Spray Painting: Health and Safety

Introduction

Spray painting operations create the potential for employees (and others) to be exposed to substances that are hazardous to health.  These substances include: solvents (often refer to as or thinners); simple paint systems (which may contain lead) and two pack paint systems (such as epoxy paints and polyurethane paints).  Polyurethane systems involve the use of isocyanates (in the hardener) which are respiratory sensitizers and are strongly associated with occupational asthma.  Further to this, preparation of surfaces for painting may involve exposure to dusts generated from rubbing down and to filling materials, such as epoxy resins. 

This blog article does not deal with the fire and explosion risks associated with solvents or with the paint spraying operation.

COSHH - The Control of Substances Hazardous to Health

The prime piece of legislation applicable when considering the potential for exposure to hazardous substances is the Control of Substances Hazardous to Health Regulations 2002 (COSHH), as amended.  If lead based materials are being used, then consideration must be given to the provisions of the Control of Lead at Work Regulations 2002 (CLAW). 

Under COSHH, the employer is charged with the duty of preventing exposure to hazardous substances (where this is reasonably practicable) and for controlling exposure to prevent harm to employees (and others).  The employer must:

·         assess the health risk arising from the work done and decide what precautions are needed

·         implement appropriate measures to prevent or control the risk

·         ensure that control measures are used and the equipment is properly maintained and procedures observed

·         where appropriate, monitor exposure to hazardous substances and carry out appropriate health surveillance

·         inform, instruct and train employees as to the risks and of the precautions to be taken

·         make suitable arrangements for dealing with accidents, incidents and emergencies

There is an explicit duty on the employer to avoid the use of a hazardous substance by replacing it with another substance or process that either eliminates or reduces the risk to employees, so far as is reasonably practicable.  The Approved Code of Practice for the COSHH Regulations makes it clear that it is an employer’s overriding duty and first priority to consider how to prevent employees being exposed to substances hazardous to health.  Failure to tackle this duty is a failure to comply with a fundamental principle of the Regulations.  To achieve this, employers should consider:

·         changes to the method of work such that the operation giving rise to the exposure is no longer required (such as using a water based system in place of a solvent based system); or

·         modifications to the processes to eliminate the generation of a hazardous by-product or waste material; or

·         substitution of a hazardous substance with a non-hazardous substance that presents no risk to health

Where use of a hazardous substance cannot be eliminated, the employer must consider routes to reduce exposure to hazardous substances.  These should include:

·         using an alternative, safer substance (such as moving to a one pack isocyanate free system in place of a two pack polyurethane); or

·         using a different form of the same substances; or

·         using a different process

It should be noted that such changes may create new or different risks.  These risks should be considered as part of the risk assessment processes required under COSHH, the Management of Health and Safety at Work Regulations 1999 and the Dangerous Substances and Explosive Atmosphere Regulations 2002 or any other piece of relevant legislation.  It may not be appropriate to change to a slightly safer substance, health wise, if the fire risks are increased disproportionately.
 

Health hazards

Solvents/Thinners

Direct skin contact with organic solvents can cause defatting, irritation and even lead to dermatitis.  Commonly used solvents include xylene, acetone and methylethylketone (MEK). These solvents may be absorbed through unbroken skin and are also harmful by inhalation.  Once absorbed into the body they may cause systemic effects.   

Paints

The hazards associated with paints vary enormously and are often associated with the solvent, the hardener (such as isocyanates) or with the pigment system (such as lead), etc.

Lead

Lead can be absorbed into the body by inhalation and ingestion.  Typical symptoms of lead poisoning include headaches, tiredness, stomach pains, constipation and loss of weight.  Continued exposure may cause more serious problems such as nerve and brain damage.  In the case of pregnant workers, the developing foetus is especially vulnerable to the effects of lead, which may lead to impaired mental development.

Dusts

Prolonged exposure to dust can cause respiratory disorders and any dust of a substantial concentration is regarded as hazardous under COSHH, whether or not the substance of the dust is hazardous.  Some dusts will be more hazardous than the so called nuisance dusts above.  For example: if paint work if rubbed down as part of the preparation process, then if the original paint contained lead, the dust will also contain lead, but it will be present in a form that is more easily inhaled.

