The first request by the inspector will be to see your respirator fit test for all your required employees along with their medical questionnaire. By the way, it is September 2016. You tell him that you have not done the fit test this year (needs to be done yearly), but you will get to it when you have a chance. You will be issued a citation for $7,500 and that is just the start of it. There are examples where OSHA fined a facility over $10,000.00 for not furnishing the proper respirators and not having done a fit test.
Starting in June of 2013, OSHA was given a mandate to determine isocyanate protection in the collision industry and part of the mandate, an OSHA inspection, could inspect for isocyanate protection without a complaint. They could also inspect to see that any lifts/hoists in a body shop have been inspected. Again, inspection without a complaint. So what are isocyanates, where are they found in the body shop, and what PPE is necessary for isocyanate protection?
Isocyanates are powerful irritants to the mucous membranes of the eyes and gastrointestinal and respiratory tracts. Direct skin contact can also cause marked inflammation. Isocyanates can also sensitize workers, making them subject to severe asthma attacks if they are exposed again. There is evidence that both respiratory and dermal exposures can lead to sensitization. Death from severe asthma in some sensitized subjects has been reported. Workers potentially exposed to isocyanates that experience persistent or recurring eye irritation, nasal congestion, dry or sore throat, cold-like symptoms, cough, shortness of breath, wheezing, or chest tightness should see a physician knowledgeable in work-related health problems.
Isocyanate exposure generally occurs through inhalation and/or dermal routes. Depending on the isocyanate type and the application method, there may be significant exposure potential from either, or both, of these routes and this should be considered in the risk management approach.
Inhalation exposure can occur when isocyanates are present in the workplace air, either as a vapor or an aerosol. In some instances, airborne isocyanates can be present in both of these forms simultaneously.
Aerosols can be generated by deliberate means, such as spraying, or inadvertently when isocyanates are mechanically agitated or vigorously disturbed. For example, fine aerosol particles will be generated when liquids are brush applied or poured from one vessel to another. However, the amount of aerosol generated in this way will usually be much lower than from spraying processes. Where solid isocyanates are handled, there is potential for airborne dust to be generated.
Dermal (skin) exposure can occur wherever there is potential for workers’ skin to come into contact with isocyanates. The main mechanisms by which dermal exposure to isocyanates occur are:
* Direct contact with workers’ skin
* Deposition of aerosol from the air onto workers’ skin
* Splashing, during pouring or mixing activities for example
* Handling contaminated items such as tools or used personal protective equipment (PPE)
* Contact with contaminated surfaces, such as control panels or process plant, during maintenance
Isocyanates are found in virtually any two part products, such as bondo, seam sealers, plastic two repair and primers and clear coats. What are the necessary Personal Protection Equipment items for isocyanate protection? Gloves, Goggles, paint suits and respirators. Let’s look at respirators.
There are two types: particulate and vapor. Particulate respirators have fine mesh screens that trap various size particles that pass thru the microscopic holes. Some examples of particulates would be weld thru primer, aerosols products, and welding fumes to name a few. These filters are pink in color.
Vapor respirators have charcoal inside the cartridge that absorbs the vapors as they pass thru the filter. These filters have a black ring to distinguish it as a vapor cartridge.
There is a third cartridge that is both a particulate and vapor all rolled into one filter. These are pink and black.
All of the above filters have an hour limit and should be changed on a regular basis. I perform annual respirator fit test and give my shops a book that contains the medical exams, respirator fit test and a page for each employee log that dates when the cartridges have been changed (a game changer when and OSHA inspector walks into shop and wants to see your records). It should also be noted that it is a large OSHA fine if a respirators is not stored in a protective container when not in use.
Another area that OSHA is actively looking at is repairable crystalline silica.
Crystalline silica is found in sand blasting and rubbing compound.
3M states in Section 8 for their SDS sheet for Ultra finishing Rubbing Compound you should avoid breathing of vapors, mists or sprays. Avoid breathing of dust created by cutting, sanding, grinding or machining.
