Every profession has its own terminology, principles and practices that outsiders often find hard to understand. Specific priorities and standards of numerous legal, financial and governmental agencies often are seen as intimidating, frustrating or sometimes incomprehensible to a typical business owner.
Few sets of initials strike more fear into hearts of collision repair owners than OSHA (the Occupational Safety and Health Administration) and EPA (the Environmental Protection Agency). Regulations for shops from both agencies are frequently viewed as intrusive, unclear and expensive to comply with. Owners and managers say the guidelines intrude into the operation of shops by requiring added processes and practices in an already highly complicated and technical business. They also point out that the rules and requirements are written in confusing terms, sometimes making the procedures for compliance unclear. Above all, it seems, without exception, the implementation of these required rules is expensive. Additionally, it seems every few years a new rule is added to the agencies' growing lists of requirements. With all these concerns, we haven't even mentioned how both agencies can levy fines or shut down a business for violations. (Though OSHA rules are applied nationwide, some EPA regulations may be stricter in select locations and less in others.)
Let's make sense of two commonly overlooked requirements. Unlike other regulations, which may or may not apply to your shop depending on your location, these rules are required nationally and are in effect already:
1) OSHA: Respiratory Protection Standard, 29 CFR 1910.134. (http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=standards)
2) EPA: National Emission Standards for Hazards Air Pollutants 40 CFR Part 63, subpart HHHHHH (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div6&view=text&node=40:14.0.1.1.1.20&idno=40)
The following isn't intended as a complete outline of the rules. Shops intending to comply with these rules should contact the ruling body or seek advice from their jobber, respirator manufacturer and/or paint makers.
Respiratory protection
This OSHA regulation is part of worker personal protection equipment (PPE), which each worker is directed to use when working with hazardous/harmful materials (Fig. 1; Fig. 2). The sure way to know which PPEs are required when working with a material is by consulting the material's MSDS (material safety data sheet), Section 8 of a product's MSDS list exposure control and personal protection. PPEs for working with paint and strippers are typically: 1) Safety glasses (Fig. 3) 2) Protective gloves3) Respirator 4) Paint suit5) Protective shoes 6) Ear protection.Safety glasses
Glasses must meet the Z87 safety standard set by ANSI (American National Standard Institute) and be marked accordingly. These glasses must have approved lenses, side shields and frames, and shouldn't be modified. Safety glasses should be used even when using a full face shield or respirator. When mixing paint or using other chemicals that may splash, technicians are advised to wear goggles or a face shield.Protective gloves
Gloves also pose a problem for some shops. Commonly, inexpensive latex gloves are used, but these offer little or no protection because they degrade rapidly after being exposed to many chemicals found in paint materials. Nitrile gloves, in contrast, provide a better barrier to paints and organic solvents – the chemicals that are toughest on gloves. Butyl rubber, which is often thicker, is commonly recommended when washing paint guns and equipment. It provides good protection from solvents. Wearing thicker butyl gloves while still wearing nitrile gloves is fast and cuts down on the amount of nitrile gloves used in a day. However, that contaminates the inside of the butyl glove, and an unprotected hand shouldn't be inserted after it's contaminated.Respirators
OSHA 29 CFR 1910.134 broadens the requirements for safe use of respirators in the workplace. The employer shall comply with the following provisions of this section, as applicable:
These seem overwhelming and difficult to comply with, but when examined closely, many of the requirements are done just once or only from time to time.
1. Selecting the proper respirator for your work environment. By checking the MSDS for the materials used in your shop, you'll find in some areas, such as the sanding areas, a dust particle mask (often called an NR95) is sufficient. In spray areas where coatings don't contain isocyanate, a dual-cartridge, paint vapor respirator may be the best choice. When coatings with isocyanate are present, a supplied air respirator is the best choice. Once the selection is completed, it'll only need to be updated if you change to a product that uses a different respirator requirement. The MSDS, respirator supplier, your jobber and paint representative can help in establishing the best practices for each work area relative to the materials used in that area.2. Medical evaluation. Though this requirement may seem difficult and expensive to obtain for each employee, employees can satisfy it by answering an online medical questionnaire. The information is submitted to a medical specialist, who, for a nominal fee, will return a certificate for your employees.
