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Cleaning solvent flashpoint for electrostatic spray equipment

Summary A manufacturer requested a variance to clean electrostatic spray equipment with n-butyl acetate. OSHA said no variance was needed because that solvent's stated flashpoint exceeded the lower flashpoint of the solvents in the plant's paint. It warned that a change in paint formulation could require a different cleaning solvent.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-04-14
Date issued
April 14, 1996
Status
Active
Status last verified October 9, 2026

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April 14, 1996

Mr. Roger L. Tynes
Manager Ergonomic and
Safety Engineering
Cambridge Industries, Inc.
[Recipient address omitted]
Dear Mr. Tynes:

Thank you for your letter of July 12, 1995 which requested a permanent variance from 29 CFR 1910.107(g)(5), in order to utilize n-butyl acetate as a solvent for the cleaning of electrostatic bells in your operation.

You indicated in your request for a variance that the paint spray used in your facility contains two solvents, MAK (methyl n-amine ketone) and toluene having flashpoints of 102 and 40 degrees F, respectively. In accordance with OSHA's standard, §1910.107(g)(5), you would be in compliance when you use any solvent for cleaning auxiliary equipment with a flash point of 40 degrees F or higher. Therefore, you do not need a variance to be in compliance, since you are using n-butyl acetate (flashpoint 83 degrees F).

Please note that in the future, if you should change your paint formulation, where the solvents in the paint may have flashpoints above 83 degrees F, then you would be required to select a solvent with a higher flashpoint than n-butyl acetate for the cleaning of auxiliary equipment.

Thank you for your inquiry. If you need further assistance, please call Alcmene Haloftis of my staff at 202-219-8031.

Sincerely,

John B. Miles, Jr., Director
Directorate of Compliance Programs

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