You can also call your state agency and they will come out a give you a courtesy inspection. All violations will need to be corrected, but there is no fine/ticket issued at the time of inspection. You should know that they will return to check if the violations have been corrected and you will be on their radar screen. I will need another article to complete this checklist, so stay tuned next month.
To see the OSHA standards, go to Google.com and type in 29CFR 1910. 38. This is the official OSHA web site.
First off, do you have 10 or more employees? If ‘yes,’ you will need a written Emergency Contingency Plan. I took this description from the OSHA Manual:
1910.38(b) Written and oral emergency plans. An emergency action plan must be in writing, kept in the workplace, and available to employees for review. However, employer with 10 or fewer employees may communicate the plan orally to employees.
An example of an Emergency Exit Plan
Do you have a Written Hazard Communication Plan?
OSHA rule 29CFR 1910.1200 states that you need to have an active safety and health program in operation that deals with general safety and health program elements as well as management of hazard specific to your shop. A written plan which describes training, labeling, Material Safety Data Sheet (MSDS) management and other requirements of “Right-to-Know” must be in place. A good start for you and your employees is I-CAR’s 4-hour WKR 01 (Hazardous Materials, Personal Safety, and Refinish Safety) class. The class deals with MSDS sheets, personal protection equipment and a number of hazards that are common in the body shop.
A couple of other items that you may want to incorporate into your plan.
● A written procedure for handling in-house employee complaints regarding safety and health.
● An incentive program for reducing work place injuries
● A formal disciplinary policy relating to safety. I know one shop that will write up techs who do not wear their safety glasses. Second time is a one day suspension, third write up is 3-day suspension, and the fourth write up is termination.
Do you have all your current and past MSDS sheets? Are they in a conspicuous location? Did you know that you must retain all MSDS sheets for 30 years after product is no longer being used? After the evacuation plan, this is a big ticket item with OSHA inspectors. You can obtain them from your jobber, manufacturer’s reps and on-line.
Personal Protective Equipment (PPE)
Let’s talk about Personal Protective equipment. Look at the picture below and tell yourself what is wrong.
The refinish tech is mixing paint with no eye protection, gloves, respirator, and paint suit. He is being exposed to isocyanates and doesn’t know it. Who is responsible for the Personal Protective Equipment (I will refer to it a PPE) and its use? Well, the employer is responsible for providing the equipment and the training in using it and the employee is responsible for actually using it.
● A respirator fit test is requires yearly (29 CFR 1910.134).
● Respirators must be placed a sealed container when not in use (29 CFR 1910.134)
● A program in place for training and proper use of respirators.
● The type of respirator used for specific products will be found in the Preventative Measures of the MSDS sheets.
● Respirator cartridges need to be replaced on a regular basis. 3M P100 cartridges need to be replacing after 40 hours of use or 30 days, whichever comes first.
Here are some common questions that are asked about PPE:
● Are approved safety glasses required to be worn at all times in areas where there is a risk of eye injury?
● Are protective goggles provided and worn where there is any danger of flying particles and harmful vapors (isocyanates for example)?
● Are protective gloves issued for various toxic exposures? (Again, you can look in the Preventative Measures of the MSDS sheets for specific type of gloves that are necessary for a particular product).
● Do you have an eye-wash station and it is properly maintained?
● Is protective clothing supplied for painting (paint suit for protection against overspray and isocyanates) and welding (jackets and gloves)?
● Is proper hearing protection equipment furnished? Here is an example of an ear muff.
What Gets Most Scrutiny from OSHA?
The area that receives the most attention during an OSHA inspection is the paint department. Let’s look at some of the problem areas that need your attention. The painter is first on my list.
All painters should be wearing a paint suit, glove and utilize a fresh-air system. I think that the fresh air system incorporates goggles and respirator into one system. Your painter can wear a half-mask fresh air system or a respirator, but must also wear goggles if used instead of the full fresh air system. (Did you know that the fastest route for hazardous materials to get into the blood stream is through the eyes?)
You will also need a CO monitor if you use shop-supplied air. There are systems that use electric pumps that produce no carbon monoxide, oil vapors, or oil mist. The only drawback is that the painter will need a separate air hose (The SATA unit pictured utilizes one hose. You plug your air line into a unit on a supplied belt and a small hose comes off the unit to the CO monitor and then delivers fresh air to the helmet.)
I ask the same questions every time I conduct I-CAR’s WKR 01 class to refinish technicians and helpers. Do you mix paint? Do you clean the guns? When they answer ‘yes,’ I ask them if they wear goggles, respirators, paint suits, and gloves when they perform both task. The majority answer that comes back is they ‘only wear gloves.’ Isocycantes are present in all three operations: mixing, painting, and cleaning. The appropriate PPE must be worn at all times. You need to enforce this rule or you are setting yourself up for a lawsuit. Be forewarned.
Here are some other areas in the paint department that need your attention.
● All containers need to have a workplace label. If you mix paint for the day, it is not necessary, but if the paint is not used that day, it will need a label. A piece of masking tape with the paint code is not sufficient.
This is a disaster in the making.
● All metal flammable containers must be grounded
● A fire extinguisher must be within 10 feet of any inside storage area of flammable liquids (More on fire extinguishers in the next article).
● All solvent wastes and flammable liquids must be kept in fire-resistant, covered containers when not in use.
● All hazardous liquids must have a spill containment system
● No smoking signs must be posted in areas of flammable liquid storage
● Paint mixing rooms/areas must have explosion proof lights.
There are many companies that have these materials (Grainger is an example). Craig Oliveira of Kent Automotive gave me his parent company’s (Lawson Products) Safety Catalogue and I found it to be extremely helpful in getting all the information and products necessary to be in OSHA compliance. It is free—check with your local Kent Automotive Representative or other reputable source. Next month’s article will focus on the rest of the shop. Stay safe.