WHILE AVOIDING CODE VIOLATIONS

Bob Hauck, VP - Spray Systems, Inc.

Copyright © 2018 Spray Systems | All Rights Reserved

HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS

INTRODUCTION
Today, manufacturers, or part finishers, must discover ways to avoid costly mistakes and
design the perfect spray booth that fits their paint finishing requirements. Too many times
companies assume a design of their booth for their finishing application and move too quickly
into ordering rather than designing – this is costly, in time and money, from installation to
operations. And the proper design for the booth must take into account all the applicable
booth code requirements that affect operator and plant safety – and there are many.

THE “PERFECT” SPRAY BOOTH MUST In this 3-Part presentation, titled “How to design the perfect
ADDRESS THE THREE ESSENTIALS OF A spray booth while avoiding code violations”, we reinforce
SPRAY BOOTH SOLUTION... the ultimate spray booth design objectives listed above, and
then apply the codes that might affect optimal booth designs.
1. Protecting employees and facilities at
all times from a hazardous environment The booth designer must protect the best design choice when
codes are considered; the designer’s job is to not only engineer
2. Providing a spray environment in the optimal booth environment for the best possible finish, but
which to obtain the highest quality also ensure that all building and safety codes are followed.
finish Codes cannot be underestimated – compliance is mandatory,
from NFPA33, OSHA, IFC and building codes, and violations
3. Realizing and sustaining measurable
cost reductions and optimizations can be very costly. We’ll explore what aspects of booth design
from spray booth operations. create the biggest risk and what happens if I violate.
 Part 1:
CODES HAVE
THEIR PLACE
IN DESIGNING YOUR PERFECT SPRAY BOOTH...

Booths are highly regulated by many different agencies, as well as any other regulations
that the Finisher requires within their plant – the spray environment impacts directly on
operator health, personnel and plant safety, productivity, potential fire hazard, along with
an overall environmental impact. Because of these important aspects, spray booths
are highly scrutinized by the applicable governing agencies.

The assumption that we’ve heard many of our customers make too many times...”I’ve
got the building inspector all over me...I’m sure my booth designer will meet all
required regulations.” If you don’t ask the right code questions, upfront, you’re
assuming, dangerously.

A typical spray booth installation is much like a mini-building construction project. Not
only is there the mechanical installation of the booth, but also the building interface and
utility connections to the booth. Whether a small bench booth, large equipment down draft
booth, or powder booth, they all require utility connections, such as wet sprinkler lines, electrical
connection to building electrical sources and compressed air from a compressed air source.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 4

NFPA (FIRE PROTECTION STANDARDS)

Plant and property safety is governed by national and local Fire Department regulations. Finisher’s need to protect product inventory
and the cost to replace, as well as equipment downtime due to damage, or citations issued by these regulatory agencies.

We at Spray Systems understand that the design and • NFPA 33 Spraying of Flammable Material – 5 key chapters
implementation of your spray booth can be an extremely that effect booth design
challenging and confusing process. It is our goal to provide you
with important information to help that process go as smoothly • NFPA 68 Explosion Protection Venting – especially
as possible. Although designing the perfect spray booth is very important for powder booth operations
important, designing the booth AND complying with all the federal
• NFPA 654 Handling of Combustible Particulate Solids –
and local safety codes are the most important steps in ensuring
especially important for powder booth operations
the long and continued success, productivity and efficiency of
your spray application. We believe that keeping all these codes
• NFPA 70 National Electrical Code – important electrical
in mind during the design phase is the only way to prevent any
requirements for installing spray booths
complications down the road. For this reason, we have provided
a summary of important safety code sections of NFPA 33 so that • NFPA 86 Standards for Ovens & Furnaces – critical
you can better understand the regulatory impact of designing the requirements for curing or baking parts
perfect spray booth for you

OSHA (OCCUPATIONAL SAFETY AND HEALTH STANDARDS)

• Standards - 29 CFR: OSHA Regulation 1910.107 – spray finishing using flammable and combustible materials
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 5

BUILDING CODES
• International Fire Code (IFC) – where NFPA standards are confirmed in international code

• International Mechanical Code (IMC) – where local mechanical standards are confirmed in international code

• International Building Codes (IBC) – where local building standards are confirmed in international code

LOCAL CITY CODES

• Authority Having Jurisdiction (AHJ) – local inspectors having authority to assess and apply code to installation

• UL or ETL Rated and Approved Installations (Certified in Field) – post-installation evaluation and certification

• NESHAP – filter requirements ensure meeting all air pollution limits

• State and local VOC emission limitations and regulations (BACT) – as applied to spray booth installations

