Standard Interpretations - Table of Contents
• Standard Number: 1910.123(a); 1910.123(b)

March 23, 2001

Mr. Gavin Burdge
Corporate Industrial Hygienist
Safety-Kleen
1301 Gervais St., Suite 300
Columbia, SC 29201-3326

Dear Mr. Burdge:

Thank you for your October 11, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). This response to your letter is OSHA's interpretation of the question you asked and may not be applicable to any questions- not delineated in your letter. Your specific question addressed the coverage of §1910.123 (Dipping and Coating Operation: Coverage and Definitions) when using a sink-on-a-drum parts cleaner.

Question: Does a sink-on-a-drum style parts cleaner constitute a dip tank under OSHA's rule for dip tanks, specifically 1910.123(a)?

Reply: Yes. Paragraphs (a) and (b) of §1910.123 read:

(a) Does this rule apply to me?
(1) This rule (§§1910.123 through 1910.126) applies when you use a dip tank containing a liquid other than water. It applies when you use the liquid in the tank or its vapor to:
(i) Clean an object;
(ii) Coat an object;
(iii) Alter the surface of an object; or
(iv) Change the character of an object.
(2) This rule also applies to the draining and drying of an object you have dipped or coated.

(b) What operations are covered?
Examples of covered operations are paint dipping, electroplating, pickling, quenching, tanning, degreasing, stripping, cleaning, roll coating, flow coating, and curtain coating."(1)

OSHA considers the operation you described (i.e., pumping a solvent through a brush to coat and clean parts in a sink-on-a-drum parts cleaner) to be a flow-coating operation. Also, the