CIM_10360_3D.pdf

COATINGS AND COLOR MANUAL

COMDTINST M10360.3D

January 2014

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Commandant United States Coast Guard

2703 Martin Luther King Jr Ave, SE Stop 7714 Washington, DC 20593-7714 Staff Symbol: CG-45 Phone: (202) 475-5732 Fax: (202) 475-5956

COMDTINST M10360.3D

January 21, 2014

COMMANDANT INSTRUCTION M10360.3D

Subj:

Ref:

COATINGS AND COLOR MANUAL

(a) Hazardous Waste Management Manual, COMDTINST M16478.1 (series)

(b) Vessel Environmental Manual, COMDTINST M16455.1 (series)

(c) Deck Coverings, General, NSTM CH. 634, NAVSEA S9086-VG-STM-010

(d) Requirements for Preservation of Ship Structures, SFLC Standard Specification 6310

(e) Rescue and Survival Systems Manual, COMDTINST M10470.10 (series)

1. PURPOSE. This Manual promulgates Coast Guard coating and color policy for all cutters and boats.

2. ACTION. Area, district, and sector commanders, SFLC commander, commanding officers of headquarters units, assistant commandants for directorates, Judge Advocate General, and special staff offices at Headquarters shall ensure that the provisions of this Manual are followed. Internet release is authorized.

3. DIRECTIVES AFFECTED. Coatings and Color Manual, COMDTINST M10360.3C is canceled.

4. MAJOR CHANGES. This revision incorporates all changes to previous editions of this

Manual and the following significant new changes:

a. Chapter 4 has been re-titled Coatings Management.

b. Chapters 5, 6, 7, 8, and 9: Relocated to SFLC Technical Standard 631.

c. Chapters 10, 11, and 12 are now Chapters 5, 6, and 7 respectively.

DISTRIBUTION – SDL No. 163 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 x x x x x x x x x x x x x x x x B x x x x x x x x x x x x x x x x x x x x x x C x x x x x x x x x x x x x x x x x D x x x x x x x x x E x x x x F G H x

NON-STANDARD DISTRIBUTION:

d. Chapters 13, 14, 15, and 16: These chapters have been removed, as this Manual is only applicable to vessel coating systems.

e. Appendices A, B, C, and D: Relocated to SFLC Standard Specification 6310.

f. Appendix E: Relocated to SFLC Standard Specification 6341.

5. REQUESTS FOR CHANGES. Units and individuals may recommend changes by writing via the chain of command to: Commandant (CG-452); U. S. Coast Guard; 2703 Martin Luther King Jr Ave SE Stop 7714; Washington, DC 20593-7714.

6. RECORDS MANAGEMENT CONSIDERATIONS. This Manual has been thoroughly reviewed during the directives clearance process, and it has been determined there are no further records scheduling requirements, in accordance with Federal Records Act, 44 U.S.C.

3101 et seq., NARA requirements, and Information and Life Cycle Management Manual, COMDTINST M5212.12 (series). This policy does not have any significant or substantial changes to existing records management requirements.

7. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS.

a. The development of this directive and the general policies contained within it have been thoroughly reviewed by the originating office in conjunction with the Office of Environmental Management, and are categorically excluded (CE) under current USCG CE # 4 from further environmental analysis, in accordance with Section 2.B.2 and Figure 2-1 of the National Environmental Policy Act Implementing Procedures and Policy for Considering Environmental Impacts, COMDTINST M16475.1 (series).

b. This directive will not have any of the following: significant cumulative impacts on the human environment; substantial controversy or substantial change to existing environmental conditions; or inconsistencies with any Federal, State, or local laws or administrative determinations relating to the environment. All future specific actions resulting from the general policies in this directive must be individually evaluated for compliance with the National Environmental Policy Act (NEPA), DHS and Coast Guard NEPA policy, and compliance with all other environmental mandates.

