Are applicable 1910 requirements for Scenario 1 retroactive to all spray booths?
Response: The requirements found at 1910.107 are applicable to all spray booths in which spray finishing is conducted using flammable and combustible materials, as definedin 1910.106(a)(18) and 1910.106(a)(19). The standards were first promulgated in 1971 and are applicable to all spray booths, regardless of the date of their manufacture. Question 8: If OSHA considers that the NFPA 33 (2000 edition) standards apply and that they are enforceable standards for spray booths, are they retroactive to all spray booths? Response: As stated earlier, OSHA does not enforce consensus standards. Because OSHA has a standard that addresses a particular situation, in this case 1910.107, that standard is what the Agency enforces. Question 9: Does the paint storage room have to meet the requirements stipulated for “mixing rooms” in NFPA 33 (2000 edition), Section 6.3? Response: An employer would be required to meet OSHA’s requirements for mixing rooms which are found at 1910.107(e)(3). Scenario 2: Refe
