![]() Response: If a state or local public safety agency or official, such as a fire marshal, enforces the NFPA 33 requirements for electrical safety, ventilation, and fire protection, your client would have to comply with them if they were equivalent to, or more protective than 1910.107. ![]() Question 6: Does the booth have to satisfy the NFPA 33 requirements for electrical, ventilation, and fire protection to fully comply with State requirements where those NFPA 33 standards are more restrictive than the 1910 standards? If NFPA 33 is not complied with, is this considered a violation by OSHA? If this were a violation, would OSHA issue citations for failure to comply with NFPA 33 (2000 edition)? OSHA has adopted neither the NFPA 33-2000 nor the NFPA 33-2003 standards. ยง655(b), at the current time OSHA may adopt a standard only through notice-and-comment rulemaking. As a matter of general information, we would point out that standards adopted by national standards-setting organizations do not automatically become OSHA standards. NFPA 33 was revised in 2003, and that edition is the most current. Response: The OSHA standards 1910.1.107 apply to the scenario. Question 5: Is National Fire Protection Association (NFPA) 33 Standard for Spray Application Using Flammable or Combustible Materials (2000 edition) considered a consensus standard by OSHA that applies to Scenario 1? These requirements address things such as, but not limited to, the maximum size of the room, ventilation, fire protection systems, and electrical wiring and equipment inside the room. Specific standards related to the design and construction of inside storage rooms can be found at 1910.106(d)(4). Response: The storage of flammable materials must meet the provisions of the flammable and combustible liquids standard, 1910.106. Question 4: What requirements under must the paint storage room meet? The requirements for dry chemical extinguishing systems are found in 1910.161 and those for gaseous agent extinguishing systems in 1910.162. A dry chemical extinguishing system or a carbon dioxide system installed so as to meet OSHA requirements may be used in place of an automatic sprinkler system. Question 3: If the answer to question 2 is "yes," do the regulations allow for a dry chemical fire protection system, in lieu of water sprinklers, that gives an equivalent level of protection? If a structure meets the definition of a spray booth, then it is required to be equipped with approved automatic sprinklers on the upstream and downstream sides of the filters. Question 2: Are this booth and ductwork required to be protected with automatic sprinklers in accordance with 1910.107(b)(5)(iv)? Based on the information you provided, the structure in your scenario meets the definition of a spray booth in. Question 1: Does this booth meet the definition of a spray booth as defined by. Please answer the following questions related to Scenario 1. Assume the paint is conveyed to the booth through a fixed pressurized delivery system. Assume the paint supply is stored in a separate enclosed room that is adjacent to the booth and which shares a common concrete block wall with the booth and which is inside the same building as the booth. Assume the booth is located inside the room of a building. Assume that the materials to be spray-painted consist of individual parts that have been removed from construction machinery and repaired. ![]() Assume the booth is to be used 1-2 times per week and less than 1 gallon of flammable liquid paint is sprayed in an 8-hour period. ![]() Scenario 1: The photo in Figure 1 shows pictures of a typical small-capacity power-ventilated structure used to capture paint overspray and safely conduct it to the outside. Your paraphrased scenarios and inquiries follow. You included two photos, posed three scenarios and asked several questions related to each scenario. You had specific questions regarding standards related to spray booths. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. This is in response to your correspondence dated Decemto the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. ![]()
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