Safety and Environmental Precautions

The 1990 Amendments to the Clean Air Act (CAAA) and the promulgation of several Constructional Industry Standards by the Occupational Safety and Health Act administered through OSHA have had a major impact on the blasting and coating industries. Several of these regulatory initiatives are of special importance to industries that use paint and other organic coatings.

Volatile Organic Compounds (VOCs). Regulatory activity required under the 1990 CAAA continues to dominate the protective coatings industry. Many items are under negotiation with the Joint Industry, Government and Regulatory Negotiation Committee. Several items in the forefront of development and negotiation include

• A national volatile organic compounds rule on architectural and industrial maintenance (AIM) coating applied to stationary sources is being developed. Under a tentative agreement, industrial maintenance coating would be restricted to a maximum VOC level of 350 g/L as applied.

• Tentative VOC levels have also been established for around 50 other categories and subcategories of coating.

• The Regulatory Negotiation Committee has also tentatively agreed to reduce current average VOC emissions (CAVE), which are based on total corporate product line levels compared to 1990 levels. Reduction is scheduled for 25% by 1996, 35% by 2000, and 45% by 2003.

• The CAAA directs the EPA to develop control technique guidelines (CTGs) on shipbuilding and shipyard repair coating operations.

• Under the National Emission Standards for Hazardous Air Pollutants (NESHAP), the EPA under the CAAA must create a national standard regarding the control and emissions of 189 hazardous air pollutants.

• The CAAA mandates a review of the current ozone standard by the EPA.

EPA has formally revised its Method 24 for measuring VOCs in coatings to make it applicable for use with multicomponent coatings. The method is now consistent with ASTM D 2369 and ASTM D 3960.

OSHA Cadmium Exposure Regulations. In September 1992, OSHA published a Cadmium Exposure in Construction Standard (29 CFR 1926.63) to address occupational exposure to cadmium during construction activities.

In 1993, OSHA published its final rule on permit-required confined space entry (29 CFR 1910.146). It established strict provisions for facility owner and contractors involved in confined space operations. This standard was printed in the Federal Register in January 1993 and became effective 15 April 1993.

OSHA Lead Exposure Regulations. OSHA published its Interim Final Rule on Lead Exposure in Construction (29 CFR 1926.62) in May 1993 for the protection of construction workers from overexposure of airborne lead. The Rule went into full effect in August 1993. The Rule lowers the permissible exposure limit (PEL) to 50 pg/m3, incorporates many provisions of the General Industry Standard, and establishes "trigger tasks" to establish presumed exposure levels.

Published Standards. All aspects of the OSHA and EPA VOC requirements cannot be covered within this article. The following provide greater detail:

• Interim Final Rule on Lead Exposure in Construction (29 CFR 1926.62)

• Confined space entry (29 CFR 1910.146)

• Rule on Cadmium Exposure in Construction (29 CFR 1926.63)

• The Clean Air Act Amendments of 1990

Individuals and organizations involved in industrial painting and coating should maintain contact with OSHA, EPA, and state and local regulatory agencies in order to keep abreast of current, revised, and pending regulations.

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