10.6 Hazardous Materials (Subpart H): Compressed Gases, Spray Finishing & HAZWOPER (1910.101, 1910.107, 1910.120)

10.6 Hazardous Materials (Subpart H): Compressed Gases, Spray Finishing & HAZWOPER

What Is Left in Subpart H

29 CFR 1910 Subpart H - Hazardous Materials is the widest-ranging subpart in Part 1910. Two of its heaviest sections already have their own chapters in this guide: 1910.106 (Flammable Liquids) and 1910.119 (Process Safety Management). This section covers the rest of the subpart that OSHA 511 names in its hazardous materials module:

Note the boundary that trips people up: Subpart H, 1910.101 covers the compressed gas in the cylinder; Subpart M (1910.166-1910.169) covers compressed air receivers and compressed air equipment. Two different subparts, two different tabs.

Compressed Gases (1910.101 and 1910.102-1910.105)

29 CFR 1910.101 is unusually short because it does its work almost entirely through incorporation by reference under 1910.6. Three duties:

1. Cylinder inspection (1910.101(a)): the employer must determine that compressed gas cylinders under its control are in a safe condition to the extent that this can be determined by visual inspection, performed in accordance with Compressed Gas Association (CGA) Pamphlet C-6. Visual inspection means checking for corrosion, gouges, dents, arc burns, fire damage, bulges, defective valves, and illegible or missing markings.
2. Handling, storage, and utilization (1910.101(b)): must comply with CGA Pamphlet P-1, which is where the practical rules live - cylinders secured upright, valve protection caps in place when the cylinder is not in use or being moved, cylinders never used as rollers or supports, and cylinders kept away from ignition sources and electrical circuits.
3. Safety relief devices (1910.101(c)): compressed gas cylinders, portable tanks, and cargo tanks must have pressure relief devices installed and maintained in accordance with CGA Pamphlets S-1.1, S-1.2, and S-1.3.

The sections that follow are gas-specific: 1910.102 acetylene (adopting CGA G-1), 1910.103 hydrogen, 1910.104 oxygen, and 1910.105 nitrous oxide. The bulk oxygen and welding-gas separation rules that OSHA 511 tests are in 1910.253 and are covered in Section 10.5 of this guide - oxygen separated from fuel-gas cylinders and combustibles by 20 feet or by a 5-foot noncombustible barrier with at least a half-hour fire rating.

Spray Finishing with Flammable and Combustible Materials (1910.107)

A spray booth is a small, deliberately ventilated flammable vapor space with an ignition source pointed into it, which is why 1910.107 is prescriptive.

Booth Construction (1910.107(b))

• Spray booths must be substantially constructed of steel, securely and rigidly supported, or of concrete or masonry (1910.107(b)(1)).
• Interior surfaces must be smooth and continuous without edges, and designed to prevent pockets that collect residues and to permit easy cleaning and washing without injury (1910.107(b)(2)).
• Floors and baffles must be noncombustible; where the floor is combustible it must be covered with noncombustible material.

Ventilation (1910.107(b)(5) and (d))

• Each spray booth must have an independent exhaust duct discharging to the exterior.
• Air velocity through the booth must be maintained at the rates in the standard: a minimum of 100 linear feet per minute for conventional air-atomizing spraying, reduced to a minimum of 60 linear feet per minute for electrostatic operations (1910.107(b)(5)(i)).
• The ventilating system must be kept in operation while spraying and for a sufficient time afterward to exhaust vapors from drying coated articles and finishing material residue (1910.107(d)(2)). The interlock rule follows from this: spray apparatus must not operate unless the exhaust fan is running.

Ignition Control (1910.107(c))

• No open flame or spark-producing equipment may be located in any spraying area nor within 20 feet of it, unless separated by a partition (1910.107(c)(2)).
• Electrical wiring and equipment inside any spray area where deposits of combustible residues may accumulate must be explosion-proof and approved for Class I, Group D locations; equipment within 20 feet of the spray area, but outside it, must not produce sparks under normal operating conditions and must meet Class I, Division 2 requirements (1910.107(c)(6)).
• Space heating appliances, steam pipes, or hot surfaces must not be located where deposits of combustible residues could ignite.

Housekeeping and Quantities (1910.107(e) and (g))

• The quantity of flammable or combustible liquid kept in the vicinity of spraying operations should ordinarily not exceed a supply for one day or one shift (1910.107(e)(2)).
• Original closed containers, approved portable tanks, approved safety cans, or a properly arranged system of piping must be used for bringing flammable liquid into spray finishing rooms.
• All spraying areas must be kept as free from the accumulation of deposits of combustible residues as practical, with cleaning done only with nonsparking tools (1910.107(g)).
• "No Smoking" signs in large letters on a contrasting color background must be conspicuously posted at all spraying areas and paint storage rooms.

HAZWOPER: Hazardous Waste Operations and Emergency Response (1910.120)

The Three Covered Populations

29 CFR 1910.120(a)(1) reaches three distinct groups. Which one applies determines everything about training and program requirements:

1. Uncontrolled hazardous waste site cleanup required by a governmental body - federal, state, local, or other - whether the site is on the National Priorities List or not, including initial investigations before the presence or absence of hazardous substances has been ascertained.
2. RCRA corrective actions - cleanup operations at sites covered by the Resource Conservation and Recovery Act, and routine operations at treatment, storage, and disposal (TSD) facilities licensed under RCRA.
3. Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. This third population is the one that reaches ordinary general industry plants, because a chemical release in a manufacturing facility is an emergency response even though the plant is not a waste site.

Site Worker Training (1910.120(e))

Employees covered by 1910.120(e)(1) must receive 8 hours of refresher training annually (1910.120(e)(8)).

The Five Emergency Response Training Levels (1910.120(q)(6))

Training is based on the duties and functions each responder will perform, and each higher level builds on the one below:

EXAM FRAMING: OSHA 511 will not ask you to design a HAZWOPER program. It will ask you to place a plant employee at the right level. The forklift driver told to call the control room and evacuate when a drum ruptures is Awareness. The plant spill team that closes a valve, dikes the spill, and re-enters to plug the leak is at least Operations, and plugging or patching moves it to Technician.