Paint remover safety requirements

Under 1915.33(a) employers must protect workers from skin contact and provide eye protection in the form of goggles or face shields, as required by the shipyard PPE rules. See 1915.33(a) for the requirement and 1915 for the broader part.

• Use chemically resistant gloves and clothing to prevent skin contact when handling or applying removers.
• Provide safety goggles for splash protection and face shields when full-face/neck protection is needed (for example, when splashing or sprays may reach the face).
• Employers must supply required PPE (see OSHA guidance on employer payment for PPE) rather than shifting that cost to the employee; see the OSHA letter on Employer Payment for Personal Protective Equipment.

Under 1915.33(d) employers must provide and require the use of suitable face shields whenever paint or rust removers contain strong acids or alkalies so employees are protected from chemical burns to the face and neck. See 1915.33(d).

• "Suitable face shields" means shields selected to resist the chemical and cover the face and neck area likely to be exposed.
• Face shields are used in addition to other PPE (gloves, aprons) to provide complete protection for corrosive materials.

Under 1915.33(e) all employees working within range of a steam gun blast must be protected by suitable face shields, and the metal parts of the steam gun itself must be insulated to protect the operator from heat burns. See 1915.33(e).

• Provide face shields for anyone in the blast area to prevent scalding or blast injuries.
• Insulate any exposed metal parts of the steam gun that the operator could touch to prevent heat burns.

Under 1915.33(b) employers must take fire- and explosion-prevention precautions in accordance with 1915.36 when using flammable paint and preservative removers. See 1915.33(b).

• Typical precautions under 1915.36 include controlling ignition sources, using approved storage and transfer containers, and following facility fire-protection procedures.
• Employers should consult the specific provisions of 1915.36 for detailed requirements applicable to their operations.

Under 1915.33(c) the use of paint and preservative removers that contain volatile, toxic solvents like benzol, acetone, or amyl acetate must comply with the ventilation and exposure-control requirements in 1915.32. See 1915.33(c).

• That means employers must provide effective ventilation (local exhaust or general dilution) and other controls as required by 1915.32 to keep worker exposures below safe levels.
• Where ventilation alone is not adequate, respirators and administrative controls may be required; see OSHA guidance on respirator use and exposure assessment (for an example of sampling/assessment criteria, see the LOI on respiratory protection for wet blasting).

Under the shipyard rules, a competent person may identify and specify the necessary protections for hazardous exposures, and employers must implement ventilation and other controls required by 1915.32. See 1915.33(c) and the OSHA interpretation on competent persons in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

• The OSHA letter Competent person requirements in shipyards explains that a competent person must be capable of recognizing and evaluating hazardous exposures and "specifying the necessary protection" when no PEL exists or when exposures present serious hazards.
• In practice, the competent person (or qualified industrial hygienist) will determine whether local exhaust, increased general ventilation, work practice changes, respiratory protection, or monitoring are required under 1915.32.

(See 1915.33(c) for the trigger to apply 1915.32.)

Under 1915.33(a) the employer must provide either goggles or face shields as appropriate; choose goggles when the primary hazard is to the eyes (splashes, particles) and choose face shields when the hazard threatens the entire face and neck. See 1915.33(a).

• Goggles give better splash protection for the eyes and seal around the eye area.
• Face shields protect the entire face and neck from corrosive splashes, steam, or blast hazards and are required by 1915.33(d) and (e).
• Employers should perform a hazard assessment and provide the level of protection the hazard demands; required PPE must be provided by the employer (see OSHA's letter on Employer Payment for PPE).

Employers must use 1915.32 to control exposures to volatile solvents, and they should perform exposure monitoring when needed to demonstrate that ventilation and controls keep exposures below OSHA limits or acceptable levels. See 1915.33(c) and consult OSHA guidance on sampling and demonstration of compliance such as the respiratory protection for wet blasting letter for sampling expectations.

• The wet-blasting LOI (https://www.osha.gov/laws-regs/standardinterpretations/2015-08-13-0) outlines that to demonstrate exposures do not exceed PELs, personal samples should be collected in the worker’s breathing zone, be representative of the task, documented, and analyzed using accepted methods.
• If monitoring shows exposures exceed limits or controls are uncertain, upgrade controls (local exhaust, process changes) or provide appropriate respiratory protection per applicable standards.

Under 1915.33(b) employers must follow the fire-safety provisions of 1915.36 when using flammable paint and preservative removers. See both 1915.33(b) and 1915.36.

• Common measures include storing flammable liquids in approved containers, keeping work areas free of ignition sources, using bonding/grounding during transfer where required, and ensuring appropriate fire-extinguishing equipment is available.
• Follow the specific provisions in 1915.36 for detailed requirements tailored to shipyard operations.

Under 1915.33 employers must ensure workers are protected from skin and eye injury and must apply related standards (e.g., 1915.32 for ventilation); employers should therefore train employees on the hazards of the removers, correct use of provided PPE (goggles, face shields, chemical-resistant clothing), safe handling and storage for flammable or corrosive products, and emergency procedures. See 1915.33 and 1915.32.

• Training should include how to don/doff PPE, recognizing exposure symptoms, proper ventilation practices, and emergency response for chemical contact or fire.
• Employers must document that training was provided and ensure understanding through hands-on practice or demonstrations.

Under 1915.33(e) "insulated" means providing physical thermal protection (for example, guards, insulating sleeves, or other heat-resistant barriers) on metal parts of the steam gun that an operator could touch, so the operator will not receive heat burns. See 1915.33(e).

• Practical measures include installing insulated handles or covers, heat shields, or providing appropriate insulated gloves when contact is necessary.
• The goal is to prevent contact burns; the specific method should be selected based on the work conditions and evaluated by the employer’s competent person.

Under 1915.33(c) benzol and other volatile toxic solvents trigger the requirements of 1915.32, so employers should use engineering controls (local exhaust ventilation), safe work practices, appropriate PPE (gloves, goggles or face shields), and monitoring to ensure exposures are controlled. See 1915.33(c) and 1915.32.

• If ventilation cannot keep exposures below OSHA limits, provide respiratory protection and follow applicable respirator program requirements. Guidance on demonstrating exposures are below limits (sampling in the breathing zone, representative task sampling) is available in OSHA’s LOI on respiratory protection for wet blasting.
• Use chemical-resistant gloves and eye/face protection to prevent skin and eye contact as required by 1915.33(a).

No. While 1915.33(a) requires that employers protect employees with goggles or face shields, OSHA’s rule and interpretive guidance require employers to pay for required PPE in most situations; see the OSHA letter on Employer Payment for Personal Protective Equipment.

• Employers may not shift the cost of required protective equipment to employees in a way that effectively makes the employee pay for PPE required by the employer.
• Limited exceptions exist for certain non-required items (see the PPE payment guidance), but equipment required by 1915.33 to prevent workplace hazards is generally employer-provided at no cost.

When a shipyard chemical exposure has no OSHA PEL, a competent person may evaluate the hazard and specify the necessary protection, as required by the shipyard rules; employers must follow the protections identified and applicable requirements such as 1915.33. See the OSHA letter Competent person requirements in shipyards which explains that a competent person is responsible for recognizing hazards and specifying protections.

• The competent person should assess exposures, consult industrial hygiene guidance or OELs (such as TLVs) where appropriate, and implement controls (ventilation, PPE, work practices) to protect employees.
• The employer remains responsible to ensure the competent person’s recommendations are implemented and effective.