Keeping Yourself and the Environment Safe When You Paint

The small-scale surface preparation and maintenance painting operations performed by ships’ force personnel are a key element of the corrosion control and maintenance of ships and shipboard equipment. Unfortunately, dust is generated during these paint removal operations, and personnel are often exposed to potentially hazardous materials. NAVSEA is addressing this hazard by implementing state-of-the-art surface preparation equipment and reformulated, environmentally-friendly paints and coatings. These new tools, paints, and coatings will reduce the maintenance burden on ship’s force in addition to reducing the risk of hazardous material exposure.

Various elements that were once considered safe have now been designated hazardous by new environmental and worker safety regulations. Because of these current and pending regulations mandated by the Environmental Protection Agency (EPA) and the Occupational and Safety Health Administration (OSHA), the Navy’s traditional means of shipboard paint removal and surface preparation is obsolete. NAVSEA has had to reevaluate the Navy’s maintenance painting and forces-afloat preservation program in order to ensure that the equipment and procedures being used are environmentally Compliant. Changes in standard operating procedures are now being put in place to bring shipboard painting operations into regulatory compliance.

Among the various elements in Navy-specified paints which are now considered hazardous materials are lead and chromium. Until recently, both of these materials were commonly added to paints as corrosion inhibitors. NAVSEA has performed a large scale reformulation and testing program to replace lead and chromium with more environmentally-compliant materials without compromising corrosion control performance.

Of course, there is still a problem with the paints which are currently protecting shipboard structures. These paints continue to cause significant environmental and worker safety concerns upon t heir removal during regular maintenance.

According to a recent Navy Environmental Health Center (NEHC) study, 80 percent of the ships inspected had paints containing lead and chromium at levels greater than 0.01 percent by weight. Even at these relatively low concentrations, there is a potential for exceeding current federal limits for airborne lead and chromium in breathable dust. Thus, until these older paints which contain the hazardous lead and chromium are removed and replaced by new, compliant paint systems, the Navy must treat the dust generated during paint removal operations as hazardous material.

In addition to lead and chromium dusts, regulations are also in place which limit the amount of general airborne particulate matter emitted during surface preparation. These regulations are divided into general "nuisance" dust, and PM₁₀ rules. PM₁₀ includes all particles with a mean (i.e., average) diameter of 10 microns or less [Note: one microne = one millionth of a meter.] These dusts are hazardous since they are easily inhaled but are not easily expelled from the lungs.

Over the past several years, specific guidance regarding proper shipboard pain removal procedures has been issued. This guidance has ranged from Naval message traffic, including a recent message from the Chief of Naval Operations (CNO) which directed that no shipboard maintenance painting be conducted simply for cosmetic purposes, to the recent issuance of an updated Naval Ships Technical Manual (NSTM), Chapter 631-Preservation of Ships In Service (S9086-VD-STM-010). These documents are all helpful in addressing this often complicated problems, but the most detailed guidance available for proper environmental and worker protection procedures during shipboard paint removal operations is contained in OPNAVINST 5100.19C - NAVOSH Program Manual for Forces Afloat.

Specific guidance related to paint removal is contained in Chapter B6 - Respiratory Protection Program and Chapter B10 - Lead Control Program of the program manual. The manual includes detailed requirements for respirator use, hygiene practices, medical and dusts monitoring, required protective clothing, and worker training. [Note: In order to properly protect workers during shipboard paint removal, the equipment and procedures detailed should be used in conjunction with guidance provided by local Navy industrial hygiene personnel.] It also outlines the regulatory levels which must be met during surface preparation operations. The regulatory levels include:

• The action level (AL). The airborne concentration of a substance to which a person may be exposed without regard to the use of respirators. Expressed as a time-weighted average (TWA).
• The permissible exposure limit (PEL). The maximum concentration to which a person can be exposed while using protective equipment such as respirator. Also expressed as a TWA.
• The ceiling. The absolute maximum level of safe exposure and not an average.

Table 1 below summarizes these regulatory levels.

Proper removal and containment of lead and chromate-containing paints is a time consuming, expensive, and difficult task. When correctly followed, the procedures outlined in OPNAVINST 5100.19B will adequately protect workers and conform to environmental and worker safety regulations. However, Sailors performing the work must take personal responsibility for strictly following the regulations regarding respirators, protective clothing, and personal hygiene.

