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.

February 26, 1981

Mr. W. W. Palmer
Vice President
Black Brothers Company, Inc.
501 9th Avenue
Mendota, Illinois 61342

Dear Mr. Palmer:

This is in response to your inquiry for an evaluation of the operating, Servicing, and Safety Instructions developed by Black Brothers Company, Inc., for Glue Spreader or Roll Coater laminating machines, and confirms a conversation with Mr. Bode, a member of my staff.

As you are aware, the Occupational Safety and Health Act of 1970 contains no provisions allowing approval or endorsement of equipment or procedures. Alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the manufacturer. For this reason, the compliance of a device or process with OSHA's standards can only be determined by the safety and health professional observing it in actual use under specific circumstances.

A review of the material forwarded by you has been completed. Your material demonstrates considerable comprehension of the hazards and of sincere concern for the safety of the operators. Items warranting further consideration are presented below for your consideration.

1. The ventilation requirements noted in the literature appear to concern only flammable materials. Further consideration should be granted those situations in which toxic or carcinogenic substances and materials may be present. The composition of the material, the bonding agents and the solvents, should be verified by the users and where special ventilation or personnel protective equipment are necessary, they should be provided.

2. The users should be informed that the industry consensus standard ANSI 01.1-1978, paragraphs 4.0, 5.0, and 6.12, addresses glue spreaders and their safe operation.

3. Users should be particularly cautioned to maintain good housekeeping in the working area adjacent to the machines, because slip or fall hazards would materially contribute to employee injuries. Furthermore, OSHA regulations 29 CFR 1910.22(a)(1), (a)(2), (a)(3) and ANSI 01.1-1975, paragraph 4.2, require good housekeeping.

4. Users may be cautioned that in addition to OSHA standards, OSHA may invoke any part of ANSI 01.1 where a serious hazard is identified in the workplace.

We sincerely thank you for your contribution to workplace safety and health. If we may be of further assistance, please call or write.


John K. Barto
Chief, Division of
Occupational Safety Programming