Chapter 8
Safety and Health in the Protective Coatings Industry
Daniel P. Adley and Stanford T. Liang
Introduction
In 1999, 5.7 million U.S. workers became ill or
were injured on the job. This total includes both minor
discomfort and serious injury. Roughly 6 people out of
every 100 were affected. Of course, some industries
are more dangerous than others. In the painting and
paperhanging industry, the rate was somewhat lower
than average—4.9 per hundred—while the injury rate
for shipbuilding and repairing was 20.2 per hundred.
By contrast, the rate in the financial industry was only
1.8 per hundred. No breakdown for the painting
industry alone is available.
Workers in the painting industry have to be
alert to the possibility of falling from scaffolds, being
struck by material falling from above, or becoming
caught in or electrocuted by machinery. They also
need to be aware of occupational illnesses that may
result from coating and coating removal operations.
Exposure to lead pigments and silica in abrasives can
cause serious and even fatal illness. Various solvents
affect the nervous system and are identified as known
or possible carcinogens.
About 5,344 workers were killed on the job in
2000, or 4.3 per 100,000 full-time workers. According
to the Bureau of Labor Statistics, although fatalities
are not available for the painting industry alone, the
incidence is not much higher than this national aver-
age. These figures suggest that it is in the best
interest of everyone engaged in the painting and
coating trades—employers, employees, managers,
and suppliers—to take health and safety issues quite
seriously.
Cost Benefits from Safety
Of course, no company wants to see workers
hurt or killed, but there are also external incentives to
safety, particularly the costs of incidents when workers
are injured on the job. Lost work-time also decreases
worker productivity and lowers morale. Many facility
owners and general contractors are pre-qualifying
contractors based on their safety records, and compa-
nies cannot afford to present the image of safety being
anything but a top priority.
Workers compensation and health care costs
are becoming more of a drain on all businesses,
particularly on small companies, and any costs that
can be avoided will benefit these firms. While the
workers compensation system has traditionally
precluded a worker suing an employer for workplace
injury, various exceptions have been granted by the
courts, and more can be expected to follow. For
instance, because several different entities are often
involved in a painting job, an injured worker employed
by a contractor may bring suit against a third party,
such as the specifier. An effective safety program may
help to reduce these types of costs.
Role of OSHA, NIOSH, and Other
Organizations and Safety Professionals
In 1970, Congress passed the Occupational
Safety and Health Act, which created the Occupational
Safety and Health Administration (OSHA), a division of
the Department of Labor. OSHA is responsible for
developing and enforcing mandatory job safety and
health standards. OSHA receives assistance from the
National Institute for Occupational Safety and Health
(NIOSH), a complementary agency established under
the Act as a branch of the Department of Health and
Human Services. NIOSH conducts research on safety
and health issues and provides technical assistance to
OSHA.
Safety and health organizations, such as the
American Industrial Hygiene Association, the Ameri-
can Conference of Governmental Industrial Hygien-
ists, the American Society of Safety Engineers, and
the National Safety Council provide information to help
managers and health and safety professionals to stay
abreast of developments in this rapidly changing field.
Professional organizations for the painting and coating
trades, such as the Society for Protective Coatings,
the International Brotherhood of Painters and Allied
Trades, the National Paint and Coatings Association,
and the Painting and Decorating Contractors of
America, provide industry specific information.
Why Owners and Specifiers Need to be
Aware of Safety and Health
Owners and specifiers have a stake in ensur-
ing that the contractors they employ have the capabil-
ity to comply with health and safety regulations. Many
painting specifications require the successful bidder to
comply with all applicable safety regulations during a
contract. In order to comply, a contractor must know
what materials employees may be exposed to and
what federal, state, and local regulations require. The
contractor must also be familiar with various ap-
proaches to compliance, including engineering, work
practice and administrative controls, air and personnel
monitoring, and the proper use of personal protective
equipment (PPE).
A contractor who does not have the expertise
to keep abreast of safety regulations and to comply
with them may be subject to regulatory fines and civil
and criminal liabilities. The owner who hires such a
contractor runs the risk of being included in legal
actions against the contractor. For instance, according
to OSHA guidance to inspectors, when one employer
is not meeting the requirements to inform employees
of workplace chemical hazards at a multi-employer
work site, the other employers may be cited also.
Contractors who do not make health and
safety a priority often suffer reduced productivity and
lower worker morale. An owner may also be affected
by unnecessary work stoppages and slow downs, as
well as unfavorable publicity as a result of a serious
accident, or a pattern of occupational injury and
illness, at a work site.
Contracting firms who value employees and
practice safety on each job will reap many benefits,
not only for themselves, but also for the owners who
hire them. Good safety performance reduces lost work
hours, which, in turn, reduces the contractor’s insur-
ance costs while increasing productivity. A contractor
with lower insurance costs can do the job at less cost
to the owner—everyone benefits.
Responsibilities of Employers,
Employees, Inspectors, Consultants, and
Engineers
Conscientious painting contractors have
written safety programs based on all safety standards
applicable to the industry, and make every effort to
routinely train their employees to comply with the
written program. Many progressive firms have active
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safety committees, which include management and
worker representatives, and continuously refine their
safety programs and refer suggestions for improve-
ment to upper management.
A truly professional contractor evaluates the
hazards of each job undertaken before any equipment
is brought on site, and develops a plan to control the
hazards expected during each phase of the job. For
example, the project manager may hold a pre-job
safety meeting with workers and supervisors, and
follow up with weekly “tool box” meetings with workers
to ensure that expected hazards are being controlled
and unexpected hazards are recognized as they
develop. Daily job site safety inspections by the
person responsible for safety and health are also
advisable. Workers who consistently violate safety
regulations should be suspended and, in some cases,
terminated.
Owners and specifiers can reduce the odds of
contractor safety violations by pre-qualifying contrac-
tors before they are allowed to submit a bid. OSHA’s
regulation on process safety management (PSM)
requires owners in the chemical process industry to
evaluate the safety records of contractors before they
are hired. Although other sections of the industry are
not required to do this, it is a good way for them to
protect themselves. Examples of indicators to mea-
sure a firm’s safety performance include the
contractor’s workers compensation experience
modification rate (EMR), total cases and lost workday
incident rates, and serious and willful OSHA citations.
In addition to pre-qualifying contractors,
owners and specifiers should routinely outline in their
specifications the safety responsibilities of the contrac-
tor and enforce the safety and health section of the
specification just as stringently as the quality assur-
ance sections. Owners can also require the low bidder
to submit a site-specific safety and health plan that the
owner must approve before awarding a contract.
Hazardous Operations in the Protective
Coatings Industry
Fire Hazards and Explosions
Most solvent-thinned paints and paint solvents
are highly flammable and extremely dangerous when
they, or especially their vapors, are exposed to open
flames, sparks, or very high temperatures. In a
confined area, a fire or explosion could result unless
proper precautions are taken. A certified industrial
hygienist or certified safety professional should be
consulted for advice about safe working conditions,
particularly in confined spaces.
Figure 1. Paint vapors can be flammable if adequate
ventilation is not provided.
Because of the flammability of solvent-thinned
paints, precautions need to be taken when handling
these types of coating systems. Two examples of
solvent-thinned paints include:
• Two-Component Paints: Two-component paints
should never be mixed in large quantities, generally no
more than five gallons at a time. They usually create
heat because they react immediately upon mixing. The
larger the volume mixed, the higher the temperature.
The temperature may become high enough to create
a hazard.
• Oil Paints and Specialty Coatings: Waste or wiping
rags soaked with paints based on linseed oil may
catch fire spontaneously if left lying around, especially
during warm weather. Spillage of peroxide catalysts
used in polyester laminates and other similar chemi-
cals can cause combustion.
Most paint solvents are volatile and will flash
in the presence of a flame or an electric spark. Usually,
the faster the solvent evaporates, the lower its flash
point. Therefore, solvent-thinned brushing or rolling
paints, which dry relatively slowly, will contain solvents
with a flash point of about 105°F (41°C) or somewhat
higher. A solvent-thinned spray paint that requires fast
evaporating solvents may contain solvents that flash
as low as 30°F (1°C). A spray gun, which applies a pint
to many quarts of paint per minute under high pres-
sure, will produce a greater volume of solvent vapor
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than brushes or rolled paint. Therefore, all spray
equipment must be grounded to prevent accidental
ignition by static electricity. This includes containers.
Painters should bond their empty bucket to the bulk
drum while filling it, and the drum should be properly
grounded.
