The Finishers Prayer
May your cup never runneth over
May sanding suddenly be fun
And if the EPA should visit
Let waterborne be in your gun.
This is the area that most people don’t think about investing in until there is a major problem. At this point, the cost of implementing changes is very costly. Think of these items as insurance.
Never underestimate the value of safety
It takes time and it takes money, but it is time and money well spent. There are moral issues and legal issues that arise when considering this subject. I have been on both sides of the line and, for what it is worth, I would like to say that no matter how much work or money is involved and no matter how much of a PIA the regulations are, it’s the right thing to do. These regulations are there to protect you, your workers, and your business. The cost of implementing these regulations should be considered a cost of doing business and should be a part of the overhead that you pass on to your customer.
Take a minute to think about what you are doing
Be it waterborne or be it solvent-based, there is nothing in a stain or a finish that is good for you. It is not good for the skin. It is not good for your lungs, and it is not good for your brain. In a worst-case scenario, you are taking a toxic flammable liquid and atomizing it into a fine mist; kind of like what the fuel injectors in your car do. Just like in your car it only takes a tiny spark to ignite the vapors and make them go boom.
Let’s not forget about the “nuisance particles/ dust” from sanding wood and finishes. They are respiratory irritants that along with the various finishing solvents can potentially make a pretty nasty chemical cocktail.
It should go without saying: Always wear protection
Except for the case of 2 component polyurethanes, most MSDS sheets say that if personal exposure cannot be controlled below applicable limits by ventilation, then wear a properly fitted organic vapor/particulate respirator. My question to you is “do you know how many parts per million of a chemical your finishers are actually being exposed to?” Personally, I would err on the safe side. Provide your finishers with safety glasses/ goggles, dust masks, gloves, and NIOSH-approved organic vapor respirators. If you spray a fair amount of 2K Poly then I would have air-supplied respirators with full face masks and Tyvek suits available.
The one question that arises is “do you require your finishers to wear a respirator, or is it optional?” The usual response that I have seen from OSHA is that if a respirator is required, then a baseline respiratory capacity test is required for each person involved. A class for fitting and testing the respirator is required and finally, a respiratory capacity test is required at regular intervals to check against the baseline.
Get your EPA record keeping up to date
Making sure that you have the necessary EPA info together and up to date can save you money and headaches if you ever get an inspection. Unless you are a large hazardous waste generator, it is often as simple as having all of your finishing materials Product Information Sheets & MSDS sheets in a binder and having a recent copy of your environmental compliance report. A good distributor of wood finishing products would be able to supply you with this information at little or no charge.
Product Information Sheets are the manufacturer’s information and usage instructions for a particular product. They often state the “Solids by Volume” content, reduction requirements, dry times, as well as other significant information about the product and its application. Sometimes a simple review of this piece of literature will reveal some profound insights about a product’s use or application. Many times I have seen people using a product only because a salesperson recommended it to them and really had no idea about what the product actually was or the restrictions on its use. Don’t be misled by marketing. Names and claims are often tossed around to get a sale. The PI sheet will tell you the facts.
The MSDS sheet will tell you exactly what is in the product that you are using. Sometimes you may not know exactly what you are looking at, but be aware of these sections:
- Exposure Controls/ Personal protection
- Toxicological Information
Environmental Compliance Reports can usually be generated by your finish supplier. They list the products and their quantities that you have purchased over a given time period. They break the products down into the pounds of HAP’s and VOC’s that could be emitted from the quantities purchased. Most environmental agencies assume a “potential to emit” as if every spray gun you had was in use 24/7. This report is invaluable because it links your “potential to emit” to the actual products and the quantities that you have purchased. Most finish suppliers will gladly supply this report for free, or at most a nominal charge. All you have to do is ask. If your supplier doesn’t know what this report is, I would consider getting a new supplier.
In most cases the paperwork and recordkeeping necessary to fulfill Environmental Compliance requirements are supplied by your finish supplier. Again, all you have to do is ask. The burden of asking, however, remains on you. Document your request in writing and follow up on your request until you have the information that you need. Fines for non-compliance are stiff and will cost you several times more in money, time, and energy what it would to simply have had the information on file. I would be willing to say that many EPA inspections are sparked by a phone call from a disgruntled employee or an angry neighbor.