Personal Protection Equipment (PPE) is defined by Wikipedia as “clothing, helmets, goggles, or other garments or equipment designed to protect the wearer’s body from injury or infection. The hazards addressed by protective equipment include physical, electrical, heat, chemical, biohazards, and airborne particulate matter.” This definition continues to state: “The purpose of personal protective equipment is to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective to reduce these risks to acceptable levels. PPE is needed when there are hazards present.”
Finishers are often faced with an obvious question: “Is PPE necessary for my coating process?” To answer this simple question, there are two additional questions that need to be considered: Is there a health risk present in the process, and is the risk eliminated by engineering and administrative controls? If there is a health risk that is not reduced to acceptable levels by engineering and administrative controls, then the answer is yes, PPE is required!
Now that you understand that you need some form of PPE, the next issue is the type of PPE required. There is a specific hierarchy to determine these PPE requirements. The first rule that needs to be reviewed is OSHA 29 CFR; Part 1910; Subpart 1 “Personal Protective Equipment,” that describes situations where these devices are necessary. This document is available online at www.osha.gov. The next reference sources that need to be reviewed are the Material Safety Data Sheets (MSDS), or the newer shortened official description, Safety Data Sheets (SDS). They provide information from suppliers of the consumable materials used in your process, including paint, powder, solvent, pretreatment chemicals, or blast media. These documents will detail the hazards that are present when using these materials (shown under the section entitled Health Hazard Data) and the recommended PPE to be used to mitigate these hazards (in the section entitled Exposure Control/Personal Protection). Finally, National Institute for Occupational Safety and Health (NIOSH) documents will provide the description of the level of filtration necessary for the stated health risk outlined in the SDS information. NIOSH information is available online at www.cdc.gov/niosh.
The wildcard in the situation of when and what PPE is required is the Local Authority Having Jurisdiction (LAHJ). These authorities include OSHA inspectors, state workplace inspectors, Fire Marshals or inspectors, insurance company inspectors and more. They can demand anything they consider necessary to gain their acceptance for an “approved operation” that is deemed safe. These demands may, or may not, be stipulated by any written rules or regulations and are often driven by the authority’s opinion of what is required.
If you have a situation where a LAHJ has cited noncompliance for PPE, you have only three choices for response: fight, hide, or flight; much the same as confronting a mugger in a dark alley. The flight response will end up in fines, jail time, or both, and is not recommended. In this analogy, the hide response is just to simply give in and comply with the LAHJ request. The fight response should be carefully evaluated before executing and starts with understanding the appeals process for the particular LAHJ with which you are dealing and ends with comparing the cost to comply with the cost of the appeal. Appeals are better undertaken when the written standards/regulations are clear and support your position, but even then you may not prevail.
Best Practices for PPE
Finishing systems, both liquid and powder coating, can have a variety of equipment components that use materials that pose an inherent safety hazard to personnel who must operate it. The process equipment itself may also present a threat to operators. However, some of these system components, especially those that are automated, can have engineered or administrative controls that reduce or eliminate these personnel hazards. Here we will discuss some typical equipment components used in both liquid and powder coating finishing systems, their inherent safety hazards and the PPE normally considered best practice for mitigating these hazards.
Automated Media Blast Systems
These systems have interlocks that prevent their operation while doors are open, or personnel are in the hazard zone. Additionally, the blast media is controlled by ventilation systems designed to collect the dust and spent media and return this air back to the plant or outside, as necessary. Many automated blast systems have fresh media feed systems, and media reclamation to ensure manual intervention is limited to safe tasks. As a result, these systems do not require PPE as they are considered inherently safe to the personnel operating them since they have engineered or administrative controls that prevent operators from being exposed to the hazard. However, the use of safety glasses when working in close proximity to these processes is considered best practice, as stray media can escape at any time or be dislodged when moving the products through the process.
Manual Media Blast Systems
As the name implies, these systems require personnel to use the blast gun while they are inside the enclosure to execute the process. Therefore, these operators are fully exposed to the hazards of the process, which are both airborne and mechanical. Due to the nature of these hazards, the PPE required is extraordinarily durable. Leather aprons, hard helmets, fresh breathable air supply, face shields, leather gloves, protective shoes, and protective suits are the standard. Breathable air supplies are prepackaged devices that take plant compressed air and separate out particulate and contaminants, while also monitoring carbon monoxide to protect the operator. Even manual blast systems have engineered or administrative controls to protect those persons not directly working within the blast booth, but safety glasses are still recommended.
