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OSHA 1915.172

Portable air receivers requirements

Subpart K

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.172(a), what marking and testing must a portable air receiver built after the effective date have?

Yes—Under 1915.172(a), a portable air receiver built after the regulation's effective date must be marked and reported as designed and constructed to meet the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section VIII, and must undergo a hydrostatic pressure test at one and one-half times the vessel's working pressure.

  • Marking: The vessel must bear the required ASME Section VIII identification showing it was designed and constructed to that code.
  • Hydrostatic test: The test pressure is 1.5 × working pressure and must be completed before placing the vessel in service.

Reference: 1915.172(a).

Under 1915.172(b), how often must portable air receivers built before the effective date be examined and pressure-tested?

Portable air receivers built prior to the regulation's effective date and not made to ASME Section VIII must be examined quarterly by a competent person and must receive a hydrostatic pressure test yearly at one and one-half times the working pressure, per 1915.172(b).

  • Quarterly: Visual/physical examination by a competent person.
  • Yearly: Hydrostatic test at 1.5 × working pressure.

See 1915.172(b) for the exact requirements.

Under 1915.172(c), how must relief valves on portable air receivers be set?

Relief valves must be set to either the safe working pressure of the vessel or the lowest safe working pressure of the system—whichever is lower—according to 1915.172(c).

  • Practical point: If the vessel's safe working pressure is higher than system components, set the relief valve at the lowest safe working pressure in the system to protect all equipment.

Reference: 1915.172(c).

Under 1915.172(d), what must the certification record for portable air receiver examinations and tests include?

A certification record must include the date of the examinations and tests, the signature of the person who performed them, and the serial number or other identifier of the equipment tested, per 1915.172(d).

  • Keep each record tied to the specific vessel identifier (serial number or other unique ID).
  • The record must show who performed the work and when it was done.

Reference: 1915.172(d).

Under 1915.172, who may perform the quarterly examination required for older portable air receivers?

The standard requires the examination be done by a "competent person," so the employer must designate someone capable of recognizing unsafe conditions and specifying necessary precautions to ensure employee safety, consistent with the definition of competent person in Part 1915. OSHA has explained that a competent person must be able to recognize hazards and specify needed protection, which supports using such a person for these examinations see OSHA's competent person guidance.

  • Practical steps: Document the person's qualifications and have them sign the certification record required by 1915.172(d).

References: 1915.172(b) and OSHA Letter of Interpretation on competent persons (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

Under 1915.172(a) and (b), what test pressure is required for hydrostatic testing of portable air receivers?

Both post-effective-date vessels built to ASME Section VIII and older vessels described in paragraph (b) must be hydrostatically tested at one and one-half times the working pressure (1.5× working pressure), per 1915.172(a) and 1915.172(b).

  • Ensure the working pressure used to calculate the test pressure is the vessel's official working pressure (manufacturer plate or design documentation).

References: 1915.172(a) and 1915.172(b).

Under 1915.172, must an employer keep certification records for portable air receiver tests and examinations, and what if an employer can't find the serial number?

Yes—1915.172(d) requires employers to maintain certification records that include the date, the signature of the person who performed the examination or test, and the serial number or other identifier of the equipment. If the serial number is missing, the employer should use another permanent identifier (for example, a stamped or welded ID, asset tag number, or a documented photo with measurements) and record that identifier on the certification.

  • Document how the substitute identifier was established and keep any supporting evidence with the certification record.

Reference: 1915.172(d).

Under 1915.172(b), what does a "quarterly examination by a competent person" typically include for older portable air receivers?

The standard requires a quarterly examination by a competent person but does not prescribe the exact checklist; however, a typical competent-person quarterly exam should inspect for corrosion, dents, leaks, damaged fittings, proper relief valve operation, mounting or support integrity, and visible pressure gauge function, and then be documented per 1915.172(d).

  • Recommended items to document: date, examiner's signature, vessel identifier, visible defects found, and corrective actions taken.

Reference: 1915.172(b) and the certification requirements in 1915.172(d).

Under 1915.172, if a portable air receiver fails its hydrostatic test, what must an employer do?

If a portable air receiver fails its hydrostatic test, the employer must remove it from service and repair or retire it; the failed condition should be documented in the certification record as required by 1915.172(d).

  • Practical guidance: Tag the vessel out-of-service, identify the failure cause, make repairs only if done in accordance with applicable codes or manufacturer instructions, and re-test at the required 1.5× working pressure before returning to service.

Reference: 1915.172(a),(b),(d).

Under 1915.172, when should relief valves be adjusted or replaced on portable air receivers?

Relief valves should be adjusted or replaced whenever they are not set to the safe working pressure of the vessel or to the lowest safe working pressure of the system (whichever is lower), per 1915.172(c).

  • Replace or recalibrate relief valves after repair of pressure systems, after failure during inspection or testing, or when serial documentation indicates they no longer meet the required setting.
  • Document any adjustments or replacement in the certification record as part of the examination/test history per 1915.172(d).

Under 1915.172, does the standard specify who may perform hydrostatic pressure tests on portable air receivers?

The regulation requires hydrostatic pressure tests but does not explicitly specify the certification or licensing of the person or agency that performs them; however, the employer must maintain certification records showing who performed the tests as required by 1915.172(d). Employers commonly use qualified testing shops or technicians experienced in pressure-vessel testing and should ensure the tester is competent and follows accepted procedures.

