Get your paint shop in complete compliance through safety focus

Jan. 6, 2015
Managing an effective shop safety program in your paint department, as part of an overall safety plan for your business, is the answer to making your shop as safe and compliant as possible. 

One of the biggest challenges when dealing with shop safety is not knowing you have a problem until after it's too late. Consider the Montana shop that grabbed industry attention in late 2013 after a paint department explosion killed one employee and left another seriously injured.

(Photo courtesy of Lefler Collision and Glass) - An effective safety program will help create a problem-free, profitable paint department. 

The workers had been pouring lacquer from a barrel through a funnel into a smaller container when fumes from the lacquer ignited. An investigator from the Occupational Safety and Health Administration (OSHA) later determined a lack of grounding and no physical clip between the containers were the cause. These violations were among the nine OSHA issued the shop, along with a proposed fine of $51,000.

While it may be convenient to write off this accident as a rare occurrence, repairers need to keep a couple of things in mind. One, this was no fly-by-night shop. It had been in business for over three decades and was very successful, commanding over thirty percent of its market. In the previous five years, the shop had received no OSHA citations. Finally, how many shops can say, in complete confidence, something like this could never happen in their paint departments?

Strictly adhering to regulations set by OSHA, the Environmental Protection Agency (EPA), and state and local governments is the cornerstone of your shop's safety. Considering the number of regulations, along with new rules being added, this can be difficult ‑ especially considering you need to make sure every one of your employees sticks to them. Managing an effective shop safety program in your paint department, as part of an overall safety plan for your business, is your answer. Here's what you need to know and do to put one in place.

(Photo courtesy of Sherwin-Williams) - Mixing rooms fall under a number of federal and local regulations. Avoid issues with yours by keeping it as clean and orderly as possible.
(Photo courtesy of PPG) - Mixing scales provided by your paint vendors will reduce waste and help maximize profits.

Stumbling blocks
What are your biggest safety issues in your paint department? The answer to that question will, of course, vary from one shop to another. There are several specific issues that cause the industry, as a whole, the most problems.

Judging from a review of the most common OSHA citations and input from paint companies and repairers, two major areas are the sources of most problems -- personal protection gear and the mixing room.

In the first case, getting repairers to wear mandated equipment like OSHA-approved respirators and eye protection has bedeviled shops for years. Over a decade ago, the EPA published an article that declared the main challenge for shop owners -- "nine times out of 10" -- is getting employees to wear protective gear.

In the mixing room, as evidenced by the Montana explosion, employees often fail at properly sealing containers and transferring flammable liquids. Other problems arise due to that fact that mixing rooms fall under a host of federal and regional regulations covering everything from storage to the room construction.

Tony Wise, owner of Wise's Expert Auto in Charlotte, N.C., has spent several decades in the industry and has dealt with these issues at several different shops. Recently, he continued renovations on his business by relocating then redesigning his mixing room, a task he calls "the single biggest self-inflicted pain" of his entire career. He believes failures with protection and the mixing room have two main sources.

"First, you're dealing with employees who are working too fast to do their jobs properly -- which means thoroughly and safely," Wise says. "Today's paint departments are under incredible pressure to push out work as quickly as possible."

The second source, he notes, is "a failure of management to follow up." There too, says Wise, managers often are so focused on production, they overlook safety.

 "When you're trying to squeeze every last dollar from your paint operation, it's way too easy to simply put off fixing a broken fan switch or ordering new storage containers because your old ones may be leaking," he explains. 

Wise also suspects some repairers might have trouble maintaining OSHA compliance in their mixing rooms because they may be relocating them to open up production areas, as he did. Also, with shops expanding their operations to multiple locations, owners may be overlooking safety problems in shops they purchase. Owners may be taking on employees they assume are following OSHA codes when, at times, they are not.

(Photo courtesy of Sherwin-Williams) - Utilize inventory systems and controls, like this inventory cart, to help reduce the number of products in your inventory.
(Photo courtesy of PPG) - Let your painters try out a variety of protective gear so they can pick gear that offers the most comfort. Upgrade to fresh air supplies if possible.

Regulation complications
Problems like these can be further complicated by new regulations. The most significant recent regulatory change affecting your business is the EPA rule commonly referred to as 6H, which aims to reduce pollutants released during automotive painting.

Note: This rule, as with other EPA regulations, are targeted more at health than safety. Because the areas and issues they cover also fall under OSHA regulations, you need to tie health and safety together. This approach reduces complexities and helps ensure your business's total regulatory compliance.

Existing shops needed to become compliant with 6H more than three years ago (new structures have 180 days), but repairers still have plenty of concerns with it, according to paint vendors ABRN has spoken with.

Those concerns stem from the extensive requirements tied to 6H that cover everything from products, spray guns, spray booths, training and documentation. It's therefore worthwhile to re-examine the basics of the 6H rule:

Products

  • If more than one ton of Methylene Chloride (MeCl) products are used per year, management must develop and implement a written MeCl minimization plan
  • If less than one ton are used annually, no written plan is required, but the following MeCl alternatives must be considered:
    • Stripping agents that do not contain MeCl (such as formic acid or benzyl alcohol)
    • Mechanical stripping
    • Thermal or cryogenic decomposition
    • Blasting with wet or dry media
    • Intense light

Spray guns

§  Spray-applied coatings must be applied with HVLP spray guns, electrostatic application, airless or air-assisted airless spray guns or equivalent technology.

