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Recirculating exhaust air in spray-finishing booths

Summary An industrial-systems company asked OSHA to confirm when spray-booth exhaust could be recirculated to an occupied booth. OSHA said employers fully meeting NFPA 33-1995 specifications would not be cited under the cited OSHA exhaust provision. OSHA marks this 1997 letter as archived and says it may no longer represent agency policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1997-07-28-1
Date issued
July 28, 1997
Status
Archived by the agency
OSHA labels this an archive document and says it may no longer represent agency policy; the page does not state a withdrawal or replacement.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 28, 1997

Mr. Samir Karandikar
EPSON Industrial Systems
[Recipient address omitted]
Dear Mr. Karandikar:

This is in response to your September 12, 1996 letter requesting an interpretation of 29 CFR 1910.107(d)(9), air exhaust requirements for spray finishing using flammable and combustible materials. Please accept our apology for the delay in responding. Your request and our reply follow:

Request:

Please confirm the Occupational Safety and Health Administration (OSHA) interpretation in the OSHA August 27, 1991 letter to Mr. Tom Ellis of Classic Systems, Inc. which stated that employers who fully comply with the specifications and requirements of the National Fire Protection Association standard NFPA-33-1989, concerning the recirculation of exhaust air to an occupied spray booth, would not be cited under 29 CFR 1910.107(d)(9).

Reply:

This letter reconfirms the interpretation in the OSHA letter you referenced above. Employers who fully comply with the specifications and requirements of the National Fire Protection Association standard NFPA 33-1995 (previously, NFPA 3301989) concerning the recirculation of exhaust air to an occupied spray booth would not be cited under 29 CFR 1910.107(d)(9).

We appreciate your interest in Occupational Safety and Health. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald Davies, telephone (202) 219-8031, ext. 110.

Sincerely,

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

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