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Checklist
Safety Issue:
Dipping and coating operations require
special precautions to protect employee safety.
Your facility is covered by OSHA’s dipping and chemicals in the tanks, you will need to follow the
OSHA regulations for that chemical (Subpart Z)
coating regulations if you use a dip tank for cleaning,
coating, or changing the character of an object as well as the general requirements for the Hazard
with some kind of liquid chemical other than water. Communication Standard (1910.1200). If your
Examples include paint dipping, electroplating, employees enter the tanks to clean them or perform
pickling, quenching, tanning, degreasing, stripping, other work on them, the permit-required confined
cleaning, roll coating, flow coating, and curtain space standard applies (1910.146). The flammable
coating. Dipping into molten material is not liquid (1910.106) and welding (1910.251–255)
covered by the standard. regulations may have to be adhered to as well.
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BLR Dipping and Coating
Audit Operations
Checklists
Checklist
✔ Safe work environment. Dipping and coating ✔ Material Safety Data Sheets. Whenever
operations pose many hazards to employees who hazardous chemicals are used in dipping and
work in and around areas where these operations coating operations, employees must be provided
take place. In addition to providing adequate with MSDSs for those chemicals and trained
ventilation, you must also take steps to make sure to interpret the information contained in these
employees are protected against fire, contamination, documents.
and other hazards.
✔ Safe work procedures and practices.
✔ Safe work practices and procedures. It is Employees must be trained to follow all safety
critical to establish and require safe work practices procedures and obey established work practices
and procedures for these operations. It is also without exception.
essential to train employees to perform their
work safely to prevent injuries and illness. ✔ Disposal of wastes. Employees must be
instructed to follow safe housekeeping rules
✔ Cleaning and maintenance operations. When and dispose of all wastes produced by these
employees enter tanks to clean them or perform other operations properly.
work, you must make sure that these employees are
well trained and protected from potential hazards. ✔ Personal hygiene. Preventing contamination by
In addition, you need to be certain that the work is chemicals used in dipping and coating operations is
carried out in compliance with the requirements of extremely important. Employees should be trained
OSHA’s confined space standard. to wash thoroughly before breaks and at the end of
their shifts. They must realize the importance of
not spreading contamination outside the work area.
Training Issues
✔ Emergency response. The regulations also
Training can make the difference between an
require you to train employees in basic first aid
unsafe operation and an injury- and illness-free
and emergency response procedures for the
one. Your employee training should include ses-
injuries and situations they are likely to face on
sions on:
the job, given the nature of the substances used in
your operations.
✔ Selection, inspection, and use of PPE. It is
essential that employees use proper PPE to protect
against the particular hazards of the substances
used in your dipping and coating operations.
Take Action
Employees should be trained to select appropriate Use the information in these checklists to make
PPE, inspect it for damage or wear, and use it sure that your dipping and coating operations are
correctly for maximum protection. in compliance with OSHA regulations and that
employees are well protected from the various
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BLR Dipping and Coating
Audit Operations
Checklists
Checklist
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Audit Work Area: _________________________
Checklists Inspected By: _______________________
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❏ Do you provide each room having exhaust ❏ Do you inspect hoods and the ductwork of the
hoods with a volume of outside air that is at ventilation for corrosion damage at least every
least 90 percent of the volume of the exhaust 3 months during operation and before operation
air? [(d)(1)] after a prolonged shutdown?
[(j)(1)(i) and (ii)]
❏ Do you ensure that the outside air supply does
not damage exhaust hoods? [(d)(2)] ❏ Do you inspect hoods and ductwork to ensure
that airflow is adequate at least once every
❏ When an employee enters a dip tank, do
3 months during operation and before operation
you meet the entry requirements of OSHA’s
after a prolonged shutdown? [(j)(2)(i) and (ii)]
standard for permit-required confined spaces
(1910.146)? [(e)] ❏ Do you periodically inspect all dipping and
coating equipment, including covers, drains,
❏ Do your employees know the first-aid
overflow piping, and electrical and fire
procedures appropriate to the dipping or
extinguishing systems, and promptly correct
coating hazards to which they are exposed? [(f)]
any deficiencies? [(j)(3)]
❏ Do you provide locker or other storage space to
❏ Do you provide mechanical ventilation or
prevent contamination of employees’ street
respirators to protect employees in the vapor
clothes? [(g)(1)]
area from exposure to toxic substances released
❏ Do you provide an emergency shower and during welding, burning, or open-flame work?