8. FORMS/REPORTS. NONE.

R. J. Rábago /s/ Assistant Commandant for Engineering and Logistics

RECORD OF CHANGES

CHANGE

NUMBER

DATE OF

CHANGE

DATE

ENTERED

BY

WHOM ENTERED

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TABLE OF CONTENTS

CHAPTER 1 INTRODUCTION ................................................................................................. 1-1

A. Purpose .................................................................................................................... 1-1

B. Change Process ....................................................................................................... 1-1

C. Distribution ............................................................................................................. 1-1

D. Points of Contact ..................................................................................................... 1-2

CHAPTER 2 SAFETY AND OCCUPATIONAL HEALTH ..................................................... 2-1

A. General .................................................................................................................... 2-1

B. Operational Risk Management (ORM). .................................................................. 2-1

C. Storage of Coatings Onboard Vessels ..................................................................... 2-1

D. Storage of Vessel Coatings Ashore ......................................................................... 2-2

E. Paint Operations Hazards ........................................................................................ 2-2

CHAPTER 3 ENVIRONMENTAL LAW AND POLICY ......................................................... 3-1

A. General .................................................................................................................... 3-1

B. Procurement ............................................................................................................ 3-1

C. Surface Preparation Issues ...................................................................................... 3-2

D. Painting Issues ........................................................................................................ 3-4

E. Waste and Air Emission Management Reduction .................................................. 3-5

F. Waste Disposal........................................................................................................ 3-7

CHAPTER 4 COATINGS MANAGEMENT ............................................................................. 4-1

A. Coast Guard Coatings Policy .................................................................................. 4-1

B. Frequency of Painting/When to Paint ..................................................................... 4-1

CHAPTER 5 CUTTER AND BOAT SAFETY COLORS AND MARKINGS ......................... 5-1

A. Colors For Safety .................................................................................................... 5-1

B. Coast Guard Safety Marking System ...................................................................... 5-1

CHAPTER 6 CUTTER AND BOAT COLORS - EXTERIOR AND INTERIOR ..................... 6-1

A. General .................................................................................................................... 6-1

B. Exterior Spaces ....................................................................................................... 6-2

C. Interior Spaces ...................................................................................................... 6-11

CHAPTER 7 CUTTER AND BOAT IDENTIFICATION MARKINGS ................................... 7-1

A. General .................................................................................................................... 7-1

B. Other Markings ....................................................................................................... 7-1 ii

LIST OF TABLES

Table 5-1: Color For Safety Helmets .......................................................................................... 5-4

Table 6-1: Antenna Hardware Colors ......................................................................................... 6-3

Table 6-2: Underwater Body, Boot-Top, And Freeboard Colors ............................................... 6-3

Table 6-3: Miscellaneous Details And Fittings .......................................................................... 6-5

Table 6-4: Underwater Body Paint Scheme .............................................................................. 6-11

Table 6-5: Interior Colors – Epoxy ........................................................................................... 6-12

Table 6-6: Interior Colors – Fire Retardant Paint ..................................................................... 6-12

Table 6-7: Miscellaneous Interior Spaces ................................................................................. 6-13

Table 6-8: Piping System Identification Color Code ................................................................ 6-15

Table 7-1: Painted Replicas Of Commendation And Service Insignia ....................................... 7-2

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CHAPTER 1 INTRODUCTION

A. Purpose. This Manual is published to promulgate Coast Guard coatings and color policy for all cutters and boats.

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 the Surface Forces Logistics Center (SFLC) Engineering Services Division (ESD) and the cognizant SFLC Product Line Manager. Headquarters units and program managers may submit their proposals directly to Commandant (CG-45).

2. SFLC Engineering Services Division and the cognizant SFLC Product Line Manager 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 effects of implementation.

b. Conduct technical review by SFLC-ESD-Survivability and Sustainment Branch

(SSB).

c. Promulgate any approved changes by appropriate means, i.e., published change/new revision or advance change message.

d. Return any disapproved change request to the originator with an explanation for the disapproval.

4. Commandant (CG-45) is the final approving authority and has overall responsibility for this Manual.

a. All approved changes will be promulgated by change notices to this Manual.

b. Changes that require immediate action shall be submitted directly to Commandant

(CG-45) via message, information copy to the SFLC-ESD-SSB.

C. Distribution. No paper distribution will be made of this Manual. An electronic version will be located on the following Commandant (CG-612) web sites.

