Comment from Willis, Richard; Alabama Power Company

Our area of concern is the recommended practice of using a flow rate of one-tenth of the cylinder capacity per hour during intermittent use, and one-fifteenth of the cylinder capacity per hour during continuous use. As long as this flow rate remains advisory in nature this is not a problem. If this became mandatory, it could require the use of larger cylinders or the manifolding multiple cylinders in order to maintain a sufficient flow of acetylene to the torch tip. In the first case, the weight of the cylinders would dramatically increase and produce a corresponding increase in the employee’s exposure to back and other musculoskeletal injuries. If manifolding is used to get the desired flow rate then extra cost would be incurred for purchasing and maintaining the equipment plus the amount of manual handling of the cylinders would be increased. If the 2003 edition of CGA-1 is adopted, OSHA should ensure that employers continue to be able to use a flow rate of either the one-seventh of the capacity of the cylinder found in the 1966 edition of CGA pamphlet G-1 or the one-tenth rate found in the 2003 edition of CGA pamphlet G-1.