Dipping and coating operations overview

Yes—1910.123(a) requires you to determine whether your operations fit the scope of 1910.123–1910.126 by checking the coverage criteria and definitions in that section.

• Look at the operations listed in 1910.123(b) to see if your process is specifically covered (for example, dip tanks, roll coating, vapor degreasing are among the operations addressed).
• If your activity is excluded under 1910.123(c), you do not have to follow 1910.123–126 for that activity.

Always read the definitions in 1910.123(d) so you apply the rules correctly.

Dip tanks must be built and maintained consistent with the general construction requirements laid out in 1910.124(a).

• Ensure tanks are constructed of appropriate materials and designed to contain the process liquids and any heating systems safely.
• Inspect tanks regularly and repair defects to prevent spills, leaks, or failures as required by the inspection and maintenance items in 1910.124(j).

See 1910.124 for the full set of general construction and maintenance duties.

You must provide ventilation for vapor areas around dip tanks as required by 1910.124(b).

• Provide exhaust or general ventilation to keep vapor concentrations below hazardous levels and protect workers from inhalation hazards.
• If you intend to recirculate exhaust air, follow the recirculation requirements in 1910.124(c).

Document your ventilation design and maintenance so you can show it meets the obligations in 1910.124.

You must meet the specific recirculation requirements in 1910.124(c) before returning exhaust air to the work area.

• Ensure the exhaust is properly treated or filtered so contaminants are removed to acceptable levels.
• Verify that recirculation will not create a hazardous condition for employees; if it could, exhaust must be discharged outdoors.
• Maintain and inspect the recirculation equipment as required by 1910.124(j).

Follow the recirculation provisions in 1910.124(c) to ensure you are compliant.

You must design, install, and maintain exhaust hoods so they effectively capture vapors and meet the requirements of 1910.124(d).

• Position hoods to capture vapors at the source and avoid worker exposure.
• Maintain proper airflow and test hood performance periodically.
• Keep records of inspections and repairs under the inspection and maintenance rules in 1910.124(j).

Refer to 1910.124(d) for the specific hood-related duties.

You must follow the entry requirements of 1910.124(e) to protect employees who enter dip tanks.

• Restrict entry to authorized, trained personnel and use appropriate protective equipment.
• Implement procedures to control hazards like vapors, engulfment, and slippery surfaces.
• Provide rescue measures and ensure first-aid procedures are in place per 1910.124(f).

Document the entry procedure and training to demonstrate compliance with 1910.124(e).

You must provide the first-aid and treatment measures described in 1910.124(f) and (h).

• Ensure employees know emergency first-aid procedures for exposure to dips, solvents, and vapors.
• Provide on-site first-aid supplies and arrange for medical treatment when needed.
• Train employees to respond to skin or eye contact, inhalation, and burns according to the procedures in 1910.124(f) and (h).

You must provide hygiene facilities required by 1910.124(g).

• Supply washing stations, eye-wash facilities, and change areas as appropriate for the hazards of the process.
• Keep facilities accessible, clean, and maintained for immediate use.
• Train employees on proper use of hygiene facilities and when to use them, as part of your overall safety program in 1910.124.

Before cleaning a dip tank, and for ongoing inspection and maintenance, you must follow the procedures in 1910.124(i) and (j).

• Isolate and make the tank safe before cleaning—control vapors, lock out energy, and prevent access to hazardous areas.
• Use written procedures and train authorized employees on safe cleaning practices.
• Inspect tanks, hoods, ventilation, and safety equipment regularly and keep maintenance records as required by 1910.124(j).

If cleaning requires temporary re-energization of machinery for testing or positioning, follow the sequence in 1910.147(f)(1) and OSHA's Letter of Interpretation on the minor servicing/testing exception (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21) to protect workers during those transition steps.

Dip tanks that contain flammable or combustible liquids must be constructed of materials appropriate to control fire risk as required by 1910.125(a).

• Use construction materials and designs that reduce the chance of ignition and resist fire spread.
• Follow the additional fire control and drainage requirements in 1910.125(b)–(g).

Consult 1910.125 for the full set of construction and fire protection duties for flammable-liquid dipping operations.

You must provide overflow piping and bottom drains when your tank design and operations create the need to control overflows and efficiently remove liquids, per 1910.125(b) and (c).