INSURANCE STANDARDS
• FM Global – achieving the “FM Approved” mark for meeting safety standards
 Part 2:
COMPLYING WITH ALL
STANDARDS & CODES
IN EACH ASPECT OF DESIGN

The liability to your business for violation can be far-

reaching. The Fabricator can’t be too cavalier about
these codes and standards. Too often, any code or
standard violation can bring on lawsuits, whether they’re
initiated by agencies or employees, especially where workers
compensation claims get involved. These can be avoided
if the booth designer understands and appreciates how these
codes can be satisfied while protecting your design solution –
preventing is certainly less expensive than curing a code violation.
Plant and property safety is governed by national and local Fire Department regulations.
Finisher’s need to protect product inventory and the cost to replace, and equipment downtime
due to damage, or citations issued by regulatory agencies.

To start, here are some key highlights of agency standards and codes that we recommend
you understand and apply early on in your booth design...
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 7

NFPA 33 (STANDARD FOR SPRAY APPLICATION USING FLAMMABLE

OF COMBUSTIBLE MATERIALS)
(Figures and Sections reproduced with permission from NFPA • Chapter 5: Construction and Design of Spray Areas, Spray
33-2018, Standard for Spray Application Using Flammable of Rooms, and Spray Booths
Combustible Materials, Copyright © 2017, National Fire Protection
• Chapter 6: Electrical and Other Sources of Ignition
Association, Quincy, MA 02169. This reprinted material is not
the complete and official position of the NFPA on the referenced • Chapter 7: Ventilation
subject, which is represented only by the standard in its entirety
• Chapter 8: Storage, Handling, and Distribution of Flammable
which can be obtained through the NFPA web site at
and Combustible Liquids
[Link]
• Chapter 13: Spray Booths and Rooms Used for Drying at
Here are (5) key chapters from NFPA that you should know Elevated Temperatures
as they pertain to spray booth design and installation and are
further discussed below... • Chapter 15: Powder Coating

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

CHAPTER 5: CONSTRUCTION AND DESIGN OF SPRAY covers the allowable construction materials for illumination,
AREAS, SPRAY ROOMS, AND SPRAY BOOTHS observation panels, and ventilation systems.

Chapter 5 of the NFPA 33 document covers the basics of design Here are some important examples about booth construction and
and construction requirements of a spray paint operation. This separation you should know:
section outlines the materials that are permitted in the construction
of a spray booth with specific examples and exemptions given Section 5.1.1: Walls, doors, and ceilings that intersect or
the location and purpose of a spray booth component. In addition enclose a spray area shall be constructed of noncombustible
to spray booth construction requirements, this section also or limited combustible materials or assemblies and shall
provides guidelines for spray booth location in relation to other be securely and rigidly mounted or fastened. The interior
working operations in the same building. These requirements are surfaces of the spray area shall be smooth, designed and
paramount for the safe operation of a spray booth as well as for installed to prevent pockets that can trap residues, and
the ease of maintenance and filter replacement. Finally, this section designed to facilitate ventilation and cleaning.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 8

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

installed to prevent pockets that can trap residues, and CHAPTER 6: ELECTRICAL AND OTHER SOURCES OF
designed to facilitate ventilation and cleaning. IGNITION
Section 5.5: Separation from Other Operations. Spray booths
Chapter 6 of NFPA 33 lists the requirements and restrictions for
shall be separated from other operations by a minimum
electrical wiring and spark-producing materials that are allowed
distance of 915 mm (3 ft) or by a partition, wall, or floor/
within a spray paint booth area. The first section defines the
ceiling assembly having a minimum fire resistance rating
applicable zoning system as well as class/division determination.
of 1 hour; multiple connected spray booths shall not be
This section is very important in spray booth electrical design as
considered as “other operations” except as provided for in
it provides an in-depth description of electrical area classification.
Section 13.3.
Similar to Chapter 5, this chapter covers restrictions on the
The following are other sections in Chapter Five that address the electrical equipment that is permitted to be within certain areas
Construction and Design of Spray Areas and Spray Booths. You can surrounding a spray booth. Figures (or sketches) are provided that
review these fully from our website at: [Link] show specific areas where electrical equipment can/cannot be
located.
• Outlines materials allowed/not allowed in spray booth
construction. Here are examples of some important electrical requirements
- Provides specific exemptions. you should know:
• Requirements for conveyor openings. 6.2.5: Open flames, spark-producing equipment or
processes, and equipment whose exposed surfaces exceed
• Requirements for booths using nitrocellulose. the autoignition temperature of the material being sprayed
• Required distances between spray operations. shall not be located in a spray area or in any surrounding area
- Clear areas around spray booths and other operations. that is classified as Division 2, Zone 2, or Zone 22.
• Outlines requirements for glass covering lighting and 6.2.6: Any utilization equipment or apparatus that is capable
observation windows. of producing sparks or particles of hot metal and that is
located above or adjacent to either the spray area or the
• General filter requirements. surrounding Division 2, Zone 2, or Zone 22 areas shall be of
• Restrictions on filters being used for multiple materials that the totally enclosed type or shall be constructed to prevent
are highly combustible. the escape of sparks or particles of hot metal.
6.5.2: Electrical area classification NFPA-33, confirms that if
spray application operations are conducted within a closed-
top, open-face or open-front booth or room, as shown in
Figure 6.5.2, any electrical wiring or utilization equipment
located outside the booth or room but within 915mm (3 ft) of
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 9

