Flammable glue spraying under spray-finishing rules

March 17, 1983

MEMORANDUM FOR: GILBERT J. SAULTER
REGIONAL ADMINISTRATOR
THRU: JOHN B.MILES, JR., DIRECTOR
OFFICE OF FIELD COORDINATION
FROM: BRUCE HILLENBRAND
ACTING DIRECTOR, FEDERAL COMPLIANCE AND STATE PROGRAMS
SUBJECT: Reguest for Interpretation of Scope of 29 CFR 1910.107 (Spray Finishing Using Flammable and Combustible Materials as it Applies to Glue Spraying Operations)

The essence of the problem raised in your March 2, 1983 memorandum, on the above subject, is stated in the "Scope," 29 CFR 1910.107(n), as the application of "finishing materials."

The appropriate definitions of "finish" in The American Heritage Dictionary of the English Language are "the material used in surfacing or finishing something" and "the last treatment or coating."

Since the "finishing materials" are not identified or limited in 29 CFR 1910.107(n), a glue finish preparatory to lamination would be covered by 29 CFR 1910.107 as well as the example, commonly used, of the primer and paint coatings.

It has always been the intent of the NFPA-33 Committee to cover all spray application of flammable and combustible materials. The 1969 NFPA-33 source code was titled "Spray Finishing Using Flammable and Combustible Materials," but because of confusion as to what might be considered "Finishing," the title was changed in the 1973 NFPA-33 code to "Spray Application Using Flammable and Combustible Materials."