All personnel that spray-apply coatings must be trained and certified on spray gun equipment selection, spray techniques, maintenance and environmental compliance.
- 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.
Subscribe to ABRN and receive articles like this every month…absolutely free. Click here