Spray Painting Policy
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1 Spray Painting Policy Form: Revision: MFG-20 C Revision Date:
2 Spray Painting Policy Granite Falls, MN New Ulm, MN Watertown, SD Prentice, WI a.) Configuring, testing and maintaining the paint booth and paint zones. b.) Operating and use of the paint equipment within the paint booth and paint zones. c.) Storage of paint supplies. This policy has been assembled because of the conflicting feedback and information that has been received from numerous government representatives. RITALKA Inc. is stead fast in its desire to provide a safe and productive work area for its employees. As part of this desire it is important to note that RITALKA Inc. management requested a review from OSHA, with the spray painting operation as one of the specific areas of review. This consultation produced a positive review, with all issues being resolved shortly after receipt of the findings. It is only after our own review of the standards that we feel a written policy is in our best interest. Although the understanding of the standards as applied to spray booths seems to be reasonably straight forward, this is not the case when applying the standards to a spray area. It is important to note that each facility is equipped with a sprinkler system throughout the facility, and the entire facility is designated NO SMOKING. This policy, to the best effort of management of RITALKA Inc., complies with the intent of the OSHA and NFPA spray paint standards. The driving standards are understood to be as follows: a.) CFR 29, Standard b.) OSHA , Ventilation, March 2000 Edition c.) OSHA , Flammable and Combustible Liquids, March 2000 Edition d.) OSHA , Spray Finishing Using Flammable and Combustible Materials, March 2000 Edition e.) OSHA , Electrical Standards for Hazardous Locations, March 2000 Edition f.) NFPA 33, Spray Application Using Flammable or Combustible Materials, 1995 Edition
3 Spray Painting at all locations occurs in a designated and approved paint booth manufactured for the purpose and manner of which it is used. Touch-up paint process is a reality of the industry and occurs under controlled parameters when outside of the designated paint booths. Much of the touch-up is a cup and brush task. Spray painting that occurs outside of the booth setting is further elaborated on below. Procedures for configuration, operation, and maintenance of each area can be provided upon request. Primary Paint Booths Spray paint is largely completed in the main designated paint booths located at each facility. Each paint booth is a purchased structure and is understood to be compliant with respect to installation, ventilation/air flow, wall structure, wiring, and filtration. Details about each paint booth can be provided upon request by authorized inquirers (in general: appropriate government/regulatory bodies, or appropriate outside auditors). Secondary Paint Booths In some locations there is a secondary paint booth, which historically is the smaller of the two. Where present, they meet and apply to the same standards as stated for the Primary Paint Booths. Paint Storage and Mixing Paint storage is limited to approved storage locations in accordance with OSHA/NFPA standards and proximity to the paint booth(s). Mixing of paint is often a manual process completed by company trained personnel in the event that paint requires mixing or adding agents for curing, thinning, specifications, etc. Importance of OSHA Compliance In not every case throughout the year is spray painting completed in a formal paint booth due to size and capacity reasons. In the event that spray painting occurs in volume outside of a ventilated paint booth precautions are taken to minimize exposure and protect the health of our work force. When this scenario can be avoided it is. Paint booths are the first choice for spray painting in every instance. Remaining Facility No specific policy is presented for the remaining facility other than general safety when spraying paint. Welding, grinding and other heat generating tasks in the general area shall be terminated during and immediately after spraying. Proper masks shall be used during the spray application. The remaining facility falls under the NFPA 33, section 1-1.4, which states: This standard shall not apply to the use of small portable spraying equipment or aerosol products that are not used repeatedly in the same location. Outside of Facility No specific policy is presented for the outside area of the facility other than general safety when spraying paint. Welding, grinding and other heat generating tasks in the general area shall be
4 terminated during and immediately after spraying. Proper masks shall be used during the spray application. The remaining facility falls under the NFPA 33, section 1-1.3, which states: This standard shall not apply to spray application processes or operations that are conducted outdoors. Configuration, Maintenance and Operation Air Makeup Systems The air make-up system is located in an appropriate location so to avoid re-recirculation or fire hazard. Booth Configuration/Installation: Current installation, as well as lighting, wiring, ducting, filtration, and overall construction of the spray booth are integral to the purchased booth(s) and have been inspected by several government agencies and found to be compliant. A 18 inch outside perimeter of the paint booth shall be cleared of any items, including paint storage, allowing for periodic inspection and cleaning. Nothing is to be stored on the roof of the spray booth. Secondary Booth Configuration/Installation: The current installation utilizes an existing room within the main building structure. Updated wiring, lighting, ducting and air filtration, were considered during the construction of the spray booth. An 18 inch outside perimeter of the paint booth shall be cleared of any items, including paint storage, allowing for periodic inspection and cleaning. Nothing is to be stored on the roof of the spray booth. Primary Booth Operation: Where applicable: The ventilation system shall be operated during all spraying operations. When the inside temperature falls below 65 o F, the air make-up system will be operated when the spray booth ventilation system is on. When the air make system is not operated, at least one of the large overhead doors will remain open during spraying operations. Portable lights within the paint booth are not allowed at any time. Secondary Booth Operation: Where applicable: The ventilation system shall be operated during all spraying operations. When the inside temperature falls below 65 o F, the air make up system will be operated when the spray booth ventilation system is on. When the air make system is not operated, at least one of the large overhead doors will remain open during spraying operations. Portable lights within the paint booth are not allowed at any time. Maintenance: Brief daily overview of all equipment and systems shall be performed by the painting staff, with any areas of concern being resolved or brought to the attention of management. The spray booth, spray equipment, and respirator systems will be thoroughly inspected and serviced on a quarterly basis. Inspection and cleaning will be completed utilizing the check list form located in the appendix of this document.
5 Filters that have been replaced shall be handled as follows: Waste generated from the paint booth maintenance and cleaning process will be disposed of in accordance with local landfill or waste depository institutions. Empty paint containers and solvent containers shall be handled as follows: Remaining paint film is generally allowed to air dry and be disposed of with solid waste sent to the landfill. In instances that this may not be acceptable waste will be disposed of in accordance with local landfill or waste depository institutions.
6 Maintenance Schedule for Paint Operations Spray Booth inspection : Inside Walls To be checked BIWEEKLY Date Residue buildup (check ) Low Med Hi Corrective action taken Outside Walls (Cleaning) To be checked ANNUALLY Date Residue buildup (check ) Low Med Hi Corrective action taken Fan/ducts To be checked MONTHLY Date Residue buildup (check ) Low Med Hi Louvers Correctly Operating on Wall Fans yes Corrective action taken Paint suits To be checked WEEKLY Date Inspect for tears/holes. Corrective action taken Waste Refer to Waste Inspection Manual for proper procedures. Respirator Refer to the respirator policy for proper inspection and procedures.
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