COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

For applicable OSHA standards, it is essential that the employer make an initial determination as to the potential for worker exposure. All refinish processes should be reviewed. Besides coating application processes, substrate prep operations including sanding, grinding and parts welding operations should be scrutinized. Older vehicles may have been coated or treated with a lead, hexavalent chromium or cadmium containing material. Although most U.S. original equipment automobile manufacturers have moved to eliminate use of these heavy metals, fleet and previously refinished vehicles may be a potential source. Coatings processes may be evaluated by utilizing air monitoring data, historical monitoring data or objective data. Objective data might include identification of products that contain the items of concern used on site. PPG product Safety Data Sheets identify hazardous ingredients in Section 2, based upon hazard communication requirements. Container labels also list product ingredients. The PPG Refinish website offers a list of "PPG Products Containing Restricted Metals" which indicates the PPG Refinish products that contain intentionally added lead, hexavalent chromium, cadmium and/or selenium. During this initial recognition phase, it would be appropriate to make a list of products utilized that contain lead, hexavalent chromium, cadmium and selenium and identify the frequency and quantity consumed in the coatings process. If there are likely worker exposures to these metals in the workplace, federal, state and local regulations should be consulted. Compliance with OSHA standards, found at www.osha.gov , is an excellent starting point; however, be aware that regulations are periodically revised. It is essential to stay current with all regulations. The information gathered during the recognition phase of your investigation can be used to identify where there is a potential for worker exposures. If necessary, air monitoring determinations should be made by using industrial hygiene air sampling and analytical methods. It is important to work with an EHS professional and American Industrial Hygiene Association (AIHA) accredited industrial hygiene laboratory. It may be possible to sample and analyze for several metals at the same time. Compliance with all applicable requirements of the OSHA Hexavalent Chromium Standard, except engineering controls, shall be in effect Nov. 27, 2006 for facilities with over 20 employees and May 30, 2007 for facilities with 19 or less employees. Where engineering controls are mandated they must be complete by May 31, 2010. Depending upon exposure levels determined to be at or above the PEL, respirator protection may be required per 29 CFR 1910.34. When levels of exposure for the items of concern are above prescribed levels stated in the standards, review the OSHA standards and all related regulations to determine your plan for corrective action to reduce levels. HMRules.doc Page 2 of 4