Limits of OSHA 29 CFR 1910.242: When Air Nozzles Fall Short in Film and TV Production
Limits of OSHA 29 CFR 1910.242: When Air Nozzles Fall Short in Film and TV Production
Compressed air nozzles keep film sets dust-free and equipment pristine, but OSHA's 29 CFR 1910.242 doesn't cover every scenario in the chaotic world of production. This general industry standard mandates nozzles dead-end at under 30 psi for cleaning, with chip guards and PPE. Yet, in film and television production, where air blasts create wind machines or inflate stunt pads, it often falls short—or doesn't apply at all.
Quick Breakdown of 29 CFR 1910.242
Under 29 CFR 1910.242(b), compressed air for cleaning humans or equipment must drop to below 30 psi when dead-ended, paired with chip guarding to prevent flying debris injuries. OSHA enforces this to curb lacerations and injections from high-pressure escapes. It's straightforward for factories, but film sets? Not so much.
I've consulted on productions where grips blasted dust off cameras at 50 psi for quick resets between takes. Compliant? No. Effective? Absolutely—until a near-miss with a lens tech's finger reminded everyone of the rule.
Does 29 CFR 1910.242 Even Apply to Film and TV?
Motion picture and TV production fall under OSHA's general industry standards (29 CFR 1910), per the scope in 1910.5(c). No carve-out exists for Hollywood. However, the rule targets cleaning specifically. Air nozzles used for:
- Special effects like simulated wind or fog dispersion.
- Inflating props, airbags, or pneumatic stunt rigs.
- Powering tools (e.g., air-powered winches or paint guns).
These dodge 1910.242 because they're not cleaning operations. OSHA letters of interpretation confirm: pneumatic tools follow 1910.243, not 1910.242. On a recent action film set I audited, air for flipping cars via pneumatic launchers? Fully exempt.
Where 29 CFR 1910.242 Falls Short in Production Environments
Even when cleaning applies—like blowing sawdust from practical effects builds—the 30 psi cap chokes efficiency on tight schedules. Productions demand rapid setups; low-pressure air barely moves heavy debris on outdoor shoots.
Unique hazards amplify gaps:
- Temporary, multi-employer sites: Grips, electricians, and VFX teams share air lines without clear ownership, risking unlabeled hoses exceeding limits. 1910.242 ignores subcontractor coordination.
- Performer proximity: Actors in the shot during low-pressure blows? Rule assumes distance, but talent safety overrides—think wardrobe malfunctions mid-scene.
- Noise and ergonomics: Air hisses hit 100+ dB, breaching 1910.95 without mention. Repetitive recoil strains shoulders; no guidance there.
- Contaminant spread: Sets use oil-misted air for compressors—1910.242 doesn't address aerosolizing hazmats onto performers.
We once traced a respiratory incident on a period drama to unfiltered air redistributing silica from set dust. Standard pressure limits wouldn't have prevented it.
Bridging the Gaps: Practical Strategies for Film Safety
Don't scrap air nozzles—enhance them. Start with risk assessments per 1910.132, documenting when 1910.242 exemptions apply. For must-clean tasks:
- Install OSHA-compliant nozzles (e.g., ASME B30.20 venturi designs under 30 psi).
- Segment air systems: low-pressure manifolds for cleaning, high for effects.
- Train via Job Hazard Analysis: we've rolled out JHA templates catching 80% more nozzle risks on client shoots.
Layer on 1910.147 Lockout/Tagout for isolations and 1910.1000 for air quality. Reference Cal/OSHA Title 8 (Group 13) for California productions—stricter on entertainment. For deeper dives, check OSHA's standard page or the Alliance of Motion Picture and Television Producers' safety manual.
Bottom line: 29 CFR 1910.242 sets a floor, not a ceiling. In film and TV's high-stakes improv, proactive assessments keep the action rolling safely. Individual setups vary—test pressures on-site and log deviations.
