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Commandant United States Coast Guard
2100 Second Street, S.W.
Washington, DC 20593-0001 Staff Symbol: CG-45 Phone: (202) 267-2003 Fax: (202) 267-4742
COMDTNOTE 10360
9 JUN 2006
COMMANDANT NOTICE 10360 CANCELLED 9 JUN 2007
Subj: CH-1 TO THE COATINGS AND COLOR MANUAL, COMDTINST M10360.3C
1. PURPOSE. This Notice publishes changes to the Coast Guard Coatings and Color Manual, COMDTINST M10360.3C.
2. ACTION. Area and district commanders, commanders of maintenance and logistics commands, commanding officers of headquarters units, assistant commandants for directorates, Judge Advocate General, and special staff offices at Headquarters shall comply with the provisions of this Notice.
Internet release authorized.
3. DIRECTIVES AFFECTED. None
4. SUMMARY OF CHANGES. Changes to ref a, which are denoted by ‘bold’ type, include:
a. Chapter 1:
Revised to clarify guidance on the Coatings and Color Manual waiver/prototype process, reflect recent organizational changes, and points of contact for coatings guidance.
b. Chapter 3:
Revised to clarify definition of paint containing lead exposure and handling requirements.
DISTRIBUTION – SDL No. 145 a b c d e f g h i j k l m n o p q r s t u v w x y z
A 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 B 8 20 1 5 31 5 3 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 C 1 1 3 1 3 3 1 5 1 1 2 1 1 1 1 5 1 D 1 1 1 1 1 1 1 1 1 E 1 1 1 1 F G 1
NON-STANDARD DISTRIBUTION: *B:c MLCs (6 extra); *D:l SWOSCOLCOM, ATG Mayport (3 extra), ATG Norfolk (3 extra), ATG San Diego (3 extra), ATG Pearl Harbor (3 extra), TAFT Roosevelt Roads only
c. Chapter 5:
Revised to include more detailed information on removing soluble salts. Added/revised surface preparation standards. Modified table for average profile heights obtained with various abrasives. Provided greater detail on abrasives to be used for aluminum substrates. Removed/ revised references for fiberglass repair.
d. Chapter 9:
Revised list of Critical Coated Surfaces, reflected recent organizational changes, and authorized corrosion inhibitive thermoplastics.
e. Chapter 10:
Clarified the requirements for which cutters shall install photoluminescent Bull’s Eyes.
f. Chapter 11:
Revised Deck Machinery section and Table 11-3: Miscellaneous Details and Fittings.
Reflected recent organizational changes and clarified application of non-skid to weather decks.
g. Chapter 12:
Removed reference to the DOT Graphics Standards Manual. Reflected recent organizational changes. Added Coast Guard diagonal stripe color scheme for use on red hull icebreakers.
Added 6 inch letters to be used for miscellaneous boats greater than 24 feet.
h. Appendix A:
Modified underwater body and boot-top antifouling systems for steel and fiber reinforced plastic hulls with two options for up to 7 years and up to 12 years, nominally. Added underwater body and boot-top antifouling system for high speed aluminum hulls. Added weather deck slip resistant sheet installation for fiber reinforced plastic hulls
i. Appendix B:
Modified to reflect new requirement for low VOC versions of corrosion preventive compounds.
j. Appendix C:
Added generic material classes for high speed non-copper antifoulants and corrosion inhibitive thermoplastics and added coatings approved under these generic categories. Replaced NEHC approval as a criteria for potable water tanks with QPL authorization for MIL-PRF-213236.
Authorized gray slip resistant sheet material to replace the current black material. Updated the list of CG approved coatings/materials and contact information for associated vendors.
Corrected the definitions of the anti-abrasion coating systems for icebreakers.
5. PROCEDURE.
a. Remove and insert the following
(1) Table of Contents
(2) Chapters 1, 3, 5, 9, 10, 11 and 12
(3) Appendices A, B, and C
6. CHANGES. Recommendations for improvements to this Manual should be submitted via the chain of command to the Commandant (CG-45).
7. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS. This Manual meets the Coast
Guard's Categorical Exclusions #4, from the National Environmental Policy Act. This Manual addresses Coast Guard routine maintenance and contains no significant procedural or materiel changes.
8. FORMS AVAILABILITY. Forms called for in this Manual, Request for Allowance Change, Form CG-5323, and Request For Directives, CG-4428, are available in USCG ADOBE Forms on SWSIII or on the Internet at http://www.uscg.mil/ccs/cit/cim/forms1/welcome.htm or the Intranet at http://cgweb2.comdt.uscg.mil/cgforms/ . The form DOD Single Item Requisition System Document, DD-1348-6, must be ordered through the Navy, stock number 0102LF0132272.
D. G. GABEL, RADM /s/ Assistant Commandant for Engineering and Logistics
Encl: (1) CH-1 to the Coast Guard Coatings and Color Manual, COMDTINST M10360.3C http://www.uscg.mil/ccs/cit/cim/forms1/welcome.htm http://cgweb2.comdt.uscg.mil/cgforms/
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DISTRIBUTION – SDL No. 142 a b c d e f g h i j k l m n o p q r s t u v w x y z
A 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 B 8 20 1 5 31 5 3 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 C 1 1 3 1 3 3 1 5 1 1 2 1 1 1 1 5 1 D 1 1 1 1 1 1 1 1 1 E 1 1 1 1 F G 1
NON-STANDARD DISTRIBUTION: *B:c MLCs (6 extra); *D:l SWOSCOLCOM, ATG Mayport (3 extra), ATG Norfolk (3 extra), ATG San Diego (3 extra), ATG Pearl Harbor (3 extra), TAFT Roosevelt Roads only
Commandant United States Coast Guard
2100 Second Street, S.W.
Washington, DC 20593-0001 Staff Symbol: G-SEN Phone: (202) 267-2003 Fax: (202) 267-4742
COMDTINST M10360.3C
11 MAR 2005
COMMANDANT INSTRUCTION M10360.3C
Subj: COATINGS AND COLOR MANUAL
1. PURPOSE. This Manual promulgates Coast Guard coating and color policy and selected procedures for all vessels, buildings, structures, fixed equipment and aids to navigation.