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1. Internet: http://www.uscg.mil/directives/

2. Intranet: http://cgweb.comdt.uscg.mil/CGDirectives/Welcome.htm

3. CGPortal: https://cgportal2.uscg.mil/library/directives/SitePages/Home.aspx.

D. Points of Contact.

1. Manual Manager: Office of Naval Engineering, Environmental Policy (CG-452), (202) 475-5557

2. SFLC-ESD-SSB Coatings Subject Matter Expert: (410) 762-6936 http://www.uscg.mil/directives/ http://cgweb.comdt.uscg.mil/CGDirectives/Welcome.htm https://cgportal2.uscg.mil/library/directives/SitePages/Home.aspx

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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 Health, Safety and Work-life Service Center (se) is available to assist in the ORM process.

C. Storage of Coatings Onboard Vessels. Paint and paint-related products shall be stored and disposed of in accordance with Reference (a) and Chapter 3 of this Manual. Stowage aboard vessels should be minimized to only mission essential stock to prevent compounding of personnel and fire hazards. Stowage shall be limited to flammable liquid storerooms with the exception of in-use stock that may be stowed in paint mix rooms. For further guidance, see the Naval Engineering Manual, COMDTINST M9000.6 (series), Chapter 670 and Naval Ships’ Technical Manual, Chapter 670.

1. Paints shall 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. 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 29 CFR

1910.106 which sets out OSHA requirements for flammable liquids.

4. Oily rags shall not be stored in paint storage cabinets; they shall be stored in metal containers with self-closing lids. Oils 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. Oils such as linseed oil, turpentine, and fish oils can form serious fire hazards when left in rags.

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

2-2 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. Storage of Vessel Coatings Ashore.

1. Storage cabinets. Required for the storage of in-use or working stocks of flammable or combustible paints and thinners, whether in manufacturer sealed containers or in containers which have been opened and resealed.

2. Storage Cabinet Specs. Types that comply with the National Fire Code #30 are commercially available and shall be used for paint storage. These cabinets are constructed in the following manner: The bottom, top, door, and sides of the cabinet are constructed of at least No. 18 gauge steel and are double walled and floored with a 1-1/2 inch air space between inner and outer surfaces. Joints are riveted, welded, or otherwise sealed. The door is secure at three points when latched. The doorsill is raised at least 2 inches above the inner bottom surface of the cabinet. Cabinets should be painted yellow (13538) or as supplied by the manufacturer and shall have the words, FLAMMABLE -- KEEP FIRE AWAY, conspicuously stenciled or painted in a contrasting color such as red or black.

3. Maximum Quantity. Sixty (60) gallons of flammable products and one hundred and twenty (120) gallons of combustible products are the maximum quantity allowed to be stored in any one cabinet. Not more than three such cabinets may be placed in any work center or room. Factory sealed stocks in excess of these amounts shall be stored in an outside storage building or specially designed interior room or compartment provided the storage facility is built, protected, and used as required by regulation.

E. 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.

2. Special Hazards of Painting, Paint Removal, and Paint Evaluation in Confined Spaces.

a. 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

(2) has limited or restricted means for entry or exit

(3) is not designed for continuous employee occupancy.

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b. 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.

c. 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, Safety and Environmental Health Manual, COMDTINST M5100.47 (series), Chapter 077 of the Naval Engineering Manual, COMDTINST M9000.6 (series) and Naval Ships Technical Manual (NSTM) 074 Volume 3 apply. In addition, when painting is to be conducted in a confined space, the following precautions shall apply:

(1) Prior to the start of any work in confined spaces, a marine chemist, qualified industrial hygienist 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.

d. Fire and Explosion Hazards.

(1) 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.

(2) 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.

(3) Ventilation shall be continued after completion of work until the space is vapor free at less than one percent of the lower explosive limit. Tests to determine this

2-4 condition shall be made after the ventilation has been stopped for at least ten minutes.

(4) Exhaust ducts shall discharge to outside environment, clear of working areas, away from ignition sources and away from all fresh air inlets.

(5) 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.

(6) 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.

(7) 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 an 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.

(8) No matches, cigarette lighters or other ferrous articles shall be taken into the areas where work is being done.

(9) 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.

(10) All personnel protective equipment shall be non-sparking, e.g. rubber soled safety shoes.

e. Personal Protective Equipment.

(1) 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 to applicable Safety Data Sheet (SDS)/Material Safety Data Sheet (MSDS) for the products being used.

