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

E

energy

#1
To Spray or not to Spray

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.
 
Elsmar Forum Sponsor

Randy

Super Moderator
#2
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.:eek:

I'll get back tomorrow hopefully.
 
#3
"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.
 
E

energy

#4
He needs proof.

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.
 
Last edited by a moderator:
E

energy

#5
The Jury is in

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.

:smokin:
 
Thread starter Similar threads Forum Replies Date
K Troubleshooting Salt Spray (ASTM B117) Manufacturing and Related Processes 2
B Guidance Required for Examining 168 Hour Salt Spray Test Samples Manufacturing and Related Processes 5
Q Salt spray test on anodic coating B117 vs NES M0140 Reliability Analysis - Predictions, Testing and Standards 2
B Improper R&R Test? Downdraft Velocity in Automotive Spray Booths Gage R&R (GR&R) and MSA (Measurement Systems Analysis) 2
R Salt spray per Mil-DTL-5541 coupons required 5 or 10 AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 3
C Advise on Oral Spray Pad Printing and Compliance 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 2
M Quality issues in a manufacturing plant - High-pressured solvent spray cans Quality Manager and Management Related Issues 2
J Salt Spray Failure Question (ASTM B 633 and B 117) Inspection, Prints (Drawings), Testing, Sampling and Related Topics 9
S Measurement Uncertainty for Neutral Salt Spray test to BS EN ISO 9227:2006 General Measurement Device and Calibration Topics 4
T Supplier Spray Process Audit - Fish Eye, Spray Dust and Fiber Dust Defects Manufacturing and Related Processes 8
L Dry Lube Application (Ever lube 620) - Manual Application vs. Automated Spray Process Manufacturing and Related Processes 1
T Spray Paint Manufacturing Processes and related Information Manufacturing and Related Processes 3
T Control Chart - Salt Spray Test Hours - Powder Coated Parts Statistical Analysis Tools, Techniques and SPC 3
R Spray Drier Equipment Optimization - How to start Statistical Analysis Tools, Techniques and SPC 6
S Salt spray test on nickel? Parts were plated to QQ-N-290 Manufacturing and Related Processes 5
J Salt Spray Test on 3 year old Zinc Die Casting Chromed part per ASTM B 117-03 Manufacturing and Related Processes 2
J 200 hour Salt Spray per ASTM B 117 - What should be reported? Inspection, Prints (Drawings), Testing, Sampling and Related Topics 6
P Found Blue Green Rust in Bolt after Salt Spray Testing Reliability Analysis - Predictions, Testing and Standards 11
C An Explanation of Salt Spray (Corrosion) Testing based on ASTM B117 Design and Development of Products and Processes 1
S Insecticidal spray and ISO 14001 ISO 14001:2015 Specific Discussions 11
V Is spray painting allowed for non-blood contact medical devices? ISO 13485:2016 - Medical Device Quality Management Systems 3
C SPC In a Manual Spray Paint Application Statistical Analysis Tools, Techniques and SPC 7
P Salt spray testing - Comparative corrosion data of 302 S26 vs Galvanised carbon steel Manufacturing and Related Processes 6
W Plastic Part Painting/Spray Failure Mode - Sample PFMEA or control plan Manufacturing and Related Processes 7
Z Salt Spray Procedure to ASTM B 117-90 - Seeking Example Various Other Specifications, Standards, and related Requirements 8
P What are GM's requirements for Salt Spray Testing? General Measurement Device and Calibration Topics 1
A Uncertainty in Test - Durability test, High Performance, Salt Spray chambers, etc Measurement Uncertainty (MU) 5
V Salt spray testing procedure and training requirements - ASTM B-117? QS-9000 - American Automotive Manufacturers Standard 4
B Plating Shop - Forums specifically related to the plating / metal finishing industry ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 3
H ISO Standard for Titanium & Stainless Steel finishing for Implant Other Medical Device Regulations World-Wide 3
A Finishing Design Validation per 21 CFR Part 820 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 6
M Manufacturer Process Specification (MPS) for a Spiral Finishing Mill Manufacturing and Related Processes 8
I Medical, Vacuum Heat Treat or Not if Subsequent Finishing Operations are Performed Benchmarking 3
Marc Finishing a Room in Unfinished Aromatic Cedar After Work and Weekend Discussion Topics 5
D Finishing a Quality Manual to AS9100 requirements AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 3
T Finishing an G8D - Step D8 advice please Nonconformance and Corrective Action 9
P Printing-Sheetfed-Web-Print Finishing - How Many are ISO Registered? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 5
B What is "CLS"? Mercedes Benz Coupe, Long-wheel base and 'S' class finishing Various Other Specifications, Standards, and related Requirements 11
J Definition Finishing Services - TS 16949 Section 3.1.6 references finishing services Definitions, Acronyms, Abbreviations and Interpretations Listed Alphabetically 1
C Master's Student finishing up in Dec. Wondering what jobs to look for? Career and Occupation Discussions 11
W Metal Finishing - Powder Coating and Painting QS-9000 - American Automotive Manufacturers Standard 6
C Macbeth Light Booth Gage R&R (GR&R) - Audit Nonconformance Gage R&R (GR&R) and MSA (Measurement Systems Analysis) 3
O Gretag MacBeth Light booth Calibration General Measurement Device and Calibration Topics 6
O ISO 17025 and SAE J361 Question - MacBeth booth - Daylight filter was a D75 ISO 17025 related Discussions 1
M Paint booth prints - Painters using them as ?ground cloth? after the job is shipped Document Control Systems, Procedures, Forms and Templates 2

Similar threads

Top Bottom