OSHA recently issued a new NEP, National Emphasis Program, which may have your business in its sights. There are not any new regulations, instead there will be a focused enforcement scheduled over the next 3 years. Now is the time to consider the chemicals known as isocyanates in your workplace and how best to control them.
Isocyanates are compounds commonly found in polyurethane-type products (things that harden), such as spray-on clear coats, spray-on bed-liners and some gaskets, sealers, and fillers. If you have any concerns about a particular chemical, check the MSDS, SDS, talk to your product supplier, or talk to KPA employee. Isocyanates are most common in spray operations and place employees at highest risk when they are airborne. Accordingly, OSHA’s NEP lists the auto body collision and repair industry, amongst many others, as a target for enforcement.
KPA has long taken the stance that whenever possible, isocyanate exposure should be eliminated by controlling the application. When not possible, the use of a supplied air system is the best practice to minimize employee exposure. For certain products with high isocyanate concentrations, such as most spray-in bed liners, supplied air is the only solution.
Supplied air systems bring in fresh air from outside the booth. When used in conjunction with an impermeable paint suit and hooded supplied air respirator, concerns over the most common isocyanate exposure routes (inhalation, skin, or eye contact) can be virtually eliminated for spray coating operations. Supplied air also eliminates concerns over other harmful chemicals, such as VOCs, and is therefore considered the best practice for reducing employee exposure.
There are other considerations for the proper set-up based on the scale of your operation, chemicals used, and employee concerns. If using supplied air, consider any employee concerns (the hose gets in the way, the suit does not breathe, the air is too hot, too cold, etc.) and consult with a product supplier to implement a working solution. Many painters prefer supplied air with the right set-up.
If you’re using air purifying respirators (typical face respirators or powered air-purifying respirators {PAPR} systems) either remove the isocyanates from the workplace or collect all pertinent documentation. Keep in mind, there are levels of compliance to consider. In order to best document that operations will pass inspection complete the following:
- isocyanate exposure testing through an industrial hygienist,
- re-evaluate the PPE Hazard Assessment on body, face, hand, eye, and inhalation exposure
- re-evaluate respirator filter efficiency, and
- implement regular employee health check-ups through a medical surveillance program.
Note that the emphasis program will focus on all methods of exposure including skin and eyes. This means eye goggles/hoods and paint suits will be required for painters. Paint suits vary by type, costs, and longevity (single-use, limited-use, and re-usable). The selected paint suits must cover all skin exposure (i.e., hooded) and limit isocyanate permeability. KPA risk consultants are a good resource for PPE Hazard Assessment questions.
Again, this is not a regulation. In fact, the Respiratory Protection Standard has remained relatively unchanged since it was adopted back in October of 1998. OSHA is simply now targeting the issue of isocyanates and has included the auto industry within their focus.
Click here to read more on OSHA’s isocyanate emphasis program.
Now is the time to evaluate your respiratory protection program, including fit testing, respiratory protection training, medical evaluation process, and respirator change-out schedules. As a recommended partner of your state or national organization, we hope your association recommends any stores, particularly those with collision centers, to consider KPA’s compliance services as means to ensure these compliance concerns are covered.
This article is provided by KPA, a recommended partner of your State or National Association providing Environment & Safety services for Auto, RV, and Heavy Equipment/Agricultural Dealers. If you have additional questions, please contact KPA at info@kpaonline.com or 800.853.9659