Isocyanates

Vapours containing isocyanates are highly irritating to the eyes and to the respiratory tract and may cause asthma.  Asthmatic attacks may occur immediately or may be delayed for up to 12 hours after exposure.  Symptoms of over exposure include: sore eyes; running nose; sore throat; coughing; wheezing; tight chest fever and breathlessness.  In many cases, complaints will (at first) clear up at weekends or during other breaks from work, but are likely to return on resumption of work.  Some people may become sensitised and even minute concentrations of isocyanates can lead to severe asthmatic attacks.  There are an estimated 1,500 to 3,000 new cases of occupational asthma each year and this rises to 7,000 cases a year if you include asthma made worse by work (work-related asthma).  There are thought to be at least 150 new cases of occupational asthma associated with paint spraying operations, although the figure may be higher and paint sprayers are considered to be 80 times more likely to develop work related asthma than the rest of the working population.
 

Control measures - to protect employees and other from harm

The best control measures are those that avoid exposure to hazardous substances, while others limit the amount of contact or attempt to mitigate the effects.

Elimination

If hazardous substances are not used, then employees cannot be exposed to them and so avoidance is the best solution.  Inferior to this is to user safer, rather than safe, substances.  If is essential that alternatives are sought to paint systems that contain or that utilise isocyanates.  Increasingly, lead free paints are now available and new water based paint systems have been developed.

Ventilation, extraction systems and spray booths

Ensure that hazardous substances are not used in confined spaces or areas of poor ventilation.  Where possible, use them in areas of good natural ventilation, such as outdoors.  If natural or general ventilation is inadequate, then local exhaust ventilation may be required to remove hazardous fumes and vapours from the workplace.

Most spray painting operations take place inside a booth.  The booth needs to be designed to deal with the operations to be undertaken: it needs to be the right size and have suitable extraction for the materials being sprayed.  It must be designed such that the solvents and the overspray are captured and then ducted away and exhausted into a safe area. There have been cases of “home made” booths being used that were inadequate for the tasks (and so did not protect the sprayer) or which exhausted fumes into the workplace, causing ill health (from exposure to solvents and to isocyanates) to develop in others, including the receptionist in one case. 

All local exhaust ventilation systems must be tested and inspected, by a competent person, at least once in every fourteen month period.  They must also be maintained in working condition and should be checked, routinely, by the operatives.

Personal Protective Equipment

Despite the fact that personal protective equipment (PPE) is to be considered as the last resort, it will often have a role to play in protecting spray painting operatives.  Different types of PPE are available: skin protection (overalls, gloves, gauntlets); eye protection (glasses, goggles, face masks, etc) and respiratory protection (dust masks through to air fed respirators).  It is important that the appropriate PPE is provided and that risk assessments have been carried out to show that the PPE provided is appropriate and that it provides the right level of protection.

Welfare facilities

Decent washing facilities are necessary to remove hazardous substances from the skin.  These should include both hot and cold running water as well as suitable skin cleansers.  Suitable hand drying facilities should also be provided, such as paper towels.  The use of suitable conditioning creams after washing can help to counter the degreasing effects of the oil on the skin.  Skin must never be cleaned with solvents, etc.  So called “barrier creams” must not be relied on to protect the skin from exposure to solvents.  They can, however, be a useful extra protection and can make it easier to wash oils off of the skin after exposure.

Smoking, eating and drinking

Smoking is now prohibited in all workplaces.  Suitable welfare arrangements should be made so that there is no eating or drinking in areas where hazardous substances are present.  Employees should be discouraged from consuming food or from drinking in the work area as any contamination on their hands may easily be ingested.

Health surveillance

Heath surveillance will not protect employees from exposure to hazardous substance.  However, appropriate health surveillance will often allow for early identification of symptoms so that additional preventive measures can be taken at an early stage.  Where workers are exposed to solvents, the employer should carry out routine skin inspections as a precautionary measure.  Where workers are exposed to isocyanates, the employer should arrange for lung function testing to be carried out regularly.  The results of health surveillance must be recorded and records must be retained for 40 years.

Information, instruction and training

Employees must be made aware of the hazards associated with the substances to which they may be exposed and of the control measures to be used to protect their health.  Awareness can also be raised by obtaining and distributing suitable notices and leaflets, many of which are available from the HSE.

Spillages

Spillages should be cleaned up immediately, using suitable absorbent granules.  A suitable spillage response kit should be kept available on site.  Employees should be trained in the safe use of this spillage response kit and the disposal of the materials.

Active Monitoring

The use of control measures should be actively monitored by the employer.  It is not sufficient to put systems in place: they must be monitored and their effectiveness and use checked by managers and/or supervisors.