2. ACTION. Area and district commanders, commanders of maintenance and logistics commands, commanding officers of headquarters units, assistant commandants for directorates, Judge Advocate General, and special staff offices at Headquarters shall comply with the provisions of this Manual.
Internet release authorized.
3. DIRECTIVES AFFECTED. Coatings and Color Manual, COMDTINST M10360.3B is canceled.
4. SUMMARY OF CHANGES. This revision incorporates all changes to previous editions of the Coatings and Color Manual and the following significant new changes:
a. Chapter 1:
Revised to include guidance on the Coatings and Color Manual change process, feedback via the Naval Engineering Forum website, and points of contact for coatings guidance.
b. Chapter 2:
Added detailed information about safety and personal protection equipment required for high pressure water coatings removal (water jetting).
c. Chapter 3:
Addressed environmental concerns with surface preparation by water jetting and highlighted anticipated future VOC regulations.
d. Chapter 4:
Revised Table 4-3 Coatings Preservation QA Checklist to check for soluble salt with conductivity measurements rather than chloride content.
e. Chapter 5:
Revised to include detailed information on testing for soluble salts. Also included are refined procedures and environmental considerations for water jetting. Removed/revised references for fiberglass repair.
f. Chapter 6:
Updated information on use of solvents and thinners and deleted Table 6-1
g. Chapter 9:
Revised list of Critical Coated Surfaces, updated information on use of rust converters, and added reference to U.S. Navy Uniform Industrial Process Instruction for powder coating application.
h. Chapter 10:
Revised the requirements for which cutters shall install photoluminescent Bull’s Eyes.
Additionally, clarified where photoluminescent markings are required vice suggested.
i. Chapter 11:
Updated Table 11-2: Underwater Body, Boot-Top, and Freeboard Colors. Defined International Orange as authorized color for boat collars and fixed fendering. This color will be matched as close as possible within limitations of material. Revised Table 11-3:
Miscellaneous Details and Fittings to remove ambiguity about color of hooks used for boat davits, cranes, or cargo booms. Authorized COs/OICs to paint interior/exterior areas with flat black paint as necessary to reduce glare. Authorized painting bilges and cofferdams light gray to facilitate inspection.
j. Chapter 12:
Added information on finding the proper display requirements for cutter Achievement Awards.
k. Appendix A:
Added Polysiloxane as authorized coating system for boat foam filled collars. Authorized non-working areas of buoy deck to be coated with Organic Zinc/High Build Epoxy, color to match working areas. Simplified the icebreaker classifications for defining the underwater body coating systems.
l. Appendix B:
Allowed the use of coarse slip resistant sheet material in place of MIL-D-17951 where greater durability and performance are needed.
m. Appendix C:
n. Updated the list of CG approved coatings/materials and contact information for associated vendors. Modified the definitions of the anti-abrasion coating systems for icebreakers.
o. Appendix D:
This newly drafted appendix discusses and outlines the various requirements for new ship construction.
5. REQUESTS FOR CHANGES. Recommendations for improvements to this Manual should be submitted via the chain of command to the Commandant (G-SEN) as per Chapter 1.
6. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS. This Manual meets the Coast Guard's Categorical Exclusions #4, from the National Environmental Policy Act. This Manual addresses Coast Guard routine maintenance and contains no significant procedural or materiel changes.
7. FORMS AND REPORTS AVAILABILITY. Forms called for in this Manual are available in USCG ADOBE Forms on SWSIII or on the Internet at http://www.uscg.mil/ccs/cit/cim/forms1/welcome.htm or the Intranet at http://cgweb.uscg.mil/g-ccs/g-cit/g-cim/forms1/main.asp . The form Request For Directives, CG-4428, stock number 753000F020620, must be ordered from ELC and the form DOD Single Item Requisition System Document, DD-1348-6, must be ordered through the Navy, stock number 0102LF0132272.
