Welding or cutting can involve metal that is galvanized, painted or plated. A practical question is what OSHA's general industry welding rule requires when the base metal, filler metal or coating contains zinc, lead, cadmium or similar materials. The answer is in 29 CFR 1910.252(c), "Health protection and ventilation", paragraphs (c)(5) through (c)(12). This explainer reads the current eCFR text for general industry (Part 1910); it does not describe a rule change. OSHA rules are separate from any welder certification: they set duties at the workplace, not a test.
What is the general rule before the specific materials?
Section 1910.252(c)(1)(iii) states: "Local exhaust or general ventilating systems shall be provided and arranged to keep the amount of toxic fumes, gases, or dusts below the maximum allowable concentration as specified in § 1910.1000 of this part."
For ordinary metals, (c)(2)(i) requires mechanical ventilation in the three situations it lists (small spaces per welder, low ceilings, and confined or obstructed spaces) "when welding or cutting is done on metals not covered in paragraphs (c)(5) through (c)(12) of this section." It adds: "For specific materials, see the ventilation requirements of paragraphs (c)(5) through (c)(12) of this section." So the material-specific paragraphs below are the ones to read when the metal or coating is one of them.
Many of those paragraphs point back to two other paragraphs: (c)(3), "Local exhaust hoods and booths", and (c)(4), "Ventilation in confined spaces". Under (c)(4)(i), welding and cutting in confined spaces "shall be adequately ventilated to prevent the accumulation of toxic materials or possible oxygen deficiency", and (c)(4)(v) states: "Oxygen shall never be used for ventilation."
What about zinc, such as galvanized steel?
Section 1910.252(c)(6) has two parts:
- Confined spaces: welding or cutting "involving zinc-bearing base or filler metals or metals coated with zinc-bearing materials shall be done in accordance with paragraph (c)(4) of this section."
- Indoors: welding or cutting "involving zinc-bearing base or filler metals coated with zinc-bearing materials shall be done in accordance with paragraph (c)(3) of this section."
What about lead, including lead paint?
Section 1910.252(c)(7) covers lead. In confined spaces, "welding involving lead-base metals (erroneously called lead-burning)" follows (c)(4), and indoors it follows (c)(3). Paragraph (c)(7)(iii) then states: "In confined spaces or indoors, welding or cutting operations involving metals containing lead, other than as an impurity, or metals coated with lead-bearing materials, including paint, must be done using local exhaust ventilation or airline respirators. Such operations, when done outdoors, must be done using respirators approved for this purpose by NIOSH under 42 CFR part 84. In all cases, workers in the immediate vicinity of the cutting operation must be protected by local exhaust ventilation or airline respirators."
What about cadmium and mercury?
For cadmium, (c)(9)(i) states that in confined spaces or indoors, welding or cutting "involving cadmium-bearing or cadmium-coated base metals must be done using local exhaust ventilation or airline respirators unless atmospheric tests under the most adverse conditions show that employee exposure is within the acceptable concentrations specified by 29 CFR 1910.1000." Outdoors, such work "must be done using respirators, such as fume respirators, approved for this purpose by NIOSH under 42 CFR part 84." Under (c)(9)(ii), brazing with cadmium-bearing filler metals in a confined space uses the ventilation in (c)(3) or (c)(4).
Mercury, in (c)(10), follows the same pattern for "metals coated with mercury-bearing materials, including paint": local exhaust ventilation or airline respirators in confined spaces or indoors, unless the same atmospheric tests show exposure within the limits, and NIOSH-approved respirators outdoors.
What about beryllium, fluorine fluxes and stainless steel?
- Beryllium, (c)(8): welding or cutting "indoors, outdoors, or in confined spaces involving beryllium-containing base or filler metals shall be done using local exhaust ventilation and airline respirators unless atmospheric tests under the most adverse conditions have established that the workers' exposure is within the acceptable concentrations defined by § 1910.1000 of this part."
- Fluorine compounds, (c)(5): in confined spaces, work with "fluxes, coverings, or other materials which contain fluorine compounds" follows (c)(4). Outside confined spaces, the paragraph says the need for local exhaust or airline respirators "will depend upon the individual circumstances", and that such protection is not necessary where air samples taken at the welding location show the fluorides liberated are below the maximum allowable concentration.
- Stainless steel, (c)(12): oxygen cutting with a chemical flux or iron powder, or gas-shielded arc cutting, of stainless steel "shall be done using mechanical ventilation adequate to remove the fumes generated."
- Cleaning compounds, (c)(11)(ii): degreasing with chlorinated hydrocarbons "shall be so located that no vapors from these operations will reach or be drawn into the atmosphere surrounding any welding operation."
Does hazard communication apply to these materials?
Yes. Under (c)(1)(iv), the employer must include the potentially hazardous materials in fluxes, coatings, coverings and filler metals in its Hazard Communication program under § 1910.1200, and "Potentially hazardous materials shall include but not be limited to the materials itemized in paragraphs (c)(5) through (c)(12) of this section."
Where to check before you act
These are the general industry rules as they read in eCFR on the date above; the exposure limits themselves are in § 1910.1000 and are not summarized here. Construction work has its own welding rules in 29 CFR Part 1926, Subpart J. Our study guides cover the rest of each subpart: OSHA general industry welding and OSHA construction welding and cutting. Welding certification is a planned topic on goraedu; see all certifications for its status.
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