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.

January 17, 1975

Mr. Ray Cason
Administrative Assistant
Ecodyne Corporation Ecodyne
Cooling Products Division
P.O. Box 15687
Tulsa, Oklahoma 74115

Dear Mr. Cason:

Assistant Secretary John H. Stender has asked me to respond to your letter dated December 23, 1974, requesting a permanent variance and interim order from Section 1910.107(b)(3) concerning Spray Booths, of the Occupational Safety and Health Standards.

Your operation involves the use of chopper guns which spray polyester resins and chopped fiberglass roving into prepared molds. This process creates considerable overspray and residue buildup on the booth floor and/or walls. To facilitate the required daily clean up, you are using fire treated cardboard on the floor and extreme lower portion of the walls. It is for the use of this treated cardboard that a variance is sought.

After a careful study of your application, and consultation with both yourself and our Tulsa Area Director, Mr. James Knorpp, we have concluded that your use of the treated cardboard as described, meets the intent of the above standard. Therefore, a variance is not required.

Your have stated that the booths meet all other OSHA standards in their construction including being fully sprinklered. In addition, you have had the treated cardboard tested for burn rate by an independent testing laboratory. In order to insure the integrity of the treated cardboard, we suggest that your quality control procedures of visually inspecting the material prior to use, be continued.

No further action will be taken on your request for variance.


Barry J. White
Associate Assistant Secretary for
Regional Programs