Dipping And Coating Operations: Dipping And Coating Operations 1910.122 - 126, Subpart H
James E. Roughton, CSP, CRSP, CHMM
www.asse-ga.org
Summary: Summary Rule developed to accomplish
Rewrite former standards in plain language
Consolidate former requirements
Increase compliance options
Coverage and Definitions -1910.123 : Coverage and Definitions -1910.123
Does This Rule Apply to Me?: Does This Rule Apply to Me? When a dip tank contains a liquid other than water
When you use a liquid or vapors to:
Clean or coat
Alter the surface
Change the characteristic
Draining or drying an object,dipped or coated
What Operations Are Covered? : What Operations Are Covered? Paint dipping
Electroplating
Pickling
Quenching
Tanning
Degreasing
Operations Covered (Continued): Operations Covered (Continued) Stripping
Cleaning
Roll coating
Flow coating
Curtain coating
What Operations Are Not Covered?: What Operations Are Not Covered? An operation that only uses a molten material
Alloy
Salt
How Are Terms Defined?: How Are Terms Defined? Adjacent area
Any area within 20 feet of a vapor area that is not separated by tight partitions
Approved
Designated equipment - listed/approved by a nationally recognized testing laboratory
Autoignition temperature
The minimum temperature required to cause self-sustained combustion, independent of any other source of heat
Terms Defined (Continued): Terms Defined (Continued) Combustible liquid
A liquid with a flash point of 100 deg.F or >
Dip tank
A container holding a liquid other than water and used for dipping or coating
An object may be immersed (or partially immersed) or it may be suspended in a vapor area
Flammable liquid
A liquid with a flashpoint < 100 deg.F
Terms Defined (Continued): Terms Defined (Continued) Flashpoint
The minimum temperature where a liquid gives off a vapor in sufficient concentration to ignite
Lower flammable limit (LFL)
The lowest concentration of a material that will propagate a flame
Expressed as a % by volume of the material in air (or other oxidant)
Terms Defined (Continued): Terms Defined (Continued) Vapor area
Any tank, including drain boards, drying or conveying equipment, and any surrounding area where the vapor concentration > 25% of the LFL
You
The employer, as defined by the occupational safety and health act of 1970
General Requirements -1910.124 : General Requirements -1910.124
What Construction Requirements Apply to Dip Tanks? : What Construction Requirements Apply to Dip Tanks? Any container that must be strong enough to withstand any expected load
What Ventilation Requirements Apply to Vapor Areas? : What Ventilation Requirements Apply to Vapor Areas? Keep airborne concentration < 25% of its LFL
Meet levels specified Subpart Z
Use of tank covers or floating materials
When You Use Mechanical Ventilation?: When You Use Mechanical Ventilation? Must conform with standards incorporated by reference:
ANSI
NFPA
ACGIH
Draw the flow of air into a hood or exhaust duct
Mechanical Ventilation (Continued): Mechanical Ventilation (Continued) Tanks must have an independent exhaust system unless the combination of substances being removed will not cause a:
Fire
Explosion
Chemical reaction
What Requirements Must I Follow to Recirculate Exhaust Air? : What Requirements Must I Follow to Recirculate Exhaust Air? Can not recirculate exhaust air when substance poses a health hazard to employees
> 25% the LFL
Recirculate Exhaust Air (Continued): Recirculate Exhaust Air (Continued) Exhausted air recirculated using flammable or combustible liquids is:
Free of any solid particulate
Monitored by approved equipment
Sounds an alarm, automatically shuts down when the vapor concentration > 25% the LFL
What Must I Do When I Use an Exhaust Hood? : What Must I Do When I Use an Exhaust Hood? Provide area with a volume of outside air that is at least 90 % of the volume of the exhaust air
Outside air supply does not damage exhaust hoods
What Requirements Must I Follow When an Employee Enters a Dip Tank? : What Requirements Must I Follow When an Employee Enters a Dip Tank? Meet the entry requirements for permit-required confined spaces
What First-aid Procedures Must My Employees Know? : What First-aid Procedures Must My Employees Know? The first-aid procedures that are appropriate for the operation
What Hygiene Facilities Must I Provide? : What Hygiene Facilities Must I Provide? Lockers or other storage space to prevent contamination of employee's street clothes
Emergency shower and eye-wash station close to the operation
Can use water hose at least 4’ and at least 3/4” thick, a quick-opening valve, and a pressure of 25 lbs. psi or <
At least one basin with a hot-water faucet for every 10 employees
What Treatment and First Aid Must I Provide?: What Treatment and First Aid Must I Provide? A physician's approval before an employee with a sore, burn, or other skin lesion that requires medical treatment works in a vapor area
Treatment by a properly designated person of any small skin abrasion, cut, rash, or open sore
Appropriate first-aid supplies located near the operation
Employees who work with chromic acid, periodic examinations of exposed body parts, especially their nostrils
What Must I Do Before an Employee Cleans a Dip Tank?: What Must I Do Before an Employee Cleans a Dip Tank? Drain the tank, open the cleanout doors
Ventilate and clear any pockets where hazardous vapors may have accumulated