Pure solvent vapors are heavier than air and
tend to move along the ground when in confined
areas. Thus, all flames near the area must be extin-
guished. Solvent vapors must be mechanically ex-
hausted from all enclosed areas with the ventilation
designed for efficient airflow. Explosion-proof lighting
must be used. All electric motors should be turned off.
The following precautions will help prevent the
possibility of fires.
• Store solvents in Underwriter’s Laboratory (UL) listed
containers.
• Prohibit smoking wherever solvent-thinned paint is
stored, mixed, or used. Allow no other sources of
ignition, such as electric coffee pots, hot plates, or
other such appliances to be used in the area.
• Provide adequate ventilation in all working areas to
prevent a build-up of explosive concentrations of
solvent vapor. Properly calibrated direct reading
detection instruments should be used to monitor
confined areas or closed spaces to be sure vapor
concentrations are maintained below explosive limits.
•Use nonmetallic ladders in confined areas or within
10 ft. (3.05 m) of exposed electric wiring.
• Use non-sparking tools to clean metal surfaces
where fire hazards are present.
• Extinguish all sources of flame in the area. Turn off
all gas valves and open all electrical switches if
working in confined areas or near electrical equipment.
• Be sure that all equipment, motors, and lights in the
area are grounded, and consider using only explosion-
proof lighting.
• Keep fire extinguishers nearby. Be sure that they are
of the proper type, as follows:
Class A—Paper, wood, rubbish, where water is
effective;
Class B—Burning liquids, where smothering action is
required;
Class C—Electrical equipment, where the extinguish-
ing agent must be non-conductive.
• Keep pails of sand or similar absorbent materials
near dispensing pumps and spigots to absorb any
spills. Replace all leaking containers.
• Clean up before, during, and immediately after
painting operations. Wet down sweepings, rags, and
waste with water and store in closed metal containers.
Dispose of daily.
• Always clean up paint or solvent spills immediately.
Health Hazards
A variety of paint ingredients or chemicals may
be harmful to the human body. For instance, some
chemicals may cause irritation sensitization, central
nervous system effects, or systemic effects. Most
people can withstand chemical exposures for short
periods of time at low doses; however, some people
are immediately sensitive to some ingredients and
almost everyone will be affected to some degree if
exposed for a sufficient period of time. Continued
exposure may cause the body to become sensitized
so that subsequent contact may result in an aggra-
vated reaction, especially for anyone with a chronic
illness.
Types and Components of Paints. The term paint is
commonly used to identify a range of products
including conventional paints, varnishes, enamels, and
lacquers. Conventional paint is an inorganic pigment
dispersed in a vehicle consisting of a binder and
solvent, with selected fillers and additives. Varnish is a
non-pigmented product based on oil and resin in a
solvent that dries first by the evaporation of the solvent
and then by the oxidation and polymerization of the
resin binder. A pigmented varnish is called an enamel.
Lacquers are coatings that are commonly based on a
cellulose ester in a solvent that dries by evaporation,
leaving a film that can be re-dissolved in the original
solver.
•Alkyd Paints: Employ metal soaps of organic acids
to catalyze the oxidation of the drying component.
Because lead soaps are commonly used, lead is a
potential hazard in any drying oil-type paint (alkyd,
epoxy ester, oleoresin, and urethane-oil). Lead used
as an oxidation catalyst may comprise 0.5–1.0% of the
paint solids by weight. (For more information, see the
section Hazards of Pigments and Other Additives.)
• Liquid Epoxy Resins and Curing Agents: Are
primarily used in solvent-borne and waterborne
two-component epoxy paints. These liquid resins are
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modified by the addition of reactive diluents (glycidyl
ethers) that are themselves irritants to the skin, the
eyes, and the respiratory tract.
•Aliphatic and Aromatic Polyamines, Polyamine
Adducts, and Polyamides: Are used as curing
agents in two-component epoxy coating systems. The
aliphatic amines are potent irritants and sensitizers;
the aromatic amines are somewhat less potent. The
polyamide resins are relatively harmless. Acid anhy-
drides and formaldehyde resins are used as
cross-linking agents in powder coatings and baking
enamels. The acid anhydrides are irritants and sensi-
tizers. Formaldehyde is a strong irritant and is also
considered a human carcinogen.
• Epoxy Resins: Are commonly reacted with fatty
acids to produce epoxy esters. Because coatings
produced with these resins contain no un-reacted
epoxy groups, no hazard exists.
• Urethane Resins: Organic isocyanates are the
principal hazard associated with urethane coatings.
Isocyanates can cause severe irritation to the conjunc-
tiva, as well as respiratory distress. They react with
various protein functional groups and should be
capable of forming antigens. A typical response to
isocyanate inhalation, either as a vapor or an aerosol,
is the manifestation of an asthma-like syndrome,
characterized by a feeling of chest constriction and
difficult breathing, sometimes accompanied by a dry,
irritating cough. A small percentage of the population
may become sensitized to isocyanates, whereupon the
above symptoms are produced on exposure to even
low airborne concentrations. The toxicity can be
minimized, however, by avoiding use of smaller
molecular weight species.
Hazards of Solvents and Thinners. Most solvents are
toxic to some degree, depending upon the exposure.
Solvents may enter or affect the body in three ways.
The most frequent way solvents affect the body is
through skin contact. When a solvent is allowed to
contact the skin, even for a short period of time, it will
start to damage the skin or cause dermatitis (a red-
dening and swelling of the skin). The second route of
entry of solvents into the body is by breathing, or
inhalation. Once solvents are inhaled, the vapors can
pass from the lungs directly to the blood. The solvent
may irritate the respiratory tract and/or cause adverse
health effects to other body systems by being trans-
ferred through the blood stream. The third route of
entry of solvents into the body is by ingestion. Inges-
tion of solvents may affect the gastrointestinal tract as
well as other body organs. The following precautions
should be used while working with toxic solvents:
• Properly label, seal, and store all toxic solvents when
not in use.
• Adequately ventilate all areas where solvents are
used or stored.
• Wear the proper respirator and eye protection.
• If a solvent gets splashed into the eye, immediately
flush the eye with water for a minimum of fifteen
minutes and seek medical attention.
• Wear the appropriate gloves and clothing when
handling solvents.
• Practice good personal hygiene after handling any
solvents.
• Consult the Material Safety Data Sheet (MSDS) to
determine the toxicity of the material that is in use and
the specified protective equipment needed when using
the material.
• If permissible exposure limits are exceeded, as
determined through air monitoring conducted by an
industrial hygienist, then engineering control and
respiratory protection becomes necessary.
Prevention of Health Hazards. The following precau-
tions should help reduce potential hazards. They
describe a common sense approach to avoiding
contact:
• Identify and seal all toxic and dermatitic materials
when not in use.
• Adequately ventilate all painting areas. Provide
general exhaust ventilation in the form of blowers and
fans supplying fresh outside air to the work area where
necessary, and use National Institute for Occupational
Safety and Health/Mine Safety and Health Administra-
tion approved respiratory protection equipment if the
vapors cause irritation or intoxication.
• When surface preparation involves removal of old
paint films, take care to minimize dusting to protect
workers from the dust and to properly dispose of
coating residues in accordance with applicable state
and federal regulations.
• Wear goggles and the proper respirator when spray
painting or performing any operation where an abnor-
mal amount of vapor or dust is formed.
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• Wear appropriate gloves and clothing when handling
dermatitic materials. Change and clean work clothing
daily.
• Avoid touching any part of the body when handling
dermatitic materials. Wash hands, face, and arms
thoroughly before eating and at the end of the day. Try
to shower at or near the job site. Change clothing
before leaving. Toxicants can be transferred easily.
• Paint removers containing solvents are often toxic.
They should be used only with ventilation controls and/
or respiratory protection.
Hazards of Pigments and Other Additives. Heavy
metal pigments are another paint component that may
be toxic to the human body. The most common contain
lead, chromium, and oxides of iron, titanium, and zinc.
Precautions such as ventilation, respirators, hygiene
facilities, and personal protective clothing should be
implemented when applying or removing paints
containing these pigments. The substitution of hazard-
ous pigments with non-hazardous pigments is the best
method of controlling future occupational health
hazards.
