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Fiberglass spray-up under spray-finishing rules

Summary A manufacturer asked whether fiberglass lay-up and spray-up were covered by OSHA’s spray-finishing standard. OSHA said a chopper gun accelerating resin and chopped fiberglass into a form was within the rule’s scope, so applicable provisions had to be followed.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1979-12-11
Date issued
December 11, 1979
Status
Active
Status last verified October 10, 2026

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December 11, 1979

Mr. Kim E. Anderson
Corporate Manager
Industrial Hygiene
[Recipient address omitted]
Dear Mr. Anderson:

This is in response to your inquiry requesting an interpretation of the applicability of 29 CFR 1910.107, spray finishing using flammable and combustible materials, for fiberglass lay-up/spray-up.

29 CFR 1910.107(n) of the general industry safety and health standards provides the scope for spray finishing using flammable and combustible materials. It reads as follows: "This section applies to flammable and combustible finishing materials when applied as a spray by compressed air, "airless" or "hydraulic atomization", steam, electrostatic methods, or by any other means in continuous or intermittent processes."

Your operation involves the use of chopper guns which accelerate resins and chopped fiberglass into a form, therefore, you must comply with the applicable requirements in 29 CFR 1910.107.

We hope this information is helpful. If we may be of any further assistance, please feel free to call or write.

Sincerely,
Grover C. Wrenn Director,
Federal Compliance and State Programs

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