eyewash station close to the dipping or coating [(j)(4)]
operation (or in place of this equipment, a
❏ Have dip tanks been thoroughly cleaned of
water hose that is at least 4 feet long and at
solvents and vapors before welding, burning,
least three-quarters of an inch thick with a
or open-flame work is permitted? [(j)(5)]
quick opening valve and carrying pressure of
25 psi)? [(g)(2)]
ADDITIONAL REQUIREMENTS
❏ Do you provide at least one basin with a hot
water faucet for every 10 employees? [(g)(3)] FOR DIPPING AND COATING
OPERATIONS THAT USE
❏ Do you make sure that employees with sores,
burns, or other skin lesions that require medical FLAMMABLE OR COMBUSTIBLE
treatment have a physician’s approval before LIQUIDS
working in a vapor area? [(h)(1)] 29 CFR 1910.125
❏ Do you provide treatment for small skin
❏ Are your dip tanks made of noncombustible
abrasions, cuts, rashes, or open sores? [(h)(2)]
materials? [(a)]
❏ Do you provide appropriate first-aid supplies
❏ Do you provide trapped overflow piping that
near the dipping or coating operation? [(h)(3)]
discharges at a safe location for any tank with
❏ Do you provide employees who work with a capacity of greater than 150 gallons or a
chromic acid with periodic examinations of liquid surface area of greater than 10 square
their exposed body parts (especially their feet? [(b)(1)(i) and (ii)]
nostrils)? [(h)(4)]
❏ Do you ensure that overflow piping is at least
Before permitting an employee to clean the 3 inches in diameter and has sufficient capacity
interior of a dip tank, do you: to prevent the dip tank from overflowing?
❏ Drain the contents of the tank and open the [(b)(2)(i)]
cleanout doors? [(i)(1)] ❏ Do piping connections on drains and overflow
❏ Ventilate and clear any pockets where pipes allow ready access to the interior of the
hazardous vapors may have accumulated? pipe for inspection and cleaning? [(b)(2)(ii)]
[(i)(2)]
Continued ☞
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❏ Is the bottom of each overflow connection at ❏ Has adequate mechanical ventilation that
least 6 inches below the top of the dip tank? operates before and during the drying
[(b)(2)(iii)] operation? [(e)(3)(ii)]
❏ Do you provide a bottom drain for dip tanks ❏ Shuts down automatically if any
that contain more than 500 gallons unless the ventilating fans fail to maintain adequate
tank is equipped with an automatic closing ventilation? [(e)(3)(iii)]
cover or the viscosity of the liquid at normal ❏ Are all vapor areas kept free of combustible
atmospheric temperature does not allow the debris and as free as possible of combustible
liquid to flow or be pumped easily? stock? [(e)(4)(i)]
[(c)(1)(i) and (ii)]
❏ Are rags and other materials contaminated
Do you ensure that bottom drains: with liquids from dipping or coating
❏ Will empty the dip tank during a fire? operations placed in approved waste cans
[(c)(2)(i)] immediately after use? [(e)(4)(ii)]
❏ Are properly trapped? [(c)(2)(ii)] ❏ Are waste containers properly disposed of
at the end of each shift? [(e)(4)(iii)]
❏ Have pipes that permit the removal of the
dip tank’s contents within 5 minutes after ❏ Do you prohibit smoking in vapor areas and
a fire begins? [(c)(2)(iii)] post readily visible “No Smoking” signs near
each dip tank? [(e)(5)]
❏ Will discharge to a safe location?
