Have you seen these devices before? They are a neat little device, but I would call them the "snuggy" of the welding world! You know the "snuggy", "the blanket with sleeves" for people who struggle to use an ordinary blanket!!! They have sold millions of "snuggies" and I would bet, these little contraptions will not be far behind. But do they really make us compliant or just lazy?
1910.253(b)(4)(iii) Oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of 20 feet (6.1 m) or by a noncombustible barrier at least 5 feet (1.5 m) high having a fire-resistance rating of at least one-half hour.
Before I go any further, can anyone tell me why the cylinders in the marketing photo above are NOT in compliance? That is correct... no safety caps - yet they are in storage! But I digress...
This fire wall device is meant to allow us to leave the cylinders on the cart, most often a welding/torch cart, rather than removing them and separating them by 20'. The requirement stated in the above referenced standard speaks for itself, but the question lies in the what OSHA considered "in storage" or "in use/ready to use". So in May of 2006 OSHA issued the letter of interpretation (LOI) - General industry and construction standards regarding "in use" or "ready to use" and "storage" of compressed gas and oxygen cylinders for welding; §1910.253(b)(2)-1910.253(b)(4) and §1926.350(a)(10), which defines "storage" as... when it is reasonably anticipated that gas will not be drawn from the cylinder within 24 hours (overnight hours included). So by having this 5' tall 30-minute fire wall allows us to "store" the oxygen with the acetylene on the cart. Pretty clever idea, huh? HOWEVER, it may not be so simple all of the time!!!
This year I have come across several instances where these special carts have created true storage compliance issues. You see when the two cylinders on the same cart are seperated by the fire wall and there is ONLY the one (1) cart in the area, all is OK; but when there are more than one (1) of these two-cylinder carts parked within 20' of each other, we do NOT have proper seperation distance AND we VERY WELL MAY have oxygen cylinders stored directly next to acetylene cylinders! Depending on how the cylinders are arranged on each cart, we could very easily have oxygen and acetylene cylinders stored next to each other. Let's say (and this is what we saw) that two of the carts are sitting next to each other AND the cylinders on each cart are in the same order (Oxygen on the left and Acetylene on the right). With them parked next to each other, we now have a compliance issue - even though each cart has its 30 minute 5' fire wall!!!
Although I could not take a photo, imagine a 10' X 10' fenced cage area with about a dozen of these two wheeled carts with their cylinders seperated by the fire wall. At the end of the day, the contractors roll these carts into this cage to secure them while they are not being used during off hours. I happened to walk by about the time the gate was being closed and asked about the "storage". Seeing how this was on a Friday and no one was working the weekend, I knew the carts and cylinders would be there longer than the 24 hours. The manner in which they were so neatly parked in their rows within the fence, they had oxygen cylinders and acetylene cylinders within inches of each other. As shown by the cart design below, the larger diametered acetylene cylinders are forced to go on the same side on each cart. This means that when two of these style carts are sitting next to each other, or in front of another cart - the firewalls on the two carts do not seperate the acetylene on cart #1 and the Oxygen on Cart #2.
So bottom line, these speciality carts do help facilities achieve compliance for those torch/welding carts they wish to maintain in a "ready state". I for one do not understand the urgency of having to have a welding cart be ready in a moments notice, but that is me ( I do not own a "Snuggy" either). But if we stored multiple carts of this type within 20' of each other we very well may be out of compliance (although minor) since we will not have a 20' seperation or a 5' 30-minute fire wall between all the the oxygen and acetylene cylinders. Just something to consider when bringing these devices into your plant or worksite.