ERROLL BROWN /s/ Assistant Commandant for Systems
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Coatings and Color Manual
Table of Contents
Chapter Section Title Page
1 INTRODUCTION
A Purpose 1-1 B Change Process 1-1 C Exemptions 1-2 D Distribution 1-2 E Ordering 1-2 F Feedback 1-2 G Points of Contact 1-2
2 SAFETY AND OCCUPATIONAL HEALTH
A General 2-1 B Operational Risk Management 2-1 C Storage and Disposal Hazards 2-1 D Paint Operations Hazards 2-1
3 ENVIRONMENTAL LAW AND POLICY
A General 3-1 B Procurement 3-1 C Surface Preparation Issues 3-2 D Painting Issues 3-3 E Waste and Air Emission Management Reduction 3-4 F Waste Disposal 3-7
4 PAINTING ORGANIZATION AND SUPERVISION
A Frequency of Painting 4-1 B Weather Conditions 4-1 C Procurement of Paint 4-2 D Ordering and Receipt of Paints 4-2 E Organizing for the Job 4-3 F Paint Records 4-4 G Contract Painting 4-5 H Reports of Deficient Paint 4-5
CH-1 i
5 PREPARATION OF SURFACES
A General 5-1 B Health and Environmental Considerations 5-1 C Surface Cleanliness and Contaminant Removal 5-1 D Surface Preparation Methods 5-2 E Preparation and Repair of Particular Substrates 5-6 F Repair of Surfaces 5-12
6 PAINT MATERIALS
A General 6-1 B Paint Chemistry 6-1 C Paint Pigments 6-4 D Solvents and Thinning 6-5
7 STORAGE, PREPARATION, AND APPLICATION OF PAINT
MATERIALS
A Stowage Areas 7-1 B Paint Distribution 7-1 C Containers 7-1 D Storage 7-1 E Paint Conditioning and Mixing 7-2 F Brush Application 7-3 G Roller Application 7-5 H Spray Painting 7-8
8 PAINT DETERIORATION AND FAILURE
A General 8-1 B Types of Deterioration and Failure 8-1
9 CUTTERS AND BOATS GENERAL INFORMATION AND
MAINTENANCE PAINTING
A When To Paint 9-1 B Changing Painting Practices 9-1 C Vessel Maintenance Painting 9-2 D Critical Coated Surfaces 9-3 E Rust Converters and Stabilizers 9-3 F Reconstruction Primers 9-3 G Powder Coatings 9-3 H Stripe Coats 9-4 I Corrosion Inhibitive Thermoplastics 9-5
CH-1 ii
10 CUTTERS AND BOATS SAFETY COLORS AND MARKINGS
A Colors For Safety 10-1 B The Coast Guard Safety Marking System 10-1 C The Navy Damage Control Marking System 10-3
11 CUTTERS AND BOATS COLORS - EXTERIOR AND INTERIOR
A General 11-1 B Exterior Spaces 11-1 C Interior Spaces 11-10
12 CUTTER AND BOAT IDENTIFICATION MARKINGS
A General 12-1 B Markings 12-1
13 FACILITIES COLORS AND IDENTIFICATION
A Exterior Colors 13-1 B Interior Colors 13-2 C Colors for Safety 13-6
14 FACILITIES PAINTING SYSTEMS
A Introduction 14-1 B Tables 14-1 C Items Not Included in Tables 14-2 D Individual Item Painting Guidance 14-3
15 FACILITIES SIGNS
A Signs 15-1 B Safety and Warning Signs 15-2 C Accident Prevention Signs 15-2 D Coast Guard Identification Signs 15-2 E Signs and Markers for Inactive Units 15-3 F Traffic Control Signs 15-3
CH-1 iii
16 PROTECTIVE COATINGS FOR AIDS TO NAVIGATION
A Steel Ocean Buoys 16-1 B River Buoys 16-3 C Foam Buoys 16-4 D Plastic Buoys 16-4 E Minor Fixed Aids to Navigation 16-4
APPENDICES
Appendix A: CUTTERS AND BOATS EXTERIOR PAINTING SYSTEM Appendix B: CUTTERS AND BOATS INTERIOR PAINTING SYSTEM Appendix C: COATINGS AUTHORIZED FOR USE ON CUTTERS AND BOATS Appendix D: NEW CONSTRUCTION REQUIREMENTS FOR COATINGS AND
CORROSION CONTROL OF UNITED STATES COAST GUARD VESSELS
CH-1 iv
CHAPTER 1. INTRODUCTION
A. Purpose. The Coatings and Color Manual, COMDTINST M10360.3 (series), is published to promulgate Coast Guard coating and color policy and selected procedures for all vessels, buildings, structures, fixed equipment, and aids to navigation. While the Coatings and Color Manual, COMDTINST M10360.3C, does authorize different coating systems from revision B, implementation of this Manual does not constitute a significant change in Coast Guard policy. Accordingly, this Manual qualifies for Categorical Exclusion 33 under the National Environmental Policy Act (NEPA) and therefore does not require NEPA analysis.
Note: Aircraft and Vehicles. For information on painting or preservation of aircraft, refer to the applicable Technical Notes listing the reference drawings maintained by Aircraft Repair and Supply Center. For information on painting vehicles refer to Motor Vehicle Manual, COMDTINST M11240.9 (series).
B. Change Process. To ensure this Manual remains up-to-date, coincides with current practices, and continues to meet program needs, future change proposals shall be forwarded as specified in the following paragraphs.
1. Change proposals may be originated at any organizational level. Proposals shall be submitted by letter to Commandant (CG-45) via their cognizant Maintenance and Logistics Center (MLC).
Headquarters units and program managers may submit their proposals directly to Commandant (CG- 45).
2. MLCs shall review, endorse, and forward approved proposals to Commandant (CG-45).
Disapproved requests shall be returned to the originator with an explanation for disapproval.
3. Upon receipt, Commandant (CG-45) will initiate the following action:
a. Conduct a thorough investigation of each proposal to justify the need, identify possible conflicts with other directives and publications, and assess the affects of implementation.
b. Forward the proposal to the Engineering Logistics Center (ELC) technical point of contact for a technical review.
4. The ELC responsibilities include:
a. Conduct a technical review of all change proposals.
b. Return any disapproved change request to the originator with an explanation for the disapproval.
Maintain custody of all approved change requests for inclusion into the next change to the Manual.
c. When directed by Commandant (CG-45), collate all change proposals and supporting documentation into a package and forward to Commandant (CG-45) for concurrent clearance routing and approval.
5. Commandant (CG-45) is the final approving authority and has overall responsibility for the Coatings and Color Manual, COMDTINST M10360.3 (series).
a. All approved changes will be promulgated by future change notices to this Manual.
CH-1 1-1
b. Changes that require immediate action shall be submitted directly to Commandant (CG-45) via message, information copy to the ELC and MLCs.
