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.

June 9, 1978

MEMORANDUM FOR:  JAMES W. LAKE
                 REGIONAL ADMINISTRATOR SEATTLE

ATTN:            John A. Granchi

THRU:            Donald E. Mackenzie Field Coordinator

FROM:            Bruce Hillenbrand Acting Director, Federal Compliance and
                 State Programs

SUBJECT:         Mr. Rodia's letter of August 15, 1977, re:  Spray Finishing
                 Using Water-Base Paints

This is in response to your memo dated March 31, 1978, subject as above. As indicated in a telephone conversation between Mr. Granchi and Ms. Meyer of our staff, we have no record of receiving Mr. Rodia's letter.

When spray finishing operations involve the use of water-base paints exclusively, the following would apply:

1. Certain water type finishes, although involving little or no hazard in the liquid state, may leave highly combustible residues upon evaporation of the liquid carrier. The provisions of 1910.107 minimizing the hazards of combustible residues shall be enforced irrespective of the characteristics of the liquid. (Ref: NFPA No. 33.)

2. Some water-base paints do contain toxic substances. If they do, the requirements of 1910.94(c) would apply.