Decommissioning paint shops: Three areas to watch

Consider environment, utility and safety issues when making your plan.

By Gary Winslow, Ghafari Associates February 15, 2018

When market conditions require decommissioning a paint shop, the process involves constant changing conditions. The key to survival is having a definitive plan. During the decommissioning process, there are hazards everywhere that must be addressed to ensure a safe workplace before, during, and after decommissioning.

A comprehensive plan that anticipates these challenges and outlines how to deal with them is definitely essential to survival.

There are three areas to keep an eye on:

1. Environmental concerns

There are many potential environmental impacts and safety concerns stemming from the automotive manufacturing industry, not the least of which are the chemicals and hazardous materials used in the painting process.

Great care must be taken in the day to day operation of the paint line. Even more careful consideration is required when decommissioning or making drastic changes that require equipment to be moved or reconfigured. Safety managers and experienced personnel can help develop detailed plans to ensure compliance, protect the environment, and keep workers safe.

Protecting the environment is more than just a moral code. In many cases, there are defined local, state, or federal codes and regulations that must be met. Whichever regulations a plant adheres to, there are possible environmental impacts that need to be considered. Proper cleaning and disposal of materials are a key part of the environmental regulations.

The best way to stay ahead of code requirements is through daily housekeeping in the plant, ensuring that all refuse is properly disposed of. Coordinate with plant managers and environmental management staff to dispose of production materials, and with the waste management team to dispose of scrap materials. Engage a crew of cleaning contractors to collect and remove residues throughout the plant.

In a paint shop where there are many liquid chemicals to dispose of, ground water issues can arise, especially when leaks are overlooked or there is additional particulate in underground systems. Other unique challenges include wastewater and residues spilled onto the roof from stack cleaning operations.

Drainage must be controlled and routed away from roof storm-water systems into the industrial waste system. Leakage of high-pressure pump systems often has an oily residue and should migrate into catch basins to avoid spillage. The paint shop needs to monitor all chemicals and paint residues throughout the plant.   

Weather can also pose a unique challenge, depending on the locale. Temporary covers for the building roof and wall openings may also be used during construction or demolition that may not be weathertight. Such issues can be problematic in terms of regulatory compliance. Proper planning, monitoring, and documentation of compliance with storm water plans can save costly EPA fees. If the shutdown and reactivation will span several months, air intakes may require sealing to prevent the elements, as well as birds and other small animals, from entering. Stacks must be closed to prevent backdrafts into the building, and outside doors, windows, and other openings should be secured against weather. Building pressurization should be monitored to keep proper air balance.

Despite the best efforts toward planning, some environmental considerations may be overlooked. This is where experience really becomes useful, in knowing what to look for based on lessons learned from previous projects. When removing chemicals in bulk, for instance, testing the quality of the materials before and after removal to see if any contamination has occurred can be a huge time saver down the road.

The owner or plant manager is responsible for the control of all disposal of materials and equipment to approved sites. Hazardous materials must be segregated and sent to the approved disposal sites so no chemicals contaminate the ground water. Ground water contamination can be a huge problem with widespread effects on plants, animals, and people.

2. Utilities concerns

Efficient utility consumption is another way companies can prioritize the environment. Reduced use of power and lighting when the plant is not operating at full capacity is a good place to start. At a minimum, the power-on safety and security systems must be maintained. Lighting, aside from minimal security/safety lighting can be disconnected once cleaning operations are completed.

Fire protection is always important, and shutdowns that take the system offline must be carefully coordinated with plant security personnel. Any changes in fire protection piping and other fire protection equipment during demolition and removal can compromise safety and property if mishandled. Fire watch is critical when removing equipment and material. Failure to complete the full 30 minutes of fire watch after the completion of welding and burning activities can result in injuries and property destruction. 

While NFPA codes dictate that fire protection must never be relocated, during decommissioning some systems are less critical and can be deactivated earlier than others. The most important consideration is identifying the risk such that no activity may create a fire hazard if a system has been shut down. Fire protection systems in process equipment, booths, and ovens may be temporarily deactivated, so these systems may have maintenance or other activities performed. Great care and planning is required to prevent burning and welding activities from initiating an alarm from the IR detectors in spray booths.   

Other utilities to consider are gas and steam. Gas can be immediately disconnected when not in use. Secure the gas line at its entry point into the paint building, unless it is needed for minimal heating or freeze protection. This is typically not required if fire protection systems are deactivated and drained. Low and high-pressure steam systems, along with their condensate piping and related equipment, must be decommissioned in a safe and environmentally friendly manner, once they are no longer needed.

A unique situation like an extended shutdown prompts owners and operators to look at all the utilities in a way they normally don’t during day-to-day operations. There are some things that may be overlooked, such as bus duct and electrical safety protocols. For loading of bus ducts when equipment is added or removed, an electrical engineer should review the changes in the bus loading and determine what is needed for a balanced power grid.

Safety procedures including Lockout/Tag out (LOTO) and Electrical Safe Work Practice (ESWP) tags, need to be updated when equipment is relocated. These are often moved with the equipment and become obsolete in their new location when changes occur and tags no longer show the correct amperage loadings.    

3. Safety considerations

Housekeeping is something that can be erroneously perceived as insignificant but is often a leading indicator of site safety. A clean site is usually a safe site. Daily housekeeping tours eliminate trip hazards such as extension cords on the floor and provide a good ongoing review of safe work practices.

Establish a more detailed safety program for specific site conditions, including detailed safety PTPs (pre-task plans) with contingency plans. Revise and update the PTPs as working conditions change, such as weather and lighting during each shift.

Angle grinders are a specific safety consideration in automotive paint plants. Due to the unusual positions workers are in while operating these tools, accidents with blade binding are more prevalent. This is compounded when workers are cutting on ladders and scaffolding.  Check and validate loading labels for relocated equipment, and tie-off points at the new locations.

Alarms for weather emergencies and evacuation may be impacted by removal and/or modifications to egress paths will change regularly during demolition and need to be communicated to everyone on the site. Toolbox talks and PTPs are critical tools to the safety of everyone involved in the construction project and day-to-day operations in the plant.

A key for safety in paint application is chemical and hazardous materials safety. Residual chemicals in the system after flushing are an inherent danger to workers. It is vital to flush and check all piping systems prior to dismantling them. During this process, workers must wear proper PPE to safeguard themselves from chemicals remaining in low points of the piping. Piping often does not have drains at the low points and must be cut into for drainage. Boilers and hot water generators require draining and special procedures for storage if they are to be transferred/sold.

Safety managers play a key role in these important plans and procedures. Supervisors often are not aware of the level of training and expertise the safety managers have, and potentially see their role as conflicting with the daily output of the plant. However, everyone is truly committed to safety, and leadership often ultimately discovers how the safety manager’s work actually saves time and money in the long run by guiding big projects to completion and avoiding costly accidents.

Making detailed plans, updating them as circumstances change, and following them closely is the best way to avoid accidents. Good planning will ensure that nothing is overlooked and reduces the potential for dangerous spills and leaks, as well as the health effects of exposure to hazardous chemicals for workers.

There are many pieces to coordinate for the safety of both workers and the environment when making big changes to the plant building, layout, or process flow, but with good planning and coordination, the plant, environment, and workers will be able to safely decommission a paint shop.

Gary Winslow is with Ghafari Associates.