C. Exemptions. All units shall comply with the requirements of The Coatings and Color Manual, COMDTINST M10360.3(series) unless otherwise authorized by CG-45. CG-45 may authorize variance from this manual for color, prototype, and material substitution. For cutters and boats, ELC may authorize variance from this Manual for prototype evaluation purposes only (ELC(024) for non-standard boats, ELC(01) for cutters and standard boats). For shore facilities and buoys, Commandant (CG-43) may authorize variance from this manual for prototype evaluation purposes only. MLCs may authorize variance from COMDTINST M10360.3(series) only when material substitutions are required to meet operational requirements. All authorized variances from COMDTINST M10360.3(series) shall be in CG Letter format addressed to the applicable unit, and copied to CG- 45, ELC and MLC (as applicable). Units seeking a waiver from this Manual for cutters and boats shall submit their request to Commandant (CG-45), via their cognizant MLC(v), copy ELC(01) and ELC(024). Units seeking a waiver from this manual for shore facilities and buoys shall submit their request to Commandant (CG-45) via their cognizant MLC(s) and Commandant (CG-43). Units seeking to test new coating systems or materials on cutters and boats shall submit prototype requests to: ELC(01) for standard boats and ELC(024) for non-standard boats; via their cognizant MLC(v); copy to Commandant (CG-45), ELC (024) if appropriate, non-cognizant MLC(v), and the Acquisition Program Manager, if appropriate. Letter reports of performance data will be described in the approval document.
Units seeking to test new coating systems or materials on shore facilities and buoys shall submit prototype requests to Commandant (CG-45) via their cognizant MLC(s) and Commandant (CG-43).
D. Distribution. Commandant (CG-45) shall determine distribution of this Manual. Requests for changes to the distribution should be submitted on "Request for Allowance Change" (Form CG-5323), addressed to Commandant (CG-612), via the chain of command.
E. Ordering. The Directives Publication and Reports Index (DPRI), COMDTNOTE 5600 provides guidance for ordering The Coatings and Color Manual, COMDTINST M10360.3 (series), and its associated changes. Request For Directives, (Form CG-4428), ordered from ELC, shall be completed and forwarded to the appropriate stockpoint. The Manual is also available on the Commandant (CG-45) website at http://cgweb.comdt.uscg.mil/g-sen/gsen.htm and the Coast Guard Directives website at http://www.uscg.mil/ccs/cit/cim/directives/welcome.htm or http://cgweb.uscg.mil/g-c/g-ccs/g-cit/g-cim/directives/welcome.htm .
F. Manual Changes. Denoted by bold type.
G. Feedback. All errors, omissions, discrepancies, questions, and suggestions for improvement regarding this Manual can be reported on the Naval Engineering Forum website at http://cgweb.lant.uscg.mil/vdiv/NEForum/ under the “Paint” category.
H. Points of Contact.
1. Manual Manager: Office of Naval Engineering, Environmental Projects
(CG-453), (202) 267-2003
2. ELC Coatings Technical Expert: (410) 762-6739
3. MLCA (vs) Coatings Technical Expert: (757) 628-4573
4. MLCP (vs) Coatings Technical Expert: (510) 637-5942
CH-1 1-2
http://cgweb.comdt.uscg.mil/g-sen/gsen.htm http://www.uscg.mil/ccs/cit/cim/directives/welcome.htm http://cgweb.uscg.mil/g-c/g-ccs/g-cit/g-cim/directives/welcome.htm http://cgweb.uscg.mil/g-c/g-ccs/g-cit/g-cim/directives/welcome.htm http://cgweb.lant.uscg.mil/vdiv/NEForum/
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CHAPTER 2. SAFETY AND OCCUPATIONAL HEALTH
A. General. Ensuring the Occupational Safety and Health (OSH) of Coast Guard personnel shall be an intrinsic element of all operations. Personnel involved in the planning and execution of painting operations and/or the storage and disposal of painting materials shall ensure that management of OSH risks are their highest priority.
Application of this principle is particularly important due to the variety and potential severity of the hazards associated with the use and storage of paint systems and supplies.
B. Operational Risk Management (ORM). In accordance with Operational Risk Management, COMDTINST
3500.3 (series), personnel conducting painting operations shall apply ORM principles to manage all applicable OSH risks. Key steps to the ORM process are recognition of hazards, evaluation of the risks posed by those hazards, and use of risk vs. gain to determine how to control such hazards. The following sections discuss specific hazards often associated with paint operations; these are not all inclusive and are not a substitute for a full hazard analysis of a painting operation. The MLC Safety & Environmental Health staffs are available to assist in the ORM process.
C. Storage and Disposal Hazards. Paint and paint-related products shall be stored and disposed of in accordance with the Hazardous Waste Management Manual, COMDTINST M16478.1 (series) and Chapter 3 of this Manual.
1. Paints should only be stored in tightly sealed containers. When the top is left off the can, or when the lid is not tightly closed, volatile liquids in the paints can more easily vaporize.
2. Limit the amount of paint in the mixing areas to one day’s supply and store the bulk of the paint in a separate area. Paint left over from a day's work must be tightly closed and returned to the paint storage cabinet.
3. Rags, rope, and other combustible material must be kept clear of the paint mixing room or storage area.
Disposing of brushes is preferred to storing for later use. However, if wet brush stowage tanks are used, they shall be equipped with sheet metal covers to prevent evaporation of volatile solvents. For additional requirements see the Civil Engineering Manual, COMDTINST M11000.11 (series) and 29 CFR 1910.106.
4. Guard against spontaneous combustion in paint lockers. Oils of organic origin dry by oxidation and produce heat that can lead to spontaneous combustion. If this heat cannot escape, it accumulates to the point of igniting the organic materials and results in fire. Linseed oil, turpentine, and fish oils are of organic origin and can form serious fire hazards when left in rags. These rags shall not be stored in paint storage cabinets, they shall be stored in metal containers with self-closing lids.
