3.1 Introduction. Environmental and health concerns have led to increased restrictions on coating operations. Material composition, surface preparation procedures, and application techniques have been affected. This chapter summarizes these restrictions and concerns. Detailed information on specific regulations related to these issues can be obtained from installation offices responsible for environmental, occupational, and safety issues.
3.2 Material Composition Issues
3.2.1 VOC Restrictions. VOCs make up the solvent portion of coatings. When emitted into the atmosphere, they may combine with oxides of nitrogen to form ozone, a major component of smog. The Clean Air Act of 1970 (amended in 1977 and 1990) requires states to develop and implement plans to ensure that the Environmental Protection Agency’s (EPA) National Ozone Standard (less than 0.12 parts ozone/million parts air (ppm), by volume) is met (National Ambient Air Quality Standard, 40 Code of Federal Regulations (CFR) 50). To help meet this requirement, some states and regions have placed limits on the VOC content of paints and coatings.
188.8.131.52 Definition of VOC. For paints and coatings, VOC is defined as the amount of volatile organic material measured in a specific test procedure. The test procedure used in most regions is EPA Method 24 (40 CFR 60, Appendix A). The VOC content that is measured following such a procedure may be different from that calculated based upon the coating formulation. For field applied coatings, the VOC is determined on the coating as it is applied. That is, if the coating was thinned for application, the thinner contributes to the VOC level.
184.108.40.206 Types of Regulations. VOC regulations may place a limit on the VOC content of liquid coatings or the amount of VOC that a coating shop can release into the atmosphere, or may require a minimum transfer efficiency, depending upon the local regulations. VOC-content regulations vary from region to region within states and between states, depending upon the ability of a region or state to maintain compliance with the National Ambient Air Quality Standard for ozone. VOC-content regulations may apply to either or both shop-applied coatings and field-applied coatings (architectural). Many regions of the country have restrictions on shop-applied coatings, but only a few have restrictions on architectural coatings. (However, a national rule for architectural coatings is expected to become effective in 1996.) For military facilities, rules affecting shop-applied coatings (e. g., the miscellaneous metal parts rule) are of
greatest concern to the facility. The VOC limit for miscellaneous metal parts is 340 grams per liter (g/L) in most parts of the country. This limit is the result of a 1978 Federal EPA guideline for shop-applied coatings for metals (commonly called miscellaneous metal parts) which 35 states adopted as part of their state implementation plans for VOC control. Regulations that limit the total amount of organic materials released into the air by a coatings shop are also in effect in some areas of the country. Architectural coatings are regulated in California and some other regions of the country. In California, the acceptable limits are based on the type of structure to be coated (e. g., residential versus industrial) and coating type. For example, for most coatings for residential use, the limit is 250 g/L and for steel in corrosive environments, the limit is usually 420 g/L. Some special use coatings have higher or unrestricted VOC limits. Since these regulations are subject to change and since they vary from region to region, a general listing of which paints comply with local regulations is not presented.
220.127.116.11 Effect on Coatings. Traditional solvent-borne coatings, such as alkyds and epoxies, have been reformulated to meet the VOC regulations by using binders with lower viscosities, modifying the solvents or using other techniques to lower the VOC content. As examples, an epoxy, MIL-P-24441 has been reformulated to have a VOC content less than 350 g/L. New lower VOC content coating types have also been developed by using other coating technologies such as waterborne or powder. VOC-induced trends in coating selection are summarized below:
a) Greater use of water-based paints
b) Greater use of high-solids paints
c) Less use of oil-based paints
d) Elimination of lacquers (vinyls and chlorinated
e) Increased use of powder coatings
In general, to obtain an acceptable service life, a cleaner, better prepared surface is required for low-VOC content coatings than for traditional higher vOc content coatings. Application of low-VOC content field-applied coatings may also be more difficult than higher VOC content coatings.
Problems have been encountered with the use of some low-VOC content paints. They are summarized in Table 2.