What Must I Do to Inspect and Maintain My Dipping or Coating Operation? : What Must I Do to Inspect and Maintain My Dipping or Coating Operation? Inspect hoods and ductwork of ventilation system for corrosion or damage:
At least quarterly during operation
Prior to operation after a prolonged shutdown
Ensure that the airflow is adequate:
At least quarterly during operation
Prior to operation after a prolonged shutdown
Inspect and Maintain (Continued): Inspect and Maintain (Continued) Periodically inspect all equipment
Covers
Drains
Overflow piping
Electrical
Fire-extinguishing systems
Promptly correct any deficiencies
Inspect and Maintain (Continued): Inspect and Maintain (Continued) Provide mechanical ventilation or respirators to protect employees from exposure to toxic substances during
Welding
Burning
Open-flame work
Clean solvents and vapors before permitting welding, burning, or open-flames
Additional Requirements for Flammable or Combustible Liquids - 1910.125 : Additional Requirements for Flammable or Combustible Liquids - 1910.125
Flammable or Combustible Liquids: Flammable or Combustible Liquids Must comply 1910.123, 124, 125, and126
Must comply if:
Flashpoint of flammable or combustible liquid is 200 deg. F or >
Liquid is heated as part of the operation
Heated object is placed in the liquid
What Type of Construction Material Must Be Used in Making My Dip Tank? : What Type of Construction Material Must Be Used in Making My Dip Tank?
Noncombustible material
When Must I Provide Overflow Piping? : When Must I Provide Overflow Piping? Properly trapped overflow piping that discharges to a safe location for:
A capacity > 150 gallons
A liquid surface area > 10 feet
Overflow Piping (Continued): Overflow Piping (Continued) Overflow piping is at least 3” in diameter and has sufficient capacity to prevent the tank from overflowing
Piping connections on drains and overflow pipes allow ready access to the interior of the pipe for inspection and cleaning
Bottom of the overflow connection is at least 6” below the top of the tank
When Must I Provide a Bottom Drain?: When Must I Provide a Bottom Drain? For tanks that contain > 500 gallons of liquid, unless:
The tank is equipped with an automatic closing cover
The viscosity of the liquid at normal atmospheric temperature does not allow the liquid to flow or be pumped easily
Bottom Drain (Continued): Bottom Drain (Continued) Must ensure that the bottom drain:
Will empty the dip tank during a fire
Has pipes that permit the contents to be removed in 5 minutes
Is properly trapped
Discharges to a safe location
Bottom Drain (Continued: Bottom Drain (Continued Must be capable of manual and automatic operation
Manual operations must be from a safe and accessible location
Must ensure that automatic pumps are used when gravity flow from the bottom drain is impractical
When Must My Conveyor System Shut Down Automatically?: When Must My Conveyor System Shut Down Automatically? If a conveyor system is used, the system must shut down automatically:
If there is a fire
If the ventilation rate drops below requirements
What Ignition and Fuel Sources Must Be Controlled?: What Ignition and Fuel Sources Must Be Controlled? In each vapor area and any adjacent area:
All electrical wiring and equipment conform requirements of Subpart S
Except as permitted in 1910.126
There are no flames, spark-producing devices, or other surfaces that are hot enough to ignite vapors
Ignition and Fuel Sources (Continued): Ignition and Fuel Sources (Continued) Portable container used to add liquid to the tank is electrically bonded and grounded
Heating systems used in a drying operation that could cause ignition:
Is installed in accordance with NFPA
Has adequate mechanical ventilation that operates before and during drying operation
Ignition and Fuel Sources (Continued): Ignition and Fuel Sources (Continued) Shuts down automatically if any ventilating fan fails to maintain adequate ventilation
All vapor areas are free of combustible debris
Rags and other contaminated material placed in approved waste cans immediately after use
Waste can contents are properly disposed of at the end of each shift
Post "no smoking" sign near each tank
What Fire Protection Must I Provide? : What Fire Protection Must I Provide? Required for:
Any tank with a capacity of at least 150 gallons or a liquid surface area of at least 4’
Any hardening or tempering tank with a capacity of at least 500 gallons or a liquid surface area of at least 25’
Fire Protection (Continued): Fire Protection (Continued) For vapor areas, you must provide:
Manual fire extinguishers for flammable and combustible liquid fires
Automatic fire-extinguishing system, Subpart L
Fire Protection (Continued): Fire Protection (Continued) May substitute a cover that is closed by an approved automatic device for the automatic fire-extinguishing system if the cover:
Can also be activated manually
Is noncombustible or tin-clad, with the enclosing metal applied with locked joints
Is kept closed when the tank is not in use
To What Temperature May I Heat a Liquid in a Dip Tank? : To What Temperature May I Heat a Liquid in a Dip Tank? Must maintain the temperature of the liquid:
Below the liquid's boiling point
At least 100 deg. F below the liquid's autoignition temperature