 

Summary

Occupational ill health may result from uncontrolled or inadequately controlled exposure to hazardous substances associated with paint spraying.  Isocyanates are one of the most hazardous substances used in paint spraying, leading to over 150 new cases of work related asthma each year.  A key to avoiding ill health is to avoid or control exposure to hazardous substances, including solvents, lead and isocyanates.  This may involve extraction and ventilation systems (such as spray booths), PPE, personal hygiene regimes, training and health surveillance.

Michael Ellerby

Director

LRB Consulting Limited

Michael@Lrbconsulting.co.uk

Telephone: 01509 550023
Website: www.LRBconsulting.co.uk
 

Let me sell you some time (and some Peace of Mind)

The most important things that I sell to other organisations are time and expertise.  People buy my skills, my experience and my expertise. They also buy Time and "Peace of Mind".

In some cases, I can help them by doing (most of) the work for them. Because of my skills and experience, it takes me less time to create a new Health and Safety Policy for a client than it would do for the client to write their own - months less time in some case. It takes me less time to do their fire risk assessment, their COSHH assessment, to complete a Health and Safety questionnaire for them, ... and so on.

Some businesses (or their owners, more accurately) can become bogged down by health and safety concerns that get in the way of them running their business. It is at this point (but preferably before it) that I can offer help to a business! So, if you don't know when you'll find time to do your risk assessments, finish the safety section of the tender documents, review Fire Safety, etc, then NOW might be a good time to talk to me. Don't worry about it. Instead: get me to do it for you and let me be your outsourced Health and Safety function.

What can I do for you that will release some time for you, allowing you to focus on making money by running your business? Can I help you achieve peace of mind?

Visit our Website

Social Networking and when not to Twitter

Like many people, I find that twitter is both amusing and (slightly) addictive. I do not intend to introduce Health and Safety as a reason for not Tweeting, but we should all consider the application of common-sense. There have been some lawsuits recently over the  inappropriate use of social media by some people.  It seems that the use of social networking is in need of some for moderation as one of the Tweets (better than twits) that I came across declared a time when one should not do it: http://bit.ly/KEdvW

I, for one, would rather that the control was exerted by the users, rather than imposed on us by some form of ineffective legislation. A few examples of other times it is (or may be) inadvisable to Tweet (send a Twitter message) are:  

• During an appraisal or annual review
• When climbing a ladder (probably not long before this features in risk assessments and method statements)
• When driving (I'm sure people do it!)
• After a row
• After drinking (too much)
• When you don't want to look like a geek In the swimming pool
• In the bath (sadly) http://www.austriantimes.at/index.php?id=14023
• and many more ...

All that said - twitter is still fun, if used properly.

Coming soon, potentially to a company near you

Have you heard a rumour of another potential charge on a business?

This is more than rumour: The HSE (Health and Safety Executive) will charge companies if they visit them if that visit results in some form of enforcement action. This will start from 01 October 2012 and it is not something that the HSE will have discretion about; it will be mandatory and could affect any company, including those reading this article.  Gordon MacDonald (the HSE's programme director), said:

"The Government has agreed that it is right that those who break the law should pay their fair share of the costs to put things right - and not the public purse.  These proposals provide a further incentive for people to operate within the law, levelling the playing field between those who comply and those who don't. Compliant firms will not pay a penny in intervention fees."

So, how much might a company be charged by the HSE?

Cost recovery is almost certainly going to be at £124. The actual costs that will recovered by the HSE (when the Health and Safety (Fees) Regulations 2012 come into force) will be dependent on the complexity of the investigation that is required to follow all reasonable lines of enquiry, but some guideline figures have been offered:

•               Inspection with no action taken - No costs will be recovered

•               Inspection which results in a letter - Approximately £750

•               Inspection which results in Enforcement Notice - Approximately £1500

•               Investigations carried out by the HSE - Ranging from approximately £750 through to several thousands of pounds to, in extreme cases, tens of thousands of pounds

Looking for some simple steps to avoid such charges?

The obvious answer is to do the common-sense things and ensure that you are (and remain) compliant with the relevant Health and Safety legislation and this will help you to avoid attracting the unwanted attention of the HSE:

•               Keep your health and safety policy and associated procedures up to date.

•               Keep your risk assessments reviewed and up to date.

•               Ensure that you have adequate control over your contractors.

•               Take prompt action to prevent situations developing that may attract the interest of the HSE.

•               Ensure that you keep suitable records.

•               Keep your employee training records up to date.

Your actions may protect your employees, but it is your records that will protect your Company and provide you with peace of mind.

Michael Ellerby

Director, LRB Consulting Limited
Tel: 01509 550023 www.Lrbconsulting.co.uk