(2) When required, personnel shall be protected by appropriate National Institute for Occupational Safety and Health (NIOSH) approved respirators.

3. Paint Application.

a. Some good general guidelines for all painting operations include:

(1) Ensure all personnel applying, mixing, or removing paints have read the product’s SDS/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.

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(2) Store paint and solvent containing materials and supplies in well ventilated areas, away from heating equipment, open flames, direct sunlight, and flammable/combustible materials.

(3) Do not smoke, eat, or drink while mixing or applying these materials. No welding, grinding, or cutting (hot work) shall be allowed in areas adjacent to painting operations.

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 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) 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) 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 include: 1) antifouling paints used on vessels and buoys contain toxic materials that are hazardous upon skin contact or ingestion/inhalation and 2) 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.

4. Paint Removal.

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a. Health Hazards. The major hazards associated with paint removal operations are those of explosion, skin or eye injury, electrical shock from removal equipment, and respiratory illnesses from inhalation of hazardous heavy metals and chemicals in paint dusts. All removal operations, including chipping, require use of proper protective equipment and procedures to control risk. For guidance, contact the Health, Safety and Work-life Service Center (se). 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.

(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).

b. 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.

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(1) 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 Health, Safety and Work-life Service Center (se) regarding the risk vs. gain of other types of abrasives.

(2) Personal Protective Equipment. All personnel in the vicinity of abrasive blasting operations must wear double hearing protection unless a sound level survey indicates that single hearing protection (earplugs or earmuffs) is adequate.

c. 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, water jetting uses water at high pressure which can cut through a body, causing serious injury or death.

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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 Reference (a). Additionally, a summary of environmental responsibilities is found in Reference (b).

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.

Coatings with potentially 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 0.009% lead by weight.

b. Chromate. Paints containing chromate pigments are prohibited except as primer for aircraft.

c. Heavy Metals. Paints containing cadmium, mercury, beryllium, and arsenic 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. Coast Guard 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 0.009% lead by weight.

f. Isocyanates. Two-part paints containing isocyanates, including Toluene Diisocyanate

(TDI), Hexamethylene Diisocyanate (HDI) and Diphenylmethane Diisocyanate (MDI), are prohibited. Examples of such paints include, but are not limited to, polyurethanes, polyureas, polyaspartics, and hybrids of these chemistries.

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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.

a. The Coast Guard has adopted a fleet wide maximum as applied VOC content standard which meets the Federal Control Technique Guideline for Shipbuilding and Ship Repair Operations (Surface Coating). Marine paints, thus, shall be lower than or equal to the following maximum as-applied (i.e. at time of application to the substrate) VOC content limits: 400 grams/liter for antifouling bottom paint, and 340 grams/liter for all other marine paints. VOC regulations are expected to be significantly reduced in the near future to 340 grams/liter for antifouling bottom paint and 250 grams/liter for all other marine paints.

b. Additionally, units must check to ensure that paint systems meet any state or local requirements for as applied VOC content limits that are more stringent than paragraph B.2.a (above).

c. Units requiring assistance in determining their state and local VOC limits should contact their cognizant Product Line. Additional assistance may be obtained from the SFLC-ESD-SSB-MP Environmental Specialist.

C. Surface Preparation Issues. Depending on the method used, surface preparation operations can generate significant air emissions or potentially hazardous waste. Air emissions could include release of particulate emissions from paint chips or blasting abrasives, or emitting VOCs and hazardous air pollutants (HAPs) arising from the use of solvent cleaners.

Potentially hazardous waste could include the residual waste of paint chips, or spent abrasives from blasting, or water contaminated with solvents. These emissions and wastes can cause health problems and damage the environment. For this reason, proper precautions must be taken. Regulations must be followed to prevent environmental violations.

1. Paint Containing Lead. This Manual will no longer use the term “lead based paint”.

There is no universal definition of lead based paint. However there are paints that contain lead. The relevant distinction in this otherwise innocuous adjective use is significant. Lead based paint in most cases refers to paint manufactured prior to the 1980’s that contained high quantities of dangerous lead levels. Currently, paints are authorized to contain a small quantity of lead. Referring to current coatings as “lead based paint” can lead to confusion that ultimately clouds a much larger picture. There are five succinct and separate vessel situations that deal with paint containing lead:

a. Allowable lead in paint procurement. Introduction onboard vessels of new paint containing more than 0.009% lead by weight in the dried film is prohibited. All paints authorized for use by this Manual comply with this requirement.

