Monthly Archives: December 2012

Spray Finishing (29CFR1910.107)

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Twitt

If you use products that are coated with aerated solid powders, then you need to be sure you are in compliance with OSHA Standard 1910.107, which governs spray finishing using flammable and combustible materials. This standard discusses the spraying area, including the spray booth utilized, the venting, the parts uses, access doors, maintenance, cleaning, and signage, among other things. OSHA very clearly states exactly what is and is not acceptable leaving very little gray area for you to work with.

A spray booth requires a system for minimizing dust or residues entering exhaust ducts and permitting the recovery of overspray finishing materials. This can be most easily accomplished with a water washing system. In lieu of a water washing system, you must have either: distribution of baffle plates to promote an even flow of air through the booth or cause the deposit of overspray before it enters the exhaust duct, overspray dry filters to minimize dusts, overspray dry filters to minimize dusts or residues entering exhaust ducts, overspray dry filter rolls designed to minimize dusts or residues entering exhaust ducts, or, where dry powders are being sprayed, powder collection systems so arranged in the exhaust to capture oversprayed materials. Further, the ventilation system you use must meet similarly regulated specifications, including all requirements of NFPA 91-1961 and OSHA 1926.57.

The most common issue with this Standard, however, relates to proper signage. Required signs include: no smoking signs, safe distance signs, and other applicable warning signs, based upon your spray finishing operation. If you have not recently, it is a good idea to ensure that you have adequate signage, and that signs you have placed have not been inadvertently removed.

This has been a very high level overview of the Spray Finishing requirements set forth by OSHA. If you have not recently audited your operation, or have any questions about whether or not you are in compliance, please contact us and we can answer your questions or schedule an audit. If you have anything to add to the conversation, please leave a comment.

Hearing Conservation (29CFR1910.95)

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Twitt

Understanding OSHA’s policy on occupational noise exposure and hearing conservation is essential to anyone who wants to run their business safely. Standard 1910.95 lays out exactly what OSHA expects of an employer in relation to testing, monitoring, employee notification, observation, evaluation, auditing, and required controls. Following this standard will ensure that you have created a safe work environment for your employees, and that you have an OSHA friendly work environment, in case you are ever audited.

OSHA created a very useful table (1910.95 (a) figure G-9) which can be used to determine if your work zone has any areas which require your attention. If you do have any high noise areas, you must take immediate action to either reduce the noise exposure, limit the length of exposure through various controls, or require proper personal protective equipment be worn at all times. Failure to act in this manner can lead to significant hearing problems for your staff and hefty penalties for you.

But your responsibility as the employer does not end there. OSHA requires that you properly monitor any high noise areas, regularly checking to make sure that your safety measures are adequately protecting your employees from harm, and that all affected employees are enrolled in your hearing conservation program. You must also routinely test your monitoring equipment to make sure it is acting effectively. Additionally, you must offer audiometric testing to all employees who work in the affected areas, to ensure that the methods in place are properly protecting your employees. They are required to be tested at least annually, and any significant threshold shifts must be reported and followed up on, to ensure employee safety.

If you have not had your company properly evaluated recently, it might be a good idea to consider bringing in professionals to ensure that your work space is up to code, and that your employees are safe from excessive noise exposure. Also make sure you properly sign any high noise areas, to both notify employees who are not usually working in this area, and to remind employees who do, to wear their protective equipment. Please leave a comment or contact us if you have any questions about this standard.

Machine Guarding (29CFR1910.212)

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Twitt

OSHA standard 1910.212 discusses machinery and machine guarding. In this standard, OSHA lays out the requirement for the guards which must be in place to protect employees from potential harm due to unsafe machinery. OSHA lays out how to affix said guards to the machine, and how to act if a guard can not be affixed to the machine directly. Finally, OSHA lists specific types of machines which are likely to need guarding, and examples of how to guard several of them.

“One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.” (1910.212 (a)(1)) This is OSHA specifically laying out exactly what kinds of dangers must be guarded against, and where they must be protected. So, if your company uses any machines like these, it is imperative that you properly guard them.

“Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible.” (1910.212(a)(2)) This is OSHA being very specific about how to implement your machine guards. If there is any conceivable way to attach the guards directly to the machine, then do it. And if you are unsure, then have a professional take a look, to make sure that you are in compliance.

OSHA then goes on to specifically list several machine risks and what, specifically, needs to be done to ensure their safety. If you have not recently had a third party safety audit, it might be time to consider one. An auditor will be able to see if you are up to code on your guards. You will also need to have proper signage around dangerous machines. If you have not already implemented your signage, check out our extensive collection of signs, to find one that fits your needs. If you have any questions about your machine guards, please contact us or leave a comment.