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

any opening shall be suitable for Class I, Division 2; Class I, CHAPTER 7: VENTILATION
Zone 2; Class II, Division 2; or Zone 22 locations, whichever is
applicable. Chapter 7 of NFPA 33 outlines the most important requirements
of spray booth ventilation. The three main topics covered in this
6.6.1: Luminaires, like that shown in Figure 6.6.1, that are
section are powder coating systems, make-up air, and recirculated
attached to the walls or ceiling of a spray area but that are
air. For each of these, the minimum performance requirements
outside any classified area and are separated from the spray
are listed as well as general information on when each of these
area by glass panels that meet the requirements of Section
is required in spray booth design. The routing requirements of
5.6 shall be suitable for use in unclassified locations. Such
all exhaust ducts are another important section of this code.
fixtures shall be serviced from outside the spray area.
Penetrations and discharge restrictions are discussed and exact
Also covered in this chapter is the requirement to ground all measurements are provided for reference. Exhaust duct support
electrically conductive objects in a spray area. is another important code listed in this
section. The code outlines the structural
• Zoning system is described and restrictions on class/ requirements of any component that
division location are provided. is meant to hold exhaust duct in place.
• Restrictions on spark producing equipment and/or These requirements are meant to ensure
processes. that the duct is securely fastened to the
• In depth description of electrical area classification. building and need to be able to support
any fire protection systems that are
• Electrical wiring and equipment allowed/not allowed within added. The final section of this code
a spray booth setting. outlines the allowable construction
• Electrical wiring and equipment allowed/not allowed in materials of exhaust fans and drives as
areas adjacent to a spray booth setting. well as restrictions on where exhaust
• Drawings provided to show areas within/adjacent to a spray fan components can be located within a
booth where electrical restrictions apply. spraying operation.
• Guidelines for luminaires located within a spray booth. Here are examples of some important ventilation requirements
• Guidelines for grounding all electrically conductive objects you should know:
in a spray area. 7.2.3 Mechanical Ventilation. Mechanical ventilation shall be
kept in operation at all times while spray operations are being
conducted and for a sufficient time thereafter to allow the
vapors from drying coated objects or material and residues
to be exhausted. Where spray operations are conducted
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 10

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

automatically without an attendant constantly on duty, the • Powder coating systems

operating controls of the spray apparatus shall be arranged • Make-up air systems
so that the spray apparatus cannot function unless the
exhaust fans are operating. • Exhaust ducts
7.5 Recirculation of Exhaust. Air exhausted from spray • Exhaust recirculation
areas shall not be recirculated unless all of the following • Heating of recirculated air
requirements are met... • Allowable materials of construction given the spray booth
(1) Recirculation particulate filters as defined in this application.
standard shall be used to remove particulates from the • Requirements of exhaust duct support structure.
recirculated air.
• Restrictions for construction and location of exhaust fans
(2) The concentration of vapors in the exhaust and drives.
airstream shall not exceed 25 percent of the lower
flammable limit. • Ventilation requirements of drying rooms and enclosures.
(3) Listed equipment shall be used to monitor the
concentration of vapors in all exhaust airstreams. CHAPTER 8: STORAGE, HANDLING, AND DISTRIBUTION
OF FLAMMABLE AND COMBUSTIBLE LIQUIDS
(4) The equipment specified in 7.5(3) shall initiate a
local alarm and shall automatically shut down the Chapter 8 of NFPA 33 is very important if the medium that is being
spray operation if the concentration of any vapor in sprayed within a spray booth is flammable or combustible. This
the exhaust airstream exceeds 25 percent of the lower chapter is meant to ensure the safety of all personnel during the
flammable limit. storage, mixing, and distribution phases of spraying. The general
(5) All equipment installed to process and remove requirements for mixing paints and ventilation within a mix room
contaminants from the air exhausted from spray are outlined. It is very important to be familiar with this code as it
operations shall be approved by the authority having explains the restrictions on the amount of liquid that is permitted
jurisdiction. per day given certain circumstances. Diagrams have been provided
to demonstrate the relationship between the proximity of a mix
(6) For occupied spray areas where a portion of the room to a paint booth and the amount of liquid that can be used
exhaust air is recirculated within the spray area, toxicity during a 1-day period. Finally, this chapter covers the general rules
and worker exposures shall be addressed. for paint distribution and piping mechanisms. This section of NFPA
Other Performance requirements under NFPA Chapter 7 you can 33 references other parts of the NFPA code and it is important to
research are... be familiar with all applicable codes in order to ensure a successful
spraying operation.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 11