The removal of paints containing heavy metal
pigments without control measures greatly increases
an employee’s chances of developing heavy metal
poisoning. Airborne pigments such as lead may enter
the body by inhalation and ingestion. Exposure to lead
may affect each person differently. Even before
symptoms appear, lead may cause unseen injury to
the body. During early stages of lead poisoning, mild
symptoms may be overlooked as everyday medical
complaints, including: loss of appetite, trouble sleep-
ing, irritability, fatigue, headache, joint and muscle
aches, metallic taste, lack of concentration, and
moodiness. Brief but intense exposure or prolonged
overexposure may result in severe damage to the
blood-forming, nervous, kidney, and reproductive
systems. Some noticeable medical problems include:
stomach pains, wrist or foot drop, high blood pressure,
nausea, anemia, constipation or diarrhea, tremors,
convulsions, or seizures.
Silica (both crystalline and amorphous) and
the silicates clay, diatomaceous earth, mica, and talc
are widely used as extender pigments. With the
exception of clay, all have been demonstrated to
produce fibrosis of the lung. A preliminary study of the
health hazards in the painting trades suggested that
“mixed dust pneumoconiosis” is common among
painters. While extender pigments are used in sub- particles, the toxicity of the materials in the dust, and
stantial quantities in some paint formulations, these the amount of dust breathed into the lungs. To deter-
materials may be at least partially locked up by mine the toxicity of the dust, refer to the MSDS for the
encapsulation in the resinous binder. abrasive in use, then identify the chemical makeup of
The chronic hazards posed by organic pig- the coating being removed and the substrate or object
ments are largely unknown. Many of the pigments are being cleaned. To control workers’ exposures to
based on dyestuffs; the dyestuff is combined with an potentially toxic dust, a well-designed ventilation
inorganic compound to produce an insoluble pigment. system should be installed. Respirators and proper
The dyestuffs have been studied more extensively protective equipment should also be used to ensure
than the pigments, and several have been implicated adequate protection.
as carcinogenic. In paint, the biological availability of
these materials is probably limited by the insolubility of
the pigments and their partial encapsulation in the
paint resin matrix. Fat and/or water-soluble dyes are
used in some wood stains, increasing the potential
hazard.
Activators and catalysts found in some coat-
ings, such as mercury compounds, can be very
harmful if proper protective clothing and respiratory
protection is not used.

Figure 3. Health effects of lead.

Abrasive fines used to remove paint coatings

that contain lead, cadmium, chromates, zinc, or nickel
should be treated as hazardous unless testing can
prove otherwise. In addition, abrasives may contain
small amounts of toxic heavy metals such as lead,
copper, arsenic, cadmium, and beryllium. Respiratory
devices and protective clothing should be worn when
working with abrasive fines. Of particular concern is
the presence of silica (quartz) in sands and other
mineral abrasives.
Chronic or acute short-term exposure to silica
dust can cause a debilitating disease known as
silicosis. Air-supplied respirators, operated in accor-
dance with the OSHA Respiratory Protection Standard
Figure 2. Eye and respiratory protection are needed for
1926.103, can protect blasters from this hazard.
spray painting.
However, because of poor maintenance of respiratory
equipment and poor hygiene, many workers have
Hazards of Surface Preparation Materials. Blast
been exposed to and injured by excessive levels of
cleaning can turn paint, rust, and substrate surfaces
silica. NIOSH recommended as early as 1974 that
into a dust cloud consisting of many airborne particles,
abrasive blasting be restricted to abrasive with a
some too small for the naked eye to see. Whether or
maximum of 1% silica content. In a Hazard Alert,
not any of the airborne dust particles are a potential
NIOSH described specific health hazards from silica,
health hazard depends on the size of the dust
and cited several case histories where blast cleaners

424
had died from this condition. NIOSH also identified
inadequate engineering controls, inadequate respira-
tory protection, and failure to conduct adequate
medical surveillance programs as contributing to the
development of silicosis. NIOSH recommends a series
of preventative measures, including substitution of
alternative abrasives, air monitoring, use of contain-
ment structures, personal hygiene, protective clothing,
respiratory protection, medical monitoring, posting of
warning signs, and worker training.
The Texas Department of Health also issued
an advisory on the hazards of using silica abrasives to
the oil and gas pipe coating industry. Both documents
strongly recommend observing the OSHA PEL (Per-
missible Exposure Limit). The PEL is based on an
8-hour time-weighted average and is calculated using
a formula that requires an analytical laboratory to
determine the percentage of crystalline silica in
respirable dust collected during worker exposure-
monitoring.
Chemical strippers are used to soften the
existing coating for removal by scraping and/or flush-
ing. Chemical strippers eliminate airborne hazards, but
proper protective clothing such as coveralls, gloves,
and glasses should be worn to prevent skin and eye
irritation. Caustic compounds in some chemical
strippers can cause burns if not immediately washed
off the skin and can cause eyes, nose, and throat
irritation upon inhalation. Solvent-based strippers are
also available. Health hazards may vary from irritation
and central nervous system depression, possible with
substances such as xylene, to the possibility of
carcinogens affecting humans, as with methylene
chloride. Methylene chloride is also regulated by an
OSHA standard as a carcinogen. Use of methylene
chloride should be avoided whenever possible.
Chemical strippers containing solvents may require
use of respiratory protective devices. Refer to SSPC
Technology Update (TU 6), Chemical Stripping of
Organic Coatings from Steel Surfaces for additional
information on the safe use of chemical strippers.
Acids and alkalis commonly found in “wash
primers” and chemical strippers (e.g., sodium hydrox-
ide and phosphoric acid) are highly corrosive, and
appropriate measures should be instituted concerning
storage, handling, waste disposal, ventilation, personal
protection, and first aid.
A pre-job analysis of the surface materials
should be conducted to determine whether the coating
425
contains hazardous materials. If the coating contains
potentially hazardous constituents then respiratory and
protective clothing should be worn while working with
the removed material.
All spills should be cleaned up immediately
and workers should wash immediately if their skin
comes into contact with a hazardous substance. If a
solvent chemical gets splashed into the eye, immedi-
ately flush the eye with water for a minimum of fifteen
minutes and seek medical attention. Wear the appro-
priate gloves and clothing when handling spills.
Practice good personal hygiene after handling any
spills. Consult the MSDS to determine the toxicity of
the material that is in use, and the specific protective
equipment needed when using the material. Store and
dispose of all oily or solvent wetted rags in metal
containers with tightly sealed lids. Respiratory protec-
tion should be worn if the spill creates a hazardous
atmosphere, or the MSDS indicates it is necessary.
Paint Application
Paint products are used widely in industry to
provide a surface coating for protection against
corrosion, for appearance, as electrical insulation, and
for a number of special purposes. Common methods
of application include airless spray, conventional spray
(air atomizing), and electrostatic spray.
Because airless spray systems operate at high
pressure, special attention must be given to them to
ensure safety during operation. A tip guard and trigger
lock must be present on airless spray guns. Fluid
sprayed from the gun is propelled with sufficient force
to penetrate skin and cause serious damage. In the
event of injection, special treatment by a physician is
required. The attending physician should be advised of
the material’s ingredients (an MSDS would be helpful)
and of the nature of the injection (high pressure). The
entire system is pressurized so that hose ruptures or
leaks at fittings can result in dangerous high-pressure
spray.
Some important safety practices to help avoid
these hazards include:
• Never point the gun at anyone.
• Do not make adjustments to the equipment setup,
such as changing nozzles or fittings, without first
shutting off the pump and releasing the system
pressure.
• Always make sure the fluid hose is in good condition
before spraying; kinks or abrasion can develop into a
rupture. Store the hose in a dry area.
• Do not use standard hardware on an airless system;
only high-pressure fittings can be used. A high-
pressure hose is required for fluid flow. The hose must
never be bent or kinked in less than a 4-inch (102-mm)
radius.
• Ground airless spray equipment to prevent static
sparking. If extension cords are used, make sure that
they have a ground wire and that the ground is con-
nected.
• Do not spray solvent through the nozzle tip, because
this can cause a build-up of static electricity and an
explosion or fire. Take the tip off before spraying
solvent through the system.
• Secure the blast hose at a point no more than 10 ft.
(30.5 m) from the operator.
• Conduct hydrostatic tests at least once, and prefer-
ably twice, a year. Check all valves, including safety
valves, daily.
The conventional, or air atomizing, spray gun
is widely used due to its versatility, its low cost, and
because it creates a high-quality finish. In this method,
cold pressed air provides the energy to atomize the
finish. The atomization is produced by an air nozzle.
Two types of nozzles are used: external mix and
internal mix. In the external mix nozzle, the coating
and the compressed air exit from separate orifices and
are mixed outside the nozzle. The jet atomizes and
shapes the spray fan. Internal mix nozzles combine
the compressed air and finishing materials in a
chamber inside the nozzle. The atomized mixture is
shaped by the geometry of the chamber opening.
