13. Respiratory Protection
Written Respiratory Protection Program
The Program Must Include the Following:
-Procedures for selecting respirators for use in the workplace
-Medical evaluations of employees required to use respirators
-Fit testing procedures for tight-fitting respirators
-Procedures for use of respirators in emergency situations
-Procedures and schedules for cleaning and maintaining respirators
-Procedures to ensure adequate air quality for atmos-supplying respirators
-Training of employees in the respiratory hazards
-Training of employees in the proper use of respirators (donning)
-Procedures for regularly evaluating the effectiveness of the program
The program must be available to employees at any time
14. Respiratory Protection
Respiratory Protection Training
-Why the respirator is necessary and how one could be compromised
-What the limitations and capabilities of the respirator are
-How to use the respirator effectively in emergency situations
-How to inspect, put on and remove, use, and check the seals of the
respirator
-What the procedures are for maintenance and storage of the respirator
-How to recognize medical signs and symptoms that the respirator is
defective
15. Respiratory Protection
Medical Evaluations
-Is the employee able to wear a respirator?
-Must be completed by a PLHCP
-Typically a survey filled out by the employee
-Online Med Evals
-Spirometer Test
-How Often
-Questionnaire is found at
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&
p_id=9783
16. Respiratory Protection
Fit Testing
-Required before going into operation with respirator
-Required Annually
-Qualitative vs Quantitative
Portacounts
Smoke – Saccharine – Banana Oil - Bitrex
-Seal Checks
20. Respiratory Protection
Change Out Schedule
How often should the cartridges be changed
out?
Lab Analysis
Manufacturer’s Recommendation
OSHA.gov Advisor Genius Program
http://www.osha.gov/SLTC/etools/respiratory/mathmodel_advisorgenius.html
22. Paint Booth Compliance
-Constructed of non-combustible materials
-Must have a means of egress
-NFPA 33 Chapter 9 section 1requires an automatic
fire protection system
-Lights are to be guarded by laminated, heat
treated, or hammered wired glass
-Minimum distance from other operations of 3 feet
-Local building codes could require a permit or
certificate of occupancy
-IFC chapter 15 requires spray area permit
23. Paint Booth Compliance
Ventilation
-Air Make = 3 changes in 1 hour
-Top down is better than cross draft for
employee health
-Fan output reading must meet the range found
in table G10 of next slide
-NFPA also requires ventilation to maintain a
maximum concentration of flammable vapors
to 25% of the Lower Flammability Limit
(obtain assistance from the paint booth ventilation installer in calculating this)
24. Paint Booth Compliance
Ventilation Fan Speed
Example
-Using an air operated
gun and have a cross
draft up to 100fpm
-Booth face is 8ft across and
10ft tall
-Booth face = 8ftx10ft
= 80ft2
125fpm x 80ft2 = 10,000cfm minimum must be pushed by fans
25. Paint Booth Compliance
Mixing Room
-Contain a spill
4 inch sill or pit
-Max area of 150ft2
-Approved Automatic Fire Protection System
-Portable Fire Extinguishers
-The max amount of liquid that can be stored is 300 gallons
-Electrical outlets, scales, and computers are rated for Class
1 Division 1 locations
-Ventilation on at all times and flow at 150cfm
26. Air Regulations
Air Permits
Title V - area source that emits a large amount of chemicals
into the atmosphere
Non Title V – permit created by states and federally for
Native American Reservations, typically smaller sources
Permits By Rule – example of exemption for collision
centers
De Minimis Sources – sources that are exempt from any
source and typically requires daily emissions
recordkeeping
27. Air Regulations
6H
-1/9/2008 – 40 CFR Part 63 Subpart HHHHHH
-Reduces the amount HAPs in the atmosphere
-HAPs include the following:
Cadmium - Cd
Chromium - Cr
Lead - Pb
Nickel - Ni
Manganese – Mn
Methylene Chloride
28. Air Regulations
6H
-Paint Booth 4 walls and roof
-Prep station 3 walls and a curtains
-HVLP Guns
-Filters that are 98% efficient
-Employee training
-Gun cleaning without atomizing
-Notification of compliance
Checklist is available – contact Becky or Zach
29. Air Regulations
6H Exemptions
-Less than 2 cars/year
-Applications cannot contain:
Cadmium - Cd
Chromium - Cr
Lead - Pb
Nickel - Ni
Manganese – Mn
3 oz Cup exemption/loophole?