Select one of the following NIOSH approved respirators based on airborne concentration of contaminants and in accordance with half face piece or full-face air-purifying respirator with organic vapor cartridges and P100 particulate prefilters.
OSHA states that the final rule takes effect June 23, 2016 after which industries have two years to comply. In other words, your person who polishes the vehicles with cutting compound needs to was a proper respirator and also has a medical questionnaire filled out along with a respirator fit test. I would recommend that you make sure that your tech is in compliancy now and not wait. Another new rule took place last year is the GHS rules (the Globally Harmonized System of Classification and Labeling of Chemicals or GHS) on labeling effective June 1, 2016. Employers need to update all work place labels. The label pictured is courtesy of Kent Automotive.
The above pictured label is now needed on all products that need a work place label.
Body Shop Transfers Chemical from larger container to a smaller one, a work place label is required*
Here is what OSHA has stated about the new work place labels and SDS sheets.
“Labels: All labels will be required to contain four elements: a pictogram that conveys the specific hazard a chemical may present, signal words that specify the level of severity of hazard, a hazard statement that assigns a class and category to the chemical, and a precautionary statement that advises how the chemical should be handled to reduce the risk of injury.
Safety Data Sheets: SDS sheets will all need to follow the standardized 16-section format.”
Here is a partial list of the top 5 OSHA Violations in 2015:
#2 Violation. Hazard Communication (1910.1200) - 5,192 Citations
About The Standard: Hazard Communication standards address chemical hazards produced or used in the workplace, and governs how those hazards are communicated to workers through things like labels, safety data sheets and classification standards. Recent updates in Hazard Communication standards aligned OSHA's standards with the Globally Harmonized System (GHS) standards already used internationally. When the new updates began going into effect in 2013, many businesses did not properly implement revisions or train employees on the new standards. Most violations, though, were due to employers not having a written hazard communication program at all, or not providing training and information on hazardous chemicals to workers
#4 Violation. Respiratory Protection (1910.134) - 3,305 Citations
About The Standard: Employees who work around harmful dusts, fogs, fumes, mists, gases, smokes, sprays and vapors are at risk of very dangerous occupational diseases if precautions are not taken to protect their respiratory systems. OSHA's Respiratory Protection standards set expectations for control measures, respirator use, cleaning and repair, written programs and worker medical evaluations, and these citations are most frequently issued for medical evaluation requirements, implementation of a written respiratory protection program and fit testing.
What does this mean collision shop employer? An unlabeled container falls into the Serious Violation—Each Unlabeled material is subject to a $1500 fine beginning 8/1/2016. Furthermore, Other-Than-Serious Violation, a violation that has a direct relationship to job safety and health, but probably would not cause death or serious physical harm. OSHA may assess a penalty from $0 to $1,000 for each violation. The agency may adjust a penalty for an Other-Than-Serious violation downward by as much as 95 percent, depending on the employer's good faith (demonstrated efforts to comply with the Act), history of previous violations, and size of business.
Serious Violation -- A violation where there is a substantial probability that death or serious physical harm could result. OSHA assesses the penalty for a serious violation from $1,500 to $7,000 depending on the gravity of the violation. OSHA may adjust a penalty for a serious violation downward based on the employer's good faith, history of previous violations, and size of business. Last topic I would like to discuss is MSDA to SDS.
June 1, 2016 – By this date employers should be fully compliant with HazCom 2012. That includes making any necessary updates to their HazCom program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake) and updating safety data sheets libraries and secondary labels. I have included a SDS Check List for Compliance.
The following checklist will help to ensure you comply with the rule: Obtained a copy of the rule.
-Read and understood the requirements.
-Assigned responsibility for tasks.
-Prepared an inventory of chemicals.
-Ensured containers are labeled.
-Obtained SDS for each chemical.
-Prepared written program.
-Made SDSs available to workers.
-Conducted training of workers.
-Established procedures to maintain current program.
-Established procedures to evaluate effectiveness.
I realize that our days in the body shop business are filled with many major concerns (where do I find new techs, for instance) and a work place label is not at the top of the list, but large OSHA fines can be devastating.