Automated washers will clean and pre-treat products to
be coated within an enclosure, where operator personnel are located outside during operation. These systems have ventilation fans, protected heating systems, chemical reservoirs, and spray pumps and pipes to ensure that the operation is performed under controlled conditions. Therefore, these systems are considered to have engineered or administrative controls to protect the operators and require no specific PPE requirements. However, working with chemicals has its own hazards, especially when performing titrations and chemical adds; therefore, PPE is required for these activities. At a minimum, safety glasses and gloves should be used as best practice, but refer to the SDS information for each chemical used in the process.
Manual Spray Wand Systems
These systems are much like the manual blast systems
described previously, and as such, require similar PPE to protect operators from the inherent hazards of working with alkaline- and acid-based chemicals. The SDS information provided by the chemical supplier usually recommends face shields or goggles, rubber aprons, rubber boots, and possibly respirators. These systems normally have ventilation packages and walls/curtains to contain overspray and capture/exhaust any steam or fumes from the plant air space (engineered or administrative controls). Therefore, persons not directly working within the spray wand booth do not require any PPE, except for the normal good practice of using safety glasses.
Automatic Liquid or Powder Coating Application Systems
These systems have engineered and administrative controls that preclude the necessity of any specific PPE to protect personnel during operation. However, if there are touch-up persons in, or alongside, these devices, then you need to review the requirements in the next section. Of course, if your personnel handle the liquid paints and powder coatings to feed these automated processes, they will need to follow the PPE recommendations listed in the SDS information for these materials.
Manual Powder Coating Application Systems or Touch-Up within an Automated System
Manual powder application or touch-up spraying can be performed either inside a spray booth or outside the spray booth, while reaching inside to coat the part. Where the operator performs these spraying activities directly affects the PPE that is required to protect them from the inherent hazards of working with these coatings and equipment. If the operator is outside the booth, then the normal best practice PPE requirements allow for dust mask, safety glasses, and conductive gloves to be sufficient protection against the hazard exposure. Dust masks must meet the NIOSH requirements listed in the SDS information. Conductive gloves, to ensure proper operator grounding from electrostatic build-up and discharge, are required to protect operators from the powder coating that may cause skin dryness and irritation.
If the operator is conducting the spray activity within the spray booth, then the PPE requirements increase to either a full respirator or breathable air supply for inhalation risks, face shield, protective clothing, conductive gloves for skin, and eye protection. The respirator must meet the NIOSH requirements listed in the SDS information. The protective clothing (Tyvek paper) with a hood, coupled with breathable air, provide a safe and comfortable environment for the operator and have become the best practice in the industry, although not a requirement. This simple combination also eliminates respirator fitment requirements and documentation.
Personnel outside the booth and not involved with handling the powder coatings do not require any specific PPE, save the safety glasses normally in use in most of today’s manufacturing environments.
Manual Liquid Coating Application or Touch-Up
Manual liquid coating application or touch-up requires the same PPE no matter where it is performed i.e. within an enclosed spray booth or in an open-faced booth. Respirators or breathable air, face shield, protective suits, and conductive gloves (if electrostatic applicators are used) are the normal PPE for the operator hazards. Special coatings may require breathable air supply in lieu of respirators, due to the intense inhalation hazard to the operators. Always check the SDS information for the coating and solvents to ensure the operators use the approved PPE protection.
As with the powder coating spray operations, personnel outside the booth normally do not require any specific PPE because of the engineered and administrative controls designed in these devices.
Part Striping and Hanger Maintenance/ Cleaning Systems
The systems designed to perform these tasks (burn-off ovens, bake-off ovens, molten salt, fluidized sand bed, and chemical stripping systems) all have engineered and administrative controls that eliminate the hazards to the operator. However, any operator coming into contact with the chemicals and sand used within these devices must follow the recommendations for PPE listed within the SDS information for these materials. Additionally, the post cleaning tasks, like ash removal, will also require PPE to protect the operators. The appropriate PPE is dependent upon the methods used to remove the ash or wash the chemicals from the parts or hangers. Spray wand systems will require the PPE listed in the spray wand section discussed previously. Other ash removal systems may also require special PPE, so check with the manufacturer of the device to be sure.
Every finisher must know the requirements and standards for PPE as described in OSHA 29 CFR; Part 1910; Subpart 1 “Personal Protective Equipment.” Additionally, the finisher must know the health and safety risks posed from the materials/chemicals used within their processes or the risks with using the associated equipment to verify suitable PPE devices. This information is available from the SDS of the specific material/chemical and the operator’s manual for the equipment. The degree of respiration filtration is identified by NIOSH standards and must be consulted prior to using these devices.
Finally, comply with or appeal, but do not ignore, the LAHJ recommendations for your process/system to avoid fines and incarceration. No matter what, always use the “Best Practices” described in this article, at a minimum, to mitigate hazards your operators are exposed to in their everyday work.
- by Nick Liberto, P.E., President of Powder Coating Consultants, Division of Ninan, Inc.