A bit too far
A recent OSHA bulletin confuses the issue of using bonding adhesives for roofing applications
From time to time, the Occupational Safety and Health Administration (OSHA) publishes Safety and Health Information Bulletins (SHIBs); these bulletins are advisory in nature and not standards or regulations. They are intended to help employers provide safe, healthful workplaces without creating new legal obligations. In April, OSHA issued SHIB 03-13-2014, which focuses on alleged fire hazards that may result from using a certain type of spreader of flammable bonding adhesives used in roof system installations. OSHA states using the device listed in the bulletin does not meet its requirements for dispensing flammable liquids.
The OSHA bulletin was a result of a job-site inspection conducted by the agency's Region 1, Concord, N.H., office. Bonding adhesives used in the roofing industry for adhering single-ply membranes often meet the definition of a flammable liquid—generally a liquid with a flash point of 199.4 F or lower. Adhesives can be rolled, brushed or sprayed onto a roof surface or membrane. The OSHA bulletin cites "dolly-type roller devices" do not meet OSHA's requirements for spreading flammable liquids.
The spreader is designed to allow application of adhesive directly from an original 5-gallon container onto a roller that spreads the adhesive as a worker moves the equipment along a roof's surface. OSHA states the manufacturer's instructions advise applicators to place the container horizontally on the device's cradle and punch holes along the center to allow the contents to flow through the holes onto the roller that spreads it along the surface. According to the agency, punching holes nullifies the container's approval because it does not comply with requirements for dispensing flammable liquids under 29 CFR 1926.152(e).
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