Regardless of which paint method is used, most
industrial spray paint operations require exhaust
ventilation, the use of air-supplied respirators, protec-
tive clothing, and adequate washing facilities.
In electrostatic spraying, an electrical charge
is applied to the atomized coating particles, either by
the creation of an ionized zone within the spray area,
or by imparting a charge to the fluid stream prior to its
release from the spray gun head. The charged,
atomized paint particles are attracted the conductive
object being finished by the electrostatic potential
between the paint and the object.
The level of exposure to the paint is deter-
mined by the overspray and rebound that occurs
during spraying. Effective ventilation controls should
be in place, and protective clothing and respiratory
protection should be worn while using this painting
426
method. All electrostatic equipment must be properly
grounded.
When using a compressor during any of these
three application methods, never overload it. Place the
compressor in an open and level area in a remote
location because it requires a good supply of clean,
fresh air in order to properly operate. It should also be
grounded before being started. Allow a reasonable
amount of time for it to warm up before building up
pressure in the receiving tank and never tamper with
preset safety valves.
Figure 4. Airless spray systems exert considerable force
and can cause serious injury if not handled carefully.
Gauges should be kept clean and visible at all
times. Workers need to see the gauges to tell whether
all air pressure has been released before disconnect-
ing any couplings or opening any lids. The gauges are
also used to ensure that the compressor is operating
safely.
Do not add fuel to a gasoline-powered com-
pressor when it is hot or running. The fuel can easily
ignite, causing a fire or explosion. All re-fueling of the
compressor should be done in the morning before
start-up. The compressor should be kept tuned-up and
out of confined spaces. If compressors are used to
supply breathing air for respirators they must be
equipped with carbon monoxide monitor and filter
systems capable of providing Grade D air.
Surface Preparation
Abrasive Blast Cleaning. Without proper precautions,
the high pressures used in blast cleaning can cause
injuries. Injections of water beneath the skin should be
treated as seriously as any other chemical injection. In
addition, abrasive material may cause harm at high or
even moderate pressures, and continuous exposure to
the dust may result in lung disease.
Figure 5. Specialized protective equipment is required
for abrasive blast cleaning.
Protective equipment is essential to protect
the abrasive blaster and fellow workers from the
hazards of the job. At a minimum, a continuous flow
respirator with helmet and wide angle, clear vision lens
must be used by the abrasive blaster. The helmet must
fit completely over the head and neck to the shoulders.
The helmet should be equipped with a constant supply
of clean air (Grade D or better) of not less than 6 ft.3
(.168 m3) per minute. The air-line should be equipped
with air-purifying filters, pressure regulator gauge,
relief valve, air-flow control valve and a NIOSH/MSHA
approved blasting respirator. The abrasive blaster
should also be equipped with appropriate work gloves,
coveralls, and other clothing.
The blaster must use a “dead-man” control
valve on the blasting nozzle to cut off the air and
abrasive stream when the pressure on the control is
released. The hoses for the blasting equipment must
be equipped with a static dissipating tube or be lined
with carbon black. This prevents shock from static
electricity build-up. Such a shock could cause the
operator to fall if working on an elevated surface.
Before starting any abrasive blasting opera-
tion, thoroughly examine the condition of hoses, hose
fittings, couplings, and unions. Any of the above
427
showing wear must be replaced to prevent sudden
parting and whipping under pressure.
Hand and Power Tools. Common hand tools used for
hand tool cleaning are sandpaper, non-woven abra-
sive pads, wire brushes, chipping hammers, scrapers,
and chisels. Prolonged use of chipping hammers and
chisels may cause trauma to the hands, wrists, and
elbows. Use of shock absorbing gloves and/or wrist
supports or ergonomically designed tools may be
advisable.
Common power tools are pneumatically driven
hammers or rotary hammers, needle guns, roto peens,
rotary grinders, sanders, or wire brushing tools. It is
important to have a proper equipment setup when
using power tools. Follow the manufacturer’s instruc-
tions for the tool being used.
Power tools can be dangerous, and safety
precautions must be taken when operating them.
Protective equipment must be worn. In addition to a
hardhat and eye protection, work gloves should be
worn. Power tool cleaning may be very noisy, and it is
therefore very important to use adequate hearing
protection. Respiratory protection and coveralls are
advisable whenever hand or power tools are used to
remove paint, and are required for removal of lead-
based paints.
If electrically driven (rather than air-powered)
tools are used, they must be adequately grounded or
double insulated, and used in a dry atmosphere to
avoid the possibility of shock. Ground Fault Circuit
Interrupters (GFCI) should be used with all electric
cords and tools. In confined spaces and other areas
where there may be a danger of explosion, power tool
cleaning should not be conducted because of the
possibility of sparking.
The operator must be certain that the tools in
use are checked and safe. Make sure that the abra-
sive media is attached securely and tightened. Tools
should not be operated above maximum operating
speed or run at all unless in contact with the work
surface. Manufacturer’s directions should always be
strictly followed.
Waterjetting. Although water itself is relatively safe, the
extremely high pressure often used for waterjetting
can be hazardous. Prior to waterjetting, employees
should examine the condition of the hoses, hose
fittings, couplings, and unions. All equipment showing
wear should be replaced to prevent sudden parting
and whipping under pressure.
Waterjetting hoses should be secured to the
staging at the working level, leaving only enough free
hose so the hose weight can be properly and safely
handled by the blaster. Any electrical equipment in the
area of operations that presents a hazard to the
operator should be de-energized, shielded, or other-
wise made safe. Operators should wear appropriate
waterproof clothing, head, eye, and hearing protection
during all waterjetting operations.
When waterjetting operations are conducted in
confined spaces, the blaster should be in constant
communication with the stand-by person. Employees
should take precautions to protect the water blasting
equipment from freezing in cold weather and signs
should be posted to advise others in the area when
water blasting operations are being performed. As
always, injection of water beneath the skin should be
treated as seriously as any other chemical injection,
and a physician should be consulted.
Welding, Cutting, or Heating. All welding, cutting, or
heating on surfaces with preservative coatings should
be performed according to OSHA standard 29 CFR
1926.354, Welding, Cutting, and Heating in Way of
Preservative Coatings. Before welding, cutting, or
heating, the potential toxicity and flammability of
preservatives should be evaluated. All surfaces
covered with toxic coatings require the use of protec-
tive clothing and a respirator that is capable of filtering
out the emissions generated during surface cleaning.
Means for fire protection and proper ventilation should
also be provided during welding, cutting, or heating.
Pressure Pots. Sandblast pots and related blast
machinery should be built to standards set by the
American Society of Mechanical Engineers (ASME) or
National Board Code. Pots not meeting these require-
ments must not be used. The ASME code means that
everything has been done to make the vessel as safe
as possible. The code prohibits any field welding on
blast machines. Blast pressures should stay within the
manufacturer’s blast machine ratings.
Pot tenders and others working near abrasive
blasting operations may need to be equipped with
respirators, gloves, hard hats, and safety glasses.
Most abrasive blasting operations produce noise
levels in excess of 90 decibels, therefore hearing
428
protection devices (ear plugs or earmuffs) should also
be worn.
Never force the lid off the sandblast pot. If the
lid is difficult to open, stop and check the air pressure.
The pot must be depressurized before opening the pot
lid, or before any changes to hose couplings or repairs
of any kind are allowed. A blast machine should never
be moved while it contains abrasives. Abrasive
blasting machines that will be towed on a highway
should be equipped with properly operating brakes,
taillights, fenders, and side reflectors.
Access and Rigging
Ladders. Use the following procedures in storing,
setting up, and using ladders:
• Use safety shoes.
• Store ladders off the ground in a warm, dry arc
protected from the weather.
• Protect wood ladders with a clear finish so that
defects are visible.
• Inspect ladders daily during use. Keep them clean
and free of oil or grease.
• Use ladders that can be carried and erected by two
workers.
• Use a stepladder that is less than 12 ft. (4 m) high.
• Ladders should be fully opened with a locking device.
• Do not stand on the top step. One worker should
hold a ladder if the worker climbing the ladder will be
more than 8 ft. (2 m) from the ground.
• Avoid placing ladders in front of doorways, unless the
door is blocked.
• Only one worker should work on a ladder at a time.
• Do not use a ladder as a horizontal scaffold member.
• The ladder should extend at least 3 ft. (.92 m) above
the point of support and should be tied off when
accessing unusually high levels.
