This document was published in Ontario, Canada, which may have different regulations than the U.S. |
Construction
Safety Association of Ontario
Two workers
have died and four have been critically injured as a result of preparing
or spraying waterproof coatings in rooms or confined spaces. In
all cases, the spray operators were self-employed and used portable
spray equipment in trailers or trucks. These incidents occurred
over the past four years.
Waterproofing
products contain toluene and heptane that are toxic by inhalation
and extremely flammable. The process requires stringent controls
to prevent and protect against hazardous levels of contaminants.
Construction
projects and industrial establishments where a waterproofing application
is required.
This hazard
occurs during the spraying application or cleaning of equipment
used to apply the waterproof coatings where inadequate ventilation
and a source of ignition are present.
Legal:
- The Occupational
Health and Safety Act (the Act) applies.
Section 25(2)(h) states that: "an employer shall, take every precaution
reasonable in the circumstances for the protection of the worker."
Precautions include (but are not limited to) training, safe handling
and storage of flammable liquids and work in confined spaces.
- The Workplace
Hazardous Materials Information System (WHMIS) Regulation, R.R.O. 1990,
Reg. 860, also applies with respect to training, labels and Material
Safety Data Sheets (MSDS).
- The Regulations
for Construction Projects made under the Act (O. Reg. 213/91)
sections 43 and 58 about use and storage of flammable liquids,
sections 52 to 57 about fire safety, and sections 60 to 63 about
confined space entry also apply.
Precautions:
- Safe work
procedures must be prepared and reviewed prior to spraying or
application in a room or confined space. Workers shall receive
adequate training and instruction in safe work procedures and
in the use of respiratory protective equipment.
- Operators
must be fully trained in WHMIS, equipment and procedures involving
confined spaces.
- All sources
of ignition, particularly static electricity, must be eliminated
or disconnected or removed. All equipment must be properly grounded
and explosion proof.
- The room
or confined space must have adequate ventilation. The operation
must NOT be carried out in unventilated areas.
- Appropriate
personal protective equipment must be worn.
- Confined
space requirements must be followed where applicable. Requirements
include:
- Entry
by operators working alone is strictly prohibited. Operations
involving confined spaces require a minimum of two persons
plus a provision for rescue.
- Entry
is permitted if it is certified as safe by a competent worker
or if:
- the
worker wears suitable breathing apparatus,
- the
worker wears a full body harness, securely attached to
a rope, with the free end tied to a fixed support outside
the confined space,
- the
worker outside the confined space is equipped with an
alarm,
- a
means of communication between the worker in the confined
space and the worker outside is provided,
- a
person trained in artificial respiration and equipped
and able to perform rescue operations is readily available,
- all
equipment is inspected by a competent worker who confirms
it is in working order
- Spray operations
are prohibited if the concentration of vapour in the air exceeds
10% of the Lower Explosive Limit (LEL), i.e., 1000 ppm if the
LEL is 1% vol/vol. Entry into confined spaces is not permitted
if the concentration of flammable vapours exceeds 50% of the LEL.
The work locations must be evaluated by a competent person before
work in a confined space is attempted.
- This value
will almost certainly be exceeded in unventilated areas, or where
ventilation is poor or uncertain. The operation must
not be attempted unless adequate mechanical exhaust
ventilation is provided.
- Since high
vapour concentrations are likely from the spray operation, the
operator must wear a self-contained breathing apparatus, or a
supplied-air respirator.
- Continuous
monitoring of the level of flammable vapours is encouraged.
Remember
that while complying with the occupational health and safety
laws, you are also required to comply with applicable environmental
laws.
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