The OSHA regulation for fire safety for spraying of flammable liquid (29 CFR 1910.107), applicable to resin and gelcoat spray operations, is based on what was the NFPA code for spray painting, a more hazardous operation. One of the subsequent updates to the NFPA standard for spray application of flammable liquid (NFPA 33) was to add requirements specifically for resin and gelcoat spray. For example, the updated NFPA code, unlike the original spray-painting code, does not restrict resin spray operations to spray booths but also allows them in spray areas, accommodating the fabrication of large composite products.
In recognition of the outdated nature of many of their regulations, OSHA does consider as de minimis (without penalty) the violation of an OSHA regulation if the applicable NFPA code is followed and if it provides an equal or greater level of protection. Per this policy, OSHA should issue only a de minimis violation for a composite resin spray operation not fully in compliance with 29 CFR 1910.107 if the facility is fully in compliance with NFPA 33.
In the summer Tech Talk column, I’ll tackle the intricacies of some specific fire codes applicable to composites manufacturing operations.
John Schweitzer is senior advisor to the president at ACMA. Email comments to firstname.lastname@example.org.
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