3. Fit testing. (Fig. 4) Each employee who uses a respirator must have an annual fit test. This shouldn't be confused with a seal test, which should be performed each time a respirator is donned. A fit test is a procedure in which an employee puts on the respirator and a tester sprays different mists into the hood to verify the respirator fits properly. This might seem like a cumbersome, difficult and costly procedure, but it can be performed annually in your shop, often by the respirator supplier, sometimes at no cost.
4. Provisions 4, 5, 6 and 9 in the aforementioned list. The four standard operating procedures (SOPs) can be made with the aid of your respirator supplier. Once completed, the SOPs should only need to be revised periodically.
5. Training requirements. Provisions 8 and 9 can be satisfied by having employees view numerous training videos, such as the one produced by the U.S. Department of Labor (http://www.youtube.com/watch?v=Tzpz5fko-fg) It's a nine-minute video training your employees about the proper care and use of respirators. Other sources for this type of training are your local jobber or the respirator supplier.
Regarding paint suits, it seems many painters choose not to wear them because they're cumbersome and hot in the summer. Though the OSHA requirement doesn't specify the use of a paint suit, each painter should realize he's only putting himself at risk. A painter who hasn't used a paint suit at work and then gives loved ones a big hug must remember this: They're getting a big, warm and dangerous isocyanate hug from your contaminated clothes.
National emission standards for air pollutants (HM 181 63 subpart HHHHHH)
This ruling issued by the EPA covers emissions of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs), specifically targeting chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni) and cadmium (Cd). It requires training, specifications for the spray application area, recordkeeping and certification of compliance with the regulation protocols. Collision repair refinishing shops and other types of refinish facilities are targeted specifically. There are exemptions to this rule, but they are narrow, and a written application to the EPA is required to receive them.
Training
The rule requires that all painters are trained and certified in the appropriate application of surface coatings, the correct set-up and maintenance of spray equipment, the proper operation of spray guns, how to minimize paint overspray/waste, including improving transfer efficiency, and spray booth filter maintenance.
Spray application area
The rule requires all spray-applied coating be applied in a spray booth, prep station or mobile enclosure. Spray booths must use filters that capture at least 98 percent of the paint overspray.
Spray booth and prep stations that spray complete vehicles must be completely enclosed, with a full roof and four complete walls or side curtains. It also must operate with a negative pressure, so air is drawn in and overspray (fugitive air emissions) won't escape the booth.
The rule requires all spray applications must use a high volume low pressure (HVLP) spray gun or an EPA-approved equivalent technology that achieves comparable transfer efficiency, which means compliant guns can be used as long as the manufacturer provides, in writing, they've been deemed compliant.
It requires all spray-gun cleaning be done so no atomized coating of solvent is vented outside the cleaning container. The gun can be cleaned by hand and solvent can be flushed through it outside the container, as long as no pressure is used or atomizing occurs.
The rule seeks to limit the amount of methyl chloride (MeCl) used for stripping. If a refinish shop uses strippers containing MeCl for stripping, the technicians must be trained to use, store and dispose it safely.
Recordkeeping
The rule requires shops keep records for five years, recording:
These two rulings may seem intrusive, difficult to comply with and expensive. But there is a lot of help out there for shops. Your jobber or supplier of respirators can be accessed free from the Internet; medical evaluations can be obtained for a nominal fee through the Internet; and the respirator manufacturer can supply the recordkeeping for respirator requirements.
For compliance with the National Emission Standards for Air Pollutants, your paint manufacturer or spray gun manufacturer can provide all the training. Recordkeeping and applications can be done with the help of your paint supplier or manufacturer. Your paint manufacturer or jobber can provide assistance with the evaluation of your spray area and filters.
This article is not intended to be complete regarding the requirements of the two rules; shops should contact their jobber, paint suppliers or ruling agencies for complete requirements. Once put in place, the requirements should be easy to maintain.
