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.”
Finisher’s 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 what type of PPE is required? There is a specific hierarchy to determine these PPE requirements. 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 on line at www.osha.gov. The second reference sources that need to be reviewed are the all the Material Safety Data Sheet (MSDS), or new newer shortened official description Safety Data Sheet (SDS), information from the all the consumable materials used in your process including paint, powder, solvent, pretreatment chemical, or blast media suppliers. 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, 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 this entire situation of when and what PPE is required is the Local Authority Having Jurisdiction (LAHJ). These authorities include OSHA inspectors, State Workplace Inspectors, FM or IRI insurance Inspectors, Fire Marshals or Inspectors, Insurance Company Inspectors, and more. These authorities can demand anything they deem is 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 often are drive 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 3 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 that must operate it. The process equipment themselves may also present a hazard 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 opened 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 as recommended with automated media systems is still recommended.
Automated washers will clean and pretreat 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 these operators and require no specific PPE requirements. However, working with chemicals have their own hazards, especially when performing titrations and chemical adds, and 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.
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