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b. Encapsulating paints containing lead. Once paint containing lead has cured, the health risks usually only arise from the direct ingestion of paint chips. This should not place Coast Guard personnel at risk for routine day to day operations. If the need for touch up arises, the in-place paint containing lead can be directly overcoated with fresh paint, thereby encapsulating the paint containing lead and further reducing the risk of direct lead paint exposure. It should be noted that this overcoating must take place without abrading the surface of the existing paint containing lead. Any abrasion can release dust that may contain lead, and as such special PPE procedures must be in place.

c. Identification of paints containing lead. Often vessels will need to remove coatings from a surface for a variety of reasons. Prior to this removal, identification must be made to determine if the paint contains lead. While the presence of lead could be confirmed via commercial home use kits, the specific quantity of lead contained in the paint is necessary to ensure required follow-on procedures are followed. Units seeking to determine if paint contains lead should work with their Health, Safety and Work-life Service Center (se) to take paint samples for lab analysis. This identification and documentation ensures that removal and disposal procedures are followed as required for the actual quantity of lead documented. It is vital that vessels which will be undergoing commercial contracts for the disturbance of paint containing lead document this fact early in the contract process, specifically during the initial A-team meetings. This prevents extremely costly adjustments after the contract has been awarded as the contractor changes the scope of work and performance.

d. Surface abrasion of paints containing lead. If a surface is comprised of paint containing lead, depending on the scope of work, engineering controls, work practices, and specific PPE must be in place prior to any abrasion (sanding, blasting, chipping, etc) taking place. For the most up-to-date PPE requirements, please contact your Health, Safety and Work-life Service Center (se).

e. Disposal of paint containing lead. After paint containing lead has been removed, the debris (waste stream) should be treated as hazardous waste until proven otherwise.

At this point, sampling again may need to take place as different quantities of lead present in the debris will trigger different disposal procedures. For example, paint containing lead mixed in with blast media (sand, grit, etc) may be in such low quantities that the lead may be negligible. However paint containing lead removed by water jetting will have a higher concentration of lead waste. These disposal procedures may differ between states also, so units must contact their Health, Safety and Work-life Service Center (se) to ensure that all applicable local, state and federal regulations are followed.

2. Asbestos. If surface preparation involves disturbing or removing asbestos containing material, special legal requirements may apply. Contact your Health, Safety and Work-life Service Center (se). Also, refer to the Asbestos Control Exposure Manual, COMDTINST M6260.16 (series).

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3. Abrasive Blasting. In states enforcing a "no visible dust" rule, abrasive blasting must be performed inside a temporary structure. Knowledge of state and local regulations is critical; review the regulations applicable to your area for visible dust rules as well as any specific requirements for the temporary structure construction.

4. Water Jetting. Paint chips, debris and contaminants from water jetting operations are considered “pollutants” under the Clean Water Act and may also qualify as hazardous waste. Run off from water jetting operations must be contained, and may potentially require collection for processing before release in order to prevent pollutants from entering the ground, waterways, storm water systems, or sewer systems. In considering the degree of containment or collection, processing and disposal required, compliance with Federal (EPA), State and local pollution laws must be considered. Usually, state and local authorities will grant permits to allow waste water to be disposed of in the sewage treatment system as long as the water does not contain toxins which can kill the microbes used in the treatment process. Contact your Health, Safety and Work-life Service Center (se) for advice on proper waste water disposal procedures.

5. Paint Removal on Cutters and Boats. Top-side maintenance surface preparation for cutters and boats poses special problems in controlling paint chips and dust so that they are not released to the water. Reference (a) requires that Commanding Officers and Officers in Charge of vessels appoint a Hazardous Waste Coordinator (HWC). The HWC shall develop policy to ensure that all equipment (such as vacuum-equipped surface prep tools) and containment systems (such as drop cloths and wrapping materials) are working and in place such that no paint chips or dust are allowed to enter the water.

Paint chips and dust are considered “pollutants” under the Clean Water Act and may also qualify as hazardous waste. The Health, Safety and Work-life Service Center (se) can assist in determining the proper procedures to use for top-side surface preparation.

