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 http://www.osha.gov.

October 2, 1975

Mr. Frank Fatta
District Manager
Paasche Airbrush Co.
1944 West Ridge Road
Rochester, New York 14626

Dear Mr. Fatta:

This is in response to your letter referring to an advertisement for "Electronic Air Cleaners", and reviewing several hazards in spray finishing operations.

The OSHA Standard 1910.107(d)(9) does state in part "...Air exhausted from spray operations shall not be recirculated." However, the flyer you enclosed in your letter merely advises of the availability of an electronic air cleaner. It in no way directly states that it meets OSHA standards and neither directly or indirectly refers to removal of all air contaminants. The cartoon infers that particulate matter is removed to preclude damage to products, not people. When a premises is inspected by an OSHA compliance officer, the standards of air purity and spray booth operation are applied fully. This includes removal of contaminated air, replacement by external air sources and the purity and temperature of incoming air. If a spray operation uses electronic precipitators as well as all the other required equipment, there would be no OSHA objection unless such precipitator created an additional hazard.

Please feel free to contact us if there are further questions about OSHA.


Alfred Baden
Assistant Regional Director
Occupational Safety and Health