Comment from Killough, David; AARC Environmental, Inc.

COMMENTS from AARC Environmental, Inc. 1. Incorporation verbatim of CGA G-1-2009 Acetylene into 29 CFR 1910.102 will introduce a conflict with existing OSHA Rules, such as the following examples: 1910.253(b)(3): “Fuel-gas cylinder storage. Inside a building, cylinders, except those in actual use or attached ready for use, shall be limited to a total gas capacity of 2,000 cubic feet….” However, CGA G-1-2009 Acetylene, Paragraph 5 states: “Acetylene cylinders stored inside a building shall be limited to a total capacity of 2500 ft3....” 1910.253(b)(5)(ii)(P): “Unless connected to a manifold, oxygen from a cylinder shall not be used without first attaching an oxygen regulator to the cylinder valve. Before connecting the regulator to the cylinder valve, the valve shall be opened slightly for an instant and then closed. Always stand to one side of the outlet when opening the cylinder valve.” 1910.253(b)(5)(iii)(C): “Before connecting a regulator to a cylinder valve, the valve shall be opened slightly and closed immediately. The valve shall be opened while standing to one side of the outlet; never in front of it. Never crack a fuel-gas cylinder valve near other welding work or near sparks, flame, or other possible sources of ignition.” However, CGA G-1-2009 Acetylene, Paragraph 6.2 states: “...- Visually examine the CGA connection on the cylinder and remove any visible contamination before connecting the regulator. Clean out the contaminant using nitrogen, air, or a clean rag. Avoid opening an acetylene cylinder valve without a suitable regulator or flow restrictor such as a torch attached;....” “…- Never open a valve without proper attachments (regulator and torch or regulator and flow restriction of some type such as a flowmeter).” 2. AARC believes that the rulemaking process should include an assessment of how other existing OSHA Rules may be affected by the new or amended rule.