- Standard Number:
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.
July 28, 1997
Mr. Samir Karandikar
EPSON Industrial Systems
P.O. Box 7060
The Woodlands, TX 77387
Dear Mr. Karandikar:
This is in response to your September 12, 1996 letter requesting an interpretation of 29 CFR 1910.107(d)(9), air exhaust requirements for spray finishing using flammable and combustible materials. Please accept our apology for the delay in responding. Your request and our reply follow:
Please confirm the Occupational Safety and Health Administration (OSHA) interpretation in the OSHA August 27, 1991 letter to Mr. Tom Ellis of Classic Systems, Inc. which stated that employers who fully comply with the specifications and requirements of the National Fire Protection Association standard NFPA-33-1989, concerning the recirculation of exhaust air to an occupied spray booth, would not be cited under 29 CFR 1910.107(d)(9).
This letter reconfirms the interpretation in the OSHA letter you referenced above. Employers who fully comply with the specifications and requirements of the National Fire Protection Association standard NFPA 33-1995 (previously, NFPA 3301989) concerning the recirculation of exhaust air to an occupied spray booth would not be cited under 29 CFR 1910.107(d)(9).
We appreciate your interest in Occupational Safety and Health. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald Davies, telephone (202) 219-8031, ext. 110.
John B. Miles, Jr., Director
Directorate of Compliance Programs