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Texas Department

of Insurance

Welding Hazards
Safety Program

Provided by

Division of
Workers’
Compensation
HS04-044A(12-06)
Welding Hazards Safety Program • chemical reactions which result by the action of
Welding, cutting, and brazing are hazardous activities ultraviolet light from the arc, and heat;
that pose a unique combination of both safety and • process and consumables used; and
health risks to more than 500,000 workers in a wide • contaminants in the air, for example vapors from
variety of industries. According to the Occupational cleaners and degreasers.
Safety and Health Administration (OSHA), the risk The health effects of welding exposures are difficult to
from fatal injuries alone is more than four deaths per list, because the fumes may contain so many different
thousand workers over a working lifetime. Protect- substances that are known to be harmful (depending
ing the worker when performing welding operations on the factors listed above). The individual compo-
depends on understanding of the hazards involved and nents of welding smoke can affect just about any part
the proper way to control them. Control of welding of the body, including the lungs, heart, kidneys, and
hazards includes avoiding eye injury, respiratory pro- central nervous system.
tection, ventilation of the work area, protective cloth- Welders who smoke may be at greater risk of health
ing, and having safe equipment to use. impairment than welders who do not smoke, although
Welding joins pieces of metal by the use of heat, pres- all welders are at risk.
sure, or both. There are more than 80 different types Exposure to welding smoke may have short-term and
of welding and associated processes. Some of the long-term health effects.
most common types of welding include: arc welding, Short-term (acute) health effects
which includes “stick” or shielded metal arc welding • Exposure to metal fumes (such as zinc, magnesium,
(SMAW), the gas-shielded methods of metal inert gas copper, and copper oxide) can cause metal fume
(MIG) and tungsten inert gas (TIG), plasma arc weld- fever. Symptoms of metal fume fever may occur
ing (PAW), and submerged arc welding (SAW). Other 4 to 12 hours after exposure, and include chills,
welding processes may use oxy-acetylene gas, electri- thirst, fever, muscle ache, chest soreness, coughing,
cal current, lasers, electron beams, friction, ultrasonic wheezing, fatigue, nausea, and a metallic taste in
sound, chemical reactions, heat from fuel gas, and the mouth.
robots. • Welding smoke can also irritate the eyes, nose,
Brazing or soldering, involves a filler metal or alloy chest, and respiratory tract, and cause coughing,
(a combination of metals), which has a lower melting wheezing, shortness of breath, bronchitis, pulmo-
point than the metal pieces to be joined. The filler ma- nary edema (fluid in the lungs), and pneumoni-
terials (such as lead and cadmium) can be very toxic. tis (inflammation of the lungs). Gastrointestinal
Cutting involves heating the metal with a flame, and effects, such as nausea, loss of appetite, vomiting,
directing a stream of pure oxygen along the line to be cramps, and slow digestion, have also been associ-
cut. ated with welding.
Health Hazards of Welding • Some components of welding fumes, for example
Gases and Fumes cadmium, can be fatal in a short time. Secondary
Welding “smoke” is a mixture of very fine particles gases given off by the welding process can also
(fumes) and gases. Many of the substances in welding be extremely dangerous. For example, ultraviolet
smoke, such as chromium, nickel, arsenic, asbestos, radiation given off by welding reacts with oxygen
manganese, silica, beryllium, cadmium, nitrogen ox- and nitrogen in the air to form ozone and nitrogen
ides, phosgene, acrolein, fluorine compounds, carbon oxides. These gases are deadly at high doses, and
monoxide, cobalt, copper, lead, ozone, selenium, and can also cause irritation of the nose and throat and
zinc can be extremely toxic. serious lung disease.
Generally, welding fumes and gases come from: • Ultraviolet rays given off by welding can also react
• base material being welded or the filler material with chlorinated hydrocarbon solvents, to form
that is used; phosgene gas. Even a very small amount of phos-
• coatings and paints on the metal being welded, or gene may be deadly, although early symptoms of
coatings covering the electrode; exposure—dizziness, chills, and cough—usually
• shielding gases supplied from cylinders; take 5 or 6 hours to appear. Arc welding should
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never be performed within 200 feet of degreasing hot electrodes can cause eye injuries.
equipment or solvents. • Excessive exposure to heat can result in heat stress
Long-term (chronic) health effects or heat stroke. Welders should be aware of the
• Studies have shown that welders have an increased symptoms - such as fatigue, dizziness, loss of appe-
risk of lung cancer, and possibly cancer of the tite, nausea, abdominal pain, and irritability. Venti-
larynx (voice box) and urinary tract. These find- lation, shielding, rest breaks, and drinking plenty of
ings are not surprising in view of the large quantity cool water will protect workers against heat-related
of toxic substances in welding smoke, including hazards.
cancer-causing agents such as cadmium, nickel, Visible Light, and Ultraviolet and Infrared Radiation
beryllium, chromium, and arsenic. • The intense light associated with arc welding can
• Welders may also experience a variety of chronic cause damage to the retina of the eye, while infra-
respiratory (lung) problems, including bronchitis, red radiation may damage the cornea and result in
asthma, pneumonia, emphysema, pneumoconiosis the formation of cataracts.
(refers to dust-related diseases), decreased lung • Invisible ultraviolet light (UV) from the arc can
capacity, silicosis (caused by silica exposure), and cause “arc eye” or “welder’s flash” after even a
siderosis (a dust-related disease caused by iron brief exposure (less than one minute). The symp-
oxide dust in the lungs). toms of arc eye usually occur many hours after
• Other health problems that appear to be related exposure to UV light, and include a feeling of sand
to welding include: heart disease, skin diseases, or grit in the eye, blurred vision, intense pain, tear-
hearing loss, chronic gastritis (inflammation of ing, burning, and headache.
the stomach), gastroduodenitis (inflammation of • The arc can reflect off surrounding materials and
the stomach and small intestine), and ulcers of the burn co-workers working nearby. About half of
stomach and small intestine. Welders exposed to welder’s flash injuries occur in co-workers who are
heavy metals such as chromium and nickel have not welding. Welders and cutters who continually
also experienced kidney damage. work around ultraviolet radiation without proper
• Welding also poses reproductive risks to welders. protection can suffer permanent eye damage.
A recent study found that welders, and especially • Exposure to ultraviolet light can also cause skin
welders who worked with stainless steel, had burns similar to sunburn, and increase the welder’s
poorer sperm quality than men in other types of risk of skin cancer.
work. Several studies have shown an increase in Noise
either miscarriages or delayed conception among • Exposure to loud noise can permanently damage
welders or their spouses. Possible causes include welders’ hearing. Noise also causes stress and in-
exposure to: (1) metals, such as aluminum, chro- creased blood pressure, and may contribute to heart
mium, nickel, cadmium, iron, manganese, and disease. Working in a noisy environment for long
copper; (2) gases, such as nitrous gases and ozone; periods of time can make workers tired, nervous,
(3) heat; and (4) ionizing radiation (used to check and irritable.
the welding seams). • If you work in a noisy area, the OSHA Noise Stan-
• Welders who perform welding or cutting on sur- dard, Code of Federal Regulations (CFR) 1910.95,
faces covered with asbestos insulation are at risk requires your employer to test for noise levels to
of asbestosis, lung cancer, mesothelioma, and other determine your exposure. If your average noise ex-
asbestos-related diseases. Employees should be posure exceeds 85 decibels for over 8 hours, your
trained and provided with the proper protective employer must provide you with a choice of free
equipment before welding near asbestos-containing hearing protection and annual hearing tests.
material. Musculoskeletal Injuries
Other Health Hazards Welders have a high prevalence of musculoskeletal
Heat complaints, including back injuries, shoulder pain,
• The intense heat of welding and sparks can cause tendonitis, reduced muscle strength, carpal tunnel
burns. Contact with hot slag, metal chips, sparks, and syndrome, white finger, and knee joint diseases. Work
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postures (especially welding overhead, vibration, and toxic vapors may result. Containers with unknown
heavy lifting) can all contribute to these disorders. contents should be assumed to be flammable or
These problems can be prevented by proper lifting combustible.
techniques: • A fire inspection should be performed before leav-
• not working in one position for long periods of ing the work area and within 30 minutes after the
time; operation is completed. Fires extinguishers should
• keeping the work at a comfortable height; be nearby.
• using a foot rest when standing for long periods; Dangerous machinery
• locating tools and materials conveniently; and • All machines in the area with moving parts must be
• minimizing vibration. guarded to prevent workers’ hair, fingers, clothing,
Safety Hazards of Welding etc. from getting caught.