• Install overflow piping where spills or overfilling could spread flammable liquids and create hazards.
• Provide bottom drains when design, cleaning, or emergency drainage would be unsafe without them.

Review 1910.125(b) and (c) to determine the specific circumstances that make these features required.

Your conveyor system must shut down automatically when required to prevent continuous introduction of materials into hazardous areas or to stop operations during fire or overflow conditions, as specified in 1910.125(d).

• Provide automatic shutdown where continued conveyor movement could spread fire or overwhelm containment.
• Ensure shutdown interlocks and controls are maintained and tested under the inspection provisions in 1910.124(j).

When automatic shutdown is part of servicing or testing procedures that require temporary re-energization, follow safe re-energization sequences in 1910.147(f)(1) and OSHA's relevant Letter of Interpretation on temporary re-energization (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21).

You must control ignition sources (like open flames, hot surfaces, and electrical sparks) and fuel sources in dipping operations that use flammable liquids as required by 1910.125(e).

• Identify potential ignition sources and either eliminate them or implement safeguards (intrinsically safe electrical equipment, grounding/bonding, hot-work controls).
• Control storage and handling of fuels and flammable materials to reduce their availability for ignition.

Document the controls and training so you can demonstrate compliance with 1910.125(e).

You must provide fire protection measures required by 1910.125(f) to reduce the risk and effects of fire in flammable-liquid dipping operations.

• Install appropriate fire extinguishers, automatic suppression systems, and alarms where required by the hazard.
• Maintain clear access and train employees in fire response and evacuation procedures.

Follow 1910.125(f) and your local fire codes to ensure adequate protection.

You may heat liquids in a dip tank only to temperatures that are safe under the limits and controls set out in 1910.125(g).

• Avoid heating flammable liquids to temperatures that increase vapor concentrations above safe levels or that approach flashpoints unless you have proper controls (ventilation, explosion protection, and fire suppression).
• Design heating systems with limits, alarms, and interlocks and maintain them under 1910.124(j).

Consult 1910.125(g) for specifics on permitted heating and required safeguards.

Hardening or tempering tanks must meet the additional requirements in 1910.126(a) that address the special hazards of those processes.

• Implement controls for high temperatures, splashing, and safe entry and egress.
• Provide guarding, ventilation, and protective equipment tailored to the risks of hardening/tempering operations.

See 1910.126(a) for the full list of additional requirements.

Flow coating and roll coating/impregnating operations must comply with the additional safeguards in 1910.126(b) and (c).

• Control hazards from moving rolls, pinch points, and liquid contact through guarding and safe work procedures.
• Provide ventilation, spill containment, and housekeeping suitable for the specific process.

Refer to 1910.126(b) and (c) for detailed protective measures.

Vapor degreasing tanks are subject to the extra requirements in 1910.126(d) because they pose unique vapor and solvent hazards.

• Use appropriate capture ventilation, controls to limit vapor escape, and safe operating procedures.
• Monitor exposures and maintain equipment to prevent vapor leaks and worker overexposure.

Implement the specific controls listed in 1910.126(d) for safe vapor degreasing operations.

Cyanide tanks and spray cleaning/degreasing tanks have special protections in 1910.126(e) and (f).

• For cyanide tanks, implement controls for toxic exposures, emergency response, and handling procedures specific to cyanide hazards.
• For spray cleaning/degassing tanks, control overspray, aerosols, ventilation, and ignition sources as applicable.

Follow the detailed requirements in 1910.126(e) and (f) to address these higher-risk operations.

Electrostatic paint detearing must follow the special requirements in 1910.126(g) to control electrical and flammable-paint hazards.

• Use grounding and bonding, maintain safe voltages, and control ignition sources around charged particles.
• Train employees on the unique hazards of electrostatic equipment and keep maintenance records per 1910.124(j).

Consult 1910.126(g) for the complete list of requirements for electrostatic processes.

The key terms used in 1910.123–1910.126 are defined in 1910.123(d), and using those definitions correctly determines whether a requirement applies.

• Definitions tell you which tanks, coatings, or operations are covered and what words like "dip tank," "vapor degreasing," or "flow coating" specifically mean for enforcement.
• Apply those definitions when deciding which parts of 1910.123–1910.126 apply to a given operation so you implement the correct protections.

Always read 1910.123(d) first when assessing compliance obligations.