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
 

Director banned for 5 years for health and safety failings

A Worcestershire company and its managing director was fined a total of £87,000 following a series of health and safety failures. These health and safety failures saw workers exposed to a variety of risks, including: exposure to lead, falls from height and being crushed by falling objects.

The managing director of the Company was criticised by the HSE for “flagrant lack of attention” to the safety of employees at the Stratford-upon-Avon based company.

Following a tip-off from a concerned employee, the HSE carried out an investigation that resulted in 4 Prohibition and 4 Improvement Notices being issued. Workers at the plant were found to be spray-painting fuel tanks without appropriate safety equipment, even though the paint contained toxic lead chromate. Specialist HSE inspectors took air, blood and urine samples to assess the workers’ exposure to lead, and five of them were found to have higher levels than the UK average.

The workers were required to work from beneath half-tonne vessels that they were painting, with nothing to prevent them from being crushed if the lifting equipment, which had not been maintained or checked properly, had failed.

To paint the tops of the tanks, which were two metres above the concrete floor, the workers simply stood on them, with no equipment to stop them from falling. The managing director ignored a Prohibition Notice in relation to this unsafe practice and continued to instruct his employees to work on top of the tanks.

The Company pleaded guilty to the following breaches of health and safety legislation:

Regulation 6(1)(c) of the Control of Lead at Work Regulations 2002
Regulation 4(1) of the Work at Height Regulations (WAHR) 2005
Regulation 8(1)(c) of Lifting Operation Lifting Equipment Regulations 1998
Regulation 21(1) of the Workplace (Health, Safety and Welfare) Regulations 1992
Regulation 13(2) of the Management of Health and Safety at Work Regulations 1999

The Company was also found guilty of contravening Prohibition Notices on 3 occasions. As a result, it was fined a total of £70,000 and ordered to pay £27,507 in costs. It is understood that the Company is now in administration.

The managing director was fined £17,000 with £9169 in costs after pleading guilty to breaching reg.4(1) of the WAHR 2005 and s33(1)(g) of the HSWA 1974 and he was banned from directing any company for five years under the Company Directors Disqualification Act 1986.

An HSE inspector commented:

Companies and their managing directors have a legal responsibility to protect their employees. No one should be expected to work in the conditions found at (the company), and it is quite right that an employee contacted HSE to complain. Failure to properly manage health and safety can have catastrophic results.

If you need help to meet your Health & Safety obligation, contact us.