12 March 2018
Summary
During the early part of 2018, the Health and Safety Inspectorate (HSI) carried out a proactive series of inspections of the motor vehicle repair (MVR) industry.
The initiative focused on the management of health risks associated with the use of isocyanate paints (also known as 2K, two-pack or polyurethane paints).
All MVR workshops known, or suspected, to carry out paint spraying using isocyanate paints in the Island were contacted and those who confirmed that they did carry out such work were visited. In total 14 MVR workshops were visited.
The specific areas this initiative focused on during the visits were:
- spray booths/rooms including thorough examination and test of the local exhaust ventilation (LEV)
- provision and maintenance of suitable respiratory protective equipment (RPE)
- spray operator health surveillance
- provision of adequate welfare facilities
In the majority of cases, advice and guidance were provided to ensure compliance to minimum legal requirements was met. Formal enforcement action, in the form of two Improvement Notices and two Prohibition Notices, was required to be served where the standards fell far short of the minimum legal requirements.
Background
Exposure to isocyanate paint mist during paint spraying is a high risk activity which can result in serious health hazards including occupational asthma. Duty holders are required to manage the health risks associated in the use of isocyanate paints. There are industry recognised safe systems of work.
Paint sprayers are the main group at risk of exposure but others who enter the spray booth/room can be affected. Others in the vicinity of a poorly operated and maintained spray booth/room including customers can also be affected. Whilst spray painting is the main and often the only source of exposure, it is recognised that a poor spray-gun cleaning regime can also cause high exposures.
SMART (small and medium area repair technique) repair sprayers who generally have no fixed place of work did not form part of the initiative on this occasion.
Legal requirements
MVR work associated with the spraying of isocyanate containing paint is covered by the general requirements of the Health and Safety at Work (Jersey) Law 1989 (the Law). The Law places general duties on various working parties including employers, employees and the self-employed to ensure the health and safety of themselves and others who may be affected by their actions.
To illustrate the minimum standards required to meet the general duties imposed by the Law, reference would be made to authoritative guidance, including guidance published by the UK’s Health and Safety Executive (HSE).
Findings of the initiative
The initiative identified five main areas where additional measures were typically required to be taken in order for duty holders to meet the minimum legal requirements:
- thorough examination and test of LEV
- provision of suitable RPE
- air quality checks on the compressed air feeding the RPE
- the provision of sufficient health surveillance
- provision of a visible clearance time test sign at all entrances to the booth or room
General advice and guidance were provided to ensure compliance with minimum legal requirements was met, but formal enforcement action, in line with the HSI Enforcement Policy, was taken as follows:
- one prohibition notice for failure to provide adequate RPE when spraying isocyanate paints
- one prohibition notice for failure to provide adequate measures to protect people from the inhalation of isocyanate paint mist
- two improvement notices for failure to have the LEV thoroughly examined and tested within the previous 14 months
A circular letter summarizing the legal requirements and initiative findings, together with general advice on isocyanate base paint spraying, has been sent to each duty holder that was visited following the initiative.
Further information and guidance
HSE guidance INDG 388 (rev2) ‘Safety in isocyanate paint spraying'
Other specific guidance relating to the MVR industry can be found on the Health and Safety Inspectorate website and the Health and Safety Executive UK website
HSI Enforcement Policy Statement
gov.je