how to avoid osha and epa traps at your collision center
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How to Avoid OSHA and EPA Traps at Your Collision CenterTRANSCRIPT
How to Avoid OSHA and EPA Traps at Your Collision Center
October 18, 2012
Zach Pucillo
CSP
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Copyright © 2012 TK Carsites. All rights reserved. www.tkcarsites.com.
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Becky Ross @kpaonline
Overview
-Hazard Communication
-Emergency Response
-Personal Protective Equipment
-Respiratory Protection
-Paint Booth Compliance
-Air Regulations
-Land Compliance
-Recordkeeping
Hazard Communication
-Written program-Chemical inventory-Material Safety Data Sheets (MSDS)-Container labeling-Employee training
Emergency Response
-Written Program
– Fire Response
– Evacuation Procedures
– Spill Response
– Natural Disaster Response
-Employee Training
-Evacuation Map
Personal Protective Equipment
-Written Hazard Assessment– Each Department– Certified by Manager
-Written Program -Selection of PPE-Employee Training
Personal Protective Equipment
Equipment for a Collision Center
-Welding Helmets
-Welding Gloves
-Hybrid Vehicle Gloves
-Anti Vibration Gloves
-Respirators
-Ear Plugs/Muffs
-Face Shield
-Cut Resistant Gloves
Respiratory Protection
-Written Program-Employee Training-Medical Evaluations by
a PLHCP-Respirator Fit Testing-Change out log
Respiratory Protection
Is there a need?
Isocyanates
Organic Vapors
Air borne particulates
Metals
Respiratory Protection
Written Respiratory Protection Program
The Program Must Include the Following:
-Procedures for selecting respirators for use in the workplace-Medical evaluations of employees required to use respirators-Fit testing procedures for tight-fitting respirators-Procedures for use of respirators in emergency situations-Procedures and schedules for cleaning and maintaining respirators-Procedures to ensure adequate air quality for atmos-supplying respirators-Training of employees in the respiratory hazards-Training of employees in the proper use of respirators (donning)-Procedures for regularly evaluating the effectiveness of the program
The program must be available to employees at any time
Respiratory Protection
Respiratory Protection Training-Why the respirator is necessary and how one could be compromised
-What the limitations and capabilities of the respirator are
-How to use the respirator effectively in emergency situations
-How to inspect, put on and remove, use, and check the seals of the respirator
-What the procedures are for maintenance and storage of the respirator
-How to recognize medical signs and symptoms that the respirator is defective
Respiratory Protection
Medical Evaluations-Is the employee able to wear a respirator?
-Must be completed by a PLHCP
-Typically a survey filled out by the employee
-Online Med Evals
-Spirometer Test
-How Often
-Questionnaire is found at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9783
Respiratory Protection
Fit Testing
-Required before going into operation with respirator
-Required Annually
-Qualitative vs Quantitative
Portacounts
Smoke – Saccharine – Banana Oil - Bitrex
-Seal Checks
Respiratory Protection
Selection:
Supplied Air
-Must for bed liners
-Best protection against Isocyanates
-Change the air filter
-Compressor must supply at least “Grade D” breathing air
Respiratory Protection
Selection:
Dual Cartridge Full/Half Face Respirator
Cartridge Selection
Storage
Seal Check
Respiratory Protection
Selection:
N95
Dust Mask
Respiratory Protection
Change Out Schedule
How often should the cartridges be changed out?
Lab Analysis
Manufacturer’s Recommendation
OSHA.gov Advisor Genius Programhttp://www.osha.gov/SLTC/etools/respiratory/mathmodel_advisorgenius.html
Respiratory Protection
Voluntary Use
What if an employee wants to voluntarily wear a respirator?