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

Here are examples of some important paint storage 8.3.6 Where a

requirements you should know: separate mixing
8.3.2 Where the quantities of liquids required or the floor area room is provided,
necessary to provide a suitable mixing room exceeds the and the mixing
limits specified in 8.3.3 through 8.3.6, the mixing room shall room is located
meet all applicable requirements of NFPA 30. more than 1830
mm (6 ft) from
8.3.3 Mixing rooms shall meet all of the following an adjacent spray
requirements area or areas, the
(1) Mixing rooms shall meet the construction quantity of liquid
requirement of Section 5.1. permitted in the
(2) The area of a mixing room shall not exceed 14 m mixing room shall
(150 ft2). not exceed 80 L/
m2 (2 gal/ft2), up
(3) If more than one mixing room is installed, the total to a maximum of
quantity of liquids shall not exceed the limits in 8.3.5 or 1135 L (300 gal), as
8.3.6. shown in Figure 8.3.6. The amount of liquid in the spray area
(4) Mixing rooms shall be designed to contain a spill of shall not exceed 227 L (60 gal).
the contents in the room.
Other Performance requirements under NFPA Chapter 8 you can
(5) Mixing rooms where dispensing, handling, or research are...
transferring of Class I, Class II, or Class III liquids at
temperatures at or above their flash point occurs shall • Guidelines for mixing room distribution systems.
be provided with mechanical ventilation capable of • Piping
providing air movement not less than 0.3 m3/min/m2 • General
(1 ft3/min/ft2) of floor area or 4 m3/min (150 ft3/min),
whichever is greater. • Maximum allowable quantities of flammable and
combustible liquids allowed to be stored in each control
8.3.5 Where a separate mixing room is provided and the area.
mixing room is located adjacent to or within 1830 mm (6 • Table provided
ft) of an adjacent spray area or areas, as shown in Figure
8.3.5(a) and Figure 8.3.5(b), the combined quantities of • Guidelines for mixing or transferring liquids.
liquids located in the spray areas and the mixing room shall
not exceed 454 L (120 gal).
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 12

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

CHAPTER 13: SPRAY BOOTHS AND ROOMS USED FOR type spray application operations, including automobile
DRYING AT ELEVATED TEMPERATURES refinishing operations, shall be permitted to be used
alternately for drying, curing, or fusing operations,
Chapter 13 of NFPA 33 is all about the use of heating systems for provided they meet all applicable requirements of this
the purpose of paint drying and curing. This is one of the most standard and the requirements of NFPA 86 as well as
important sections to be familiar with if your spray applications the requirements of [Link] through [Link].
involve drying at elevated temperatures. The first part of this
code outlines safety requirements and fail-safes that need to be Other Performance requirements under NFPA Chapter 13 you can
present whenever heating elements are used. There are specific research are...
requirements for flash-off areas that are present in a spraying • Guidelines for ambient air drying.
application. This section mentions several other NFPA codes that
also need to be referenced when dealing with flash-off areas. The • Guidelines for spray booths and rooms used for drying at
final sections of NFPA 33 cover interconnecting doors and high elevated temperatures.
temperature limit switches that automatically shut off the drying • Requirements for Flash-Off Areas.
apparatus at a specified temperature. This code also references • Requirements for spray operations connected to or
specific warning signs that need to be in place to indicate when a adjacent to drying, curing, or fusing operations.
drying process is taking place and that can restrict access when
high temperatures are involved. • Fusion apparatus ventilation guidelines.
• Requirements for drying, curing, and fusion warning signs.
Here are examples of some important drying or curing
requirements you should know:
CHAPTER 15: POWDER COATING
13.2 Spray Booths and Spray Rooms Used for Ambient Air
Drying. If a spray booth or spray room is also used for air- Chapter 15 of NFPA 33 covers the general requirements for
drying, curing, or fusing operations and the air temperature powder coating applications. Diagrams have been provided to
therein is not elevated above ambient conditions, the that show the restrictions on where powder coating booths can
ventilation system shall maintain the concentration of any be located in relation to other spraying applications and general
vapors in the exhaust stream below 25 percent of the lower working operations. Powder coating applications require specific
flammable limit. If the temperature in the spray area is safety protections systems. These are introduced in this section
elevated for the purpose of accelerating the drying or curing with references to other codes that give more specific instruction
process, then the requirements of Section 13.3 shall apply. on these requirements. For powder coating booths that include
automation, this section covers the requirements for emergency
13.3* Spray Booths and Spray Rooms Used for Drying at shutdown protocols, ventilation systems, automatic sprinkler
Elevated Temperatures. systems, and the need for portable fire extinguishers. Electrical
13.3.1 Spray booths or spray rooms used for batch- wiring, dust collection, and explosion protection requirements
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 13