5. Mineral spirits evaporate rather than oxidize. While spontaneous combustion will not be caused by evaporation of mineral spirits, ventilation is important to rid the area of highly explosive vapors. Containers of paints, paint thinners, paint removers, and all associated or similar materials, must be kept sealed and all rags or organic solid materials must be removed from the area and stored in metal containers with self-closing lids.
D. Paint Operations Hazards.
1. General. Many paints, paint systems, and related solvents are hazardous. During mixing and application, they can create atmospheres which are explosive, can create highly flammable mixtures, and can be highly toxic to applicants and nearby occupants. Removal of these products can also create a number of chemical and physical hazards. Whenever feasible, hazardous coating materials should be replaced with less- or non-hazardous materials. Some good general guidelines for all paint operations include:
2-2
a. Ensure all personnel applying, mixing, or removing paints have read the product’s Material Safety Data Sheet (MSDS) and are following its recommendations. Personal protective equipment, including respiratory protection and protective clothing, shall be used appropriately and proper handling procedures shall be followed.
b. Store paint and solvent containing materials and supplies in well ventilated areas, away from heating equipment, open flames, direct sunlight, and flammable/combustible materials.
c. DO NOT SMOKE, EAT, OR DRINK while mixing or applying these materials. No welding, grinding, or cutting shall be allowed in areas adjacent to painting operations.
2. Paint Application.
a. Special Hazards of Painting in Confined Spaces. A “confined space” is defined as a space that: 1) is large enough and so configured that an employee can bodily enter and perform assigned work; and
2) has limited or restricted means for entry or exit; and 3) is not designed for continuous employee occupation. A “permit required confined space” is a confined space that has one or more of the following characteristics: 1) contains or has a potential to contain a hazardous atmosphere, 2) contains a material that has the potential for engulfing an entrant, 3) has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section, or 4) contains any other recognized serious safety or health hazard. Guidance for confined space entry depends upon the location and function of the space in question. For Coast Guard boats and vessels in a yard or in a repair status, (e.g. dockside availability), NFPA 306 and 29 CFR 1915 apply. For Coast Guard vessels afloat, Chapter 077 of the Naval Engineering Manual, COMDTINST M9000.6 (series) and Naval Ships Technical Manual (NSTM) 074 Volume 3 apply. For shore facilities, Ashore Confined Space Entry, COMDTINST M5100.48 (series), 29 CFR 1910, 29 CFR 1915, and 29 CFR 1926 are applicable. In addition, when painting is to be conducted in a confined space, the following precautions shall apply:
(1) Fire and Explosion Hazards.
(a) Sufficient ventilation shall be provided to keep concentrations of vapors below ten (10) percent of the lower explosive limit. Frequent tests by a competent person (see "competent person" as defined by 29 CFR 1915.7) shall be made to ascertain the concentration.
(b) If ventilation fails or the solvent concentration rises above ten percent of the lower explosive limit, painting shall be stopped and the area evacuated until safe conditions are established.
(c) Ventilation shall be continued after completion of work until the space is vapor free. Tests to determine this condition shall be made after the ventilation has been stopped for at least ten minutes.
(d) Exhaust ducts shall discharge clear of working areas, away from ignition sources and away from all fresh air inlets.
(e) All motors and control equipment shall be of the explosion proof type. Fans shall have nonferrous blades. Portable air ducts shall also be of nonferrous material. Metallic parts shall be bonded and grounded.
(f) Only non-sparking paint buckets, spray guns and tools shall be used. Metallic parts of paint brushes and rollers shall be insulated. Staging shall be erected in a manner that ensures that it is non-sparking.
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(g) Only explosion proof lights, approved for use in Class I, Group D atmospheres shall be used.
A competent person shall inspect all power and lighting cables to ensure the insulation is in acceptable condition, they are properly placed, and there are no connections or splices within the area of work or within fifty (50) feet of the area of work.
(h) No matches, cigarette lighters or other ferrous articles shall be taken into the areas where work is being done.
(i) All solvent drums or cans taken into the work area shall be placed on nonferrous surfaces and shall be bonded and grounded. Vessels being filled from a drum (or can) shall be bonded to the drum while materials are being transferred.
(j) All personnel protective equipment shall be non-sparking, e.g. rubber soled safety shoes.
(2) Personal Protective Equipment.
(a) The face, hands, eyes, head and other exposed parts of personnel working with paints shall be protected. Coveralls and other clothing shall be cotton and shall conform with applicable Material Safety Data Sheets for the products being used.
(b) Personnel shall be protected by Type C continuous flow air line respirators using properly filtered and cleaned compressed air meeting breathing air standards.
(c) When working in confined spaces, a safety observer, trained and equipped to rescue and summon help, shall be posted outside of the work area in a position to observe the workers.
(d) Portable ladders or like means of egress shall be provided. In areas where egress is difficult, tag lines and safety harnesses shall be used.
b. Special Hazards of Spray Operations.
(1) Fire and Explosion. The possibility of an explosion varies with the flash point of the material and the ambient temperature of the air. The chance of explosion for outside painting is less than in enclosed spaces. Fire hazards associated with outside painting are essentially limited to the immediate vicinity of the spraying.
(a) During spray painting, atomizing produces much more solvent vapor than would be expected by evaporation at temperatures that exceed the flash point. Solvent concentrations during spray painting operations may produce ideal conditions for ignition.
(b) Allow no smoking, welding, burning, or other flame or spark-producing operations such as chipping or grinding, electrical repairs or electric bulb changing within a work area while painting and for at least one hour after painting has ceased.
(c) In any case where interior spray painting is being done with low flash point materials (flash point below 100oF.), follow all fire and explosion precautions noted for painting in confined spaces.