Fall Hazards. Falls from heights are a significant
hazard faced by painters and blasters in day-to-day
work. Because falls are a routine hazard, there is a
tendency to ignore some of the precautions necessary
when working on elevated surfaces, but safety cannot
be taken for granted. The hazards of high work subject
employees to possible injury and death, and an
employer to possible OSHA citations and fines.
The primary means for protecting workers
from hazards of falls from heights is the use of a
standard guardrail consisting of top rail, intermediate
rail, and toeboard. Guardrails and toeboards should
be installed on all open sides and ends of platforms to
give maximum protection. The OSHA standard
pertaining to this protection is 29 CFR 1926.502(b),
which refers specifically to work on floors, platforms,
and runways. Other OSHA standards that discuss the
use of guardrails are 1926.451(g), pertaining to
scaffold arrangements, and 1926.550(9), pertaining to
suspended personnel platforms.
Figure 6. Failure to use proper access equipment can
lead to falls, a common source of injury in coating
operations.
Guardrails and toeboards cannot be used in
all fall hazard situations. When guardrails are neither
practical nor feasible, use a secondary means of fall
protection, or personal fall arrest equipment. Personal
fall arrest equipment consists of a safety harness
connected by a lanyard to an anchorage. Federal
regulations prohibit the use of body belts as part of a
personal fall arrest system. Use of body belts, even
when properly worn, can cause severe internal injuries
or suffocation in an arrested fall. OSHA regulates the
use of personal fall arrest systems in 29 CFR
1926.502(d).
While personal fall arrest equipment can be
anchored directly to a structure, personal fall equip-
ment is typically attached to a lifeline system. There
are three basic types of lifelines: horizontal, vertical,
and retractable.
Horizontal lifelines consist of a fiber or wire
429
rope suspended between two fixed anchorages. The
safety harness is connected directly to the horizontal
lifeline via a lanyard. OSHA requires that horizontal
lifelines be designed, installed, and used under the
supervision of a qualified person. An evaluation of the
horizontal lifeline should be performed to verify that it
maintains a safety factor of two, as required by OSHA.
Horizontal lifelines should be used for multiple tie-offs
only after the qualified person determines the maxi-
mum number of workers who can use the lifeline.
The vertical lifeline or dropline is a rope
system used with a harness. The harness is attached
to a lanyard and rope-grabbing device. The rope-
grabbing device is attached to a lifeline that must have
a minimum breaking strength of 5,000 pounds (2,270
kg). The rope-grabbing device should be installed and
used in accordance with the manufacturer’s manual.
Improper use or installation (e.g., installing the rope-
grab upside down) can result in failure. Only one
worker at a time is permitted to be connected to a
vertical lifeline.
A retractable lifeline is a device with an
integral line that moves upward or downward with the
worker, preventing slack from developing. This lifeline
is connected directly to the safety harness. Retracting
lifelines have a centrifugal locking or braking system to
prevent further decent in the event of a fall. Retract-
able lifelines must be kept overhead as much as
possible. As the worker moves horizontally away from
the anchor point, the severity of a “swing fall” in the
event of an arrested fall increases. A “swing fall” is
pendulum like motion that can occur in an arrested fall.
During a “swing fall,” collisions with obstructions in the
path of travel can occur with as much destructive
energy as by hitting the ground in a vertical fall.
Retractable lifelines should not be used with horizontal
lifelines unless the manufacturer approves such use.
Improper connection of a retractable lifeline to a
horizontal lifeline can result in failure of the lifeline’s
locking mechanism during an arrested fall.
Anchorages for direct connection of lanyards
or connection of lifelines must be independent of any
anchorage used to support or suspend platforms.
Anchorages must be capable of supporting at least
5,000 pounds (2,220 kg) per employee attached or be
used and designed as follows: (1) as part of a com-
plete fall arrest system, which maintains a safety factor
of at least two; and (2) under the supervision of a
qualified person.
 Shock-absorbing lanyards should be used
unless lanyards are connected to equipment that limits
free fall distance to 2 ft. (.61 m). The free fall distance
is the distance traveled in an arrested fall until the fall
protection device begins to slow decent. An example
of a device that limits the free fall distance to 2 ft. (.61
m) is the retractable lifeline.
Lanyards are only to be connected to the D-
ring on the back of the harness approximately between
the worker’s shoulder blades. Harnesses may have D-
rings at other locations for connecting other types of
fall protection equipment (e.g., D-rings at waist level
for connection to positioning systems, such as belts).
Use of the incorrect D-ring for lanyards can result in
severe injury or death. Lanyards must also be
equipped with the correct attachment device (e.g.,
snaphook) for connection to the anchorage (e.g.,
lifeline).
OSHA requires the use of locking snaphooks
to prevent “roll out” where the snaphook keeper is
accidentally depressed in an arrested fall, resulting in
disengagement. Snaphooks cannot be connected to
objects that are not compatibly shaped (e.g., the
keeper of the snaphook is unable to close after
attachment to the anchorage). When snaphooks are
not able to be directly connected to the anchorage, the
use of anchorage connection devices (e.g., cross arm
strap, carabiner) should be investigated. Snaphooks
should not be connected directly to horizontal lifelines
unless it is of a locking type and unless the manufac-
turer recommends such use.
Personal fall arrest systems must be rigged so
that workers will not free fall more than 6 ft., (1.83 m)
nor contact a lower level. The amount of clearance
beneath the anchor point needed to meet this require-
ment is determined by the free fall distance (6 ft. [1.83
m] if a six foot lanyard is used), the deceleration
distance (3.5 ft. [1.07 m] if the lanyard is equipped with
a shock absorber), and the length of the worker’s body
suspended beneath the D-ring on the back of the
harness (about 5 ft. [1.53 m] ).
A safety factor of about 4 ft. should also be
included in the amount of clearance required to allow
for D-ring slide and stretching in lifelines and webbing
in the harness and lanyard. This safety factor may
have to be increased for horizontal lifelines depending
on the amount of sag permitted by the qualified
person. Where there is insufficient clearance beneath
the anchor point, use of a retractable lifeline should be
430
investigated. These devices limit free fall to 2 ft. (.61
m), making use of a shock absorber unnecessary and
eliminating the deceleration distance of 3.5 ft. (1.07
m). Other options to reduce the amount of clearance
needed include use of a shorter lanyard or simply
moving the anchor point to a higher location. Keeping
free fall distances to less than 6 ft. (1.83 m) is accom-
plished by using lanyards that are 6 ft. (1.83 m) or less
in length (or by using a retractable lifeline) and by
maintaining the anchor point location above the D-ring
on the back of the harness.
OSHA requires employers who rely on per-
sonal fall arrest systems to have pre-planned rescue
procedures in the event of a fall. As an alternative to
developing rescue procedures, employers can provide
employees with equipment that allows for self-rescue.
An example of a self-rescue device is a retractable
lanyard with a controlled decent mechanism that
permits employees to lower themselves to the ground
after arrested falls. Since improper installation, use,
and maintenance of fall protection can result in serious
injury and death, workers must be trained when
exposed to fall hazards. OSHA training requirements
are addressed under 29 CFR 1926.503. Training
should also include information in the manufacturer’s
manual for personal fall arrest equipment used by
workers.
Sometimes personal fall arrest systems,
guardrails, or other conventional protective equipment
may be impractical or not feasible for the work method.
In these situations, personnel safety nets can be
installed under and around the work area. Personnel
safety nets are typically used in bridge work and
long-term structural projects where workers are
exposed to significant fall hazards.
Personnel safety nets must be manufactured
and tested in accordance with all pertaining ANSI
standards and OSHA standard requirements. They
should bear a label displaying the manufacturer’s
name, date of manufacture, and proof of load testing.
Every net should also carry a serial number so that
records can be kept of details such as repairs, inspec-
tions, and load test results. OSHA’s requirements for
safety nets can be found in 29 CFR 1926.502 (c).
Aerial Lifts. OSHA regulates aerial lifts under 29 CFR
1926.453. According to the OSHA standard, aerial lifts
include the following vehicle mounted aerial devices
used to elevate personnel to job sites above
the ground:
• Extensible boom platforms
• Articulating boom platforms
• Vertical towers
• A combination of any such devices
These requirements are specifically applicable
to extensible boom and articulating boom platforms:
• Only authorized persons shall operate an aerial lift.
• Belting off (i.e., connecting personal fall arrest
equipment) to an adjacent pole, structure, or equip-
ment while working from an aerial lift shall not be
permitted.
• Employees shall always stand firmly on the floor of
the basket and shall not sit or climb on the edge of the
basket or use planks, ladders, or other devices for a
work position.
• Boom and basket limits specified by the manufac-
turer shall not be exceeded.