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

are covered. In addition to operation guidelines, this section also • Description of required safety protection systems.
elaborates on paint booth maintenance. This includes, powder • Guidelines for automated spray operation.
unloading, bag dumping stations, and spill cleanup.
- Emergency shutdown
Here are examples of some important powder coating ventilation - Ventilation systems
requirements you should know:
- Automatic sprinkler systems
15.6 Enclosures. Powder shall be confined by conducting
coating operations within one of the following: - Need for portable fire extinguishers
(1) A completely enclosed, ventilated room of • Protection guidelines for automated powder application
noncombustible or limited-combustible construction equipment.
with smooth surfaces designed to prevent • Guidelines for electrical wiring and other sources of ignition
accumulation of powder and to facilitate cleaning within a powder coating enclosure.
(2) A ventilated spray booth meeting the requirements • Guidelines for ventilation, dust collection, and explosion
of Section 5.1 through Section 5.7, and having enclosed, protection.
ventilated containers (tanks, bins, etc.) • Operation and maintenance requirements.
15.8.2 Air Exhausted. Air exhausted from the recovery • Automated/handheld electrostatic powder spraying
system of a powder operation shall not be recirculated unless equipment.
the concentration of particulate matter in the exhaust air has
been reduced to a level that is considered safe for personnel - Hot flocking
occupational exposure and equipment continuously - Fluid bed coating
monitors the filtration system to signal the operator and • Requirements for powder coating delivery and circulation.
to automatically shut down the operation in the event the
filtration system fails to maintain the air in this condition. You • Requirements for powder unloading, bag dumping stations,
should know that you can recirculate your powder booth back and pneumatic conveying systems.
into the plant, which makes powder applications so efficient • Storage and handling guidelines.
– no make-up air. • Housekeeping guidelines.
Other Performance requirements under NFPA 33 Chapter 15 you - Spill clean up
can research are...
Here are some other NFPA codes and standards that apply to spray
• Restrictions on powder coating booth locations. booths. Please refer to the complete edition for specific standards
• General safety and protection requirements. as they apply to your booth design...
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 14

QUICK LOOK AT THE ESSENTIALS OF NFPA 33

NFPA 68 Standard on Explosion Protection by Deflagration dryers, and furnaces; thermal oxidizers; and any other heated
Venting. This standard applies to the design, location, enclosure used for processing of materials and related
installation, maintenance, and use of devices and systems equipment…Class A ovens and furnaces (specifically for
that vent the combustion gases and pressures resulting from spray booths) are heat utilization equipment operating at
a deflagration within an enclosure so that structural and approximately atmospheric pressure, wherein there is a
mechanical damage is minimized. potential explosion or fire hazard that could be occasioned by
the presence of flammable volatiles or combustible materials
NFPA 70®: National Electrical Code®. Broadly covers the processed or heated in the furnace. Such flammable volatiles
workplace in this 800+ page code. Safety requirements for or combustible materials can originate from any of the
Special Equipment can be found in Chapter 3. NFPA-70 also following...paints, powders, inks, and adhesives from finishing
outlines a documented system of electrical safety principles processes, such as dipped, coated, sprayed, and impregnated
and procedures that directs activities for the risk associated materials.
with electrical hazards. Article 105 address the application of
safety-related work practices and procedures and Article 120 Note: NFPA 70® and National Electrical Code® are
addresses establishing an electrically safe work condition. registered trademarks of the National Fire Protection
Association, Quincy, MA
NFPA 86: Standards for Ovens and Furnaces. This standard
shall apply to Class A, Class B, Class C, and Class D ovens,
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 15

OSHA (29 CFR: OSHA REGULATION 1910.107)

SPRAY FINISHING USING FLAMMABLE AND COMBUSTIBLE MATERIALS
Employee safety is addressed by OSHA under section CFR-1910. These OSHA requirements not only cover personnel and operator
safety but also address special guidelines for the operator which directly affect the design of the spray booth. Items such as emergency
egress, proper airflow, storage of paint, minimum clearances are all items addressed in this code.

