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.

April 18, 1985

Mr. Michael J. Lacey
Principal Safety Engineer
Department of Industrial Relations
State of Nevada, DOSH
1370 South Curry Street
Carson City, NV 89710

Dear Mike:

I am responding to your request for the definition of "substantial non-combustible material" and "facilitate cleaning and washing."

The two paragraphs, (6)(1) and (b)(2), would have to be used in conjunction with each other to get the desired material to meet both paragraphs.

In paragraph (b)(1), the examples are metals or concrete, therefore, any other material would have to be similar, not including drywall or particle board. Also the aluminum or other material can only be used when intermittent or low volume, spraying is done. If the booth is used daily, it would not apply.

In paragraph (b)(2), the material would have to prevent pocketing and facilitate cleaning; drywall would not provide either function satisfactorily.

On drywall you would have a continuous build-up of over-spray creating a fire hazard, an unacceptable consequence.


Technical Engineer
Office of Technical Support