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Substantial noncombustible material in spray booths

Summary A Nevada safety engineer asked what materials were substantial enough to satisfy two spray-booth construction requirements. OSHA said the provisions had to be read together: metals or concrete were examples for the material requirement, while the material also had to prevent pocketing and allow cleaning. It said drywall and particle board would not meet those functions and that daily use required a different analysis.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1985-04-18
Date issued
April 18, 1985
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Spray Finishing Fire Prevention Materials Storage
Source
View the official document

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April 18, 1985

Mr. Michael J. Lacey
Principal Safety Engineer
Department of Industrial Relations
State of Nevada, DOSH
[Recipient address omitted]
Dear Mike:

I am responding to your request for the definition of "substantial non-combustible material" and "facilitate cleaning and washing."

The two paragraphs, (6)(1) and (b)(2), would have to be used in conjunction with each other to get the desired material to meet both paragraphs.

In paragraph (b)(1), the examples are metals or concrete, therefore, any other material would have to be similar, not including drywall or particle board. Also the aluminum or other material can only be used when intermittent or low volume, spraying is done. If the booth is used daily, it would not apply.

In paragraph (b)(2), the material would have to prevent pocketing and facilitate cleaning; drywall would not provide either function satisfactorily.

On drywall you would have a continuous build-up of over-spray creating a fire hazard, an unacceptable consequence.

Sincerely,
JAMES R. GUENTHER
Technical Engineer
Office of Technical Support

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