[(c)(2)(iv)] Do you provide fire protection for:
❏ Can be operated manually and ❏ Any dip tank with a capacity of at least
automatically? [(c)(3)] 150 gallons or a liquid surface area of at
least 4 square feet? [(f)(1)(i)]
❏ Is manual operation from a safe and
accessible location? [(c)(3)] ❏ Any hardening or tempering tank with a
capacity of at least 500 gallons or a liquid
❏ Do you use automatic pumps when gravity
surface area of at least 25 square feet?
flow from the bottom drain is impractical?
[(f)(1)(ii)]
[(c)(4)]
❏ For every vapor area, do you provide manual
❏ Do any conveyor systems used with dip tanks
fire extinguishers that are suitable for flamma-
shut down automatically when there is a fire
ble and combustible liquid fires? [(f)(2)(i)]
or if the ventilation rate drops below the
required rate (see 1910.124 [b])? ❏ Do you have an automatic fire extinguishing
[(d)(1)(i),(ii)] system that conforms to the requirements of
Subpart L of the OSHA standards? [(f)(2)(ii)]
❏ Do you control all ignition sources in vapor
areas and adjacent areas? [(e)(1)] ❏ Can any automatically closing tank covers
also be activated manually? [(f)(3)(i)]
❏ Do you ensure that employees electrically bond
and positively ground any portable container ❏ Are tank covers noncombustible or tin clad?
used to add liquid to a tank? [(e)(2)] [(f)(3)(ii)]
Do you make sure that a heating system used ❏ Are tank covers closed when tanks are not
in a drying operation: in use? [(f)(3)(iii)]
❏ Is installed in accordance with NFPA ❏ Do you maintain the temperature of liquids in
86-1969? [(e)(3)(i)] dip tanks below the liquid’s boiling point and
at least 100°F (37.8°C) below the liquid’s
auto-ignition temperature? [(g)(1),(2)]
Continued ☞
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Audit Operations
Checklists
Checklist
Ventilation
Continued☞
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Audit Operations
Checklists
Checklist
☞ Continued
YES NO
◆ Do you periodically inspect all dipping and coating equipment,
including covers, drains, overflow piping, and electrical and fire
extinguishing systems, and promptly correct any deficiencies? ❏ ❏
◆ Do you inspect hoods and ductwork to ensure that airflow is
adequate at least once every 3 months and before operation
after a prolonged shutdown? ❏ ❏
◆ Do you use tank covers that float on the surface of the liquid
to replace or supplement ventilation? ❏ ❏
Safety Training
Continued ☞
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Audit Operations
Checklists
Checklist
☞ Continued
YES NO
◆ Do employees dispose of waste container contents properly
at the end of every shift? ❏ ❏
◆ Are employees trained to electrically bond any portable container
to the dip tank and positively ground it during any transfer of
liquids to prevent static electrical sparks and arcs? ❏ ❏
◆ Have employees been trained in the proper use of fire
extinguishers? ❏ ❏
◆ Do they know how to call for assistance in the event of a fire or
medical emergency? ❏ ❏
◆ Do employees know where first-aid supplies are located? ❏ ❏
◆ Are they trained to perform basic first-aid to treat the kinds of
injuries common to dipping and coating operations? ❏ ❏
◆ Are employees trained to wash thoroughly before breaks and at
the end of their shift before putting on street clothes? ❏ ❏
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BLR Dipping and Coating
Audit Operations
Checklists
Quiz
3.
It is permissible to recirculate
exhaust air as long as it doesn’t
pose a health hazard to employees
8. need to be trained in basic first
aid for the kinds of injuries
common to dipping and coating
or exceed 25 percent of its LFL. operations.
__ True __ False __ True __ False
Answers:
injuries they may face. 9. True. 10. False. You must post a “No Smoking” sign near each tank.
8. False. All employees who work in dipping and coating operations should be trained in basic first aid for the types of
6. False. Hoods and ductwork should be inspected at least once every 3 months or after any prolonged shutdown. 7. True.
ees may enter tanks and then only if all the requirements of OSHA’s permit-required confined space standard are met. 5. True.
removed will not cause a fire, explosion, or other chemical reaction. 3. True. 4. False. Only trained and authorized employ-
1. False. Airborne concentrations must be below 25 percent of LFL. 2. True. Unless the combination of substances being
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