Definitions for welding standards

A "welder" or "welding operator" is any person who operates electric or gas welding and cutting equipment. This is the plain definition given in 1910.251(a).

• Cite: see 1910.251(a).

Yes. Someone who operates a handheld oxy-fuel cutting torch is a "welding operator" because the definition covers operators of gas welding and cutting equipment. See 1910.251(a).

• Practical note: This includes any operator using gas-based cutting or welding tools, not just stationary machines.

Yes. If a person operates electric welding equipment such as automated welding robots, they meet the definition of "welder" or "welding operator" because the definition covers operators of electric welding equipment. See 1910.251(a).

• Practical implication: Employers should treat robot operators as welding operators for purposes of any Subpart Q requirements that apply to welders.

Only if the brazing or soldering is performed using electric or gas welding and cutting equipment—then the person would fall under the definition. The definition in 1910.251(a) covers "any operator of electric or gas welding and cutting equipment."

• If brazing/soldering is done with different, non-electric/gas tools, the plain definition does not automatically classify the worker as a "welder."

"Approved" means equipment or items that are listed or approved by a nationally recognized testing laboratory. The subpart explicitly defines "approved" this way and refers you to additional definitions in 1910.155(c)(3) and to the NRTL definition in 1910.7. See 1910.251(b).

• Employers should use the referenced sections to determine what qualifies as "listed" or an acceptable testing laboratory.

The formal definitions are provided in 1910.155(c)(3), and 1910.251(b) explicitly directs you to that paragraph for those definitions.

• Follow 1910.155(c)(3) for the detailed wording used to interpret "listed" and "approved."

Yes. "Approved" in this subpart means listed or approved by a nationally recognized testing laboratory, and 1910.251(b) specifically points to 1910.7 for the definition of a nationally recognized testing laboratory.

• In practice, that means the certifying laboratory must be recognized under the NRTL program described in 1910.7.

No. Under 1910.251(b), "approved" means listed or approved by a nationally recognized testing laboratory, not merely an employer's internal declaration. See also 1910.7 for the NRTL requirement.

• Practical tip: Keep documentation of the NRTL listing or approval with the equipment records.

Not automatically—equipment is "approved" only if it is listed or approved by a nationally recognized testing laboratory as defined in 1910.7. See 1910.251(b).

• If a foreign lab is recognized under the U.S. NRTL program, its listing may qualify; otherwise a U.S.-recognized NRTL listing is what the definition requires.

The subpart defines "approved" to mean listed or approved by a nationally recognized testing laboratory, so equipment intended to meet an "approved" requirement would need that listing or approval. See 1910.251(b) and the NRTL definition in 1910.7.

• Employers relying on an "approved" designation should ensure the equipment carries appropriate NRTL markings and documentation.

No—under the plain wording of 1910.251(a), a "welder" or "welding operator" is an operator of electric or gas welding and cutting equipment. Monitoring without operating would not by itself meet that definition.

• Note: Other Subpart Q requirements or employer policies may still apply to monitoring personnel even if they are not classified as operators.

Yes—if the worker operates electric or gas welding and cutting equipment (even occasionally), they meet the definition of "welder" or "welding operator" in 1910.251(a).

• Employers should consider that occasional operators may need the same protections and training as full-time operators when they perform those tasks.

You should consult the NRTL program criteria and list in 1910.7, because 1910.251(b) ties the meaning of "approved" to listings or approvals from laboratories recognized under 1910.7.

• Practical step: Use the OSHA NRTL resources referenced in 1910.7 to verify recognition status.

The definition in 1910.251(a) is part of 29 CFR 1910 Subpart Q (Welding, Cutting and Brazing), which applies to general industry; the term itself describes any operator of electric or gas welding and cutting equipment regardless of industry setting within Subpart Q's scope.

• For construction-specific rules, consult the construction standards; this definition is for Subpart Q in 29 CFR 1910.

The text of 1910.251(b) defines "approved" generically as listed or approved by a nationally recognized testing laboratory, so any item (electrical equipment, gas fittings, hoses, etc.) that a provision in the subpart requires to be "approved" must meet that listing/approval definition.

• Check the specific Subpart Q paragraph calling for "approved" items to see which pieces of equipment the requirement covers.

No. The definitions in 1910.251 only define terms—such as who is a "welder" and what "approved" means—and do not by themselves establish training or certification requirements.

• Employers should look to other specific standards and employer programs for training and qualification obligations.

Not by the definition in 1910.251(b); "approved" means listed or approved by a nationally recognized testing laboratory (see also 1910.155(c)(3) and 1910.7). A manufacturer's claim alone does not substitute for an NRTL listing or approval.

No—simply filling gas cylinders does not make someone a "welder" under 1910.251(a), because the definition specifically refers to operators of electric or gas welding and cutting equipment. However, those employees may be subject to other relevant standards for handling compressed gases.