Problems Encountered With Low-VOC Coatings
3.2.2 Application Issues. In some regions of the country,
VOC emissions into the air have been further reduced by regulations restricting the methods of application of coatings to those with a minimum transfer efficiency of 65 percent. Transfer efficiency is defined as the percent of the mass or volume of solid coating that is actually deposited on the item being coated, as shown in the following formulas:
(Percent) = Mass of Solid Coating on Item x 100
Mass of Solid Coating Consumed
(Percent) = Volume of Solid Coating on Item x 100
Volume of Solid Coating Consumed
3.2.3 Toxic Solvents. Paints and coatings often contain
solvents that are toxic at some level. While a person can withstand nominal quantities of most of these ingredients for relatively short periods of time, continuous or overexposure to them may have harmful effects. The potential severity of hazards is greatly magnified when operations are performed in enclosed or confined spaces where toxic solvent concentrations can quickly build up to levels which could produce disability and death. The threshold limit values (TLV) for several commonly used paint and cleaning solvents are given in Table 3. The TLV is a measure of the maximum concentration of solvent vapor in the air which can be tolerated during an 8-hour working day. Since these
concentrations are very low, they are expressed as parts of vapor per million parts of air by volume (ppm). The higher the value, the safer the solvent.
3.2.4 Hazardous Air Pollutants. Some solvents currently used in coatings are on the list of hazardous air pollutants of the Clean Air Act. Restrictions on the use of some of these solvents in coatings are expected. Also, halogenated solvents currently exempted from VOC restrictions because of their photo-chemical inactivity, may be eliminated from use in coatings in the near future because they deplete the upper atmosphere ozone layer. In addition, halogenated solvents can become explosive when in contact with aluminum spray guns.
3.2.5 Binders – Polyurethanes, Coal Tars, Asphalts. Coatings formulated with these resins may required special worker safety measures. Respirators and protective clothing may be needed.
The material safety data sheet and the installations health and safety office should be consulted.
3.2.6 Heavy Metal-Containing Pigments and Additives. Lead – and chromate-containing pigments have been used in paints to provide color and corrosion control. Because of health concerns, a Federal regulation limits lead concentration in new consumer paints to less than 0.06 percent of the weight of the paint solids. Although chromium, as chromate, is not specifically excluded from paints by Federal regulation, the military guide specifications for painting facilities (NFGS-09900, Paints and Coatings and CEGS 09900, Painting, General) exclude chromate – containing coatings. Chromate is also on the ACGIH list of suspected carcinogens. Mercury-containing additives have been used to provide in-can bacteria control and paint-film mildew control. Because of health concerns, mercury can no longer be used in paints for residential use. Organic materials are used to control bacterial growth in the can and mildew growth on films.
Organo-tins have been used to control fouling on paints exposed to sea water. Because of the toxic effects of these materials, they have been restricted by the EPA. Copper- containing and some organic materials are being used to provide this protection.
Table 3 (Continued)
TLV and Other Safety Data on Paint and Cleaning Solvents
NOTES: (1) Relative evaporation time is the relative time
required for the solvent to completely evaporate, based on an arbitrary value of 1.0 for ethyl ether. The higher the number, the longer the time required for evaporation.
(2) Flash point is the temperature of the solvent in degrees F at which the solvent releases sufficient vapor to ignite in the presence of a flame. The higher the value, the safer the solvent with respect to flash point.
(3) Explosive limits define the range of solvent vapor concentration in air for which the vapor could explode or ignite. Below the minimum concentration and above the maximum concentration, the vapor will not ignite. These values are expressed as the percentage of the solvent vapor in the total volume of vapor plus air. They are also called flammable limits.
(4) Threshold limit values (TLV) were obtained from the American Conference of Governmental Industrial Hygienists (ACGIH), Threshold Limit Values for Chemical Substances and Physical Agents in the Workroom Environment. TWA is the time weighted average exposure limit for an 8-hour workday or a 40 hour week. STEL is the short-term exposure limit for a maximum 15-minute exposure. Both values are expressed as parts per million (ppm) of vapor per volume of air. The higher the value, the safer the solvent. These TLV’s are ACGIH’s recommendations; Occupational Safety and Health Administration (OSHA) limits may be lower.
3.3 Issues Affecting Surface Preparation
3.3.1 Regulations. This section is aimed at environmental
issues. Worker safety issues are discussed in Section 13. Environmental concerns and regulations affecting surface preparation activities involve contamination of the environment and waste disposal. Air regulations (National Ambient Air Quality Standards described in 40 CFR 50-99) that are closely associated with surface preparation and paint removal are the ones for air particulate matter (PM 10) and lead. Air particulate matter is defined as particles with an aerodynamic diameter less than a nominal 10 micrometers. The allowable limit is 150 milligrams per cubic meter, based on a 24-hour average concentration. For lead, the criterion is 1.5 milligrams per cubic meter, based on a 90-day average. Exceeding the PM 10 criterion is more likely during abrasive blasting than other coating operations.
