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Water-based paints in spray finishing

Summary An OSHA regional office asked how spray-finishing rules apply when only water-based paints are used. OSHA said residue controls under the cited spray-finishing rule still applied if drying left combustible material. Toxic ingredients could also trigger the cited ventilation requirements.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1978-06-09-0
Date issued
June 9, 1978
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Spray Finishing Fire Safety
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

June 9, 1978

MEMORANDUM FOR: JAMES W. LAKE
REGIONAL ADMINISTRATOR SEATTLE

ATTN: John A. Granchi

THRU: Donald E. Mackenzie Field Coordinator

FROM: Bruce Hillenbrand Acting Director, Federal Compliance and
State Programs

SUBJECT: Mr. Rodia's letter of August 15, 1977, re: Spray Finishing Using Water-Base Paints

This is in response to your memo dated March 31, 1978, subject as above. As indicated in a telephone conversation between Mr. Granchi and Ms. Meyer of our staff, we have no record of receiving Mr. Rodia's letter.

When spray finishing operations involve the use of water-base paints exclusively, the following would apply:

  1. Certain water type finishes, although involving little or no hazard in the liquid state, may leave highly combustible residues upon evaporation of the liquid carrier. The provisions of 1910.107 minimizing the hazards of combustible residues shall be enforced irrespective of the characteristics of the liquid. (Ref: NFPA No. 33.)

  2. Some water-base paints do contain toxic substances. If they do, the requirements of 1910.94(c) would apply.

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