1 0 obj The requirements for dry chemical extinguishing systems are found in 1910.161 and those for gaseous agent extinguishing systems in 1910.162. Response: An employer would be required to meet OSHA's requirements for mixing rooms which are found at 1910.107(e)(3). Basic Fire & Electrical Requirements: Signs prohibiting smoking, flames, and sparks should be displayed within 20 ft of the booth. x��][s�H�~OU�CW�j+���R[[�8���ⱝ��J���iK;��P�d|~�Ф�-�):Rv��qD4�F����i��>d�5��_ON��l�zZ,��7���{{����g\�ۇ�/8�����X������勀=��}���F�f������g��!�m�^�?��"?Ѳ�xBƒ�MG�+��(�����F��m�:��'��c7�(��]���j�Zxzvv��Q�*��/s�E-WH�Ȓ�&��8�H�@ФX�oPb�#��5G�v������J:�e����@��M*� pQ�Ǧ����v�q�G�dw�ࢗ���_d�T��Ev[SF���a��R?�Tz ��V�Y�3JO�)%I|.vl+���X��~��wnbXn�X�?���n�n��Xe������bn��������4��B�%A�X��|��[z(����CP���&��Q������s�$N�VKACp���0�L�4d��s�bX�$�!�Zc�� Mr. Paul R. Thomson, Jr. After the Booth is installed/constructed – verification information must be submitted to the field SCO at time of inspection. Based on the scenario you posed, all requirements of 1910.107 must be met. For further information, you should contact the Virginia Department of Labor and Industry at: If your client is in another state with an OSHA-approved state plan, you should contact the state occupational safety and health agency. Your paraphrased scenarios and inquiries follow. Question 10: What are the answers to questions 1-9 given Scenario 2? As a manufacturer of paint spray booths, the codes are very important to us, and everything we do to create the safest work environment for our customer that is possible. Furthermore, if your client is in Virginia, the company would be required to follow the occupational safety and health standards of the Virginia Department of Labor and Industry, which has an OSHA-approved state plan. exterior wall. Question 1: Does this booth meet the definition of a spray booth as defined by 29 CFR 1910.107(a)? Response: The storage of flammable materials must meet the provisions of the flammable and combustible liquids standard, 1910.106. Please answer the following questions related to Scenario 1. Both also require paint booths to have a separate, approved sprinkler system, a fire rating of at least two hours and be built according to certain construction standards. <>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> %PDF-1.5 Assume that the materials to be spray-painted consist of individual parts that have been removed from construction machinery and repaired. According to 29 U.S.C. August 12, 2004 ?�O}�����/l�� �I QrL �>D�/ �qF. If your client is in another state with an OSHA-approved state plan, you should contact the state occupational safety and health agency. Assume the paint is conveyed to the booth through a fixed pressurized delivery system. NFPA 17). Assume the paint is conveyed from the storage room to the booth through a fixed pressurized delivery system. endobj Scenario 1: The photo in Figure 1 shows pictures of a typical small-capacity power-ventilated structure used to capture paint overspray and safely conduct it to the outside. ?�X Because OSHA has a standard that addresses a particular situation, in this case 1910.107, that standard is what the Agency enforces. As a matter of general information, we would point out that standards adopted by national standards-setting organizations do not automatically become OSHA standards. <> This letter constitutes OSHA's interpretation of the requirements discussed. OSHA has adopted neither the NFPA 33-2000 nor the NFPA 33-2003 standards. Also, from time to time we update our guidance in response to new information. Response: The OSHA standards 1910.106 and 1910.107 apply to the scenario. endobj Quick View. Response: As mentioned previously, there are no cutoff points for the amount of flammable or combustible liquid used or for the frequency of use that would eliminate the need for total compliance of spray booths with 1910.107. If a structure meets the definition of a spray booth, then it is required to be equipped with approved automatic sprinklers on the upstream and downstream sides of the filters. This is in response to your correspondence dated December 1, 2003 to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. For those already looking to make a purchase, our selection of commercial fire sprinklers and sprinkler system components can help paint shops stay in compliance with fire code. You had specific questions regarding standards related to spray booths. 2 0 obj NFPA 33 9.1.1 also addresses fire suppression systems and suggests standards that different classes of fire suppression systems have to meet to be satisfactory for paint booths. Note that our enforcement guidance may be affected by changes to OSHA rules. Directorate of Enforcement Programs Question 9 is not applicable because you specifically stated that the paint is stored in a flammable storage cabinet rather than a room. Two codes—NFPA 30A and NFPA 33—contain core requirements for paint booth fire suppression systems Spray room exits comply with CBC Chapter 10. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. <>>> %���� Question 11: Given Scenario 1 and Scenario 2, is there a cutoff point for frequency and/or quantity sprayed and/or size of the booth where some of the requirements of 1910.107 would not otherwise apply? §655(b), at the current time OSHA may adopt a standard only through notice-and-comment rulemaking. Question 4: What requirements under 29 CFR 1910 must the paint storage room meet? P.O. Question 5: Is National Fire Protection Association (NFPA) 33 Standard for Spray Application Using Flammable or Combustible Materials (2000 edition) considered a consensus standard by OSHA that applies to Scenario 1? A dry chemical extinguishing system or a carbon dioxide system installed so as to meet OSHA requirements may be used in place of an automatic sprinkler system. NFPA 33 was revised in 2003, and that edition is the most current. If this were a violation, would OSHA issue citations for failure to comply with NFPA 33 (2000 edition)? We hope you find this information helpful. Inspection of link line and position of detectors. Response: Yes. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If so, what are those cutoff points, and what are the reduced requirements? Assume the paint is conveyed to the booth through a fixed pressurized delivery system. Question 8: If OSHA considers that the NFPA 33 (2000 edition) standards apply and that they are enforceable standards for spray booths, are they retroactive to all spray booths? The standards were first promulgated in 1971 and are applicable to all spray booths, regardless of the date of their manufacture. Scenario 1 other operations and must be met Storm and Flood Recovery Assistance to spray booths, regardless the... 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