Interpretation for questions related to compliance with NFPA 33 (1995 edition).

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 14, 1996

Mr. Stephen H. Jero
Manager of Product Testing
Research Products Corporation
P.O. Box 1467
Madison, Wisconsin 53701-1467

Dear Mr. Jero:

Thank you for your letter of April 12 requesting a written interpretation for questions related to compliance with NFPA 33 (1995 edition). You inquired as to whether compliance with NFPA 33 offered "equal or greater employee protection" and if a company would be cited if they comply with NFPA 33.

Spray Finishing.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 15, 1996

Mr. Michael K. Haufe, P.E.
Technical Director
Distributions Products Division
Columbus Industries, Inc.
P.O. Box 257
2938 State Route 752
Ashville, Ohio 43103-0257

Dear Mr. Haufe:

Thank you for your letter of February 6 regarding spray finishing as covered under 29 CFR 1910.107. Your question related to the Occupational Safety and Health Administration's (OSHA) possible future updating of 1910.107(b)(5)(vi) and what the agency's interim enforcement policy will be until such an updated standard is promulgated.

The compliance of a thermoreactor product with OSHA standards.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 23, 1984

Mr. A. E. Burr
Vice President
Sunkiss Thermoreactors, Inc.
4900 Hickmore
Montreal, Quebec H4T 1K6 Canada

Dear Mr. Burr:

This is in response to your February 9 letter concerning the compliance of your thermoreactor product with Occupational Safety and Health Administration (OSHA) standards.

Spray Finishing Using Water-Base Paints.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 9, 1978

OSHA may not approve, endorse, or recommend any product or process.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 7, 1976

Mr. James E. Eads
Bloomington Manufacturing Company
1000 W. Allen Street
Bloomington, Indiana 47401

Dear Mr. Eads:

OSHA may not approve, endorse, or recommend any product or process. The word "approved" is defined in 29 CFR 1910.107(a)(8): "Shall mean approved and listed by the following nationally recognized testing laboratories: Underwriters' Laboratories, Inc.; Factory Mutual Engineering Corp."

Electrostatic Paint Spraying.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 17, 1976

Mr. A. L. Wilson
Caterpillar Tractor Company
Peoria, Illinois 61629

Subject: Electrostatic Paint Spraying - 1910.94 & 1910.107

Dear Mr. Wilson:

The minimum maintained velocity required for hand held electrostatic paint spray guns is 60 LFM or more depending on the volume of the finishing material and its flammability and explosion characteristics. This is stated in 1910.107(b)(5)(i). This agrees with range of 50-75 LFM required in Table G-10, 1910.94(c)(6)(i).

Requirements for providing eyewashes/showers near spray finishing operations.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 5, 2004

Mr. Tom Heslin
537 N. Edgewood Ave.
Wood Dale, IL 60191
Dear Mr. Heslin:

Clarification Paint Spray Booth and Spray Areas.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

November 4, 1976

OSHA/Technical Support

Clarification Paint Spray Booth & Spray Areas

All Area Directors

There appears to be some confusion as to the application of 1910.94, 1910.107 and 1910.308 and 309 to paint spray operations. An attempt is being made to clarify the requirements outlined in the standards and their source documents.

Spray booth requirements including automatic sprinkler systems, relationship to NFPA 33 requirements, and paint storage.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 12, 2004

Mr. Paul R. Thomson, Jr.
P.O. Box 14125
Roanoake, Virginia 24038-4125

Dear Mr. Thomson:

Spray booth compliance with OSHA standards is determined at the work place.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 27, 1991

Mr. Tom Ellis
Director of Sales and Marketing
Classic Systems, Inc.
P.O. Box 6130
Buffalo Shoals Road
Statesville, North Carolina 28677

Dear Mr. Ellis: