Head-To-Toe Protection for the Whole Technician Information Resources Ergonomics Paint Issues Respiratory Protection

Without proper protection and following standard guidelines, millions of workers are at risk for life-threatening and permanently damaging injuries.

Personal protective equipment (PPE) plays a key role in keeping technicians safe in the automotive workplace. The Occupational Safety and Health Administration (OSHA) maintains certain standards for personal protective equipment that are intended to protect workers from unnecessary hazards. Abiding by these standards will prevent needless injury and lost time in the workplace. OSHA and the U.S. Department of Labor estimate that, within the automotive industry, there are 326,793 establishments that employ 3,066,501 workers. Without proper protection and following standard guidelines, millions of workers are at risk for life-threatening and permanently damaging injuries.

OSHA's incident data indicates that a significant portion of all work-related injuries and fatalities involve workers being struck in the eyes, head, face, hand and/or feet by foreign objects. Finding the proper equipment is essential to proper protection. Women, especially, have problems finding proper fitting equipment in an industry that was once exclusively male. OSHA reports that as more and more females enter the automotive workplace, they often have to chose between wearing PPE that was sized to fit males or not wearing equipment at all. Based on concern for the safety of female employees, many of whom have stopped using PPE because of discomfort or improper protection, OSHA is working toward developing PPE standards for women in the automotive workplace.

Ears:

According to the National Institute on Deafness and Other Communication Disorders, 10 million Americans suffer from irreversible damage caused by noise, and 30 million more are exposed to dangerous levels of noise each day.

Hearing loss is a danger to which everyone is susceptible. But for automotive technicians, the danger is greatly increased. Noise-induced hearing loss (NIHL) is the most unnecessary, most preventable form of hearing loss. All technicians working in areas with loud or shrill noises should have access to ear plugs of some sort, and common sense should be a factor when dealing with any noise at piercing decibels.

The U.S. Department of Health and Human Services, in conjunction with the National Institute of Occupational Safety and Health (NIOSH), has launched a "Wise Ears!" campaign. The project includes a coalition of 60 government agencies, public organizations, businesses, industries and unions working to inform the public about the dangers and risk of NIHL. The program has two goals. First, to increase awareness about NIHL, and second, to motivate these audiences to take action against NIHL by advocating changes in the workplace and developing hearing loss prevention programs.

Hearing is vital in diagnosing some automotive repair problems, and damaged hearing all too often is an unnecessary liability.

Eye and Face:

OSHA's standards for eye and face protection require that each employee should use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors or potentially injurious light radiation. Employees required to wear protection for their eyes and face must be sure that this protection has side shields or protectors. Furthermore, each employee who wears prescription lenses while involved with materials that could be eye hazards must wear eye protection that incorporates the prescription in its design, or he must wear eye protection that can be worn over the prescription lenses without disturbing the proper position of either the prescription lenses or the protective lenses.

Hands:

Perhaps the most important part of a technician's body, for the purposes of collision or automotive repair, is the hands. Statistics from OSHA indicate that personal protective equipment for the hands is not worn for the majority of the time, and when a technician wears protective equipment for the hands, it does not fully or appropriately protect the worker. One study indicated that 70 percent of the workers in the automotive industry who experienced hand injuries were not wearing gloves. Furthermore, hand injuries to the remaining 30 percent of the workers who were wearing gloves were caused because the gloves were inadequate, damaged or were the wrong kind for the type of hazard present. As you can see from these statistics, wearing the proper kind of gloves at the proper time would eliminate a huge percentage of hand injuries in the automotive industry.

Currently, OSHA does not have specific criteria for hand protection or for chemical protective clothing. OSHA simply suggests that employers should select and require employees to use appropriate hand protection when employees' hands are exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns and harmful temperature extremes. According to NIOSH, one in every four workers in the country is exposed to some form of skin irritant. With new substances being introduced to the workplace each day, the risks increase daily.

Employers should consider, when selecting appropriate hand protection, an evaluation of the performance characteristics of the protection relative to the tasks to be performed, the conditions present, the duration of use and the hazards and potential hazards identified. Rulemaking participants within OSHA have suggested that OSHA provide performance criteria and test methods for gloves, which would give guidance to shop owners and managers, as well as technicians, in selecting effective protective equipment for hands.

Keeping hands spotlessly clean isn't really practical in either mechanical or collision repair. But keeping hands clean of toxic chemicals, safe from hot materials and protected from the painful effects of chapping and drying is practical, necessary and easier than ever. New products by many companies are changing the way technicians can protect their hands, and when used in conjunction with gloves, can keep hands moisturized and protected from hazards.

When cleaning hands, many lotions and cleansers take care of dirt and grime, but often leave hands chapped and dry. There are two ways to prevent the painful after-effects of frequent washing and cleaning. First, using soaps and lotions with aloe, lanolin or even cocoa butter will help keep hands moisturized. But secondly, there are products on the market today that act as gloves, or a barrier, to keep skin free of the irritants and chemicals that normally bombard it. This type of product is beneficial for both the technician who is gloveless as well as the one wearing gloves, as this barrier product also protects from the drying powder found in latex gloves as well as the drying effects of leather gloves.

Body Protection:

OSHA's concern with respect to hand protection and chemical protective clothing arose from information in workplace studies that indicated that a large number of employee injuries occur due to the lack of adequate protection from hand and skin hazards. For the time being, OSHA does not have specific criteria or requirements concerning chemical protective clothing.

CINTAS Corp., a manufacturer of uniforms for the automotive industry, and an ASA member benefit provider, offers special pricing for ASA national members. Most importantly, though, CINTAS provides clothing for the automotive technician that protects arms and legs. CINTAS has also developed flame-resistant fabric for its coveralls and uniforms—an important development for technicians who deal with flammable liquids and hazards daily.

The focus for many uniform companies developing new products is making uniforms and personal protective equipment that will fit properly. A Kimberly-Clark Company representative explained that Kimberly-Clark has worked to develop the “KREW” line of protective clothing. Because this clothing is breathable and better fitting, the company believes technicians are more likely to keep it on and remain properly suited up. Therefore, Kimberly-Clark believes they are helping to ensure that technicians are in compliance with OSHA regulations.

Feet:

Of course, comfortable footwear, whether steel-toed boots or tennis shoes, is necessary for a technician who spends most of the workday standing. OSHA regulations for steel-toed boots should be followed at all times, as it is important to protect feet from falling objects. However, when working on cement and concrete floors, even the most protective or comfortable shoes can leave feet tired and swollen. Safety mats or cushion mats for the floor keep the floors in your shop as soft and soothing as possible for the feet that tread them all day.

OSHA's standards for foot protection require that each employee should wear protective footwear in any place where there is danger of injury due to falling or rolling objects, objects piercing the sole of a shoe, and where the employee's feet are exposed to electrical hazards. OSHA requires that footwear purchased after July 5, 1994, should comply with ANSI Z41-1991, which is the American National Standard for Personal Protection. Copies of this requirement may be obtained from the American National Standards Institute at http://www.ansi.org or 11 West 42nd Street, 13th Fl., New York, New York 10036. Protective footwear purchased before July 5,1994, must comply with the ANSI standard Z41.1-1967, which is the USA Standard for Men's Safety-Toe Footwear. Copies of this standard may be obtained from OSHA or the U.S. Department of Labor.

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Information Resources

Shop owners who would like more information on safety regulations as well as safety attire and accessories to ensure head-to-toe protection for their employees can contact:

• The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA). The mission of OSHA is to save lives, prevent injuries and protect the health of America's workers. Nearly every working man and woman in the nation comes under OSHA's jurisdiction. OSHA has regulations governing both automotive mechanical and collision repair shops that must be met. Noncompliance can bring penalties.

  OSHA can be contacted by telephone, by calling its toll-free number, (800) 321-OSHA (6742); by sending e-mail to http://www.hhs.gov; or by writing to the U.S. Department of Labor, Occupational Safety and Health Administration, 200 Constitution Ave., Washington, D.C. 20210.

• The National Institute for Occupational Safety and Health (NIOSH). Although NIOSH and OSHA were created by the same act of Congress, they are two distinct agencies with separate responsibilities. OSHA is in the Department of Labor and is responsible for creating and enforcing workplace safety and health regulations. NIOSH is in the Department of Health and Human Services and is a research agency.

  NIOSH is part of the Center for Disease Control and Prevention (CDC) and is the only federal institute responsible for conducting research and making recommendations for the prevention of work-related illnesses and injuries. The institute's responsibilities include:

  1. Investigating potentially hazardous working conditions as requested by employers or employees.
  2. Evaluating hazards in the workplace, ranging from chemicals to machinery.
  3. Creating and disseminating methods for preventing disease, injury and disability.
  4. Conducting research and providing scientifically valid recommendations for protecting workers.
  5. Providing education and training to individuals preparing for or actively working in the field of occupational safety and health.

  NIOSH can be contacted by calling (800) 356-4674; by sending e-mail to http://www.cdc/niosh/about.html; or by writing to the National Institute for Occupational Safety and Health (NIOSH), Hubert H. Humphrey Bldg., 200 Independence Ave., SW, Room 715H, Washington, D.C. 20201.

• U.S. Environmental Protection Agency (EPA). The EPA was created to protect human health and to safeguard the natural environment. ASA is working with the EPA to develop a pollution prevention program for mechanical shops. ASA will kick off the program, which is designed to provide cost-effective strategies to improve environmental performance and worker safety, in November at the Congress of Automotive Repair and Service (CARS).

  Due to its size, the EPA does not have a main telephone number. Perhaps the best way to contact the EPA is by first visiting its Web site at http://www.epa.gov/epahome/hotline.htm. The site provides e-mail addresses and telephone numbers for its various clearinghouses. The EPA is headquartered at 1200 Pennsylvania Avenue, NW, Washington, DC 20460.

• The National Automotive Radiator Service Association (NARSA) is a not-for-profit trade association serving the cooling system service industry and motoring public since 1954. Studies indicate that lead exposure is substantial in radiator repair workers and NARSA is willing to share the information it has and its safety tips with ASA shop owners.

  NARSA can be contacted by calling (215) 541-4500; by sending e-mail to narsa@narsa.org; or by writing to NARSA, P.O. Box 97, East Greenville, PA 18041.

Editor's note: Most federal agencies have regional, area or field offices. Especially if you live in a larger city, there may be one in your area. Consult your phone book to find out if there are local offices. In addition, a shop owner should check his local city government for any safety regulations that might apply to an automotive repair facility. A city's fire department will usually be glad to send out a representative to do a walk-around inspection. A shop owner should also check his or her state government for safety regulations that might apply.

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Ergonomics

The Occupational Safety and Health Administration (OSHA) has announced that the agency is scheduled to finalize its controversial ergonomics rule by the end of the year. The rule, according to OSHA, is designed to protect workers from painful and costly musculoskeletal disorders such as back injuries and carpal tunnel syndrome. OSHA estimates that the rule will save the U.S. economy $9 billion a year and prevent the injury of 300,000 workers.

An OSHA press release outlining the ergonomics proposal states in part that under the proposal, about 1.6 million employers would need to implement a basic ergonomics program. This would include assigning someone to be responsible for ergonomics; providing information to employees on the risk of injuries, signs and symptoms to watch for and the importance of reporting problems early; and setting up a system for employees to report signs and symptoms. Full programs would be required only if one or more work-related musculoskeletal disorders actually occurred. The proposal also offers a "quick-fix" alternative to setting up a full ergonomics program. Correct a hazard within 90 days, check to see that the fix works and no further action is necessary. In addition, according to OSHA, a “grandfather” clause gives credit to firms that already have effective ergonomics programs in place and are working to correct hazards.

In addition, the OSHA proposal identifies six elements for a full ergonomics program: management leadership and employee participation, hazard information and reporting, job hazard analysis and control, training, musculoskeletal disorder management and program evaluation. Also according to the press release, OSHA intends that ergonomics programs cover just the specific job where the risk of developing a musculoskeletal disorder exists and jobs like it that expose other workers to the same hazard. Ergonomic programs need not cover all the jobs at the workplace.

More than 7,000 comments have been submitted to the agency so far. The business community has criticized the proposal saying it is too expensive, interferes with safety practices already in place and is based on questionable science. One organization that is critical of the rule, the National Association of Manufacturers (NAM), is estimating the cost to implement OSHA's proposed ergonomics rule at nearly $6.7 billion in the first year, while OSHA estimates the cost at $4.2 billion. That equals about $781 per employee in the first year, NAM said, which would disproportionately affect small- and medium-sized businesses.

ASA believes the proposed rule, in its current form, is far from acceptable. In an effort to ensure that the final rule will treat small businesses fairly, ASA has submitted comments as an association and through the Small Business Legislative Council.

A summarized view of a few of ASA's concerns include:

Vagueness and scope of the standard


Are there a minimum number of employees an employer must have to fall under the proposed rule? For example, who is responsible for maintaining an employee participation plan if an employer has only one employee? Also, will this trigger a full ergonomics program requirement for the employee? ASA is concerned with the ambiguity of several other aspects of the proposal, as well.

ASA also believes that the “clumping” of several industries together is detrimental to all industries and their specific needs, and there is concern that the cost for small businesses could be much higher than OSHA's estimates.

Triggering


ASA is concerned with OSHA's triggering method for activating the full ergonomics program. ASA believes that one recordable work-related musculoskeletal disorder is not significant to trigger the implementation of an ergonomics program for all situations. An alternative plan solution that would satisfy many industry concerns would be to use a three-year average of work-related musculoskeletal disorders reported for a particular position. Thus, fewer small business employers would have to incorporate a costly full ergonomics plan.

External factors


ASA is concerned that the proposal does not address external factors such as lifestyle that could promote the reporting of work-related musculoskeletal disorders. There is little in the proposed standard that would prohibit a worker from reporting an injury that occurred away from work as a work-related injury.

Related Reading:

AutoInc.'s Legislative Analysis column, February 2000

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Paint Issues

ASA Facilitates EPA Paint Discussion

The Automotive Service Association (ASA) hosted a discussion in Washington, D.C., with staff from the Design for the Environment (DfE) of the U.S. Environmental Protection Agency (EPA), concerning the health of painters in the collision industry.

