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 Center October 18, 2012 Zach Pucillo CSP

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How to Avoid OSHA and EPA Traps at Your Collision Center

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Page 1: How to Avoid OSHA and EPA Traps at Your Collision Center

How to Avoid OSHA and EPA Traps at Your Collision Center

October 18, 2012

Zach Pucillo

CSP

Page 2: How to Avoid OSHA and EPA Traps at Your Collision Center

Moderator

Becky RossMarketing Manager

Office:  (303) 228-8753

[email protected]

Page 3: How to Avoid OSHA and EPA Traps at Your Collision Center

Presenter

Zach Pucillo

Engineer III

KPA

(317) 201-2335

[email protected]

Page 4: How to Avoid OSHA and EPA Traps at Your Collision Center

If you have questions during the presentation, please submit them using the “Questions” feature

Questions will be answered at the end of the webinar

Copyright © 2012 TK Carsites. All rights reserved. www.tkcarsites.com.

Questions

Page 5: How to Avoid OSHA and EPA Traps at Your Collision Center

Interact During the Webinar!

#DealerWeb

Becky Ross @kpaonline

Page 6: How to Avoid OSHA and EPA Traps at Your Collision Center

Overview

-Hazard Communication

-Emergency Response

-Personal Protective Equipment

-Respiratory Protection

-Paint Booth Compliance

-Air Regulations

-Land Compliance

-Recordkeeping

Page 7: How to Avoid OSHA and EPA Traps at Your Collision Center

Hazard Communication

-Written program-Chemical inventory-Material Safety Data Sheets (MSDS)-Container labeling-Employee training

Page 8: How to Avoid OSHA and EPA Traps at Your Collision Center

Emergency Response

-Written Program

– Fire Response

– Evacuation Procedures

– Spill Response

– Natural Disaster Response

-Employee Training

-Evacuation Map

Page 10: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 11: How to Avoid OSHA and EPA Traps at Your Collision Center

Respiratory Protection

-Written Program-Employee Training-Medical Evaluations by

a PLHCP-Respirator Fit Testing-Change out log

Page 12: How to Avoid OSHA and EPA Traps at Your Collision Center

Respiratory Protection

Is there a need?

Isocyanates

Organic Vapors

Air borne particulates

Metals

Page 13: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 14: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 15: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 16: How to Avoid OSHA and EPA Traps at Your Collision Center

Respiratory Protection

Fit Testing

-Required before going into operation with respirator

-Required Annually

-Qualitative vs Quantitative

Portacounts

Smoke – Saccharine – Banana Oil - Bitrex

-Seal Checks

Page 17: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 18: How to Avoid OSHA and EPA Traps at Your Collision Center

Respiratory Protection

Selection:

Dual Cartridge Full/Half Face Respirator

Cartridge Selection

Storage

Seal Check

Page 19: How to Avoid OSHA and EPA Traps at Your Collision Center

Respiratory Protection

Selection:

N95

Dust Mask

Page 20: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 21: How to Avoid OSHA and EPA Traps at Your Collision Center

Respiratory Protection

Voluntary Use

What if an employee wants to voluntarily wear a respirator?

Appendix D of CFR 29 1910.134

Page 22: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 23: How to Avoid OSHA and EPA Traps at Your Collision Center

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)

Page 24: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 25: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 26: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 27: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 28: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 29: How to Avoid OSHA and EPA Traps at Your Collision Center

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/

Page 30: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 31: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 32: How to Avoid OSHA and EPA Traps at Your Collision Center

Land Compliance

RCRA

Waste Determination

Hazardous or Non Hazardous

-Generator Knowledge

-MSDS review

-TCLP (RCRA Metals, VOC…)– Toxicity characteristic leaching procedure

Page 33: How to Avoid OSHA and EPA Traps at Your Collision Center

Land Compliance

Waste Determinations

Characteristic:

-Ignitable

-Corrosive

-Reactive

-Toxic

Listed:

-F-Listed

-D-Listed

Page 34: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 35: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 36: How to Avoid OSHA and EPA Traps at Your Collision Center

Land Compliance

Page 37: How to Avoid OSHA and EPA Traps at Your Collision Center

Recordkeeping

Emergency Response

-Written Program

-Training Rosters

-Evacuation Maps

Hazard Communication

-Written Program

-Training Rosters

Page 38: How to Avoid OSHA and EPA Traps at Your Collision Center

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)

Page 39: How to Avoid OSHA and EPA Traps at Your Collision Center

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*

Page 40: How to Avoid OSHA and EPA Traps at Your Collision Center

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

Page 41: How to Avoid OSHA and EPA Traps at Your Collision Center

Free Consulting Time!

QUESTION

S?