  • Best practice: Use a qualified testing facility that follows ASME or accepted hydrostatic test procedures and document the tester's name and credentials on the certification record.

Reference: 1915.172(d).

Under 1915.172, what does "working pressure" mean for the purpose of testing and relief valve settings?

The standard uses the term "working pressure" as the basis for hydrostatic test calculations and relief valve settings, but it does not define the term within 1915.172; in practice, "working pressure" is the maximum allowable operating pressure specified by the manufacturer or by the vessel's design code and normally appears on the vessel nameplate or construction documentation.

  • Practical steps: Verify the manufacturer's stamped working pressure or documented design pressure before calculating the 1.5× test pressure and before setting relief valves per 1915.172(a),(c).

Reference: 1915.172(a),(c).

Under 1915.172, if a portable air receiver is repaired or modified, when should it be retested?

A portable air receiver repaired or modified in a way that could affect pressure integrity should be retested at the required hydrostatic pressure (1.5× working pressure) before being returned to service, consistent with the testing requirements in 1915.172(a) and 1915.172(b).

  • Document the repair/modification and the subsequent test in the certification record per 1915.172(d).

Reference: 1915.172(a),(b),(d).

Under 1915.172, are portable air receivers used on multi-vessel systems allowed to have a relief valve set to the system's lowest safe working pressure?

Yes—1915.172(c) allows relief valves to be set to the vessel's safe working pressure or to the lowest safe working pressure of the system, whichever is lower, so in multi-vessel systems you should set the valve at the lowest safe pressure to protect the entire system.

  • Ensure that the chosen setting does not exceed any component's safe pressure and that documentation shows the rationale for the chosen set point.

Reference: 1915.172(c).

Under 1915.172, what documentation should an employer keep when a portable air receiver is taken out of service permanently?

If a portable air receiver is permanently taken out of service, employers should document the removal and include the action in the certification record required by 1915.172(d), noting the date, the signature of the person who performed the disposition, the vessel's serial number or identifier, and the reason for removal (e.g., failed hydrostatic test, corrosion beyond repair).

  • While the standard does not prescribe exact retention time, maintain these records as part of the vessel's inspection and test history to show compliance.

Reference: 1915.172(d).

Under 1915.172, can an employer rely on the original ASME marking alone to prove a vessel was inspected after purchase?

No—while the ASME marking required by 1915.172(a) shows the vessel was designed and constructed to the ASME Section VIII code, employers must still ensure the required hydrostatic tests and any required periodic examinations are performed and documented in certification records per 1915.172(d).

  • Keep test records and signatures even if the vessel retains its ASME nameplate.

Reference: 1915.172(a),(d).

Under 1915.172, do portable air receivers used on ships count as “ship's equipment” and are they treated differently?

Section 1915.172 covers "Portable, unfired pressure vessels, drums and containers, Other Than Ship's Equipment," so portable air receivers that are part of the ship's equipment are excluded from this particular provision; if a vessel is "ship's equipment," it would be regulated under the rules that apply to shipboard equipment rather than 1915.172.

  • Determine whether a receiver is ship's equipment; if it is not ship's equipment, follow the marking, testing, inspection, relief valve, and recordkeeping requirements of 1915.172.

Reference: 1915.172.

Under 1915.172, how should employers handle portable air receivers that are leased or borrowed from another employer?

Employers are responsible for ensuring leased or borrowed portable air receivers meet the requirements of 1915.172, including being marked (if required), tested at the proper hydrostatic pressure, quarterly-examined where applicable, and accompanied by certification records per 1915.172(d).

  • Practical approach: Obtain the vessel's documentation from the owner showing recent tests and examinations, verify serial numbers, and keep copies in your records; if no documentation exists, treat it as your responsibility to have required tests/exams performed.

Reference: 1915.172(d).

Under 1915.172, are there specific record retention times for the certification records of portable air receivers?

No—1915.172(d) requires that certification records be maintained, including date, signature, and equipment identifier, but the paragraph does not specify how long those records must be retained. Employers should keep records for a practical period that demonstrates compliance and supports safe operation (for example, the life of the vessel while in service plus a reasonable archive period) and follow any applicable company or state record-retention rules.

Reference: 1915.172(d).

Under 1915.172, is it acceptable to set a relief valve slightly below the vessel's stamped working pressure to prevent nuisance operation?

Yes—1915.172(c) allows relief valves to be set to the safe working pressure of the vessel or the lowest safe working pressure of the system, whichever is lower; setting slightly below the stamped working pressure is acceptable provided it does not exceed any system component's safe pressure and remains protective of personnel and equipment.

  • Document the valve setting and the rationale in your inspection/test records per 1915.172(d).

Reference: 1915.172(c),(d).

Under 1915.172, may a company rely on a vendor's hydrostatic test certificate for a portable air receiver purchased used?

Yes—an employer may rely on a vendor's hydrostatic test certificate as long as the certificate documents that the vessel was tested at the required pressure (1.5× working pressure) and includes the information required by 1915.172(d) (date, tester signature, and equipment identifier). If the certificate lacks required information, the employer should arrange a new test or obtain missing documentation.

  • Best practice: Keep a copy of the vendor's certificate in your own certification file and verify the serial number or other identifier matches the vessel.

Reference: 1915.172(a),(b),(d).