Appendix D of CFR 29 1910.134
Paint Booth Compliance
-Constructed of non-combustible materials
-Must have a means of egress
-NFPA 33 Chapter 9 section 1requires an automatic fire protection system
-Lights are to be guarded by laminated, heat treated, or hammered wired glass
-Minimum distance from other operations of 3 feet
-Local building codes could require a permit or certificate of occupancy
-IFC chapter 15 requires spray area permit
Paint Booth Compliance
Ventilation
-Air Make = 3 changes in 1 hour
-Top down is better than cross draft for employee health
-Fan output reading must meet the range found in table G10 of next slide
-NFPA also requires ventilation to maintain a maximum concentration of flammable vapors to 25% of the Lower Flammability Limit
(obtain assistance from the paint booth ventilation installer in calculating this)
Paint Booth Compliance
Ventilation Fan SpeedExample
-Using an air operated gun and have a crossdraft up to 100fpm-Booth face is 8ft across and 10ft tall
-Booth face = 8ftx10ft= 80ft2
125fpm x 80ft2 = 10,000cfm minimum must be pushed by fans
Paint Booth Compliance
Mixing Room
-Contain a spill
4 inch sill or pit
-Max area of 150ft2
-Approved Automatic Fire Protection System
-Portable Fire Extinguishers
-The max amount of liquid that can be stored is 300 gallons
-Electrical outlets, scales, and computers are rated for Class 1 Division 1 locations
-Ventilation on at all times and flow at 150cfm
Air Regulations
Air PermitsTitle V - area source that emits a large amount of chemicals
into the atmosphere
Non Title V – permit created by states and federally for Native American Reservations, typically smaller sources
Permits By Rule – example of exemption for collision centers
De Minimis Sources – sources that are exempt from any source and typically requires daily emissions recordkeeping
Air Regulations
6H
-1/9/2008 – 40 CFR Part 63 Subpart HHHHHH
-Reduces the amount HAPs in the atmosphere
-HAPs include the following:
Cadmium - Cd
Chromium - Cr
Lead - Pb
Nickel - Ni
Manganese – Mn
Methylene Chloride
Air Regulations
6H
-Paint Booth 4 walls and roof
-Prep station 3 walls and a curtains
-HVLP Guns
-Filters that are 98% efficient
-Employee training
-Gun cleaning without atomizing
-Notification of compliance
Checklist is available – contact Becky or Zach
Air Regulations
6H Exemptions
-Less than 2 cars/year
-Applications cannot contain:
Cadmium - Cd
Chromium - Cr
Lead - Pb
Nickel - Ni
Manganese – Mn
3 oz Cup exemption/loophole?http://www.epa.gov/tips/
Air Regulations
State VOC regulations
-Enforced by the states (spray application/gun cleaners)
-Focuses on Volatile Organic Compounds
-Typically involves requirements for the following:
Cleaning Equipment
State Notification of Compliance
Training
Written Procedures
Land Compliance
Typical Items that could be wastes for a Collision Center-Paint
-Paint Booth Filters
-Paint Pucks from Solvent Recycler
-Solvent Soaked Rags
-Paint Cups (dripping factor)
-Solvent
-Antifreeze
-Absorbent
-Fluorescent Bulbs
-Tires
-Oil Water Separator
Recycle, Reclaim, Reuse
Land Compliance
RCRA
Waste Determination
Hazardous or Non Hazardous
-Generator Knowledge
-MSDS review
-TCLP (RCRA Metals, VOC…)– Toxicity characteristic leaching procedure
Land Compliance
Waste Determinations
Characteristic:
-Ignitable
-Corrosive
-Reactive
-Toxic
Listed:
-F-Listed
-D-Listed
Land Compliance
Generator StatusConditionally Exempt (CESQG)
Generates < 220lbs of hazardous waste in a calendar month
Small Quantity Generator (SQG)
Generates >220lbs but <2200lbs of hazardous waste in a calendar month
Large Quantity Generator (LQG)
Generates <2200lbs of hazardous waste in a calendar month
Land Compliance
CESQGNo EPA ID NumberNo annual reporting No limit on storage for hazardous waste
SQGRequires EPA ID NumberSome states require annual reportingCan hold hazardous waste onsite for no more than 180 days
LQGRequires EPA ID numberFederally require reporting and feesRequires written emergency plansCan hold hazardous waste onsite for no more than 90 days
Land Compliance
Recordkeeping
Emergency Response
-Written Program
-Training Rosters
-Evacuation Maps
Hazard Communication
-Written Program
-Training Rosters
Recordkeeping
Personal Protective Equipment
-Hazard Assessment
-Training Rosters
Respiratory Protection
-Written Program
-Medical Evaluations
-Fit Testing Records
-Training Rosters
-Respirator Change Out Schedules
-Appendix D form (if necessary)
Recordkeeping
Paint Booths
-Spray and building permit*
Air Compliance
-Air permit*
-6H Notification Form or Exemption Notice
-6H Training Certifications
-Paint Booth Filter Efficiency Rating
-State required solvent recovery notifications*
Recordkeeping
Land Compliance
-Waste Determinations
-Notification of Hazardous Waste Activity
-Annual Reports (if required)
-Hazardous Waste Manifests
Match the Following in waste manifests
-Generator Initial Copy
-Land Disposal Restriction Form
-Designated Copy Sent Back From TSDF
Retain these for a minimum of 5 years
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