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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.
Mr. James F. Sassaman
Director of Safety
General Building Contractors Association
36 South 18th Street
P.O. Box 15959
Philadelphia, Pennsylvania 19103
Dear Mr. Sassaman:
This is in response to your letter of January 23, in which you inquired whether 29 CFR 1910.107 "Spray Finishing using Flammable and Combustible Materials" applies to non-finishing spraying of contact cement to wood and to laminae which are to be joined and so bonded. We apologize for the delay in responding.
The OSHA standard at 29 CFR 1910.107 is based on the National Fire Protection Association (NFPA) Standard, NFPA-33 (1969), entitled Spray Application Using Flammable and Combustible Materials.
If the contact cement you are using in your operation falls into either the "flammable" or "combustible" category as defined in NFPA 33 1989 (copy enclosed), then your operation would fall under the scope of 29 CFR 1910.107.
If you should need additional assistance, please do not hesitate to contact us.
Patricia K. Clark, Director
Directorate of Compliance Programs