Electrical hazards • When repairing machinery by welding or braz-
• Even though welding generally uses low voltage, ing, power must be disconnected, locked out, and
there is still a danger of electric shock. The envi- tagged so that the machinery cannot start up acci-
ronmental conditions of the welder (such as wet dentally.
or cramped spaces) may make the likelihood of a Trips and falls
shock greater. Falls and other accidents can result • To prevent trips and falls, keep welding areas clear
from even a small shock; brain damage and death of equipment, machines, cables, and hoses, and use
can result from a large shock. safety lines or rails.
• Dry gloves should always be worn to protect Hazards of Welding in Confined Spaces
against electric shock. The welder should also wear A confined space is a small or crowded area with
rubber-soled shoes, and use an insulating layer, limited access and little or no airflow or ventilation.
such as a dry board or a rubber mat, for protection Adequate ventilation is essential for working in con-
on surfaces that can conduct electricity. fined spaces. Dangerous concentrations of toxic fumes
• The piece being welded and the frame of all elec- and gases can build up very quickly in a small space.
trically powered machines must be grounded. The Unconsciousness or death from suffocation can occur
insulation on electrode holders and electrical cables rapidly because welding processes can use up or dis-
should be kept dry and in good condition. Elec- place oxygen in the air. High concentrations of some
trodes should not be changed with bare hands, wet fumes and gases can also be very explosive.
gloves, or while standing on wet floors or grounded The following rules apply:
surfaces. • All workers who may enter dangerous areas either
Fires and explosions on a regular basis or in an emergency situation
• The intense heat and sparks produced by welding, should be trained on rescue procedures, self-con-
or the welding flame, can cause fires or explosions tained breathing apparatus, use of safety equip-
if combustible or flammable materials are in the ment, and proper procedures for entering and
area. exiting a confined space.
• Welding or cutting should only be performed in • The worker inside the confined space should be
areas that are free of combustible materials, includ- equipped with a safety harness, a lifeline, and ap-
ing trash, wood, paper, textiles, plastics, chemicals, propriate personal protective clothing, including a
and flammable dusts, liquids, and gases (vapors self-contained breathing apparatus. (Never use an
can travel several hundred feet). Those that cannot air-purifying respirator.)
be removed should be covered with a tight-fitting • Gas cylinders and welding power sources should be
flame-resistant material. Doorways, windows, located in a secure position outside of the confined
cracks, and other openings should be covered. space.
• Never attempt to weld containers that have held a • A trained worker must be stationed outside of the
flammable or combustible material unless the con- confined space, and equipped with appropriate gear
tainer is thoroughly cleaned or filled with an inert (including a fire extinguisher and personal protec-
(non-reactive) gas. Explosions, fires, or release of tive equipment), to assist or rescue the worker
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inside the confined space if necessary. If the worker and checked regularly.
notices any indications of intoxication or decreased • Cylinders must be stored upright so that they will
alertness from the “inside” worker, the inside not fall over.
worker should be removed from the area immedi- • Oxygen and fuel cylinders must be stored separate-
ately. ly, away from heat and sunlight, and only in a dry,
• All confined spaces should be tested before enter- well-ventilated, fire-resistant area that is at least 20
ing for toxic, flammable, or explosive gases or feet away from flammable materials such as paint,
vapors, and oxygen level. Continuous air monitor- oil, or solvents.
ing may be necessary during welding. No worker • Be aware of backfires and flashbacks that are usu-
should enter a confined space where the percent- ally caused by defective or incorrectly operated
age of oxygen is below 19.5% unless he or she is equipment. If a backfire occurs, shut off the blow-
equipped with a supplied-air respirator. pipe valves, oxygen first and then the fuel gas; shut
• Never use oxygen for ventilation. off the oxygen and fuel gas cylinder valves; cool
• Use continuous mechanical ventilation and a res- the blowpipe with water; and check the equipment
pirator whenever welding or performing thermal for damage, particularly the nozzle. To prevent
cutting in a confined space. flashbacks use the correct lighting up procedure;
• All pipes, ducts, and power lines connected to the ensure the blowpipe is fitted with spring-loaded
space, but not necessary to the operation should non-return valves to prevent a backflow of gas into
be disconnected or shut off. All shutoff valves and the hoses; use the correct gas pressure and nozzle
switches should be tagged and locked out so they size for the job; and maintain the equipment in
cannot accidentally be restarted. good condition.