D. Painting Issues. Depending on the method used, painting can produce significant air emissions or potentially hazardous waste. Air emissions could include release of VOCs and hazardous air pollutants (HAPs) from paint overspray, from equipment cleaning solvents, or from the solvent volatizing as the paint dries. Potentially hazardous waste could include the residual waste of leftover paint and solvents, or spent equipment. These emissions and waste can cause health problems and damage the environment. For this reason, proper precautions must be taken. Regulations must be followed to prevent environmental violations.

1. Ensure that the paint is lower than or equal to the maximum as applied (i.e. at time of application to the substrate) VOC content limits set out in this chapter or, if more stringent, state and local as applied VOC content limit requirements (see paragraph B.2.a and B.2.b).

2. Paint thinners, other than water, usually have a very high VOC content; thus, adding a thinner to paint increases the paint’s VOC content (transforming a low VOC content paint to a high VOC content paint). Minimize the use of paint thinner. Paint thinners should not be added unless necessary. Paint thinner that is a substance other than water will not be used unless the following condition exists: prior to any paint thinner being added, the paint has a VOC content that is lower than the maximum as applied VOC content limit. If this condition exists, then thinner can be added, but only in an amount

3-5 that ensures that the paint with thinner added is lower than or equal to the maximum as applied VOC content limit. Too much thinning of paint reduces its dry film thickness giving shorter life to the paint system. Use of thinners should be minimized as they defeat the purpose of using low VOC coatings. At no time shall thinning the coating exceed the manufacturer's recommendation found in the latest revision of the product data sheet.

The following formula may be used to ensure that the as applied VOC content does not exceed the Coast Guard allowable limits.

R = (VS) (VOHAP limit) - Mvoc where:

Dth

R = Maximum allowable thinning ratio for a given batch, i.e., Gallons of thinner Vs = Volume fraction of solids in the batch as supplied (found on product data sheet or

SDS/MSDS).

VOHAP limit = Maximum allowable as-applied VOHAP content of the coating (grams

VOHAP/ liter solids). This is not the same as maximum VOC level. Use 765 grams/liter solids for antifouling coatings and 571 grams/liter solids for all other coatings.

Mvoc = VOC content of the batch as supplied (found on product data sheet or

SDS/MSDS).

Dth = Density of the thinner in grams/liter (found on product data sheet or SDS/MSDS).

Following is a practical example for the above calculation of the maximum allowable thinning ratio using PPG PSX-700 with Amercoat 911 thinner.

Vs = 90% = 0.90 (Taken from product data sheet) Mvoc = 120 grams/liter (Taken from product data sheet) Dth = 7.34 pounds/gallon = 880 grams/liter (Taken from SDS/MSDS)

R = (0.90)(571 grams/liter solids) - 120 grams/liter = 0.45 880 grams/liter

Therefore, a maximum of 0.45 gallons (1.8 quarts) of Amercoat 911 thinner can be added to one gallon of PSX-700.

3. Spray painting operations require knowledge of and compliance with all federal, state and local requirements relating to the control of air pollution. Prior to starting spray painting operations, painting supervisors shall ensure their procedures comply with the law and obtain all necessary permits (including state and local permits). If possible, conduct spray painting inside a booth or prep station rather than an open bay. If a booth or prep station is used, ensure it is appropriately constructed and ventilated and workers use proper protection.

E. Waste and Air Emission Management Reduction. Disposing of waste paint is costly. The best way to reduce disposal costs is to carefully estimate how much paint is required for a particular application and have little or nothing remaining for disposal. In addition to careful

3-6 procurement, stocking, and application practices, there are a variety of other methods to reduce waste which also may decrease air emissions:

1. Solvents. Solvents are often used to clean equipment used in applying oil-based paints.

In some instances, you can completely avoid using solvents for equipment cleanup by painting with disposable brushes, rollers, paint cans and trays. When using solvent to clean spray guns and lines, you can recycle it by storing for several days to allow the pigment and resin to settle out. Separate the paint fines, which are the particles and fragments that have settled to the bottom, by pouring off the solvent and reusing it to clean equipment. Remember, remaining sludge is hazardous wastes and must be disposed of in accordance with applicable regulations. Avoid using solvent to wipe down or clean painted surfaces and substitute a detergent or adhesion promoter.