To meet the air regulations described above, containment of work areas may be required. More extensive containment may be needed when removing lead-based paint. The Steel Structures Painting Council (SSPC) SSPC Guide 6I,
Containing Debris Generated During Paint Removal Operations, describes five categories of containment. Worker protection must also be considered in designing containment and ventilation systems. Protecting both the environment and the workers is a challenging task.
3.3.2 Waste. Debris resulting from surface preparation may
be hazardous waste as defined by Federal solid waste regulations (40 CFR 240-280). Waste may be classified as hazardous if it exhibits any of the following characteristics: ignitability,
corrosivity, reactivity, or toxicity, or if it is on a special EPA list. For paint debris, wastes are most likely to be hazardous because of their toxicity (e. g., exceeds limits for lead, cadmium, chromium or mercury) or because of their corrosivity (e. g., pH greater than or equal to 12.5 or pH less than or equal to 2). For toxicity, waste is tested using the toxic characteristic leaching procedure (TCLP) test, described in Appendix II of 40 CFR 261. Waste is classified as hazardous because of toxicity if lead concentration in the leachate exceeds 5 mg/kg, cadmium concentration exceeds 1 mg/kg, chromium concentration exceeds 5 mg/kg, or mercury concentration exceeds 0.2 mg/kg. Paint debris wastes fail most often because of lead. Some industrial paint wastes have also been reported to fail because of chromium or cadmium. Although paint debris may contain low concentrations of mercury from old films in which mercury additives were used to control fungal or bacterial growth, experience indicates that paint waste is unlikely to fail because of mercury toxicity.
3.4 Surfaces Coated With Leaded Paint. The presence of
lead in paint films causes health, environmental, and worker safety concerns. This section describes the DOD policy for dealing with leaded-paint associated problems and summarizes DOD guidance. References for specific guidance are given in the References section.
18.104.22.168 Use of Lead in Paint. Most oil-based residential
paints contained lead pigments prior to 1940. Lead pigments provided hiding and color (tints of orange, yellow, green, and red). Lead driers were used in both pigmented oil-based paints and varnishes. The concentrations of lead in white or light – colored paints sometimes exceeded 50 percent of the mass of the dry film. Concentrations of lead in paints colored using lead pigments ranged from 1 to about 10 percent of mass of the dry film. Lead driers were used in concentrations of a few tenths of a percent of the mass of the dry film. The use of lead hiding pigments decreased when titanium dioxide became available in the 1940’s, but it was not until 1972 that a Federal regulation set the maximum allowable level of lead in residential paint transported interstate at 0.5 percent. This level was reduced to 0.06 percent for all residential paints in 1978. Thus, lead – based paint abatement is directed primarily at housing built prior to 1978. For steel structures, lead-containing primers (e. g., those pigmented with red lead) have been used on military facilities until recently to control corrosion. Yellow traffic marking paints also may contain lead.
22.214.171.124 Effects of Lead Exposure on Health. Lead can cause a variety of serious adverse health effects. These are detailed in the Strategic Plan for Elimination of Childhood Lead Poisoning, Center for Disease Control, 1991. In children, even low levels of lead increase a child’s risk of developing permanent learning disabilities, reduced concentration and attentiveness spans, and behavior problems. Adverse health effects may occur before the appearance of any symptoms. Symptoms include loss of appetite, difficulty sleeping, irritability, fatigue, headache, moodiness, joint and muscle aches, and metallic taste in the mouth. High levels of lead concentrations can result in severe damage to the blood forming, nervous, urinary, and reproductive systems of the body. Lead poisoning from leaded paint typically occurs due to the ingestion of leaded paint or lead-contaminated dust into the body through the digestive system or inhalation. Peeling and chipping of leaded paint or abrasion of surfaces of leaded paint are primary pathways for lead poisoning.
126.96.36.199 Environmental Issues. Lead containing materials are a potential hazard to the environment when released in an uncontrolled manner. Proper containment of painting operations involving leaded paint and proper disposal of the debris are required to prevent contamination of soil, water and air. Debris generated during a maintenance painting job involving leaded paint may contain enough lead to be classified as a hazardous waste. If so, storage, transportation, treatment, and disposal of waste is governed by Federal regulations and applicable local and State regulations.