To ease the burden these current regulations place upon ship’s force personnel, NAVSEA conducted a large scale testing program: the Environmentally Acceptable Surface Preparation tool Test. The central focus of this program was to test and evaluate those power tools that demonstrated state-of-the-art dust control and waste collection capabilities. The goal was to reduce the risk of potential health hazards to ship’s force, to limit contamination of the environment during Fleet painting operations, and to maintain or improve the performance of current surface preparation tools.

The Tool Test program was designed in two phases. Phase I was an industry review of state-of-the-art surface preparation equipment and materials. This review identified the best candidates for shipboard evaluation. The following tools were selected for testing:

• 90 degree sander (shrouded/non-shrouded)
• mini rotopeen (shrouded/non-shrouded)
• rotopeen (shrouded/non-shrouded)
• needle gun (shrouded/non-shrouded).

Phase II of the program was the actual shipboard e valuation and testing of the selected power tools. Testing was conducted aboard five ships: USS Merrimack (AO 179, USS John F. Kennedy (CV 67), USS Scott (DDG 995), USS Butte (AE 27), and USS Nicholson (DD 982). Ship’s force personnel were actively involved in the testing of the tools. They operated the tools and then provided performance evaluations on each. Production rate, reliability, ease of use, degree of cleanliness achieved, tool accessibility (e.g., to be used in shipboard spaces), safety, physical size and weight, and dust control were all monitored. Industrial hygienists collected personnel air samples from each tool operator and dust "wipe samples" from the surrounding area. This data, along with the removed paint’s chemical composition, was used to determine the effectiveness of each tool to conform to the established regulatory limits. Tow key observations:

• Low levels of lead (i.e., less than 0.2 percent) in dry film can cause high levels of airborne lead even during short periods of work (i.e., less than 4 hours).
• It is important for workers to wear respirators for cleanup operations as well as for the actual work itself because a considerable amount of dust remains in the air even after the work is completed.

The testing revealed that, generally, using vacuum shrouded tools can increase the amount of time that can be worked before the AL for lead is reached. For example, the use of a vacuum shrouded needle gun can more than double the average amount of time worked (i.e., form 3 hours to 6.4 hours) before the AL for lead is reached. The shrouded sander, however, performed poorly in the test. Workers’ exposure to lead and nuisance dust increased compared to dust exposure produced by a standard unshrouded sander.

Based on the test results, NAVSEA recommends that hand tools used for shipboard work:

• Be lightweight (4-6 pounds).
• Be accessible to small, confined spaces without a great deal of effort.
• Require low maintenance.
• Have the ability to achieve SP-3 and SP-11 surface preparation.
• Have a non-interfering, locally exhausted ventilation (LEV) system.
• Contain a High Efficiency Particulate Air (HEPA) filtered vacuum with a waterlift of greater than 75 inches.

Most of the Sailors who participated in the test chose the needle gun as the easiest all-around tool to use. Of all the tools, needle guns seem to best meet the above recommendations. A "good" needle gun is lightweight and capable of accessing most shipboard areas. It is fitted with a vacuum shroud that reduces the airborne lead and dust levels while cleaning. This shroud should also be adjustable so the gun can reach tight spaces. The best performing needle gun design in the NAVSEA test had a hard plastic shroud with bristles at the mouth.

According to the tests, another tool which worked well on deck areas was the rotopeen. Rotopeens come in two sizes: 2.5 inches acrose the faceplate (i.e., base) and 4 inches across the faceplate. Both sizes are extremely have and difficult to use for long periods of time on vertical surfaces, but they do give a good profile and can be easily used on deck areas. One way rotopeens can be effectively utilized on vertical surfaces is to clean the paint off with a needle gun, and then use a rotopeen to go over the surface quickly and impart a profile on the metal substrate.

An HEPA vacuum should be hooked up to the shroud of the tool with a standard vacuum hose to provide LEV. The vacuum is used to remove the dust, debris, and chips from the work area. HEPA filtered vacuum requirements have at least 75 inches waterlift. During the testing, it was difficult to get enough pressure from the ship’s low pressure air to operate an air powered vacuum at the required cubic feet per minute (cfm) and waterlift. An electrically-powered vacuum is smaller and much easier to work with.

For more information on environmentally- and worker-safe shipboard surface preparation and painting, or if you have any questions regarding the shipboard surface preparation tool test, contact: Andrew Seelinger, NAVSEA 03M1; DSN: 332-0214 x107; commercial: 703-602-0214 x107; fax: 703-602-0247

Andrew Seelinger is a materials engineer in NAVSEA’s Corrosion Control Division (SEA 03M1).

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