2. Shelf Life Extension Program. To minimize waste, Coast Guard units, cutters and boats shall extend the shelf life of coatings and use them when it is reasonable to expect they will work correctly. This applies to all paints; military and federal specification coatings as well as commercial products. Regardless of what other military or government manuals dictate, if a coating passes the inspections outlined in this chapter, and it is reasonable to believe that the coating will work correctly, then extend the shelf life for one year by filling out a shelf life extension label like the one below and fasten the label to the can with heavy duty clear tape. If it is not reasonable to expect the coating to work correctly, the material should be discarded as hazardous waste. If possible, use paint before the storage life expiration date through careful inventory management.

Previous shelf life expiration date:

New shelf life expiration date:

Signed:

Date:

a. Inspections. New coatings and coatings with expired shelf life should not be used if they do not pass the following tests:

(1) Stir the paint. Stir all components separately if the paint has more than one part.

If the stirred paint product does not result in a uniform mixture and contains abnormal clumping, jelling, skinning, or other objectionable properties, then it is not suitable for use.

(2) Apply the paint to a test patch. If it does not brush or spray evenly and consistently or if it does not dry in the correct amount of time to the appropriate hardness, it is not suitable for use.

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(3) Check the adhesion on oil based and water based paints. Cut a series of cross-hatched lines into the dried paint with a razor blade down to the base metal. Then apply and remove a strip of duct tape. If 90% of the paint stays in place, it is suitable for use.

(4) Check the adhesion of epoxy paints. Tap the dried paint film with a hammer 10-

20 times with enough force to drive a nail 3/4" into a piece of pine. If the paint does not stay intact, it is not suitable for use.

(5) On previously opened cans of paint, strain the paint through cheese cloth to separate clotted material and use the coating for a non-critical application if it appears normal.

(6) Do not extend shelf life on paints with; improperly sealed or corroded containers, two part epoxy paints stored above 140oF, water based paints which have been frozen, or oil based paints which do not mix to a smooth consistency.

(7) Some state hazardous waste laws issue notices of violation for storing paint that is past the manufacturer's storage life expiration date. It may not be possible to extend shelf life in these areas.

b. Paint Storage Life. Most two-part epoxies can be properly stored in ambient temperature conditions and remain functional for up to 10 years. Water based and oil based paints, can be stored at ambient conditions for up to 3-5 years. Previously opened cans of water based and oil based paints are usually not suitable if stored for longer than one year. Previously opened cans of unmixed two-part epoxy paint in good condition may still be good after 3-4 years storage.

F. Waste Disposal. Surface preparation operations can generate potentially hazardous waste, including the residual waste of paint chips, spent abrasives from blasting or contaminated water. Painting operations can generate significant amounts of potentially hazardous waste, including leftover paint and solvents, spent equipment, rags and other materials contaminated with paint.

1. Waste Water. After water is used in blasting surfaces or to clean equipment, the water may become waste water that contains hazardous materials, e.g., biocidal antifouling agents, solvents and petroleum products. This waste water may not be poured on the ground or into the storm water or sewage system. Disposal of waste water used for cleanup of paint is governed by federal, state and local laws. Usually, state and local authorities will grant permits to allow waste water to be disposed of in the sewage treatment system as long as the water does not contain toxins which can kill the microbes used in the treatment process. Contact environmental compliance or legal staff for advice on proper waste water disposal procedures.

2. Antifouling paint. Waste associated with antifouling bottom paints may be collected separately from the typically less toxic topside and interior paints.

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3. Hazardous Waste Management. To determine if the residual waste is hazardous, refer to Reference (a). Reference (a) should be consulted to determine the records keeping requirements. Hazardous waste must be managed and disposed of in accordance with Reference (a). Particularly relevant sections include:

a. Chapter 4 GENERATION OF HAZARDOUS WASTE; Section 4-B, Hazardous

Waste Determination; Figure 4-2 Summary of characteristics and properties of hazardous waste under 40 CFR 261; and, Figure 4-3 Common hazardous waste items at USCG units.

b. Chapter 7, MANAGEMENT/DISPOSAL PRACTICES FOR TYPICAL CG…