• The brakes shall be set and when outriggers are
used they shall be positioned on pads or a solid
surface. Wheel chocks shall be installed before using
an aerial lift on an incline, provided that they can be
safely installed.
• An aerial lift truck shall not be moved when the boom
is elevated in a working position with workers in the
basket, except for equipment that is specifically
designed for this type of operation in accordance with
29 CFR 1926.453 (a)(1) and (a)(2).
• Articulating boom and extensible boom platforms that
are primarily designed as personnel carriers shall have
both upper and lower controls. Upper controls shall be
in or beside the platform within easy reach of the
operator. Lower controls shall provide for overriding
the upper controls. Controls shall be plainly marked as
to their function. Lower level controls shall not be
operated unless permission has been obtained from
the employee in the lift, except in case of emergency.
• Climbers (i.e., spurs or spikes attached to the shoe)
shall not be worn while performing work from an
aerial lift.
• The insulated portion of an aerial lift shall not
be altered in any manner that might reduce its
insulating value.
• Before moving an aerial lift for travel, the boom(s)
shall be inspected to see that it is properly cradled and
outriggers are in the stowed position, except when the
requirement described above is met for moving the
aerial lift when the boom is elevated.
431
Many injuries and fatalities associated with the
use of aerial lifts are due to falls. Typical causes of
falls from aerial lifts include mechanical failures in the
hydraulic system that cause the basket to tip, operat-
ing the aerial lift on an incline causing the unit to tip
over, falling while climbing out of the basket onto a
scaffold or other elevated work surface, or falling out
of the basket while standing on the guardrail or
makeshift platform (e.g., board suspended from the
guard rails or a bucket).
OSHA requires personal fall arrest equipment for
all occupants in an aerial lift. In lieu of personal fall
arrest, which protects occupants if they fall from the
aerial lift, OSHA permits occupants to be provided with
a restraint system as an alternative. A restraint system
may consist of a body belt (note this exception for the
use of body belts with “restraint systems” only), or a
harness and lanyard that must be short enough to
prevent the occupants from leaving the basket.
Lanyards used in restraint systems for aerial lifts
typically must be less than 4 ft. (1.22 m) long.
Only if scissor lifts are equipped with standard
guardrails does OSHA permit, in a letter of interpreta-
tion dated August 8, 1995, an exemption to the re-
quirement to provide occupants with personal fall
arrest or restraint systems. OSHA stated in this letter
that this exemption does not apply if guardrails are
removed or are not effective. The use of personal fall
arrest for scissor lift occupants should also be consid-
ered if there is the possibility that occupants may climb
out of the platform or (improperly) stand on guardrails
while working from these platforms.
In two letters of interpretation dated January 25,
1988 and September 5, 1998, OSHA addressed
control measures for fall hazards when workers
transfer between elevated work surfaces and aerial
lifts. These letters state that employees should attach
their lanyards to an attachment point on the fixed
structure (e.g., bridge) before exiting the basket. A
vertical lifeline is given as an example of a means of
attachment. Any lifelines, including their anchorages,
used for connection of personal fall arrest must meet
the requirement of 29 CFR 1926.502 (d).
OSHA warns, in the September 5, 1998, interpre-
tation letter, that attachment of personal fall arrest
equipment to the aerial lift basket may be inappropri-
ate if the manufacturer of the lift cannot certify that the
lift will not tip over if a person, tied off to the lift, fell
from a position on top of the basket guardrail. The use
of dual lanyards should also be considered to allow
workers to be tied off at all times when disconnecting
their lanyards from the aerial lift basket and connecting
them to a lifeline suspended from the structure.
The manufacturer’s manual must be con-
sulted before operating an aerial lift on an inclined
surface. The limits in the manual for an acceptable
incline surface must not be exceeded. Many newer
aerial lifts are equipped with devices that prevent
operation if the aerial lift is tilted beyond acceptable
limits.
Confined Spaces. OSHA’s Permit-Required Confined
Space Standard 1910.146 defines a confined space as
a “space the is large enough and so configured that an
employee can bodily enter and perform assigned work;
and has limited or restricted means for entry or exit
(e.g., tanks, vessels, silos, storage bins, hoppers,
vaults and pits are spaces that may have limited
means of entry); and is not designed for continuous
occupancy.”
The confined space standard states the
minimal requirements for safe entry, continuous work
in, and exit from tanks and other confined spaces. A
confined space program should include training in:
• The duties of a standby person
• Use of ventilating equipment
• Isolation of systems
• Atmospheric testing
• Confined space entry limits
• The use/purpose of an entry permit
Understanding OSHA
General Duty Clause
Although OSHA has developed a number of
industry- and substance-specific standards, the
general duty clause takes a very broad view of worker
health and safety. It requires employers to furnish to
their workers “employment and a place of employment
which are free from recognized hazards that are
causing or likely to cause death or serious physical
harm.” OSHA can use this clause to cite an employer
when conditions it believes to be unsafe do not violate
specific OSHA regulations.
The Regulatory Process
Some OSHA standards have been mandated
by Congress. They may also be initiated by the agency
432
in response to petitions from other parties including
NIOSH, state and local governments, groups that
develop voluntary industrial standards or labor
representatives. Once the need for a new standard
has been identified, OSHA Advisory Committees,
which include representatives of management, labor,
and state agencies, develop recommendations.
In the very early stages of the process, OSHA
may request additional information needed for the
development of a standard by publishing an “Advance
Notice of Proposed Rulemaking” in the Federal
Register, a daily record of federal business. When a
first draft of the proposed regulations has been
completed, a “Notice of Proposed Rulemaking” must
appear in the Federal Register. Interested parties must
then have at least 30 days to comment on the way
proposed regulations will impact them. Following this
comment period, the final regulations are published in
the Federal Register, and incorporated into the Code
of Federal Regulations, a permanent record of
government regulations organized by subject.
Those who feel they will be adversely affected
by a standard may request a judicial review.
Employers who cannot meet the standard, or believe
an exception should be made in their cases because
their facilities or methods are “at least as effective,”
can request a temporary or permanent variance.
When new or particularly hazardous
conditions warrant, OSHA may develop emergency
standards, which take effect immediately. Once these
standards have been published in the Federal
Register, they are also subject to comment and review
before they are published as permanent standards.
Enforcement and Interpretation
Every establishment covered by the Occupa-
tional Health and Safety Act is subject to inspection by
OSHA compliance safety and health officers. Inspec-
tions are generally conducted without advance notice,
though OSHA is required to obtain a warrant if an
employer does not consent. OSHA gives highest
priority to workplaces:
• Where there is imminent danger of death or serious
physical harm
• Where fatal accidents, or accidents that hospitalized
more than five employees, have occurred
• When employees complain of alleged violations and
request an inspection
• When specific industries, occupations, or materials
Table 1. Possible Fines for OSHA Violations.
are associated with high rates of illness or injury
If OSHA discovers violations during an inspec-
tion, the employer will receive a citation, which details
the violation and includes information about penalties
and a schedule for compliance. Penalties may depend
on the seriousness of the violation, knowledge of the
violation, and a show of cooperation or good faith.
Serious penalties are also possible for repeat viola-
tions and failure to correct previous violations. Em-
ployers may want to schedule an informal meeting
with OSHA’s area director, who is authorized to enter
into settlement agreements that revise citations and
penalties.
The employer may also contest both a citation
and associated penalties within 15 days. The written
Notice of Contest will be evaluated by the Occupa-
tional Safety and Health Review Commission. Unfa-
vorable decisions can be appealed at this level and to
the U.S. Court of Appeals.
Painting contractors are considered part of the
construction industry for OSHA record-keeping
purposes. These businesses are most frequently cited
for failure to comply with the Lead Standard. They are
also frequently cited for respiratory protection, scaf-
folding (i.e., general requirements, manually propelled
ladder stands and scaffolds, and training), hazard
communication, and fall protection.
Consultation Assistance
OSHA provides a Consultation Service that
can help employers evaluate and improve their
compliance. The service was developed with small
employers in mind. Although the program is funded by
433
OSHA, it is entirely voluntary. No penalties are issued,
and OSHA enforcement compliance officers do not
see the results.
State officials or university staff often operate
the Consultation Service. They may point out weak-
nesses in an employer’s health and safety program
and provide the training and technical assistance
needed to resolve any problems. Firms that participate
in the program receive a limited one-year exemption
from OSHA inspection.
