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Non-finishing spraying of contact cement to wood or to laminae

Summary A building contractors’ association asked whether OSHA’s spray-finishing standard covered spraying contact cement on wood and laminate for bonding rather than finishing. OSHA said the operation fell under 29 CFR 1910.107 if the cement was flammable or combustible under the referenced NFPA definition. The OSHA letter itself is undated on the published page.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-04-01-0
Date issued
April 1, 1991
Status
Active
Status last verified October 9, 2026

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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.

Mr. James F. Sassaman
Director of Safety
General Building Contractors Association
[Recipient address omitted]

Dear Mr. Sassaman:

This is in response to your letter of January 23, in which you inquired whether 29 CFR 1910.107 "Spray Finishing using Flammable and Combustible Materials" applies to non-finishing spraying of contact cement to wood and to laminae which are to be joined and so bonded. We apologize for the delay in responding.

The OSHA standard at 29 CFR 1910.107 is based on the National Fire Protection Association (NFPA) Standard, NFPA-33 (1969), entitled Spray Application Using Flammable and Combustible Materials.

If the contact cement you are using in your operation falls into either the "flammable" or "combustible" category as defined in NFPA 33 1989 (copy enclosed), then your operation would fall under the scope of 29 CFR 1910.107.

If you should need additional assistance, please do not hesitate to contact us.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

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