Here are examples of 29 CFR requirements you should know...

• Spray Booth Construction, 1910.107(b)(1). This states that spray booths shall be substantially constructed of steel, securely
and rigidly supported, or of concrete or masonry except that aluminum or
other substantial noncombustible material may be used for intermittent or
low volume spraying. Spray booths shall be designed to sweep air currents
toward the exhaust outlet.

• Fan Noise Level, 1910.95a. This requires that protection against the effects
of noise exposure shall be provided when the sound levels exceed those
shown in Table G-16 when measured on the A scale of a standard sound
level meter at slow response...
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 16

LOCAL BUILDING CODES

Utility and building interface necessities will require building permits from the local city or municipality. In addition to utility connections
from building sources to the booth, there are mechanical interfaces with the building – roof openings, roof curbs, grounding
requirements – and sometimes will cover building space and distance minimums, depending on booth location. Specifically,
International Fire Code (IFC) Chapter 24 provides requirements that govern operations where flammable or combustible finishes are
applied by spraying, dipping, powder coating or flow-coating processes. As with all operations involving flammable or combustible
liquids and combustible dust or vapors, controlling ignition sources and methods of reducing or controlling flammable vapors or
combustible dust at or near these operations are emphasized.

Here are examples of IFC Section 2403 requirements you

should know...
• Spray Finishing, IFC-2404.3.3.5. Spray booths shall be
installed so that all parts of the booth are able to be accessed
for cleaning. A clear space of not less than 3’ shall be
maintained on all sides of the spray booth. This clear space
shall be kept free of any storage or combustible construction.

• Protection of Operations, IFC-2403.2.1.1. This mandates that

all electrical wiring and equipment in flammable vapor areas
shall be on an explosion proof type approved for use in such
hazardous locations. Such areas shall be considered to be
Class I, Division 1 or Class II, Division 1 hazardous locations in
accordance with NFPA 70.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 17

LOCAL CITY CODES

Sometimes third-party certification such as UL or ETL approvals are required to meet local codes. This requirement is based solely
on local City and State requirements and codes. Due to the nature of a spray booth installation, a local testing agency such as ETL
or UL (third party nationally recognized testing agency) can inspect the booth’s equipment components and installation to acquire
this certification. There is a charge to have the agency review the booth’s documentation and installation. Lastly, state and local
requirements will require an air pollution permit based on the VOC emissions for your particular booth installation. Each state and
geographical region has certain VOC emission restrictions in order to meet federal EPA guidelines and requirements. Check with
you state and local air pollution authority for the emission requirement that will affect your booth installation.

INSURANCE CODES
Manufacturers must address the specific requirements within their own insurance liability coverages. Many insurance companies follow
the same guidelines and regulations required by local and federal agencies; but sometimes they add “best practice requirements”
to ensure the proper safety in the operation of the spray booth and use of booth components.

For example, FM Global can certify a product and label with a “FM Approved” certification mark. This ensures that the product meets
the highest property loss prevention product testing and certification standards. Relative to spray booths, Air Make-up Units as well
as the overall booth installation can receive this FM approval that helps to meet the insurance requirement of the company.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 18

OTHER CLASSIFICATION AND CODE DEFINITIONS TO BE AWARE OF...

• Authority Having Jurisdiction (AHJ) – local inspectors having • International Mechanical Code (IMC) – within this IMC, there
authority to assess and apply code to booth installation are a number of specific code requirements pertaining to
mechanical installations of a spray booth.
• UL or ETL Rated and Approved Installations (Certified
in Field) – these agencies will perform a post-installation • International Building Codes (IBC) – within IBC, there are
evaluation and certification also a number of specific code requirements pertaining to
the larger booth structures, and therefore, qualify under the
• NESHAP – National Emissions Standards of Hazardous Air IBC (e.g.., seismic requirements, structural analysis, outdoor
Pollutants – requires a 3-Stage exhaust filter system which booth designs...).
meets EPA Rule Test Method 319 for paint materials with
hexavalent chrome.

