OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 25, 1997

Mr. Bernard Behrens
Export Development
Boryszew S.A.
Chemical and Plastics Company
ul. 15 Sierpnia 106
96-500 Sochaczew, Poland

Dear Mr. Behrens:

This is in response to your letter inquiring if the Occupational Safety and Health Administration (OSHA) is aware of regulatory changes that will go into effect in January 1997 in the United States, "which will restrict the use of PVC as a construction material in window frames and siding, and in buildings of more than two stories high."

We have reviewed our files and found that OSHA has not proposed, nor is intending to propose, any new regulatory changes concerning the occupational safety and health of employees and the use of PVC materials for window frames and siding. Also, please be aware that OSHA does not regulate the types or kinds of materials used for construction unless they affect the safety and health of employees.

For your information, another organization that regulates the use of materials in buildings is the Building Officials and Code Administration International (BOCA). That group publishes a document titled: The BOCA National Building Code. In 1996, BOCA issued an interpretation of Section 602.4.1 of their code, that reads as follows: Code Interpretation No. 30/40/82, First issued: 5/27/82, 1981 Edition.

Q: Are doors and windows which are constructed of combustible materials permitted in noncombustible types of construction?

A: Yes. Doors and windows are not among the elements required to be composed of noncombustible materials in Types 1,2,3, and 4 construction as described in Sections 603.1, 604.1 and 605.1. When a door or window is not required to be a protected opening, the code does not contain any requirements regulating the use of combustible vs. noncombustible materials (see Section 706.4).

You can obtain a copy of the BOCA Code by directly contacting the Building Officials and Code Administrators International, Inc., 4051 W. Flossmoor Road, Country Club Hills, Illinois 60478.

If this office can be of further assistance, you can contact either Steve Stock or Gil Esparza of this office at (202) 219-8244.

Sincerely,

Roy F. Gurnham, Manager
Office of Construction Standards and Compliance Assistance