• All unnecessary torches and other gas or oxygen- • Close cylinder valves when work is finished. Put
supplied equipment should be removed from the valve protection caps in place and release pressure
confined space. in regulators and hose lines before cylinders are
Hazards of Compressed Gases moved or placed in storage.
Gas welding and flame cutting use a fuel gas and Reducing the Hazards of Welding
oxygen to produce heat for welding. For high-pressure Before beginning a welding job, it is important to
gas welding, both the oxygen and the fuel gas (acety- identify the hazards for that particular welding opera-
lene, hydrogen, propane, etc.) supplied to the torch are tion. The hazards will depend on the type of welding,
stored in cylinders at high pressure. the materials (base metals, surface coatings, elec-
The use of compressed-gas cylinders poses some trodes) to be welded, and the environmental conditions
unique hazards to the welder. Acetylene is very ex- (outside or in a confined space, for instance).
plosive. It should be used only with adequate ventila- Ask for Material Safety Data Sheets (MSDSs) to
tion and a leak detection program. Oxygen alone will identify the hazardous materials used in welding and
not burn or explode. At high oxygen concentrations, cutting products, and the fumes that may be generated.
however, many materials (even those that are difficult Make sure you know what you are welding before you
to burn in air, such as normal dust, grease, or oil) will start. Some fumes, such as those released from weld-
burn or explode easily. These are some rules to follow ing a cadmium-plated surface, can be fatal in a short
when using compressed gases. time.
• All cylinders should have caps or regulators. After identifying the hazard, appropriate control meth-
• Only pressure regulators designed for the gas in use ods can be implemented.
should be fitted to cylinders. Engineering Controls and Work Practices
• Compressed gas cylinders, all pressure relief Use less hazardous materials such as:
valves, and all lines should be checked before and • Cadmium-free silver solders; and
during welding operations. • Asbestos-free electrodes, gloves, and hot pads.
• Blowpipes must be kept in good condition and Ventilation should be used to remove harmful fumes
cleaned at regular intervals. and gases. Local exhaust ventilation, which re-
• Hoses and fittings should be kept in good condition moves the fumes and gases at their source, is the
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most effective method. This can be provided by a • Arc welding should never be performed within 200
partial enclosure, such as a ventilated workbench, feet of degreasing equipment or solvents.
or by hoods positioned as close to the point of Personal Protective Equipment (PPE)
welding as possible. Ventilation systems should be Personal Protective Equipment should always be used
cleaned and maintained regularly. General ventila- along with, but never instead of, engineering controls
tion uses roof vents, open doors and windows, roof and safe work practices!
fans, or floor fans to move air through the entire Eye protection should be used for all welding opera-
work area. This is not as effective as local exhaust tions to protect the eyes from bright light, heat, ultra-
ventilation, and may simply spread chemicals violet light, and flying sparks. For the best protection,
around the workplace. General ventilation is often wear face shields or helmets and goggles. To keep slag
helpful, however, when used to supplement local and particles out of your eyes when removing your
ventilation. face shield, tip your head forward and keep your eyes
For gas-shielded arc welding processes, local exhaust closed.
can be provided by means of an extracting gun, which Welding helmets, goggles, or other eye protectors
can reduce worker exposure to welding emissions by must contain special filter plates or lenses for work-
70%. ers exposed to arc welding or cutting processes, and
Hoods and ductwork should be constructed of fire-re- oxyfuel gas welding, brazing or cutting. The OSHA 29
sistant materials. CFR 1910, Subpart Q requires that workers perform-
Use shielding (barriers) to protect other people in the ing welding and cutting operations are protected with
work area from the light of the welding arc, heat, and filter lenses or plates.
hot spatter. Protective clothing which should be worn during
Welding booths should be painted with a dull finish welding (by welders and nearby workers) includes:
that does not reflect ultraviolet light (such as finishes • fire-resistant gauntlet gloves;
that contain titanium dioxide or zinc oxide). • high-top hard-toed shoes;
Acoustic shields between the worker and the noise • leather apron;
source can be used to reduce noise levels. Alternative- • faceshield;
ly, the machinery or process can be totally enclosed. • flame-retardant coveralls;
Modify the process or follow safe work practices so • safety glasses;
that hazards are eliminated. • helmets; and
• Don’t weld painted or coated parts. If possible, • leggings or high boots.