• State and local VOC emission limitations and regulations,

which is oftentimes referred to as “Best Available Control
Technology” (BACT) – covering spray booth installations
which require more stringent VOC emission reductions.
 Part 3:

AVOID THESE
COSTLY PENALTIES
Effective booth design can be achieved while you’re protecting your workers
and your environment.

Here are true examples of violations and how it could have been
avoided in the design and operation of the spray booth...
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 20

VIOLATION DUE TO INSUFFICIENT SPACE AROUND BOOTH

• Company type and location? • What was the penalty and costs to the Company?
- Illinois manufacturer of silk screen printing equipment, - Pay $4,900 in fines; plus cover the cost of the
and graphic and textile screen printing machines abatement; plus raised insurance liability to person
or property in case of emergency; plus a strike on
• What is the code requirement relating to this example? company’s record with NFPA where their next violation
- NFPA Chapter 5.5 requires spray booths to be may be seen as a willful violation bringing greater fines
separated from other operations by a minimum distance and penalties
of 915 mm (3 ft)
• How could it have been avoided in the design of the
• How did the Company violate this code? booth?
- Manufacturer didn’t ensure a 3’ clearance around - Booth was engineered and installed with adequate
the booth due to storage that obstructed the 3’ pathway outside dimensions to meet this code requirement, but
around the booth (including used rags, chemical this manufacturer ignored the code by obstructing
containers...); NFPA deemed this a serious violation the space with garbage and storage – the need to
– required that the manufacturer immediately remove maintain clear and accessible pathways around the
all garbage and storage, file an abatement certificate, booth is critical for compliance and mitigation of liability.
and provide photographic evidence of the abatement
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 21

VIOLATION DUE TO EXCESSIVE SOUND OPERATING LEVELS

• Company type and location? • What was the penalty and costs to the Company?
- Metal fabricating plant located in Illinois - Company was fined $76,000 for all violations, which the
Company contested and is negotiating with OSHA;
• What is the code requirement relating to this example? plus the cost cover the cost of correction; plus raised
- OSHA Fan Noise Level, 1910 requires that protection insurance liability to person or property in case of injury;
against the effects of noise exposure shall be provided plus a strike on Company’s record with OSHA where
when the sound levels go above action level of 85dBA their next violation may be seen as a willful violation
bringing greater fines and penalties
• How did the Company violate this code?
- After receiving a complaint of unsafe working • How could it have been avoided in the design of the
conditions, inspectors with OSHA allegedly discovered booth?
that employees at the Company were over-exposed - A properly designed spray booth takes into account
to noise and dust hazards within their powder booths. not only the proper air flow requirements, but how the
OSHA deemed this a serious violation. Among exhaust ventilation equipment must meet the OSHA
the several violations that the Agency found, they did sound level requirements. This also includes the
not administer an effective hearing conservation installation and operation of alarms and gages that
program; did not use gages or alarms to monitor air monitor air flow velocity in the booth.
velocity on the paint booth; did not operate the exhaust
fans within the spray booth to reduce hazards; did
not properly ground electrical equipment.... Because
this noise violation opened up the further examination
of the work environment by OSHA, OSHA inspectors
allegedly found more than 26 violations, with 15
deemed serious.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 22

VIOLATION DUE TO INSUFFICIENT FILTER MAINTENANCE

• Company type and location? • What was the penalty and costs to the Company?
- Illinois manufacturer of silk screen printing equipment, - Pay $4,900 in fines; plus cover the cost of compliance;
and graphic and textile screen printing machines plus raised insurance liability to person or property
in case of emergency; plus a strike on Company’s
• What is the code requirement relating to this example? record with OSHA where their next violation may be
- 29 CFR OSHA 1910.107(b)(5)(i) and IFC 2018 Code seen as a willful violation bringing greater fines and
2404.7.3.1, requires company’s spray booth to maintain penalties.
the average air velocity over the open face of the booth
during spraying operations of not less than 100FPM • How could it have been avoided in the design of the
booth?
• How did the Company violate this code? - Spray booths are designed with filter cells that allow
- Paint arrester filter pads were not inspected to ensure for replacement of these filters. Ensuring that
proper replacement of filter media, nor was there a you maintain the correct airflow for the optimum
visible gage or audible alarm to indicate or ensure that finishing environment requires that you have a visible
the required air velocity was maintained, and OSHA gage (e.g.., manometer) in good, operating condition at
deemed this a serious violation. all times to indicate to the operator that filters must be
replaced.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 23