(2) Airless Spray Equipment. Airless spray guns operate at pressures high enough to inject paint into human flesh. Paint and related products injected into tissue can migrate and cause dangerous infection. If injured, seek immediate medical attention. It is equally dangerous to operate an airless gun when the cap has been removed. This could release a large volume of liquid, and great bodily harm could result. The following precautions should be observed:
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(a) Check all hose connections and fittings for leaks. Be sure all parts used are designed and intended for high-pressure use. Ensure the spray cap guard is always in place.
(b) Keep a constant check on the hose to make sure it is free of worn spots, breaks, cracks, etc.
Keep the hose away from moving parts of machinery, sharp edges, and chemicals.
(c) Fingers shall be kept off the airless spray gun trigger except when gun is in actual use and it should never be pointed at anyone.
(d) Ensure that pump pressure is released before the gun or any parts are disconnected.
(e) If materials used are highly flammable, the object or surface being sprayed, as well as the spray gun, motor, and pump, should be grounded. This is extremely important since the spray gun may accumulate an electrostatic charge.
(3) Health Hazards. Although harmful human health effects are associated with all paint processes, the potential for these to occur are increased due to the high levels of airborne paint components and solvents created during spray painting. Some examples of these include: Chromate materials present in primers can cause dermatitis, ulceration of the exposed skin and stomach or lung cancer.
Antifouling paints used on vessels and buoys contain toxic materials that are hazardous upon skin contact or ingestion/ inhalation. Epoxy paints can cause dermatitis upon skin contact and some individuals may develop an allergy or sensitization upon exposure to small amounts of the material.
The solvents commonly used in paint systems exhibit a wide range of toxicity. The less toxic solvents such as mineral spirits, some petroleum naphthas, and ethyl alcohol produce symptoms similar to those associated with alcohol intoxication. Others such as toluene, xylene, methyl ethyl ketone (MEK) and methyl isobutyl ketone (MIBK) produce symptoms of intoxication at much lower concentrations and in addition, may produce chronic damage to organs and/or cause extreme irritation to skin, eyes, and nose. All solvent materials found in non-water based paints can be hazardous to health if adequate protective measures are not taken; chronic exposure may cause permanent nervous system damage.
(a) Ensure that all precautions on the MSDS, including wearing of appropriate personal protective equipment, are followed.
(b) Where practical, all spray finishing operations should be performed in ventilated spray booths or spray rooms. Spray booths and spray rooms shall conform to paragraph 1910.107 of the General Industrial Standards 29 CFR. Semiannual tests of hazard control ventilation systems in paint spray booths are required by Ashore Confined Space Entry, COMDTINST M5100.48 (series). Assistance can be requested from the cognizant MLC (kse). Respirators certified by the National Institute for Occupational Safety and Health (NIOSH) are required when spraying in booths. Painters working in walk-in booths with inadequate air velocities shall wear airline respirators; when working in walk-in booths having adequate airflow but when painters can potentially be located downstream of the object painted, paint spray respirators shall be worn. For smaller booths where the painter stands outside the booth and airflow is inadequate, paint spray respirators shall be worn; small booths with adequate velocity eliminate the need for wearing any respiratory protection. Guidelines for selection of respiratory equipment when spraying in confined areas, enclosed areas, and open areas are the same as for spray booths. Use the airline respirator unless it has been demonstrated that a filter type will provide comparable protection. Particular attention shall be paid to coatings containing coal tar, chromates, antifoulants and toxic solvents. Always use an airline respirator when applying polyurethanes (See Para B.16 of Chapter 6 for polyurethane restrictions). In all cases where respirators are used, a respirator program shall be initiated in accordance with Technical Guide: Practices for Respiratory Protection, COMDTINST M6260.2 (series).
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(c) Skin Protection. To reduce the danger of absorbing chemicals through the skin, painters shall wear protective clothing. Gloves should be used whenever possible and should be impermeable to the solvent being used. MLC (kse) staffs may be consulted regarding glove selection.
(d) Medical Monitoring. All personnel engaged in spray painting operations more than 30 days per year shall be enrolled in the Occupational Medical Surveillance and Evaluation Program (OMSEP) as described in the Safety and Environmental Health Manual, COMDTINST M5100.47 (series) and the Medical Manual, COMDTINST M6000.1 (series).
3. Paint Removal.
a. Special Hazards for Paint Removal in Confined Spaces.
(1) Prior to the start of any work in confined spaces, a qualified IH or gas free engineer shall assure the existence of a safe working atmosphere. Where the spaces have contained volatile liquid, paints, or toxic materials or irritants, or are immediately adjacent to such materials, the atmosphere shall be tested for contaminants and checked for residues of these materials. This atmosphere shall be checked periodically during the paint removal operations.
(2) Where tests show a deficiency of oxygen in the space (other than in spaces intentionally inerted against fire or explosion) no work shall commence until the application of appropriate ventilation measures have been effective.
b. Health Hazards. The major hazards associated with paint removal operations are those of explosion, skin or eye injury, respiratory disease from inhalation of abrasives, electrical shock from removal equipment, and industrial illnesses from inhalation of hazardous paint dusts containing chromate, lead, inorganic tin or copper compounds. All removal operations, including chipping and painting require use of proper protective equipment and procedures to control risk. For guidance, refer to the cognizant MLC (kse). Some examples of these specific health hazards are:
(1) Heavy metals such as lead, chromates or organic tin compounds present in vessel primer, antifouling paints and primer coatings can accumulate in the body from ingestion and/or inhalation. Chronic exposures can produce disabling illness and possible death.
(2) Exposure to dust from plastic type (vinyl) paints may result in severe respiratory and skin irritation and some sensitive individuals may show an allergic response.
(3) Special attention must be given to operations where chromate coatings are abraded since inhalation or ingestion can cause various adverse health effects, including cancer.