The EPA's DfE program is a voluntary, partnership-based program that works with small companies to integrate health and environmental considerations into business decisions. The DfE has been working on what is known as the Small Auto Refinish Shop Project, based in the Philadelphia, Pa., area.

The project works with auto refinishers to identify and adopt safer, cleaner, and more efficient practices and technologies. Through its research, the project team has uncovered many examples of health and safety improvements that increase efficiency and help save time and money.

The DfE claims the project has been successful in not only improving the shops they visit, but also fostering a better partnership between the agency and the industry. During the meeting, ASA agreed to help the DfE by providing more shops for them to work with to expand the program to other cities.

“We are pleased to form a voluntary partnership with DfE on this,” said Bob Redding, ASA's Washington, D.C., representative. “The health of our employees is very important and ASA will continue to work with regulators to assure the best of working conditions.”

In addition to Redding, those representing ASA included Howard Lewis, AAM, chairman; Johnny Mock, AAM, immediate past chairman; Walter Trapp, president; Bob Anderson, AAM, past chairman; Jim Busch, AAM, Collision Division Operations Committee member; and Matthew Best, ASA's legislative analyst

Yale Paint Study Will Impact Industry

ASA members participated in a discussion in Washington, D.C., with researchers conducting a study of the effects of paint on refinishers in the collision industry. The study, Survey of Painters and Repairers in Autobodies by Yale University School of Medicine (SPRAY) began in 1997. It was launched to determine how commonly used chemicals in autobody paint shops may cause or aggravate asthma.

“The findings of this study will have an impact on our industry,” said Bob Redding, ASA's Washington, D.C., representative. “We appreciate the openness and candor of the research institutions involved. The necessity for such a study should be a catalyst for the federal government to restrict the sale of automotive paint to only those that are properly trained and equipped to use it safely.”

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The OSHA Standard
on Respiratory Protection

By James L. Busch, AAM

In January 1998 the Occupational Safety and Health Administration (OSHA) issued a major overhaul of its respiratory protection rule. Although most companies have some parts of their program in place, many employers have not required their employees to undergo the medical evaluation required by the rule. Individual citations for noncompliance can be issued for lack of a written program, lack of medical evaluation, lack of training, or improper administration.

Although respiratory exposures should be controlled by using sound work practices and good engineering controls such as down-draft booths, high volume/low pressure (HVLP) guns, ventilated sanders, enclosed spray-gun cleaners and adequate building ventilation, the rule does not take these into consideration when assessing worker exposure.

The Occupational Safety and Health Standards, Title 29 Labor, Subpart I-Personal Protective Equipment, states in part: “Respirators shall be provided by the employer when such equipment is necessary to protect the health of the employee. The employer shall provide the respirators, which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program.” (This statement is expanded into 37 pages of text defining exactly what is required.)

OSHA's rule required employers to develop a respiratory protection program detailing specific procedures and elements for required respirator use and assign suitably trained individuals to oversee the administration. Requirements of a minimal respirator program include:

• Written respiratory program.
• Written standard operating procedures governing the selection and use of respirators shall be established. Respirators shall be selected on the basis of hazards to which the worker is exposed. Respirators shall be selected from among those approved by the National Institute for Occupational Safety and Health (NIOSH).
• Employee Training and Medical Evaluations.
• Persons should not be assigned to tasks requiring use of a respirator unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent.
• A Synopsis of the Medical Evaluation Section.
  1. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace.
  2. The employer shall identify a physician or other licensed health care professional to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the OSHA-approved medical questionnaire.
  3. The medical questionnaire and examinations shall be administered confidentially during the employee's normal working hours or at a time and place convenient to the employee. The medical questionnaire shall be administered in a manner that ensures that the employee understands its content.
  4. The following information must be provided to the medical examiner before a determination can be made concerning an employee's ability to use a respirator:
  • The type and weight of the respirator to be used by the employee.
  • The duration and frequency of respirator use.
  • Expected physical work effort.
  • Additional protective clothing and equipment to be worn.
  • Temperature and humidity extremes that may be encountered.
• Respirator Fit Testing, Use and Operation, Maintenance
  The user shall be instructed and trained in the proper use of respirators and their limitations. Respirators shall be regularly cleaned and disinfected. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use. Respirators shall be stored in convenient, clean and sanitary locations. Respirators used routinely shall be inspected during cleaning. Worn or deteriorated parts shall be replaced. Respirators for emergency use such as self-contained devices shall be thoroughly inspected at least once a month and after each use.
• Respirator Program Effectiveness Evaluations
  There shall be regular inspection and evaluation to determine the continued effectiveness of the program. Appropriate surveillance of work area conditions and degrees of employee exposure or stress shall be maintained.

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