Methylene Chloride Issue

The purpose of this article is to put to rest confusions and inaccuracies regarding Methylene Chloride through hearsay and misinformation in trade publications. It will provide you with pertinent information as to what you must do when using Methylene Chloride based finish removers in furniture stripping and refinishing. Let me point out that Methylene Chloride is not being removed from the market and, Methylene Chloride based finish removers will be around for a very long time.

Workplace safety is a very critical area to be concerned with by a shop owner. Violation of any safety laws and regulations can be very expensive. In the mid 1990's, the US Occupation and Health Administration (OSHA) dramatically increased the minimum recommended penalties for willful, serious violations of workplace safety rules. The penalties for small businesses (those with 25 or fewer employees) increased from $5,000 to $25,000.

Pleading ignorance to workplace safety is no excuse. OSHA obligates you to know better as one shop owner recently found out. He got slapped with a $6,000 fine for Methylene Chloride safety violations. Here is the real scoop.

Effective January 10, 1997, the Occupational Safety and Health Administration (OSHA) adopted a final rule on occupational exposure to Methylene Chloride through skin contact and/or inhalation. The new standard sets an exposure limit to 25 parts per million (ppm) in an average 8 hour time period. That means that a worker stripping furniture can be exposed to a maximum of 25 ppm to Methylene Chloride during an average 8 hour time period. The previous standard was 500 ppm.

Equally important, the new standard also sets a short-term exposure limit (STEL) to 125 ppm over a 15 minute time period, which implies that taking frequent breaks from stripping furniture is essential to meeting the threshold limit. More significant, however, the new standard also sets a 12.5 ppm action level which triggers periodic exposure monitoring and medical surveillance as detailed below.

The following shops are exempt from this rule:

those that strip less than 30 days per year
where the owner(s) do the actually stripping of furniture, not employees
self-employed contractors are used to do the actual stripping (given 1099)

Engineering controls may be required based on results from initial monitoring to reduce exposure concentrations above the standard. The term "Engineering Controls" is a frightening term to everyone which is causing most of the panic. In plain English, engineering controls means installation of whatever equipment is necessary to reduce worker exposure to Methylene Chloride. Engineering controls does not mean having to deal with expensive engineering consultants, unless you wish to do so. These controls are detailed further in this pamphlet.

Furniture Strippers and Refinishers with fewer than 20 employees have until April 10, 2000 to implement engineering controls to comply with the new standards. Those with 20 or more employees had December 1998 to implement the controls.

Why have these new standards been imposed? The National Institute for Occupational Safety and Health (NIOSH) has determined that Methylene Chloride is a potential carcinogen. Overexposure to this chemical through the skin or inhalation, as perceived by NIOSH, can cause cancer. This determination was based on the observation of cancer development in rats and mice when exposed to extremely heavy concentrations of Methylene Chloride in the air. Equally important, per NIOSH, the available human studies do not provide the necessary information to determine whether Methylene Chloride causes cancer in humans. Therefore, no one agrees with NIOSH including EPA, American Medical Association and American Cancer Society. Nonetheless, as a result of the animal studies, Methylene Chloride has been determined as a potential occupational carcinogen hence, OSHA has taken a major step in minimizing the exposure of workers to this chemical.

Aside from engineering controls, medical surveillance is also required. Shops with fewer than 20 employees must have made an initial medical surveillance available to those workers exposed to Methylene Chloride by April 10, 1998. Those shops with more than 20 employees had October 7, 1997 as the deadline for initial medical surveillance.

To find out if engineering controls will be required, initial monitoring of employees exposed to Methylene Chloride must be determined. Those with 20 or more employees had until August 8, 1997 to do the initial monitoring. Shops with fewer than 20 employees had to provide initial monitoring by February 4, 1998.

Initial monitoring is not required if employees are exposed to Methylene Chloride for less than 30 days per year. Initial monitoring is also discussed further below.

Below are things you must do to conform, avoid fines and protect yourself and your employees at the same time.

DO INITIAL MONITORING

If you have less than 10 employees, contact your local (state level) OSHA office. As a small business they can provide you with the initial monitoring tests free of charge. You will not be opening up Pandora's box. Otherwise, contact your local health department and they will provide you with names of firms that will do such a test for a fee.

DO INITIAL AND PERIODIC MEDICAL SURVEILLANCE

Send those employees who strip furniture for a complete physical, including blood work and EKG, as soon as possible. Preferably send them for blood work at the end of a work shift instead of before work. Specifically check for carbon monoxide level which affects the blood's ability to carry oxygen - but so does cigarette smoking. Continue providing same complete physical annually to those over the age of 45 and every three years to those under the age of 45. A complete physical, without a stress test, should run between $250 and $300 - a cheap investment for your and their peace of mind. Local Insta-Care clinics can perform these medical tests for your employee(s).

Note: by law, test results from these physicals must be provided to the employee(s) within 15 days of availability. Furthermore, employers must make required medical surveillance available to affected employees at no cost, without loss of pay, and at a convenient time and place.

IMPROVE VENTILATION (ENGINEERING CONTROLS)

These figures below depict two samples among many of possible exhaust ventilation designs. The first figure below is nothing more than an elaborate exhaust hood similar to the ones found in your own kitchen above the stove.

Figure below is a slot hood type. Same exhaust systems would apply if you have a dip tank in place of a flow-over tray. Contact your local HVAC contractor found in the yellow pages to design and install a system most suitable for your stripping operation. The exhaust system should be made out of polypropylene or galvanized steel. The air flow recommended by NIOSH for the exhaust and make-up air should be between 1,500 and 3,000 cfm, depending on the size of the stripping area.

ISOLATE STRIPPING AREA FROM THE REST OF THE SHOP

Isolate, close off or relocate the stripping area to a separate room away from the rest of the shop. Think of a spray booth for solvent based lacquers, particularly for spraying polyester. For effective cross ventilation, make certain that there is plenty of make-up air supplying the isolated stripping area or room.

PROVIDE FREQUENT WORK BREAKS

To minimize exposure, frequent breaks from stripping furniture is highly recommended. Strip for half an hour then take a 5 to 10 minute break, outside in fresh air. Another alternative is, one hour on one hour off. Strip for one hour then do other work away from the stripping area for an hour.

POSITIVE PRESSURE BREATHING RESPIRATORS

If increased ventilation (or other engineering controls) does not meet the new standards, (which will not), self contained, positive-pressure breathing mask (PPBM) can be employed, provided that exposure to Methylene Chloride is below 650 ppm. These continuous air flow breathing masks (half-face or full-face) are approved by NIOSH and OSHA as alternatives to engineering controls, provided installation of engineering controls is not economically feasible and, exposure is below 650 ppm. For shops with less than 10 employees, engineering controls will be too expensive to install hence, not feasible.

In summary, do the best you can to improve the ventilation by April 10, 2000 and get a Positive Pressure Breathing System by April 30,2000 for whomever does the stripping . Not having both in place will cost you hefty fines unless your shop is exempt.

WARNING: air purifying organic vapor respirators are no longer approved by OSHA for use with Methylene Chloride based removers and subject to fines if caught wearing them after April 30, 2000.