Metal Finishing Guide Book

2012 Organic Finishing Guidebook Issue

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Federal Agencies OSHA is concerned with employee health and safety. Familiarization with the following OSHA codes and the booth design and safety requirements that each governs is important. The relevant OSHA codes are OSHA 1910.107 Spray Finishing, OSHA 1910.94 Ventilation and OSHA 1910.95 Noise Exposure. OSHA relies on the current National Fire Prevention Association (NFPA) Bul- letin 33 to formulate guidelines on fire prevention. In addition to NFPA-33, OSHA also bases compliance decisions on the elec- trical guidelines outlined in the current NFPA-70 (National Electrical Code). For guidelines on the acceptability of certain spray booth components, OSHA refers to Underwriters Laboratory (UL), ETL Testing Laboratories (ETL), Fac- tory Mutual (FM), and Industrial Risk Insurers (IRI). These organizations eval- uate equipment according to fire and safety standards. The Environmental Protection Agency regulates the allowable amount of tox- ic material in exhaust stack emissions, liquid, and solid waste streams. The EPA has no jurisdiction over booth design, which is designated by NFPA-33. State Agencies Federal agencies, such as OSHA, often maintain state offices to enforce their own federal regulations and to administer any state mandated variations in those regulations. Also, each state has an environmental agency (such as Georgia Environmental Department) that conducts a review of all installations. The pur- pose of the review is to obtain a disclosure or prediction regarding the level of pollutants the booth will emit. If the level is acceptable, the state agency issues a permit to operate an air con- taminant source. If the pollutant level is unacceptable, the agency may deny the per- mit, require the use of exhaust air treatment equipment, or require the use of a dif- ferent coating material. Filing an application for a permit to operate an air contaminant source can cause delays in installing and operating the equipment. The permit to operate is needed before the equipment can be used, and often before installation and as- sembly can begin. The application forms are usually complicated, and when completed the application is subject to administrative review before approval. Local Agencies City and county authorities conduct code inspections to evaluate hardware and in- stallation methods for compliance with OSHA, NFPA-33 (Spray Applications), NFPA-70 (National Electrical Code), and any local ordinances. Some municipali- ties are now writing EPA compliance into their local ordinances as well. The burden of compliance falls on the end user. Ignorance of the regulations and procedures is not a defense against prosecution, and penalties for non- compliance are becoming more severe. Become familiar with all the agencies having jurisdiction, including the environmental agency review and applica- tion requirements. Spray Booth Classifications Spray booth classifications are outlined in NFPA-33. NFPA classifies booth ar- eas according to the types of electrical equipment and other possible ignition sources that can safely be used within those areas. Class I covers flammable gases and vapors and Class II covers combustible dusts. 203

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