188.8.131.52 Occupational Safety Issues. Workers involved in leaded-paint removal are at risk for lead poisoning. Poisoning can result when the leaded paint is disturbed in a way that creates uncontrolled dust or small particles such as in sanding, open-abrasive blasting, chipping, grinding, and burning. The lead dust makes its way into an individual in many ways, including eating dust-contaminated food, hand-to-mouth activity, smoking cigarettes, and breathing dust-contaminated air. This hazard was addressed by in a rule published May 4, 1993 in the Federal Register, 29 CFR Part 1926.62. This rule amended their regulations for construction workers. It reduced the permitted level of exposure to lead for construction workers from 200 micrograms per cubic meter of air as an 8-hour TWA to 50 micrograms per cubic meter of air. Special worker-protection requirements are mandated when surfaces coated with leaded paint are disturbed, unless existing data show that the requirements are not needed. Training for workers aimed at both residential and non-residential activities is available from EPA-sponsored training centers and other private training groups.
3.4.2 Definitions. For the purposes of this discussion, residential structures are Government owned or leased family housing, child development centers, family child care homes, schools, playgrounds, and similar facilities. Target residential facilities are those constructed prior to 1978. Facilities constructed or included in whole-house revitalization or similar major rehabilitation projects since 1978, if paint coatings were removed or replaced, are considered free of lead-based paint. Non-residential structures include office buildings, warehouses, water towers, and the like. Lead-in-paint terms are defined in the following way:
a) Leaded paint – paint containing lead compounds as an ingredient at potentially hazardous concentrations.
b) Lead-based paint – a legislative term, defined by the U. S. Lead-Based Paint Poisoning Prevention Act as existing paint in residential structures having lead concentrations of
1 milligram per square centimeter or greater.
c) Lead-containing paint – a regulatory term, defined by the Consumer Product Safety Commission as residential paint (wet) offered for sale having a lead concentration greater than 0.06 percent by weight of the film solids.
3.4.3 DOD Policy/Instruction. The following sections summarize policy documents issued by DOD and military components for residential and non-residential structures (Table 4).
184.108.40.206 Residential Structures. DOD’s policy memorandum, Lead – Based Paint (LBP) – Risk Assessment, Associated Health Risk in Children, and Control of Hazards in DOD Housing and Related Structures, describes the DOD policy for residential structures.
A DOD instruction will also be developed. The DOD policy is to provide occupants of DOD residential structures (to include leased structures) a safe and healthful environment. The memorandum covers 1) assessing health risk from LBP and 2) controlling LBP hazards in DOD housing and related structures.
The memorandum states that DOD will assess and correct all recognized health-hazards in DOD residential structures and will negotiate for assessment and control of LBP in DOD-leased facilities. Control of LBP will be by either in-place management (IPM) or removal. Removal is to be performed when IPM cannot reliably control the lead hazard, or when removal is cost effective during renovation or upgrade. Specific procedures for carrying out the DOD policy are described in each of the military component’s documents shown in Table 4. The information is summarized in par. 3.4.4.
DOD and Military Component’s Policy Documents on Lead-Based Paint
220.127.116.11 Non-Residential. Although there is no corresponding DOD memorandum for non-residential structures, the Air Force,
Army and Navy have policy documents, referenced above, which prohibit the use of lead-containing paint on non-residential structures. (The Navy allows a slightly higher amount of lead in coatings for corrosion control – less than 0.3 percent by mass of the dry film – to account for possible contamination of zinc pigments by lead.) The Navy policy also states that surfaces covered with intact leaded paint do not represent a hazard until there is a need to remove or physically disturb the existing paint. Whenever surfaces covered with leaded paint are disturbed, for example during repair or as part of an operations and maintenance activity, special precautions may be required to ensure the safety of the workers and prevent contamination of the surroundings.
3.4.4 General Description of Lead-Based Paint Procedures.
Identification, risk assessment, and abatement procedures for lead-based paint in residential and non-residential structures may not be the same because of the differences in the way the structures are used and maintained.
18.104.22.168 Inspection/Assessment. The first step of inspection/assessment is to prioritize facilities to ensure that those most likely to have the worst lead-based paint problems are inspected first. Next, painted surfaces (using the Department of Housing and Urban Development (HUD) guidelines list of components and surfaces) are inspected to identify lead-based paint, lead – containing dust or lead-based paint hazards. For paint, portable x-ray fluorescence devices are used in conjunction with limited sampling of surfaces for laboratory atomic absorption spectrometric analysis. The data are analyzed to determine which surfaces present a high risk (e. g., peeling, chipping) to occupants. Both IPM and removal are part of all the strategies. The objective of the IPM is to reduce excessive exposure to lead and protect occupants from lead poisoning in facilities pending total removal of lead-based paint.