Additional Requirements for Special Dipping and Coating Operations - 1910.126: Additional Requirements for Special Dipping and Coating Operations - 1910.126 In addition to the requirements in 1910.123 -125, must comply with any requirement that applies to your operation
What Additional Requirements Apply to Hardening or Tempering Tanks?: What Additional Requirements Apply to Hardening or Tempering Tanks? Must ensure that hardening or tempering tanks:
Are located as far as practicable from furnaces
Are on noncombustible flooring
Have noncombustible hoods and vents for venting to the outside
Vent ducts must be treated as flues and kept away from combustible materials, particularly roofs
Hardening or Tempering (Continued): Hardening or Tempering (Continued) Must equip each tank with an alarm that will sound if the temperature of the liquid comes within 50 deg. F of its flashpoint (the alarm set point)
When practicable, provide each tank with a limit switch to shut down the conveyor supplying work to the tank
Hardening or Tempering (Continued): Hardening or Tempering (Continued) If the temperature of the liquid can exceed the alarm set point, equip the tank with a circulating cooling system
If the tank has a bottom drain, it may be combined with the oil-circulating system
Must not use air under pressure when filling the tank or agitate liquid
What Additional Requirements Apply to Flow Coating?: What Additional Requirements Apply to Flow Coating? Must use a direct low-pressure pumping system or a 10-gallon or < gravity tank to supply the paint for flow coating
In case of fire, an approved heat-actuated device must shut down the pumping system
Must ensure that the piping is substantial and rigidly supported
What Additional Requirements Apply to Roll Coating, Roll Spreading, or Impregnating?: What Additional Requirements Apply to Roll Coating, Roll Spreading, or Impregnating? When using a flammable or combustible liquid with a flashpoint < 140 deg. F, prevent static electricity by:
Bonding and grounding all metallic parts (including rotating parts)
Installing static collectors
Maintaining a conductive atmosphere (for example, one with a high relative humidity)
What Additional Requirements Apply to Vapor Degreasing Tanks?: What Additional Requirements Apply to Vapor Degreasing Tanks? Must ensure that the condenser or vapor-level thermostat keeps the vapor level at least 36” or 1/2-half the tank width, whichever is less, below the top of the tank
Vapor Degreasing (Continued): Vapor Degreasing (Continued) When gas as fuel is used to heat the tank liquid, prevent solvent vapors from entering the air-fuel mixture
Make the combustion chamber airtight (except for the flue opening)
Flue must be made of corrosion-resistant material
It must extend to the outside
Must install a draft diverter if mechanical exhaust is used on the flue
Vapor Degreasing (Continued): Vapor Degreasing (Continued) Must not allow the temperature of the heating element to cause a solvent or mixture to decompose or to generate excessive amount of vapor
What Additional Requirements Apply to Cyanide Tanks? : What Additional Requirements Apply to Cyanide Tanks? Cyanide tanks must have a dike or other safeguard to prevent cyanide from mixing with an acid if a dip tank fails
Additional Requirements For Spray Cleaning And Degreasing Tanks? : Additional Requirements For Spray Cleaning And Degreasing Tanks? If you spray a liquid in the air over an open-surface cleaning or degreasing tank, control the spraying by:
Enclosing the spraying operation
Using mechanical ventilation to provide enough inward air velocity to prevent the spray from leaving the vapor area
What Additional Requirements Apply to Electrostatic Paint Detearing?: What Additional Requirements Apply to Electrostatic Paint Detearing? Must use only approved electrostatic equipment in paint-detearing operations
Electrodes must be substantial, rigidly supported, permanently located, and effectively insulated from ground by nonporous, noncombustible, clean, dry insulators
Must use conveyors to support any goods being paint deteared
Electrostatic Paint (Continued): Electrostatic Paint (Continued) Must ensure that material being electrostatically deteared are not manually handled
Must maintain a minimum distance of twice the sparking distance between material being electrostatically deteared and the electrodes or conductors of the electrostatic equipment
Minimum distance must be displayed near the equipment
Electrostatic Paint (Continued): Electrostatic Paint (Continued) Must ensure that the electrostatic equipment has automatic controls that immediately disconnect the power supply to the high-voltage transformer and signal the operator if:
Ventilation or the conveyors fail to operate
Material being electrostatically deteared come within twice the sparking distance of the electrodes or conductors of the equipment
A ground occurs anywhere in the high-voltage system
Electrostatic Paint (Continued): Electrostatic Paint (Continued) Must use fences, rails, or guards, made of conducting material and adequately grounded, to separate paint-detearing operations from storage areas and from personnel
Electrostatic Paint (Continued): Electrostatic Paint (Continued) To protect paint-detearing operations from fire, must have:
Automatic sprinklers
An automatic fire-extinguishing system conforming to the requirements of Subpart L
To collect paint deposits:
Provide drip plates and screens
Clean these plates and screens in a safe location