(4) Biocide materials present in antifoulant coatings can produce severe burns upon skin or eye contact, can be transported into the body through the skin, and may produce damage to internal organs if inhaled or absorbed into the body. Hazardous exposures can result from biocidal antifouling coating dust in abrasive blasting, mist or vapor from spray painting and fume from cutting or burning painted surfaces. Although organotin antifouling coatings are now prohibited and have not been specified in a number of years, there is the possibility that they may still be found. Units shall hire licensed contractors for the removal of organotin paint. Coast Guard personnel are not authorized to perform this work.
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(5) A health hazard secondary to any blasting operations may result from supplying contaminated breathing air to air supplied respiratory equipment. Oil, water, carbon monoxide and other products of incomplete combustion may be present in breathing air if proper precautions are not taken. Refer to Technical Guide: Practices for Respiratory Protection, COMDTINST M6260.2 (series).
c. Abrasive Blasting. It has become general practice to enclose large, high volume blasting operations and provide dedicated ventilation/collection systems. In evaluating the need for enclosure of small, low volume blasting operations, primary consideration should be given to the toxicity of the abrasive used and to any pulverized coatings, the related potential for airborne contamination of adjacent work or living spaces, as well as compliance with EPA and State air pollution laws. Wet blasting may adequately suppress dust when operations such as blasting a ship's hull must be performed outdoors.
In most states, open air blasting is not permitted through regulation of visible emissions. In some states, it is specifically prohibited. These constraints leave enclosed and vacuum blasting as the only viable alternatives.
(1) Equipment shall be approved for the intended use. Hoses and fittings shall be grounded to prevent shock from static electrical charges. Hose lengths shall be joined by metal couplings secured with adhesive.
(2) Nozzles shall be similarly attached to the hose, with fittings designed to prevent unintentional disengagement of the nozzle. The nozzle end shall be provided with a deadman control to provide direct "fail-safe" cutoff of the abrasive in the case of loss of control of the hose by the operator.
Hoses and all fittings shall be inspected frequently to assure replacement prior to the development of unsafe deterioration or wear.
(3) All equipment and metallic working surfaces shall be interconnected to a common ground to avoid the development of critical electrical potentials. Operators shall check grounding connections prior to the start of work.
(4) During the application of the abrasive, pressure drops within the hose lines often cause surges that can throw operators off staging or scaffolding. Operators working on scaffolding or elevated staging shall be protected by appropriate fall protection equipment such as safety harnesses and lines.
(5) In the application of the abrasive, the operator shall assure the use of straight hose runs, or wide, sweeping curves to prevent the erosive action resulting from sharp bends in the hose, and the possibility of blowouts or similar personnel hazards.
(6) Types of Abrasive: Various types of abrasive materials are used in blasting operations, each having its own particular advantages. The hazard potential of these various abrasives also varies considerably. Use of Silica is specifically prohibited; consult with the cognizant MLC (kse) regarding the risk vs. gain of other types of abrasives.
(7) Personal Protective Equipment.
(a) Head, Respiratory, and Eye Protection. Protective gear must be worn by all personnel consisting of hoods or special helmets integrated with special masks and air respirators of a positive pressure. Eye protective gear shall be provided as an integral part of the helmet, or shall be approved eye shields complying with American Standard Safety Code Z issued by ANSI. Coast Guard personnel engaged in or located in the immediate vicinity of abrasive blasting operations (enclosed or otherwise) shall wear approved airline abrasive blasting respirators. In unusual circumstances where the abrasive blasting respirator cannot be used due to safety or operational considerations, (tight places) a type C supplied air respirator with
2-7 appropriate fabric hood and sheath should be used. Only respirators that utilize continuous flow or pressure demand regulators shall be used. In all cases where respiratory equipment is used, a respiratory protection program, shall be established as defined and described in Technical Guide: Practices for Respiratory Protection, COMDTINST M6260.2 (series).
(b) Hearing Protection. All Coast Guard employees engaged in sandblasting operations, whether as an operator or helper, shall wear double hearing protection (earplugs and earmuffs). All other personnel in the vicinity of the operation must wear double hearing protection unless a sound level survey indicates that single hearing protection (earplugs or earmuffs) is adequate.
Personnel shall be enrolled in the Coast Guard Hearing Conservation Program in accordance with the Safety and Environmental Health Manual, COMDTINST M5100.47 (series).
(c) Foot Protection. Boots or shoes (rubber sole or equivalent, with steel toes fully covered by leather or other impact-absorbent materials) and rubber or leather gauntlets shall be worn.
(d) Skin Protection. Abrasive-resistant clothing that leaves no portion of the body unprotected shall also be worn.
(8) Engineering Design. Planning and design of new abrasive blasting facilities should be done in accordance with the refe rence criteria cited in Technical Guide Practices of Respiratory Protection, COMDTINST M6260.2 (series).
(9) Breathing Air Systems. Compressors shall be constructed and situated to avoid entry of contaminated air into the system and suitable in- line air purifying sorbent beds and filters installed to further assure breathing air quality. Systems shall have alarms to warn of compressor failure or overheating. Oil lubricated compressors shall have carbon monoxide alarms. Refer to Technical Guide Practices of Respiratory Protection, COMDTINST M6260.2 (series).
(10) Medical Monitoring. All personnel engaged in abrasive blasting more than 30 days per year shall be enrolled in the Occupational Medical Surveillance and Evaluation Program (OMSEP) as described in the Safety and Environmental Health Manual, COMDTINST M5100.47 (series) and the Medical Manual, COMDTINST M6000.1 (series).
d. Water Jetting (also called hydroblasting). Run off from water jetting operations must be contained, if not collected for processing, in order to prevent pollutants from entering the ground, waterways, storm water systems, or sewer systems. In considering the degree of containment or collection required, compliance with EPA and State pollution laws must be considered. Although not considered to be as hazardous as abrasive blasting, hydroblasting uses water at high pressure which can cut through a body, causing serious injury or death. The precautions and protective personnel equipment described for abrasive blasting, and the special precautions given in the following paragraphs shall apply.
