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.

April 18, 1977

Mr. Edward M. Morris,
President
Occupational Safety Consultants, Inc.
Post Office Box 4337
Corpus Christi, Texas 78408

Dear Mr. Morris:

This is in response to your letter of March 17, 1977, regarding a formal interpretation of 29 CFR 1910.107(b)(9) Spray Booths, Cleaning.

The Occupational Safety and Health Administration (OSHA) standard states, "Cleaning. Spray Booths shall be so installed that all portions are readily accessible for cleaning. A clear space of not less than 3 feet on all sides shall be kept free from storage or combustible construction." OSHA's interpretation of "A clear space of not less than 3 feet on all sides shall be kept free from storage or combustible construction" is that it applies to the exterior of spray booths.

29 CFR 1905.11 (copy enclosed) gives the rules for variances and other relief under section 6(d) of the Occupational Safety and Health Act of 1970.

The Area Director of the local OSHA office may be of assistance for a particular worksite situation.

Thank you for you concern and continuing interest in occupational safety and health.

Sincerely,



John K. Barto,
Chief
Division of Occupational Safety Programing