OSHA’s Voluntary Protection Programs
encourage employers to take their health and safety
programs beyond the letter of the law and provide
recognition for those who accept the challenge. The
Star, Merit, and Demonstration Programs are coopera-
tive programs, and participants are volunteers. These
firms also receive limited exemptions from inspection.
Local OSHA offices can also provide publica-
tions, speakers, audiovisual materials, and technical
advice. OSHA provides funds to nonprofit organiza-
tions to conduct workplace training and education. A
number of private firms and universities also offer
OSHA compliance training.
Components of OSHA Compliance
Company safety and health programs should
be designed to be used in conjunction with the current
copy of the OSHA Construction Industry Standards 29
CFR 1926, and the General Industry Standards 29
CFR 1910. OSHA states in 29 CFR 1926.20 General
Safety and Health Provisions: “It shall be the responsi-
bility of the employer to initiate and maintain such
programs as may be necessary to comply with this
part” (part refers to all of 29 CFR 1926).
The purpose of an OSHA Compliance Pro-
gram is to establish and maintain policies, programs,
and procedures that are necessary to comply with all
applicable OSHA standards, and to establish and
maintain an effective program to prevent accidents,
injuries, and illnesses.
The components of an OSHA Compliance
Program should include:
• Policy statement establishing goals and commitment
of management and the means for communicating
these to all employees
• Delegation of responsibilities for implementing the
program
• Methods for identifying hazards and hazardous
activities and for controlling them
• Commitment to ongoing training and education of all
supervisors and employees on all aspects of job safety
and health
• Proper reporting, record-keeping, and investigation of
all accidents, injuries, and illnesses
• Methods and procedures for complying with specific
OSHA standards
• Periodic review of the program with revisions made
as necessary
Figure 7. Workers may be required to wear hearing
protection under OSHA’s Occupational Noise Exposure
Standard.
Organization and Hierarchy of OSHA Standards
The OSHA General Industry Standards 29
CFR 1910 contains several standards applicable to
the protective coatings industry. When a construction
industry standard (29 CFR 1926) is not applicable or is
non-existent, the General Industry Standard (29 CFR
1910) Protective Coatings may be enforced. Some
common aspects of the protective coatings industry
434
and their related General Industry standards include
the following:
• Abrasive Blasting: No specific standard applies to
blasting in the field, but many aspects of blasting
operations fall under other applicable standards.
• Noise/Hearing Conservation: Noise protection
should be provided, and a Hearing Conservation
Program should be in place and be in compliance with
OSHA standard 29 CFR 1910.95, Occupational Noise
Exposure.
• Respiratory Protection: The selection, issue, use,
inspection, cleaning, storage, and repair of respirators
should comply with the OSHA Respiratory Protection
Standard, 29 CFR 1926.103. See section III F for more
information on choosing respirators.
• Confined Spaces: Practices and procedures used to
protect employees from the hazards of entry into
permit required confined spaces should comply with
OSHA Standard, 1910.146, Permit-Required Confined
Spaces.
Figure 8. In order to test the level of air contaminants, a
vacuum pump on the worker’s belt is used to pull air
through a specialized filter placed in the worker’s
breathing zone.
Construction Industry Standard Relating to
Industrial Protective Coating Operations
The Construction Industry Standards, 29 CFR
1926, contain many standards that apply to industrial
protective coating operations. Some of the common
standards that apply to the construction industry
include:
• Hand Tools and Power and Pneumatic Tools: All
hand, power, and pneumatic tools should be equipped,
inspected, guarded, used, and maintained according
to the manufacturer’s specifications and limitations
and OSHA standards 29 CFR 1926.300-305, Tools–
Hand and Power.
• Compressed Air: There is no existing OSHA stan-
dard for compressed air. However, there are standards
set by the American Society of Mechanical Engineers
(ASME).
• Electrical: All electrical systems and equipment
should be designed and installed according to OSHA
standards 29 CFR 1926.402-408, Installation Safety
Requirements, and the most current edition of NFPA
70, National Electric Code. All employees performing
work on electrical equipment or systems should
comply with the work practices in OSHA standards 29
CFR 1926.416-417, Safety-Related Work Practices.
• Eye and Face: Eye and face protection should be
provided when machines or operations present
potential eye or face injury from physical and chemical
hazards as required by OSHA Standard 29 CFR
1926.102, Eye and Face Protection. Eye and face
protection equipment required by OSHA should meet
the requirements specified in American National
Standards Institute Z87.1, Practice for Occupational
and Educational Eye and Face Protection.
• Fire Protection/Flammable, Combustible Liquids:
Fire protection should be developed for all company
activities according to OSHA standard 29 CFR
1926.150, Fire Protection. This should include provid-
ing, maintaining, inspecting, and testing fire suppres-
sion systems and portable fire extinguishers, as
required by this OSHA standard. The fire prevention
requirements, specified in OSHA standard 29 CFR
1926.151, Fire Prevention, should be implemented for
all jobs.
The storage, handling, use, and fire protection
requirements for flammable and combustible liquids
and their containers should be in compliance with
OSHA standard 29 CFR 1926.152, Flammable and
Combustible Liquids.
• Exposure to Gases, Vapors, Dusts, Mists, and
Fumes: Employee inhalation, ingestion, skin absorp-
tion, or contact with any material or substance at a
concentration above the permissible exposure limit
(PEL) specified in OSHA standard 29 CFR 1926.55,
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Gases, Vapors, Fumes, Dusts, and Mists is prohibited.
Generally, OSHA requires employers to
minimize employee exposure to air contaminants as
much as possible through the use of engineering
controls such as enclosure or confinement of an
operation, ventilation, or substitution of less toxic
materials. Only when acceptable levels of exposure
cannot be achieved through these approaches (as is
often the case in coating operations) may employers
use respiratory protective devices to comply with these
standards.
• Housekeeping: During the workday, work areas,
passageways, and stairs in and around buildings or
other structures must be kept clear of debris according
to OSHA Standard 1926.25, Housekeeping.
• Ladders and Scaffolding: Stairways and ladders
must be designed, constructed, and used according to
the manufacturers’ specifications and limitations and
OSHA standards CFR 1926.1050 through 29 CFR
1926. 1060. Job-made ladders must conform to the
design and construction specifications of these OSHA
standards. The design, construction, load-bearing
capabilities, platform guarding, and use of all scaffold-
ing must comply with OSHA standard, 29 CFR
1926.450-454, Scaffolding.
• Personal Protective Equipment for head, foot,
and body: Hard hats must be used where there is a
possible danger of head injury from impact, from
falling objects, or from electrical burns as required by
OSHA standard 29 CFR 1926.100, Head Protection.
Helmets and hardhats for the protection of employees
against impact and penetration of falling and flying
objects should meet the specification contained in
American National Standards Institute, Z89.1, Safety
Requirements for Industrial Head Protection. Helmets
for the head protection of employee exposed to high
voltage electrical shock and burns should meet the
specifications contained in American National Stan-
dards Institute Z89.
Where the potential for serious foot injury
exists, safety-toe footwear for employees should be
required and meet the requirements specified in
American National Standard for Personnel Protection–
Protective Footwear, Z41. Employees working with
chemicals or materials that can cause damage to the
skin or that can be absorbed should be provided
Table 2. Task-Related Triggers Under the Construction Industry Lead Standard.
appropriate protective clothing.
The selection, issue, use, inspection, clean-
ing, storage, and repair of respirators must comply
with the OSHA Respiratory Protection Standard, 29
CFR 1926.103. See section III F for more information
on choosing respirators.
Standards for Lead and Lead Removal
The Construction Industry Lead Standard,
1926.62 provides the practices and procedures for
protecting employees exposed to lead on the job. All
construction work excluded from coverage in the
General Industry Standard for Lead by 29 CFR
1910.1025(a)(2) is covered by this standard. Con-
struction work is defined as work for construction,
alteration and/or repair, including painting and decorat-
ing. Lead paint removal and maintenance activities
would be covered by the CFR 1926.62, Lead Stan-
dard. All other non-construction work is covered by the
General Industry Standard 1910.1025. Protective
measures required under the Construction Industry
Lead Standard are shown in Table 2.
Choosing Respiratory Protection Devices
It is likely that workers will be required to wear
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some type of respiratory protection during most
coating and surface preparation operations, particu-
larly when removing lead paint using techniques such
as powered hand tools and vacuum blasting, due to
the very low levels of exposure required to trigger
mandatory use (5 mg/m3). In a containment structure
in which abrasive blasting is occurring, workers will
always be required to wear respiratory protective
equipment, even if a well designed ventilation system
is being used. It is also likely that most support
personnel may be required to wear respirators in order
to meet the permissible exposure limit. In general
there are two basic types of respirators: air-purifying
respirators and supplied-air respirators.
