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Safety and
Compliance
This is
the area that most people don’t think about investing in until
there is a major problem. At this point the cost of implementing
changes is very costly. Think of these items as insurance.
Never
underestimate the value of safety.
It takes
time and it takes money, but it is time and money well spent.
There are moral issues and legal issues that arise when
considering this subject. I have been on both sides of the line
and, for what it is worth, I would like to say that no matter
how much work or money is involved and no matter how much of a
PITA the regulations are…it is the right thing to do. These
regulations are there to protect you, your workers and your
business. The cost of implementing these regulations should be
considered a cost of doing business and should be a part of the
overhead that you pass on to your customer.
Take a
minute to think about what you are doing.
Be it
waterborne or be it solvent based, there is nothing in a stain
or a finish that is good for you. It is not good for the skin.
It is not good for your lungs and it is not good for your brain.
In a worst case scenario you are taking a toxic flammable liquid
and atomizing it into a fine mist; kind of like what the fuel
injectors in your car does. Just like in your car it only takes
a tiny spark to ignite the vapors and make them go boom.
Let’s not
forget about the “nuisance particles/ dust” from sanding wood
and finishes. They are respiratory irritants that along with the
various finishing solvents can potentially make a pretty nasty
chemical cocktail.
It should
go without saying: Always wear protection.
Except for
the case of 2 component polyurethanes, most MSDS sheets say that
if personal exposure cannot be controlled below applicable
limits by ventilation, then wear a properly fitted organic
vapor/particulate respirator. My question to you is “do you know
how many parts per million of a chemical your finishers are
actually being exposed to?” Personally I would err on the safe
side. Provide your finishers with safety glasses/ goggles, dust
masks, gloves and NIOSH approved organic vapor respirators. If
you spray a fair amount of 2K Poly then I would have air
supplied respirators with full face masks and Tyvek suits
available.
The one
question that arises is “do you require your finishers to wear a
respirator, or is it optional?” The usual response that I have
seen from OSHA is that if a respirator is required, then a
baseline respiratory capacity test is required for each person
involved. A class for fitting and testing the respirator is
required and finally a respiratory capacity test is required at
regular intervals to check against the baseline.
Get your
EPA record keeping up to date
Making
sure that you have the necessary EPA info together and up to
date can save you money and headaches if you ever get an
inspection. Unless you are a large hazardous waste generator, it
is often as simple as having all of your finishing materials
Product Information Sheets & MSDS sheets in a binder and having
a recent copy of your environmental compliance report. A good
distributor of wood finishing products would be able to supply
you with this information at little or no charge.
The
Product Information Sheets are the manufacturer’s information
and usage instructions for a particular product. They often
state the “Solids by Volume” content, reduction requirements,
dry times, as well as other significant information about the
product and its application. Sometimes a simple review of this
piece of literature will reveal some profound insights about a
products use or application. Many times I have seem people using
a product only because a salesperson recommended it to them and
really had no idea about what the product actually was or the
restrictions on its use. Don’t be mislead by marketing. Names
and claims are often tossed around to get a sale. The PI sheet
will tell you the facts.
The MSDS
sheet will tell you exactly what is in the product that you are
using. Sometimes you may not know exactly what you are looking
at, but be aware of these sections:
· Exposure
Controls/ Personal protection
· Toxicological
Information
Environmental Compliance Reports can usually be generated by
your finish supplier. They list the products and their
quantities that you have purchased over a given time period.
They break the products down into the pounds of HAP’s and VOC’s
that could be emitted from the quantities purchased. Most
environmental agencies assume a “potential to emit” as if every
spray gun you had was in use 24/7. This report is invaluable
because it links your “potential to emit” to the actual products
and the quantities that you have purchased. Most finish
suppliers will gladly supply this report for free, or at most a
nominal charge. All you have to do is ask. If your supplier
doesn’t know what this report is, I would consider getting a new
supplier.
In most
cases the paperwork and recordkeeping necessary to fulfill
Environmental Compliance requirements are supplied by your
finish supplier. Again, all you have to do is ask. The burden of
asking, however, remains on you. Document your request in
writing and follow-up on your request until you have the
information that you need. Fines for non-compliance are stiff
and will cost you several times more in money, time and energy
what it would to simply have had the information on file. I
would be willing to say that many EPA inspections are sparked by
a phone call from a disgruntled employee or an angry neighbor.
The
Finishers Prayer
May your
cup never runneth over
May sanding
suddenly be fun
And if the
EPA should visit
Let
waterborne be in your gun.
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