For non-residential structures, there are no written procedures for choosing surfaces for testing for leaded paint. The primary circumstance in which paint is tested on non-residential structures is just prior to preparing a contract for maintenance painting. At that time it is important that samples be taken for laboratory analyses to determine whether the paint contains lead. This is because special worker safety and environmental controls may be needed during coating maintenance to protect workers and the environment. Environmental controls include containment of debris to prevent it from polluting air, soil, or water.
Although there are no standard procedures for this inspection, it is important that enough samples be taken to obtain a representative lead concentration of the paint. All layers of the paint film must be included in the samples. Testing should also be undertaken prior to maintenance and operation activities that will cause significant amounts of leaded paint to enter the environment. Both worker safety and local containment of debris are of concern.
22.214.171.124 In-Place Management (IPM). IPM refers to a broad range of strategies and methods for controlling exposures to lead and preventing poisonings from lead in paint pending permanent removal. Because of the high number of facilities with lead-
based paint, immediate removal of all lead-based paint will not be possible. IPM includes cleaning up lead-contaminated dust, chipping, and peeling paint, and taking steps to stabilize lead – based paint to prevent additional peeling paint. IPM also includes monitoring surfaces painted with lead-based paint and appropriate periodic clean up of lead-contaminated dusty surfaces. It also requires maintenance and repair work be carried out with attention to the potential for creating lead hazards.
126.96.36.199 Removal. The Navy Guide Specification, NFGS-13283, Removal and Disposal of Lead-Containing Paint, and the Army Corps of Engineers Guide Specification (CEGS) 02090, Removal of Lead – Based Paint, provide guidance for removal of leaded paint in both residential and non-residential structures. The following issues must be considered for both types of structures:
a) Occupant safety
b) Building contents
c) Worker safety
d) Environmental protection (containment of debris)
f) Waste disposal
Detailed guidance for paint removal from residential structures can be found in the HUD guidelines. The SSPC has prepared three documents dealing with issues pertaining to removal of lead-containing paint from industrial structures:
SSPC Guide 6I; SSPC Guide 7I, Disposal of Lead-Contaminated Surface Preparation Debris, and SSPC QP2, Evaluating the Qualifications of Painting Contractors to Remove Hazardous Paint.
188.8.131.52 Operations and Maintenance. Special operations and maintenance activities may disturb lead-containing paint, for example repairing a light fixture. In these situations, special precautions are needed to:
a) Protect the worker
b) Control the spread of the dust that is generated
c) Ensure that debris is collected, handled, and disposed of properly
3.4.5 Waste Disposal. Wastes from some painting operations involving leaded paint may be classified as hazardous waste under the Resource Conservation and Recovery Act (RCRA). Regulations resulting from this act can be found in 40 CFR 240-280. For lead-containing wastes, these regulations require that a representative sample of the waste be tested using a standard procedure, the TCLP. If the amount of lead that is leached from the waste exceeds 5 mg/kg (ppm), the waste is classified as hazardous. In addition, if alkaline chemical strippers are used for removal, the waste may fail because of its alkalinity. If the debris is classified as a hazardous waste, special procedures are required for handling, transporting, treating and disposal. These requirements are described in detail in 40 CFR 260-268.
The cost for disposing of hazardous waste is many times greater than for non-hazardous waste.
3.4.6 Demolition of Buildings Containing Lead-Based Paint. Maintenance painting is not directly involved in demolition of buildings containing leaded paint. However, sampling and testing procedures to determine whether debris is hazardous due to the presence of lead are similar. In addition, restrictions on sorting the waste into hazardous and non-hazardous groups are similar. Information on disposing of demolition debris is available in guide specification (Sampling Protocol – Building Demolition Debris and Buildings Painted With Lead-Based Paint) prepared by HSHB-ME-SH, U. S. Army Environmental Hygiene Agency, Waste Disposal Engineering Division, Aberdeen Proving Ground, MD 21010-5422.
3.4.7 Sources of Detailed Information. Details of procedures for removing, abating, and managing existing lead-based paint on surfaces can be found in the references listed below:
a) Lead-Based Paint: HUD Interim Guidelines for
Hazard Identification and Abatement in Public and Indian Housing (can be obtained by calling 1-800-245-2691)
b) Air Force policy and guidance
c) Army policy and guidance
d) Navy policy and guidance