Chess: Make sure your auto body shop isn’t lacking protective equipment, risking OSHA fineBy on
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Collision repair facilities can actually be among the nation’s most dangerous due to a variety of variables, creating a demand for employee protection that some shop owners might be overlooking, according to Society of Collision Repair Specialists Education Committee Co-Chairman Toby Chess.
But the Occupational Safety and Health Administration might remember them — and sanction the shop accordingly.
“The fines today are staggering,” Chess (Kent Automotive) told an open SCRS board meeting on Tuesday, noting how isocyanate penalties spiked in 2016 to reach even $10,000 for “minor infractions.” (See slides.)
As hopefully everyone’s aware of by now, isocyanates can be found in refinishing products — but they’re also in substances like body filler, seam sealers, and many two-party products, according to Chess. If the shop owner’s not aware of the threat, they might leave their body technicians exposed to the potentially debilitating chemicals without any thought to adequate protective equipment.
Body technicians will need gloves, long sleeves, respirators and goggles (the easiest way to enter the bloodstream is through the eyes, Chess said) to protect themselves, Chess said. He recommended body technicians use a combination respirator able to handle both particulate and vapor threats rather than one dedicated to one or the other.
All shop staff should know to check No. 8 on a Safety Data Sheet for any shop substance to see what personal protective equipment is necessary, Chess said. But ultimately, the shop owner is required by law under the General Duty Clause of the OSH Act to furnish employees with the PPE, he said — though he said California’s OSHA was considering fining both the technician as well as the owner for lapses.
Fulfilling an owner’s obligation doesn’t stop with the purchase of the equipment and techs willing to wear it. Chess described some pitfalls for respirators, including a basic, $500-fine mistake of not returning the respirator to an acceptable container when not in use.
Other respirator issues require a little more diligence, such as regularly changing out respirators after an appropriate number of hours and documenting it instead of going off of “‘They’re supposed to be pink, but they’re black,'” according to Chess.
But before techs can even begin to use a respirator to the point when new filters become necessary, a shop must perform a test fit of any respirator and keep that test current, or “they’ll shut you down,” Chess said. The fine for a failure to test-fit a respirator is now above $10,000, he said. The qualitative version of the test involves strapping on the respirator and seeing if you can smell, taste or be irritated by various substances when exposed to them.
Qualitative fit testing is a pass/fail test method that uses your sense of taste or smell, or your reaction to an irritant in order to detect leakage into the respirator facepiece. Qualitative fit testing does not measure the actual amount of leakage. Whether the respirator passes or fails the test is based simply on you detecting leakage of the test substance into your facepiece. There are four qualitative fit test methods accepted by OSHA:
• Isoamyl acetate, which smells like bananas;
• Saccharin, which leaves a sweet taste in your mouth;
• Bitrex, which leaves a bitter taste in your mouth; and
• Irritant smoke, which can cause coughing. (Minor formatting edits.)
If that doesn’t sound familiar, then owners and employees might want to get together and ensure that test gets done or an appropriate alternative test, such as a quantitative one for tighter-fitting respirators, put the shop in compliance with OSHA’s rules.
The shop needs a book documenting the test fitting and the dates of change-outs so an owner can tell an unannounced OSHA inspector, “‘Here’s my book. Up to date.'”
Asked about technicians with facial hair, Chess said, “I can’t test them.” You’d need to shave first.
What was an employer’s obligation if the employee grew back the facial hair? Chess said he didn’t know for sure.
SCRS board member Tim Ronak (AkzoNobel) said his understanding was it was a condition of employment to be appropriately shorn, and Chess said he thought it would probably raise liability if the employee was too hairy to wear the respirator properly.
It does look like you’ve got to limit your facial hair during regular to stay safe and presumably unfined. Here’s a fun November 2017 graphic from the Centers for Disease Control and National Institute for Occupational Safety and Health on what facial hair couldn’t be sported by an employee using a respirator:
“The reason for this is simple – gases, vapors, and particles in the air will take the path of least resistance and bypass the part of the respirator that captures or filters hazards out,” a Nov. 2, 2017, NIOSH blog post states. “So then, why can’t facial hair act as a crude filter to capture particles that pass between the respirator sealing area and the skin? While human hair appears to be very thin to the naked eye, hair is much larger in size than the particles inhaled. Facial hair is just not dense enough and the individual hairs are too large to capture particles like an air filter does; nor will a beard trap gases and vapors like the carbon bed in a respirator cartridge. Therefore, the vast majority of particles, gases, and vapors follow the air stream right through the facial hair and into respiratory tract of the wearer. In fact, some studies have shown that even a day or two of stubble can begin to reduce protection. Research tells us that the presence of facial hair under the sealing surface causes 20 to 1000 times more leakage compared to clean-shaven individuals.”
