Comment from Paulson, Nicholas; University of Wisconsin-Stout

The new proposed regulations for acetylene seem to have greater depth than the old regulations. However, in reading the other comments to this proposal by representatives of the industry, it would appear that there are still some loose ends which would need to be addressed. In order for the regulation changes to be affective, it would seem that more input from the industry would be necessary. Please note the comments submitted by the Technical Manager from the CGA. In the comment he states changes which have been made since the 2003 version of the pamphlet, specifically the note in section 5.2. He also states that this change was made to comply with the National Fire Protection Agency publication NFPA 51. One question that I have after reading that is if the regulations are up to date with the NFPA publications? I find it a bit preposterous that the current regulation still references a CGA pamphlet from 1966. In order to have the best interest in mind for the industry and the people involved in the industry, it would seem that the changes and regulations would need to be kept more current to the practices in use. As a Quality Engineer, I have been exposed to a number of standards, policies and procedures. In order for an adequate review of a change in any of those it would require all of the reference documents. In this case, the documents are not all accessible to non members of the CGA. With consideration to changes being made on an annual basis by all of the industry groups that OSHA uses in reference, it would incredibly difficult for OSHA to keep up to date in all of their regulations. It would seem that the best course of action would be to incorporate the latest version of the pamphlet when submitting proposed regulation changes.