Air-purifying respirators remove particulates
from the air in the worker’s breathing zone by filtering
it prior to the worker inhaling it. Air-purifying equipment
has the advantage of being lighter and less restrictive
as well as more economical than supplied-air
respirators.
Supplied-air respirators supply breathing air
from outside the work environment. Supplied-air
respirators protect workers from simultaneous expo-
sure to multiple contaminants, which is not uncommon
in coating operations. High dust levels associated with
many surface preparation techniques may quickly
overload the filtering systems on which air-purifying
respirators are based, and air-purifying equipment
may not be adequate to protect workers from high
lead levels associated with containment systems.
Protection Factors. Various groups have established
protection factors for respirators, including NIOSH,
OSHA, ANSI, and others. In fact, there is quite a
controversy over the level of protection afforded by
different categories of respirators. In general, protec-
tion factor describes a degree of protection a given
respirator will provide, versus some airborne concen-
tration of contaminant outside the respirator. For
instance, for the half-mask respirator equipped with
HEPA filtration cartridge, a protection factor of 10 is
assigned for lead. This means that the respirator can
be worn in an atmosphere up to 10 times the PEL and
still protect the worker so that the concentration of
lead inside the mask is below the PEL. Assuming a
PEL of 50 mg/m3, this respirator can then be safely
worn when airborne concentrations are up to 500
mg/m3. Similarly, a protection factor of 50 is assigned
for full-face respirators.
Figure 9. Air purifying respirators filter contaminants
from the air workers breathe.
Powered air-purifying respirators (PAPR)
highlight a variation on assigned protection factors.
For lead, NIOSH has taken a very conservative
posture and established a protection factor of only 50
for PAPRs, while OSHA and others have established
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protection factors of up to 1000.
Figure 10. Supplied air respirators deliver breathing air
from outside the work environment.
Similar problems occur when looking at the
standard respirator for blasting, the abrasive blasting
hood. NIOSH’s current position is to assign a protec-
tion factor of only 25. This same protection factor was
incorporated into respirator protection factors assigned
under the OSHA Construction Industry Lead Standard.
However, since 1995 OSHA has issued letters of
interpretation permitting specific models and makes of
abrasive blasting helmets to be assigned a protection
factor of 1,000. The protection factor assigned to
these helmets is based upon using the helmets in
accordance with the manufacturer’s instruction manual
and setting up the air-supplied system identical to the
way the system was certified by NIOSH. It should be
noted that these letters of interpretation only apply to
enforcement of the OSHA Construction Industry Lead
Standard. Other OSHA standards may assign different
protection factors to the same respirator. For example,
the OSHA Cadmium Standard 29 CFR 1926.1127
assigns a protection factor of 25 to abrasive blasting
helmets, which is the same as that recommended by
NIOSH, while the OSHA Arsenic Standard 29 CFR
1926.1118 assigns a protection factor of 2,000.
When OSHA published its recent revision to
the Respiratory Protection Standard 29 CFR
1926.103, rulemaking to standardize protection factors
was deferred until a later date. However, OSHA has
provided employers with guidance in choosing a
protection factor in the compliance directive for the
Respiratory Protection Standard CPL 2-0.120. In this
compliance directive, OSHA states that it will refer to
protection factors assigned by NIOSH, except in
cases where protection factors have been published
in substance-specific standards (e.g., cadmium) or
are addressed by OSHA in separate letters of
interpretation.
Breathing Air Requirements. With any of the
supplied-air respirators, including abrasive blast
hoods, it is essential that Grade D breathing air reach
the respirator. ANSI Standard Z 86.1/Compressed Gas
Association commodity specification G-7.1 for Grade
D Air requires oxygen levels of 19.5–23.5%, no more
than 5 mg/m3 condensed hydrocarbon contamination,
no more than 10 ppm carbon monoxide, no pro-
nounced odor, and a maximum of 1,000 ppm carbon
dioxide. Controls must be installed on compressors to
achieve and verify compliance with these require-
ments, or special-built, dedicated breathing air com-
pressors must be used. The control/filter systems of
existing oil lubricated compressors must be equipped
with a constant monitor for carbon monoxide or a
heat-rise alarm with frequent measurement of in-line
carbon monoxide. In addition, periodic samples from
the air stream should be drawn, bottled, and sent to a
laboratory to verify that each parameter of Grade D
breathing air has been met.
Implementation of Safety and Health
Problems
Establishing Worker Safety and Health Programs
A worker safety and health program should
first establish and then maintain those policies,
programs, and procedures necessary to comply with
all applicable OSHA standards, while also effectively
preventing accidents, injuries, and illnesses. After
identifying the program components, it is important to
dedicate the time to sit down with all company
managers and supervisors to review the program and
set specified goals for implementing its requirements.
Have managers and supervisors do the same for all
the employees. Encourage participation. Be honest
and sincere. Continually ask for feedback and ways
for improving the program. Let everyone know they
will be consistently held accountable for fulfilling their
responsibilities under the program. Let good
performers know that they are doing a good job. At the
same time, do not let poor or mediocre performance
go unnoticed.
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Monitor and maintain records relating to
accidents, injuries, illnesses, medical examinations,
training, fit testing, and exposure monitoring for the life
of the company. Analyze the firm’s total workers
compensation costs over the years. Compare accident
rates and evaluate changes in employee attitudes and
work quality. Seek assistance from employees to get
feedback on the success of the program.
Owner Evaluation and Monitoring of Contractor
Programs
A representative of each facility owner should
evaluate and monitor all contractor health and safety
and OSHA compliance programs. These programs
should be submitted, approved, and monitored by a
qualified individual, such as a certified safety profes-
sional (CSP) or certified industrial hygienist (CIH). The
program evaluations should be completed before any
work begins. Monitoring should be conducted through
job site visits and review of daily work logs.
OSHA Standard 1910.119 Process Safety
Management of Highly Hazardous Chemicals contains
the specific requirements and responsibilities for
owner and contractor safety and health programs.
This standard states that the owner is responsible for
obtaining and evaluating information regarding con-
tractor safety performance and programs.
A good example of a safety program that each
contractor in the coatings industry should have is
OSHA 1910.146 Permit-Required Confined Spaces.
Under this standard, the contractor must develop a
written permit space entry program that complies with
the requirements of the standard. This program must
be reviewed by the owner to verify that contractor
safety procedures and practices are adequate and are
being followed.
Maintaining a site injury and illness log, OSHA
Injury and Illness Records Form 300, is another
method employers must use to track work activities
involving contract employees working on or adjacent
to covered processes. Injury and illness logs of both
the employer’s employees and contract employees
allow an employer to have full knowledge of process
injury and illness experience. This log will also contain
information that will be of use to those auditing pro-
cess safety management compliance and those
involved in incident investigations.
It is very important for owners to write OSHA
compliance requirements into their contracts and
specifications. This will help ensure that the contrac-
tors are complying with the applicable OSHA
standards.

About the Authors

Daniel P. Adley, CIH/CSP

Daniel P. Adley is vice president of operations for KTA-
Tator, Inc. Mr. Adley has a BA in chemistry and an MS
in industrial hygiene. He is a certified industrial hygien-
ist and certified safety professional with over 25 years
of diversified safety and health consulting experience.
Mr. Adley is an active member of the SSPC, where he
chairs Group Committee C.5 on environmental, health,
and safety compliance and was the recipient of the
1994 Education Award and 1999 Technical Achieve-
ment Award. Mr. Adley was the technical editor of the
first and second editions of the Industrial Lead Paint
Removal Handbook (Volume 1). He is co-author of
Volume 2 of the Handbook: Project Design. He also
served as a contributing safety editor for the Journal of
Protective Coatings and Linings.

Stanford T. Liang, CIH

Stanford T. Liang is a certified industrial hygienist
(CIH) with the EH&S group of KTA-Tator, Inc. Mr.
Liang is also a certified environmental trainer and
OSHA construction outreach program trainer. He has
extensive experience performing industrial hygiene air
monitoring, conducting job safety analysis, developing
safety programs (including confined space entry,
lockout/tagout, and emergency response plans), and
presenting safety training and OSHA compliance
audits. His experience with KTA has included updating
a comprehensive safety and health program for 12
PDCA-member painting firms. Mr. Liang previously
served as an assistant safety officer for the U.S. Navy.
He is a member of the National Environmental
Training Association, American Industrial Hygiene
Association, and the American Academy of Industrial
Hygiene.

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