http://www.epa.gov/tips/
30. Air Regulations
State VOC regulations
-Enforced by the states (spray application/gun
cleaners)
-Focuses on Volatile Organic Compounds
-Typically involves requirements for the
following:
Cleaning Equipment
State Notification of Compliance
Training
Written Procedures
31. Land Compliance
Typical Items that could be wastes for a Collision Center
-Paint
-Paint Booth Filters
-Paint Pucks from Solvent Recycler
-Solvent Soaked Rags
-Paint Cups (dripping factor)
-Solvent
-Antifreeze
-Absorbent
-Fluorescent Bulbs
-Tires
-Oil Water Separator
Recycle, Reclaim, Reuse
34. Land Compliance
Generator Status
Conditionally Exempt (CESQG)
Generates < 220lbs of hazardous waste in a
calendar month
Small Quantity Generator (SQG)
Generates >220lbs but <2200lbs of hazardous
waste in a calendar month
Large Quantity Generator (LQG)
Generates <2200lbs of hazardous waste in a
calendar month
35. Land Compliance
CESQG
No EPA ID Number
No annual reporting
No limit on storage for hazardous waste
SQG
Requires EPA ID Number
Some states require annual reporting
Can hold hazardous waste onsite for no more than 180 days
LQG
Requires EPA ID number
Federally require reporting and fees
Requires written emergency plans
Can hold hazardous waste onsite for no more than 90 days
38. Recordkeeping
Personal Protective Equipment
-Hazard Assessment
-Training Rosters
Respiratory Protection
-Written Program
-Medical Evaluations
-Fit Testing Records
-Training Rosters
-Respirator Change Out Schedules
-Appendix D form (if necessary)
39. Recordkeeping
Paint Booths
-Spray and building permit*
Air Compliance
-Air permit*
-6H Notification Form or Exemption Notice
-6H Training Certifications
-Paint Booth Filter Efficiency Rating
-State required solvent recovery notifications*
40. Recordkeeping
Land Compliance
-Waste Determinations
-Notification of Hazardous Waste Activity
-Annual Reports (if required)
-Hazardous Waste Manifests
Match the Following in waste manifests
-Generator Initial Copy
-Land Disposal Restriction Form
-Designated Copy Sent Back From TSDF
Retain these for a minimum of 5 years
Adequate documentation will include a statement about whether or not the waste is hazardous as well as copies of all documentation. Documentation isrequired for all wastes, both non-hazardous and hazardous. Some examples of documentation that may be included are:• Generator Knowledge Material Safety Data Sheets (MSDSs);• Analytical results from a state-certified laboratoryAnother document that is inadequate by itself is a Waste Profile from a contractor. These forms are often filled out by hazardous waste transporters and contractors through interviews with generators and frequently are not supported by any real investigation into the process generating the waste.Conducting an adequate determination for each waste stream will help facilities stay in compliance and avoid costly mistakes. These determinations are the foundation of any good hazardous waste management program and will help reduce management and disposal costs.How can it reduce your costs?
Every waste that you generate and dispose of must have a waste determination completed. For a material to be a hazardous waste, the material must first be classified as a solid waste. Generally speaking, a material is a waste when it can no longer be used for its intended purpose and will be disposed, reclaimed, or recycled. Hazardous wastes are wastes known to be harmful or potentially harmful to human health or the environment.There a few ways that you may come to this determination. Code of Federal Regulations states that a waste is solid waste if it is a solid or a liquid that is discarded, abandoned, recycled, or considered inherently waste-likeCan of paint example…is it a waste or will I reuse…If waste is it hazardous. We determine that by determining if it is a characteristic waste or listed.
