2006 requirements for ventilation, fire protection, and other safety systems as required by 1910.102(c)(1).

  • NFPA 51A-2006 contains detailed provisions on ventilation, room separation, fire detection/suppression, and safe procedures for filling cylinders; implement those sections to meet the OSHA requirement.
  • If your plant was installed or approved before February 16, 2006, see 1910.102(c)(2)–(c)(3) about using the 2001 edition.

Under 1910.102, does OSHA require employers to follow the exact wording of NFPA or CGA documents, or may employers use equivalent safety measures?

OSHA requires employers to ensure compliance with the incorporated consensus documents referenced in 1910.102, so you must meet the safety outcomes those documents require; where you use different methods, they must provide equivalent or greater protection. See 1910.102(a) and the incorporation authority at 1910.6.

  • If you implement an alternative method, document the hazard evaluation and why the alternative provides equal or better protection.
  • Be prepared to show records or technical justification during an inspection that your alternative meets the same safety objectives as the referenced CGA/NFPA provisions.

Under 1910.102, does storage of pre-charged equipment containing a Category 1 flammable gas in one location potentially trigger OSHA's Process Safety Management (PSM) requirements?

Yes — storing multiple items that together contain a Category 1 flammable gas on site in one location at or above the PSM threshold quantity can make the storage activity a PSM-covered process, as explained in OSHA's Process Safety Management aggregation interpretation (warehouse example). See OSHA's interpretation on aggregating Category 1 flammable gases: https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

  • The PSM interpretation explains that storage and on-site movement of pre‑charged equipment can qualify as a "process" when the aggregate quantity of the flammable gas meets or exceeds the threshold.
  • Practical step: evaluate total on-site inventory of acetylene (or other Category 1 flammable gas), and consult PSM requirements and legal counsel to determine whether 29 CFR 1910.119 obligations apply; see OSHA guidance at 1910 for broader regulatory context.

Under 1910.102, who decides whether an installation qualifies to use the older NFPA 51A-2001 provisions?

The employer must be able to demonstrate that the facilities, equipment, structures, or installations were installed or approved for construction prior to February 16, 2006 in order to use NFPA 51A-2001, per 1910.102(b)(2)–(b)(3) and 1910.102(c)(2)–(c)(3).

  • Maintain evidence (construction records, approvals, permits) to support your claim that the older edition applies.
  • OSHA compliance officers will review your documentation during inspections to verify eligibility for the older edition.

Under 1910.102, if a workplace uses both cylinders and a piped acetylene distribution system, which requirements apply?

Both sets of requirements apply: cylinder handling, storage and in-plant transfer must comply with CGA G-1-2009 under 1910.102(a), while the fixed piped distribution system must comply with NFPA 51A piping provisions referenced in 1910.102(b).

  • In practice implement CGA guidance for cylinder practices at connection points, and NFPA requirements for the design, installation, and maintenance of the fixed piping that distributes acetylene.

Under 1910.102, where can I find the legal authority that lets OSHA require compliance with CGA or NFPA documents?

OSHA incorporates consensus standards by reference; the legal authority for using externally authored standards in OSHA rules is found in the incorporation language at 1910.6 and in the specific citations within 1910.102.

  • When a standard (like CGA G-1-2009 or NFPA 51A-2006) is incorporated by reference in an OSHA regulation, meeting the referenced document's requirements is required to comply with the OSHA rule.