remove all surface coatings before welding. Protective clothing should be made of wool, which
• Use a water table under the plasma arc cutting to does not ignite easily, or specially treated cotton fab-
reduce fume and noise levels. rics. Sleeves and collars should be kept buttoned, and
• Grind parts instead of air arcing. pants and shirts should be uncuffed. Capes and hard
• Use the sub arc process to minimize light and hats may also be required. Workers should use weld-
fumes created by a visible arc. ing helmets (with appropriate filter lenses), not hand-
• Position yourself while welding or cutting so that held screens. When welding overhead, extra protection
your head is not in the fumes. should be used, such as fire-resistant shoulder covers,
• Remove all nearby flammable or combustible ma- aprons, head covers, leggings, and suits. Earplugs
terials before striking an arc or lighting a flame. should be worn when sparks or hot spatter may get in
• Make sure that equipment is properly maintained, the ears.
for example, replace worn insulation and hoses. Since welders work with highly toxic materials, lock-
• Welding areas should be kept free of equipment ers should be provided so that work clothes are stored
and machines that could cause trips or falls. separately from street clothes.
• You can minimize the production of welding fumes Hearing protectors (ear plugs or ear muffs) should be
by using the lowest acceptable amperage and hold- used during noisy operations such as air arcing and
ing the electrode perpendicular and as close to the grinding.
work surface and possible. Respirators must be specific to the hazard, and fitted,
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cleaned, stored, and maintained in accordance with ing controls and work practices.
OSHA’s respirator standard. In addition, workers Labels and Other Information
must receive training on how to use respirators prop- Under OSHA’s 29 CFR 1910.252 (c)(1)(iv)(A), all
erly. The National Institute for Occupational Safety containers of filler metal, electrodes, and flux materi-
and Health (NIOSH) recommends that respirators be als should carry warning labels alerting the welder that
worn whenever a carcinogen (cancer-causing agent) welding produces hazardous fumes and gases. Base
is present at any detectable concentration, or if any metals that contain or are coated with toxic materials
other conditions are present that might be immediately (such as paints, lead, or mercury) should also be clear-
dangerous to life or health. A self-contained breathing ly labeled. Welding materials that contain carcinogens
apparatus should be worn when welding in confined (cancer-causing agents) must carry a warning label
spaces because welding may reduce the oxygen con- stating that gases from the material may cause cancer.
centration in the air. The employer must also keep MSDSs for all of these
Air Monitoring hazardous materials, and make this information read-
Routine air monitoring should be conducted to deter- ily available to all exposed workers. The MSDS must
mine the levels of hazardous materials and noise in the contain information on chemical ingredients, hazard-
welding area. ous decomposition products from welding, safe han-
Medical Monitoring dling procedures, protective measures, first aid proce-
Because welding emissions are so hazardous, NIOSH dures, and health effects of the welding material.
recommends that all workers who may be exposed Signs
to welding processes should receive medical exams OSHA’s standard for signs and tags (29 CFR
at least once a year. The doctor should examine the 1910.145) requires that signs be used to warn workers
lungs, skin and eyes, heart, and hearing, in addition to of hazards that may lead to accidental injury. Signs
any other tests that are appropriate. should be posted in welding areas to warn workers of
Training exposure hazards, and serve as a reminder for the need
All welders should receive training on the safe use for protective equipment. Signs should also notify all
of equipment and processes, safe work practices, and workers in the area that eye injury may occur from
emergency procedures. looking at the welding arc.
The Law OSHA’s Welding Standard
OSHA has standards that cover many aspects of Specific requirements for assuring the safety of weld-
welding work, including welding safety, welding in ing, cutting, and brazing operations are covered under
confined spaces, handling of compressed gases, fire OSHA Standard 29 CFR 1910.252. Below are some
and electrical safety, ventilation, protective equipment, selected requirements of the standard:
and worker training. Insist on safe working conditions • Compressed gas cylinders must be kept away from
before welding. The following is a brief summary of radiators and other heat sources and stored upright
some of the regulations that can apply to welders. in a well ventilated, dry location at least 20 feet
Workplace Exposure Limits from highly combustible materials such as oil. Cyl-
There is no OSHA standard for total welding smoke, inders should be kept away from elevators, stairs,
but OSHA does set standards for individual compo- or other spaces where they can be knocked over or
nents of welding smoke. Local exhaust or general damaged.
