Spray Finishing Booth - Fire Resistant Walls Requirement (Why not a curtain?)

This question is directed at those individuals who have the ancillary duty of being the Plant Safety Officer/Manager, in addition to the other tasks such as Quality Control/Assurance. Management has cordially invited the State OSHA in to provide consultation services to increase our compliance efforts that will satisfy Federal OSHA regulations. The issue: A Spray Finishing Booth. We have a three-sided sheet metal booth with a Flame Retardant Curtain across the front. The curtain is generally used in Automobile Spray Finishing operations. Our OSHA consultant has a concern that the curtain does not meet the requirement for Non Combustible walls. He says we need four non-combustible walls. The manufacturer cites a California Flame Retardant specification. CFM F-121.2.

I have received from the curtain manufacturer the following: CFM, California Fire Marshal, Title 19, Small Scale; 2 second after flame maximum average, 3.5 inches char length maximum average, 6 inches char length maximum individual.

Can any body assist with the interpretation of this “information”. Does anyone know specifically if the regulation would allow this type of curtain? They are the choice of Paint Spray Booth Manufacturers. I’m sure with the amount of talent of people visiting the Cove, that the answer is right under our paint filled noses. Thanks.

[Randy]

Let me double check a couple of things. Me being a Cal safety guy ought to help some.

The curtain is in standard use in auto shops and other places doing small paint operations in California. And California OSHA is tougher in many more ways than the feds are.

I'll get back tomorrow hopefully.

[Sam]

"Our OSHA consultant has a concern that the curtain does not meet the requirement for Non Combustible walls."

Energy,
What was his concern based on? How does your vendor spec compare with the Fed/State requirements? If they are the consultant they should be able to tell you precisley what the requirement is.
Here in Oklahoma I work with the Dept. of labor. They provide excellent professional guidance and on - site support,i.e., measuring, auditing,etc. And it's free.
Makes my job a lot easier.

Sam,

The burden of proof is on us. The regulation says the construction must be of substantial noncombustible materials. The "Flame Retardant" properties touted by the manufacturer of the curtain allude to a little known California test that is the object of this post. Unless we can prove to him that the curtain meets the term "substantial noncombustible" it has to go. I have some time to research this.
This program is also free and the guidance such as reference materials is also substantial. But, like everybody else, I presume, I want to authenticate the use of our curtain and continue to use it. There are companies out there who will say things like meets all regulatory requirements, until you ask for specifics. Then you get the song and dance. This OSHA Representative is just doing his job and I suspect that he has pointed out a possible violation that could result in penalties from Fed OSHA if we haven't done our homework. The other thing about these programs is that when issues are detected, they must be resolved to their satisfaction. Otherwise, you can count on a visit from the Fed OSHA, rather quickly, if you do not comply. State OSHA calls it a "referral". Then, the "curtain" becomes a minor thing because they will go through the facility with a fine toothed comb. And, I don't care how good a company's Safety Program is, they can always find something that doesn't meet the letter of the law.

Regarding the suspect curtain, this is an excerpt of my letter to Management regarding the use of:
After several faxes and telephone calls with XXXX, technical advisor for XXXX.-manufacture of the XXXCurtain, it has been determined that the use of the XXXXCurtain as a wall for the Paint Spray Booth is in violation of OSHA 1910.107, regulation regarding the use of substantial noncombustible material. The fabric portion of the Curtain meets minimum fire retardant specifications recognized by a California Fire Marshall Authority. This requires curtains in public facilities to be “small scale” flame retardant tested.
The plastic portion of the curtain will start to melt, in the event of a fire, at 160°F.

Underwriters Laboratory suggest the use of this material for the following foamed plastics or products containing foamed plastics:

Typical open-ceiling, portable exhibit booth constructions incorporating manufactured panels;

Individual, manufactured objects such as, but not limited to, mannequins, murals and signs;

Theater, motion picture, and television stage settings, with or without horizontal projections;

The Curtain may be used in conjunction with noncombustible doors that can be closed in the event of a fire. The curtain may be used to section of a portion of the spray booth, providing there are noncombustible doors installed.

It is recommended that we begin exploring for a type of noncombustible access partition that can be readily adapted to the Spray Booth.