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OSHA 1915.35

Painting safety requirements

Subpart C

23 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.35(a)(1)(i), when must air-line respirators be used for paint spraying in confined spaces?

Under 1915.35(a)(1)(i), air-line respirators must be provided and used by employees who are continuously exposed to paint spraying in confined spaces.

  • Employers must follow the respirator requirements in Subpart I of Part 1915 when employees are continuously exposed while spraying paints mixed with toxic vehicles or solvents. See the general painting rule in 1915.35(a).

Under 1915.35(a)(1)(ii), what respirator and ventilation requirements apply when spraying inside tanks or compartments?

Under 1915.35(a)(1)(ii), employees continuously exposed to spray inside tanks or compartments must be protected by air-line respirators, and where mechanical ventilation is provided the respirator protection still must meet the requirements of Subpart I.

  • This means you cannot rely on ventilation alone to eliminate respirator use for continuous exposures; follow the specific respirator program and equipment rules in Subpart I as well. See 1915.35(a).

Under 1915.35(a)(1)(iii), are respirators required when spraying in large, well‑ventilated areas?

Yes. Under 1915.35(a)(1)(iii), employees exposed to spraying with paints mixed with toxic vehicles or solvents in large, well-ventilated areas must still be protected by respirators that meet Subpart I requirements.

  • Even in large spaces, employers must assess exposure and provide the appropriate respirator under Subpart I when toxic solvents or vehicles are involved. See 1915.35(a).

Under 1915.35(a)(2), what respiratory protection is required for brush painting in confined or poorly ventilated areas?

Under 1915.35(a)(2), employees doing brush application of paints with toxic solvents in confined spaces or where ventilation is inadequate must be protected by filter respirators that comply with Subpart I.

  • Employers should choose filter cartridges appropriate for the solvent hazards and follow the respirator program elements required by Subpart I. See 1915.35(a).

Under 1915.35(a)(3), what should employers do when flammable paints or vehicles are used?

Under 1915.35(a)(3), employers must take precautions required by 1915.36 when using flammable paints or vehicles.

  • That means follow the fire-prevention, equipment, and work-practice rules in 1915.36 to control ignition sources, ventilation, bonding/grounding, and other hazards associated with flammable materials.

Under 1915.35(a)(4), what bonding requirements apply to air-moving equipment and ductwork used during painting?

Under 1915.35(a)(4), the metallic parts of air-moving devices (fans, blowers, jet-type air movers) and all duct work must be electrically bonded to the vessel's structure.

  • Bonding reduces static buildup and lowers the risk of sparks that could ignite flammable vapors during painting. See 1915.35(a).

Under 1915.35(b)(1), what ventilation and testing is required when using coatings dissolved in highly volatile solvents?

Under 1915.35(b)(1), employers must provide sufficient exhaust ventilation to keep solvent vapor concentrations below ten percent (10%) of the lower explosive limit (LEL) and a competent person must make frequent tests to verify concentrations.

  • The term "competent person" who performs these tests is expected to be able to recognize, evaluate, and specify protection and precautions; see OSHA's interpretation on competent person duties in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18. See 1915.35(b)(1).

Under 1915.35(b)(2), what actions must be taken if ventilation fails or solvent vapor reaches 10% of the LEL?

Under 1915.35(b)(2), painting must be stopped and the compartment evacuated if ventilation fails or solvent vapor concentration reaches or exceeds ten percent (10%) of the LEL; work can resume only after the concentration falls below that level.

  • Employers must continuously monitor and have procedures to evacuate and recheck concentrations before allowing employees back into the space. See 1915.35(b)(2).

Under 1915.35(b)(3), how long must ventilation continue after painting, and how is a space declared gas‑free?

Under 1915.35(b)(3), ventilation must continue after painting until the space or compartment is gas-free, and the final determination that the space is gas-free must be made after the ventilating equipment has been shut off for at least 10 minutes.

  • This procedure helps ensure trapped vapors have cleared and no pockets of flammable vapor remain. See 1915.35(b)(3).

Under 1915.35(b)(4), where must exhaust ducts discharge and what testing is required?

Under 1915.35(b)(4), exhaust ducts must discharge clear of working areas and away from possible ignition sources, and employers must periodically test to make sure exhausted vapors are not accumulating in other vessel or dry dock areas.

  • Periodic checks should include nearby spaces and outdoor areas where vapors could collect; adjust duct routing and discharge location if accumulation is found. See 1915.35(b)(4).

Under 1915.35(b)(5)–(7), what equipment and material choices reduce explosion risk during painting with volatile solvents?

Under 1915.35(b)(5) through 1915.35(b)(7), employers must use explosion-proof motors and control equipment, fans with nonferrous blades, nonferrous portable air ducts, and maintain proper grounding. Additionally, tools and staging must be non-sparking and lighting must be explosion-proof and approved for Class I, Group D atmospheres.

  • These requirements reduce ignition sources where vapors may be present; follow the listed equipment specifications exactly. See 1915.35(b)(5) and 1915.35(b)(7).

Under 1915.35(b)(8), what inspections must a competent person make of power and lighting cables?

Under 1915.35(b)(8), a competent person must inspect power and lighting cables to ensure insulation is in excellent condition (no cracks or worn spots), there are no connections within 50 feet of the operation, lines are not overloaded, and cables are suspended with enough slack to prevent stress or chafing.

  • OSHA's interpretation of competent person duties in shipyards explains that a competent person must be able to recognize and evaluate hazards and specify protective measures; see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 and 1915.35(b)(8).

Under 1915.35(b)(9), what personal protective equipment and clothing are required when handling highly volatile paints?