VIOLATION DUE TO SPRAYING CONDUCTED OUTSIDE OF PREDETERMINED SPRAYING AREAS

• Company type and location? • How could it have been avoided in the design of the booth?
- Illinois manufacturer of silk screen printing equipment, - Spray booths are specifically designed to accommodate
and graphic and textile screen printing machines particular spraying and production requirements based
upon the manufactured part. From the current part size,
• What is the code requirement relating to this example? to future parts sizes and plans for a spraying operations,
all must be considered. Current part size (from all
- 29 CFR OSHA 1910.107(g)(1) requires that spraying shall dimensions) must be evaluated and discussed to help
not be conducted outside of a predetermined spraying area. arrive at the effective size of the booth needed. Although
small parts deserve smaller booth dimensions (and larger
• How did the Company violate this code? parts deserve larger) consideration must be given to
- Company’s painters did not ensure that the spray the access needed around the part, spray clearances,
painting of parts and equipment was conducted inside of door clearances, and more. Future part size of production
the spraying area, but rather spraying activities were parts could influence the size and dimension of the
conducted outside the protected spray area, including spray booth as the Finishers consider the initial booth
design. Finisher must also anticipate plans for future
the hanging of painted parts from an overhead bar at the
parts that may be manufactured and coated within the
entrance of the dry type paint spray booth. In addition,
proposed spray booth. Not only from a size perspective,
adjacent to the spray booth, activities included spark and but also anticipating any changes in production rates
heat producing processes, such as sanding. OSHA as well. By anticipating future part needs, the Finisher
deemed this a serious violation. can extend the life of their booth. Configuration of the
part will determine how the spray booth operates to
• What was the penalty and costs to the Company? facilitate the Finisher’s spraying operation: Vertical vs
- Pay $4,900 in fines; plus cover the cost of compliance; horizontal orientation will determine proper height,
plus raised insurance liability to person or property in width and length of the booth to ensure ample room
case of emergency; plus a strike on Company’s record for spray operations; one-sided vs 2-sided part
orientation determines the need for proper width and
with OSHA where their next violation may be seen as a
depth of the booth to accommodate spraying equipment;
willful violation bringing greater fines and penalties.
and single sprayer vs. multiple sprayer operation will
determine the width and height of the booth for air quality
and safety; this is especially true for powder applications
when multiple operators or gun stations are employed.
HOW TO DESIGN THE PERFECT SPRAY BOOTH WHILE AVOIDING CODE VIOLATIONS 24

OFTEN SEEN VIOLATION DUE TO INSUFFICIENT EMERGENCY EGRESS

• What is the code requirement relating to this example? • How could a Company avoid these violations in the design
- NFPA 33 Chapter 5.1.4 requires enclosed spray areas of the booth?
shall be provided with means of egress that meet - Design of a modified downdraft booth must take into
applicable requirements of NFPA 101, Chapter 40, which account the spray operation and these safety
is entitled Industrial Occupancies. requirements. Side plenums in this type of booth can
sometimes interfere with the proper location of the door
• How does a Company violate this code? in order to comply with these Standards. Another
- It is typical for spray booths to be designed without the constraint is a booth located adjacent to a building wall
proper consideration for emergency egress for the without the proper aisleway to allow for emergency
operators. For example, the booth could be designed exit from the spray area. All design specifications
with doors that either exceed the maximum width of 48”, regarding emergency egress must be challenged by the
or not meet the minimum of 36”. Or, that the spray booth booth engineer before any booth fabrication can take
door is located outside a 25’ reach – in case of a major place.
event, there must be emergency egress available not
farther than 25’ from the painter’s area of operation.
BOTTOM-LINE
The safer the work environment, the more productive the workforce becomes, and the
more you reduce your risk – sustainable productivity improvement is key. As you can
see, it can be very costly and disruptive to underestimate these standard and code
compliances in the final spray booth solution.

It’s the Part Finisher’s job to provide the

right information about their part, the
right information about their facility, the
right information about their production
requirements and expectations, and make no
assumptions, all along the guidelines outlined
in this Presentation. And it’s the spray booth
designer’s job to take that information, give
feedback on design options, and optimize its
spray booth solution in both its mechanical
design and technical sophistication, as well as
meeting all applicable standards and codes.
 Bob Hauck, Vice President for Spray Systems, Inc., with over 40
years of technical experience in the finishing industry. Starting
as engineer for Binks-Sames Corporation, he helped design
large finishing systems for such OEMs as General Motors
and Ford. Then promoted to West Coast Regional Manager
for Binks, directing 3 west coast branches, with a business
development force of over 20, advising customers, engineers
and plant managers on designing effective finishing systems.
Now with Spray Systems as Vice President, Bob leads the
national business development team to design critical spray
booth solutions for manufacturers in the aerospace and large
equipment industries.
BOB HAUCK
Vice President
bob@[Link]