Cost-Effective Ventilation of a Large-Aircraft Painting Facility at Robins AFB, Georgia

摘要

The text of 29 CFR 1910.107(d)(9), which was imported from the 1969 revision of a fire safety standard, prohibits recirculating ventilation in spray painting facilities. Devices to measure vapor concentrations obsoleted this standard almost immediately, but efforts to amend this statement have been frustrated. To accommodate advances in technology, OSHA invoked the designation "de minimis violation" to enable the use of recirculation and other technologies that comply with the most current consensus standards applicable to their operations . . . when the employer's action provides equal or greater employee protection. Whereas industry has adapted to this expedient. Department of Defense agencies have consistently interpreted that if 107(d)(9) is still in print and the alternative is called a violation, however qualified, military installations will not be given permission to employ exhaust recirculation (ER). Individual bases working in isolation have built a few examples of painting hangars using ER, but each of these facilities suffered from one or more serious design faults. Robins Air Force Base (RAFB), near Macon, Georgia, is acquiring a painting hangar to accommodate painting of C-5 aircraft in an ER ventilation system. Because the economics of exhausting 2.5 million cfm of temperature-controlled air is untenable, critical justification for using ER is provided by RAFB's environmental conditions, which require cooling and dehumidifying air used in the ventilation process during four to five months each year. This report identifies documentary precedents for competent designs of future paint facilities and describes the preparation and issuance of a design-and-build contract for construction of this new facility at RAFB.