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Daylight blasting rule inside a contained vessel

Summary A contractor asked whether it could blast hardened material inside a furnace vessel before dawn. OSHA said the sunup-to-sundown requirement addressed outdoor blasting, where daylight helps keep people out of the hazard area, and did not apply to blasting fully contained in a vessel. Under the facts presented, the proposed early-morning work met the rule's intent.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-02-11
Date issued
February 11, 1993
Status
Active
Status last verified October 10, 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.

February 11, 1993

Mr. Kerry E. Saltzman
Fox and Grove
[Recipient address omitted]
Dear Mr. Saltzman:

This is in response to your November 17, letter requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing the use of explosives (29 CFR 1926.900(j)). I apologize for the delay of this response.

With regard to whether the requirement to conduct blasting operations, insofar as possible, between sunup and sundown applies to blasting which is completely contained within a vessel, the answer is no. This requirement only addresses outdoor applications where daylight can help visually ensure that all personnel are removed or kept out of the blast hazard area.

Based on the information you provided concerning your process of removing refractory lining and iron residue, it appears that conducting blasting operations between 4:00 a.m. and 7:00 a.m. when employee exposure is at a minimum meets the intent of 1926.900(j).

Again, we apologize for the delay in our response and if we can be of any further assistance, please contact me or Mr. Dale R. Cavanaugh of my staff at (202) 219-8136.

Sincerely,
Roy F. Gurnham, Esq., P.E.
Director
Office of Construction and Maritime
Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]

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