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.

December 11, 1979

Mr. Kim E. Anderson
Corporate Manager
Industrial Hygiene
2700 West 65th Street
Little Rock, Arkansas 72208

Dear Mr. Anderson:

This is in response to your inquiry requesting an interpretation of the applicability of 29 CFR 1910.107, spray finishing using flammable and combustible materials, for fiberglass lay-up/spray-up.

29 CFR 1910.107(n) of the general industry safety and health standards provides the scope for spray finishing using flammable and combustible materials. It reads as follows: "This section applies to flammable and combustible finishing materials when applied as a spray by compressed air, "airless" or "hydraulic atomization", steam, electrostatic methods, or by any other means in continuous or intermittent processes."

Your operation involves the use of chopper guns which accelerate resins and chopped fiberglass into a form, therefore, you must comply with the applicable requirements in 29 CFR 1910.107.

We hope this information is helpful. If we may be of any further assistance, please feel free to call or write.


Grover C. Wrenn Director,
Federal Compliance and State Programs