§  Spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent.

Spray booths and spraying areas

  • Filters achieving a minimum 98 percent capture efficiency must be installed on the exhaust of all spray operations. 
  • Shops that refinish complete motor vehicles or other mobile equipment must spray in a fully enclosed spray booth or station and operated under negative pressure. Fully enclosed booths using an automatic pressure balancing system can be operated up to 0.05 inches water gauge positive pressure.
  • Shops that refinish parts, products or vehicle “subassemblies” must spray in an area with a full roof and at least three complete walls or side curtains. This area must be vented to draw air throughout it.
  • Mobile spot repairers must enclose the area being coated, capture paint overspray and filter the exhaust. 

Training

All personnel that spray-apply coatings must be trained and certified on spray gun equipment selection, spray techniques, maintenance and environmental compliance.

Documentation

  • Records must be maintained for 5 years and must be kept on site for at least 2 years
  • Shops must maintain painter training certification with training dates, along with documentation of filter efficiency and documentation from the spray gun manufacturer that the gun is permitted under 6H.
  • Document annual usage of MeCl or MeCL minimization policies (if applicable)

Your safety program
The best way to approach safety is with a program that highlights its importance in your business and puts a consistent focus on it. Use these steps to develop your safety plan.

1. Designate a safety leader. Whether it's a manager, foreman or another employee, put someone in charge of your program who already holds a leadership position. The leader will possess a thorough understanding of all the regulations that affect your operation and will track any updates or changes. Next, build a team around that leader with one person representing each operational department who will. Your leader should set goals and discuss safety as part of regular shop meetings.

Goals for the paint department can include cutting waste, replacing toxic products and recycling finishes and other solvents. Goals also should include seeing that everyone in your organization fully understands and follows safety guidelines, even those that fall outside their job descriptions. Safety is a team effort, and everyone needs to be involved.

2. Get help. Plenty of assistance is available to ensure you meet safety and health guidelines. Paint and supply vendors and industry groups typically either offer programs or can put you in contact with compliance experts. Organizations like the Automotive Services Association of Ohio offers mock OSHA inspections. Federal and state EPA and OSHA offices can provide help, as can companies that insure your business and buildings.

Keep in mind that you'll also need to abide by state and local regulations that frequently build upon federal rules. New York state, for example, requires shops to file an Environmental Report Form. Locally, many cities and municipalities adopt recommendations from the National Fire Protection Association. Many of the same sources who help with federal compliance can offer aid here as well.

3. Organize. Bad practices often arise from disorganization. Set up your paint department so protective gear and other supplies are easy to locate and store. Remove all clutter and see that employees keep their work areas neat. Keep your mixing room clean and orderly with sufficient shelving and storage areas that are clearly marked.

Since mixing rooms are frequently areas of trouble, consider updating yours or investing in a prefabricated unit. Prefab mixing rooms can offer terrific advantages since they arrive compliant with all federal and regional codes.

4. Get up to speed. Using available assistance and tools, make your shop is fully compliant and capable of passing any inspection. Address all problem areas and inform employees of your "fixes."

5. Train regularly to maintain your program. Don't simply state your safety guidelines and goals. Demonstrate them with hands-on training. Have your employees repeat them so you'll know they understand. Note that OSHA requires you to provide training on the use of safety equipment, and other agencies can have similar mandates. Create an annual safety test for employees.

6. Optimize your safety. Your paint department is a veritable toxic stew of products that are dangerous, flammable and capable of causing immediate and long-term health problems. The best way to cut down on safety concerns is by removing/reducing threats where possible. Replace solvents and other products with environment-friendly versions. If you haven't already, move to waterborne paints. Track your inventory so you can stock minimum amount of finishes and other products. Use paint mixing systems from your vendors to ensure you're creating minimal waste. Utilize spraying techniques that reduce overspray.

Invest in an automated spray gun cleaners since they protect employees from cleaning solvents and use smaller amounts of them. Help ensure employees utilize protective gear by allowing them to try out a range of respirators, eyewear, gloves and paint suits so they can identify the versions that give them the most comfort. Upgrade your protective gear. If possible, move to fresh air respirators.  

7. Accountability. Your safety program won't work unless your make your employees fully accountable. This means routinely reviewing their safety performance and noting any problem. Put penalties in place for failures to comply with your standards. This can include verbal or written reprimands, loss of pay, suspension, etc. These actions may seem harsh, but they drive home just how important your rules are. (Also, would you rather reprimand a worker or visit one at a hospital or funeral home?)

Once you get your plan in place you'll find that maintaining it actually involves little time. Most employees simply will need to take add just a few extra minutes to some of their work tasks. You'll end up with a safer, more profitable paint operation.

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