(1) Precautions.
(a) Visual Operating Signals. Prearranged visual signals shall include: Start, Stop, Increase Pressure, Decrease Pressure (for the pump), Shut Down Engine, and Bleed Pressure.
(b) Pump Operator. One person shall be stationed at the pump at all times to monitor running condition, control reserve water level, make pressure adjustments, handle emergencies (such as a ruptured hose), perform emergency procedures (stop engine, bleed pressure), and clear hoses at ground or pump location. The pump operator shall maintain visual contact with the gun operator and his assistant, and respond immediately to their signals. Where this is not possible, audio signals shall be used. Pump operators shall wear hearing protection as prescribed in the personal protective equipment requirements for abrasive blasting.
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(c) Gun Operator. Two workers shall be assigned to each gun being operated and shall relieve each other as required. The assistant shall keep hoses clear of all obstructions, assist the operator as required by supporting the hose weight, be alert to potential hazards which may be encountered by the operator, and take corrective action as required. The assistant shall also observe work done by the pump operator, point out missed areas, and provide visual signals to the pump operator as necessary. The gun operator and assistant shall wear wet-weather gear, face shield or goggles, work gloves, shoes with antiskid soles, and when working from a scaffold or other elevated position, a safety harness.
(d) Equipment and Operating Precautions. Hydroblast equipment shall be properly maintained because operation of damaged equipment at high pressure is dangerous. Staging shall be stable and correctly positioned so that the worker can hold the gun at a 60-degree angle with tip approximately 8 to 12 inches from the surface being blasted.
(e) The hydroblast gun shall never be pointed at other personnel. The water stream is capable of severing an arm or leg.
(f) The straight jet nozzle shall be used only in special cases such as cleaning weld seams or crevices. Caution shall be used, because the water stream will rapidly cut through paint to bare metal.
(2) Personal Protective Equipment. The following protective personnel equipment requirements shall apply in addition to the protective personnel equipment requirements described for abrasive blasting.
(a) Skin Protection. Protective clothing shall be worn that is specifically designed for skin protection in water jetting operations. Protective clothing shall protect against water jet penetration and shall be water resistant.
(b) Footwear. In addition to the requirements described for abrasive blasting, footwear shall have slip resistant soles.
CHAPTER 3. ENVIRONMENTAL LAW AND POLICY
A. General. The activities associated with surface preparation and painting are regulated because of their potential to release significant amounts of pollutants (via air emissions and residual wastes), potentially endangering both human health and the environment. When conducting surface preparation and painting operations, all units must comply with applicable federal, state, and local laws. When inport, vessels should also confer with their host shore command and/or Senior Officer Present Afloat to determine if there are any additional requirements. Units are also responsible for complying with the Commandant's policies regarding the reduction of hazardous waste and materials as promulgated in The Hazardous Waste Management Manual, COMDTINST M16478.1 (series). Additionally, a summary of environmental laws and responsibilities are found in the Commanding Officer’s Environmental Guide, COMPTPUB P5090.1 (series).
B. Procurement. Maintaining and refurbishing equipment through painting can produce large amounts of hazardous waste and air emissions and is a particular focus for environmental regulatory agencies.
Paying careful attention to environmental regulations is extremely important to reducing disposal costs and environmental liability associated with this activity.
1. Toxic Materials In Paints. Use of paints containing toxic materials is prohibited unless specifically required by COMDTINST. Coatings with toxic materials will be eliminated as acceptable substitutes with less toxicity are made available. The following is provided to clarify use of coatings containing toxic materials:
a. Lead. Paints shall contain no more than 0.06% lead by weight.
b. Chromate. Paints containing chromate pigments are prohibited except as primer for aircraft.
c. Mercury. Paints containing mercury are prohibited.
d. Organotin Antifouling Paints. Organotin paints are those that contain trivalent tin compounds such as tributyl tin and are registered by EPA because of their toxicity. Organotin paints may only be removed by state licensed contractors in accordance with state and federal laws. CG personnel are not authorized to apply, remove, or maintain organotin paints or to have a license to apply or remove these coatings. Organotin coatings are not authorized on any Coast Guard cutters or boats.
e. Zinc. Units are authorized to use paints containing zinc dust. However, paints containing zinc dust are more prone to containing lead. Therefore, ensure paints with zinc dust contain no more than 0.06% lead by weight.
f. Isocyanates. Paints containing isocyanates, including Toluene Diisocyanate (TDI), Hexamethylene Diisocyanate (HDI) and Diphenylmethane Diisocyanate (MDI), are prohibited unless specifically required by this manual. See Polyurethane Coatings Exposure Control, COMDTINST 6260.30 (series) for further clarification.
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g. Coal tar epoxies. Coal tar epoxies are specifically prohibited for any application.
2. Volatile organic compounds (VOCs). Paints can produce significant emissions of VOCs when the solvents in the paint volatilize as the paint dries. Surface preparations may also emit VOCs if solvent cleaners or paint strippers are used. Release of VOCs in painting operations pose a health hazard to workers and also cause ground-level smog. The following subparagraphs apply to marine paints only. VOC content for non-marine paints shall adhere to all federal, state, and local architectural codes. Guidance on federal VOC architectural requirements can be found at http://www.epa.gov/ttn/atw/index.html.
a. The Coast Guard has adopted a fleet wide maximum as applied VOC content standard which meets the Federal…
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