Under 1915.35(b)(9), employees handling highly volatile paints must have protection for face, eyes, head, hands, and all other exposed body parts; footwear must be non-sparking (rubber or rubber-soled shoes without nails); outer clothing should be cotton; and rubber gloves are required because plastic gloves can create static sparks.

  • Choose PPE compatible with the solvent hazards and follow any respirator requirements in other paragraphs as well. See 1915.35(b)(9).

Under 1915.35(b)(10), what items are prohibited in areas where highly volatile paints are used?

Under 1915.35(b)(10), matches, lighted cigarettes, cigars, pipes, cigarette lighters, and ferrous articles are not allowed in areas where work with highly volatile paints is being done.

  • Enforce a strict ‘no ignition sources’ policy in these areas and post signage and controls to prevent prohibited items from entering the workspace. See 1915.35(b)(10).

Under 1915.35(b)(11)–(12), how must solvent drums and spray equipment be grounded and handled to prevent static and ignition?

Under 1915.35(b)(11) and 1915.35(b)(12), solvent drums taken into compartments must be placed on nonferrous surfaces and grounded to the vessel; metallic contact must be maintained between containers during transfers. Spray guns, paint pots, and metallic parts of connecting tubing must be electrically bonded and the bonded assembly grounded to the vessel.

  • Proper bonding and grounding prevent static build-up and reduce the risk of sparks during transfer and spraying. See 1915.35(b)(11) and 1915.35(b)(12).

Under 1915.35(b)(13)–(14), what respirators and clothing are required for employees continuously in compartments or doing exterior spray with highly volatile paints?

Under 1915.35(b)(13) and 1915.35(b)(14), employees continuously working inside compartments where highly volatile paints are used must wear air-line respirators and suitable protective clothing, while employees entering such compartments for limited time and those doing exterior spray must be protected by filter cartridge respirators and suitable protective clothing as required by Subpart I.

  • Match the respirator type to exposure duration and concentration, and implement a respirator program per Subpart I. See 1915.35(b)(13).

Who qualifies as the "competent person" who must perform vapor concentration tests under 1915.35(b)(1)?

The person who performs vapor concentration tests under 1915.35(b)(1) must be a "competent person"—that is, someone capable of recognizing and evaluating hazardous atmospheres and of specifying necessary protection and precautions, as explained in OSHA's shipyard competent person interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

  • For Subpart C tasks, the competent person must meet any additional qualifications required by [29 CFR 1915.7] and be able to make reliable vapor/LEL assessments and corrective recommendations. See https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 and 1915.35(b)(1).

How should an employer measure solvent vapor concentration to determine the 10% LEL threshold under 1915.35(b)(1)?

An employer should have a competent person perform frequent tests with appropriate gas/vapor detection instruments calibrated for the solvents in use to verify vapor concentrations are below ten percent (10%) of the LEL, consistent with 1915.35(b)(1).

  • Use detectors or gas monitors that can read LEL percentages for the specific solvent, follow manufacturer calibration procedures, document test results, and act immediately if readings approach or exceed 10% LEL. See 1915.35(b)(1).

Under 1915.35(b)(5), why must fans have nonferrous blades and portable air ducts be nonferrous?

Under 1915.35(b)(5), fans must have nonferrous blades and portable air ducts should be nonferrous to minimize the risk of sparks from friction or impact that could ignite flammable vapors.

  • Nonferrous materials (like aluminum or brass) are less likely to generate sparks when struck or rubbed, reducing ignition risk in solvent-vapor atmospheres. See 1915.35(b)(5).

Under 1915.35(b)(9), why does OSHA require cotton outer clothing and rubber gloves instead of plastic?

Under 1915.35(b)(9), OSHA requires cotton outer clothing because synthetic materials can generate static charges and ignite more easily, and rubber gloves rather than plastic because rubber is less likely to produce static sparks that could ignite volatile solvent vapors.

  • These clothing choices are part of controlling static and ignition hazards when working with highly volatile paints. See 1915.35(b)(9).

How should employers prevent vapor accumulation in nearby areas when discharging exhaust according to 1915.35(b)(4)?

Employers must route exhaust so it discharges clear of working areas and away from possible ignition sources and must perform periodic tests to ensure vapors are not accumulating in other areas of the vessel or dry dock, as required by 1915.35(b)(4).

  • Practical steps include choosing high-discharge locations, monitoring downwind and nearby spaces for vapor buildup, and adjusting duct length or discharge hoods if accumulation is detected. See 1915.35(b)(4).

When using highly volatile, flammable solvents, what housekeeping steps does 1915.35(b) expect to reduce fire and explosion risks?

Section 1915.35(b) expects employers to: keep solvent vapor below 10% LEL with adequate ventilation and testing, use explosion-proof motors and lighting, ban open flames and ferrous ignition sources, ground and bond containers and equipment, use non-sparking tools and footwear, and provide appropriate respirators and clothing.

  • These combined controls—engineering, equipment, administrative, and PPE—are required to reduce fire and explosion risks when working with highly volatile coatings. See 1915.35(b).

Under 1915.35, what must an employer do if solvent vapor concentration does not fall after stopping painting?

If solvent vapor concentration does not fall after stopping painting, 1915.35(b)(3) requires the employer to provide additional ventilation until the concentration falls below ten percent of the LEL and the space is declared gas-free per the shutdown and 10-minute check.

  • Do not re-enter the space or resume painting until ventilation has reduced vapors to safe levels and the competent person confirms the area is gas-free. See 1915.35(b)(2)–(3).