ventilation must be provided to keep your exposure to • Piping systems must be tested and proved gastight
toxic fumes, gases, or dusts below the OSHA permis- at 1 1/2 times the maximum operating pressure,
sible exposure limit. and shall be thoroughly purged with air, before be-
However, NIOSH has concluded that welders can be ing placed in service. Service piping systems must
harmed by welding smoke even when the concentra- be protected by pressure relief devices.
tions of the individual components are well below • Hoses showing leaks, burns, worn places, or other
OSHA permissible exposure limits. NIOSH recom- defects must be repaired or replaced.
mends that welding emissions be reduced to the lowest • Cutters and welders must be suitably trained in the
feasible concentrations using state-of-the-art engineer- safe operation of their equipment and the safe use
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of the process. New Welding Technologies
• The welder should be enclosed in an individual New technologies in welding, such as laser welding
booth, or by non-combustible screens, that are and electron beam welding, bring new hazards to the
painted with a finish of low reflectivity such as zinc welder’s environment. Special precautions must be
oxide or lamp black (to absorb ultraviolet radia- taken when using these welding methods.
tion). Other people next to the welding area must Laser Welding
be protected by noncombustible or flameproof Laser welding uses a focused beam of light to achieve
screens or be required to wear appropriate goggles. very precise welds. The major hazard of this powerful
The booths or screens should permit circulation of beam is to the eyes, which can be partially blinded
air at the floor level. when hit with the beam. Special eye protection must
• All movable fire hazards in the vicinity of welding be used, and care must be taken with any reflective
operations must be taken to a safe place. If all the surfaces since both the original and reflected beam are
fire hazards cannot be moved, guards must be used extremely dangerous.
to contain the heat, sparks, and slag. Electron Beam Welding
• Suitable fire extinguishing equipment must be This method uses a focused beam of electrons to
maintained ready for instant use. produce high precision and deep penetration welds.
• Firewatchers are required whenever welding or Since x-rays are produced as a by-product, the process
cutting is performed in a location where other than should be enclosed and shielded with lead or other
a minor fire might develop. A fire watch must be materials suitable for preventing x-ray exposure. All
maintained for at least 1/2 hour after completion of doors, ports, and other openings must have proper
welding or cutting operations to detect and extin- seals and should be checked periodically to prevent
guish possible smoldering fires. x-ray leakage.
• No welding, cutting, or other hot work shall be Operators should wear film badges to detect accidental
performed on used drums, barrels, tanks, or other radiation exposure. The high voltages required also
containers until they have been thoroughly cleaned present an electrical hazard.
(a purge with an inert gas is also recommended). Robot Welders
• Eye protection must be used during all arc welding Many industries are beginning to use robot welders
or arc cutting operations, gas welding, oxygen cut- in place of human workers on the assembly line. This
ting, resistance welding, or brazing operations (the removes workers from the hazard, but focuses on job
proper shade number should be selected). elimination rather than workplace improvements. In
• When a welder must enter a confined space through addition, industrial-welding robots can injure workers.
a manhole or other small opening, an attendant For additional safety and health information on weld-
with a pre-planned rescue procedure must be ing hazards please refer to the Occupational Health
stationed outside to observe the welder at all times and Safety Administration; the American Federation of
and to put the rescue operation into effect, if neces- State, County and Municipal Employees; or the Texas
sary. Department of Insurance (TDI), Division of Workers’
• Special ventilation and/or respirators are required Compensation (DWC).
in confined spaces, for cleaning compounds, when Remember to practice safety. Don’t learn it by acci-
fluorine compounds, zinc, lead, beryllium, cad- dent.
mium, and mercury are encountered, and when The Texas Department of Insurance, Division of
cutting stainless steel. Workers’ Compensation has the following safety and
• Warning labels are required for all filler metals and health publications with information on welding haz-
fluxes containing fluorine compounds (fluorides). ards:
• Confined Space (Safety Training Program)
• Welding, Cutting, and Brazing Checklist
• Compressed Gas Cylinders (Take 5)
• Confined Space (Sample OSHA Written Program)

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