One alternative for beardy employees might be a full-face mask with positive pressure, said SCRS board member Mark Boudreau (Caliber).
Even a paint department where a painter bundles up appropriately to fend off isocyanates during the painting process might be forgetting to do so under other exposures, according to Chess. (Some painters don’t even cover themselves correctly in the booth, Chess noted, pointing to refinishers spraying the car wearing a respirator but no other protective gear.)
Were painters protected when they mixed paints or clearcoat? What about while cleaning a paint gun? What about removing filters or cleaning out the pit in a paint booth? Isocyanate exposure was possible under all of these conditions, according to Chess.
Prolonged isocyanate exposure can prematurely end a painter’s career by causing them to develop an allergy to the substance. For more on picking gear which can adequately protect a painter — even some paint suits might not be able to do so — see here.
As Chess said, it’s not just about protecting your respiratory system; its a matter of protecting your eyes and any other exposed part of your body. Painters using an air supply need it to be a Class D air supply and to be equipped with a carbon monoxide monitor, according to Chess.
“It’s a fine if you don’t,” he said.
Painters who transfer materials from one container to another without an appropriate label — not just a piece of tape designating what’s there — on the recipient container also might be in violation, according to Chess, who called it a $500 fine in California.
A painter who maintained sole control of the containers during a workday wouldn’t need a label — but once he or she left for the day, the shop immediately risked a fine, according to Chess.
Besides isocyanates, Chess also raised the spectre of new OSHA crystalline silica rules taking effect June 23, 2018, though KPA, the National Automobile Dealers Association and Maine’s OSHA Consultation Program helped convince OSHA that body shops didn’t face high enough levels of the substance to worry about the rule. But that might not prevent a state from instituting tougher rules, and a shop might want to run the question by an environmental compliance consultant or federal and state authorities to make sure that there’s no risk of crystalline silica fines at the federal or state level. (Technically, repairers don’t have an exemption from the rule — they just can be secure they’re not going to violate it under business as usual, KPA said in 2016.)
Finally, he pointed out another interesting safety issue which might be overlooked: hearing loss. A door skin air hammer makes around 130-135 decibals of noise, according to Chess — who called it louder than a commercial jet. That’s certainly at the level OSHA considers dangerous even for a tiny duration. Yet a technician might omit ear protection.
Society of Collision Repair Specialists personal protective equipment presentation slides
SCRS, April 10, 2018
“To Beard or not to Beard? That’s a good Question!”
National Institute for Occupational Safety and Health Science Blog, Nov. 2, 2017
Occupational Safety and Health Administration respirator fit testing video transcript
OSHA, January 2012
National Institute for Occupational Safety and Health isocyanates webpage
OSHA auto body repair and refinishing hazards webpage
“Proper Paint Booth Operation”
Global Finishing Solutions via Auto Body Repair Network, Automechanika, Dec. 6, 2016
Federal Register publication of new OSHA silica dust rule
Federal Register, March 25, 2016
Occupational Safety and Health Administration silica page
Society of Collision Repair Specialists Education Committee Co-Chairman Toby Chess (Kent Automotive), right, demonstrates a qualitative fit test of a respirator on former SCRS Chairman Barry Dorn (Dorn’s Body & Paint) at the SCRS open board meeting April 10, 2018. (John Huetter/Repairer Driven News)
Collision repair facilities can actually be among the nation’s most dangerous due to a variety of variables, creating a demand for employee protection that some shop owners might be overlooking, according to Society of Collision Repair Specialists Education Committee Co-Chairman Toby Chess (Kent Automotive) at the SCRS open board meeting April 10, 2018. (Provided by Chess via SCRS)
Here’s a fun Nov. 2, 2017, graphic from the Centers for Disease Control and National Institute for Occupational Safety and Health on what facial hair couldn’t be sported by an employee using a respirator. (Provided by Centers for Disease Control)
Society of Collision Repair Specialists Education Committee Co-Chairman Toby Chess (Kent Automotive) holds a respirator in an acceptable respirator storage bag at the SCRS open board meeting April 10, 2018. (John Huetter/Repairer Driven News)