It Came From Hangar 5!
Environmental and safety considerations for aircraft painting operations
By Michelle Garetson
No, this is not a trailer for an upcoming science-fiction thriller. It could be, however, just as scary if your maintenance operations are not keeping up with environmental and safety compliance issues. Many aspects of aircraft maintenance involve hazardous chemicals and materials — especially those operations that offer painting services.
How long has it been since you last reviewed with your staff the Material Safety Data Sheets (MSDS)? Would they know where to look for them if they needed them in a hurry? Fred Workley's column (AMT March 1999, pg. 60) discussed "Right to Know" requirements, MSDS, and the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, so it might be worth taking a second look at his article.
What if you were all of a sudden tasked by your company to design and develop a plan for a new hangar or paint facility? Who would you call first; FAA? OSHA? EPA?
"Actually, you'd have to call all three," replies Mike Parnell of BizJet in Tulsa, Oklahoma. Parnell, a painter himself, was hired by BizJet to design, develop, furnish (with people and equipment), and ultimately, work in a brand new paint facility at their site in Tulsa. This is the second time Parnell has been called upon by a company to help with plans for a paint shop.
He had to contact FAA, OSHA, and the EPA to tell of BizJet's plans and get approval. Because he and his group had done their homework well in advance of contacting the various associations, when it came time to meet, the organizations were pleased with the groundwork accomplished by BizJet and gave them the "thumbs up" to the plan.
"We wanted to be way ahead of what was required of us," explains Parnell, "and I think FAA, OSHA, and EPA realized that." BizJet worked with the local branch of the EPA in Oklahoma, which is the DEQ (Department of Environmental Quality). The DEQ keeps businesses up to date with Environmental Protection Agency (EPA) compliance issues and would also be the first "police" on the scene if there were any violations of regulations or non-compliant activity. Local EPA offices differ from state to state, for example, in Wisconsin, the local EPA is the Department of Natural Resources (DNR). Various state environmental offices are listed through a link on the Environmental Resource Center's web site, www.ercweb.com/LINKS.htm, or call ERC at (919) 469-1585.
Do your homework Nick Rettler, paint operation manager for Gulfstream in Appleton, WI (formerly K-C Aviation), was faced with a somewhat different challenge in developing the addition to their paint facility that was ultimately completed in November 1997. Rettler was literally on the ground floor in helping to shape the facility. This plan began initially with a proposal to the parent company, Kimberly-Clark. Rettler and group, which included Gary Hartwig, Gulfstream-Appleton's present general manager, who at the time was director of service operations; were told to develop a financial plan as well as to outline for management the use and payback schedule for the facility. And, this was all to be done in addition to their regular duties.
"We visited several of our competitor's facilities all over the country," explains Rettler, "to see what we would need for our place. Everyone was very open and helpful with information — giving us the pros and cons of setting up a new shop." Parnell echoed those words in his research for the BizJet shop. Prior to construction, he visited various paint facilities to check out what they had done in their designs.
"Every one of the places I went to was very open with what they went through," says Parnell, "and were especially helpful with EPA issues. Very open communication at all shops."
Like Parnell, Rettler contacted all interested parties (FAA, OSHA, EPA) for guidance with regulations and compliance. He worked with the FAA and local government to obtain building permit approvals. As the facility is at an airport, building height issues with respect to line of sight conflicts with the tower had to be addressed.
Also, the local sanitary department had to inspect and approve Gulfstream's drain systems. They needed to know where the drain sewers were, and how and where would the shop dispose of its chemicals. The sanitary department looked at all of the restrooms, shop drains, sinks — any place that solvents could potentially be dumped into.
Rettler explains, "Waste materials in the paint facility get drained into our wastewater treatment room where it gets treated and then ultimately ends up with water that meets the local sanitary district's requirements."
Rettler works closely with Ryan Reed, an environmental engineer also employed at Gulfstream-Appleton.
Environmental engineers are good to have either on staff or on a consulting type basis. The maintenance people interviewed for this article confided that trying to keep current with environmental compliance issues as well as the recordkeeping involved, while keeping up with their other duties is a daunting task. But, it has to be done, especially with the shift in the past year to reduce, if not eliminate the use of many of the chemicals that are found in stripping solvents and cleaning agents.
The "M" words
"We are using the new water-based strippers because sooner or later, they're going to get rid of methylene chloride," says Parnell.
"Emissions is the name of the game and with the chemicals we're using, we need to be looking at what they are emitting," advises Rettler. "Methyl ethyl ketone is the one that comes immediately to mind and we have that under control at Gulfstream. We have been shifting to the environmentally-friendlier materials more and more, and started by allowing MEK's use only for special instances and by certain personnel in an effort to reduce its use."
The "M" words, methylene chloride (MC) and MEK (methyl ethyl ketone), are becoming more and more controversial in hangar floor conversations. While both products have proven to be effective in their application, the environmental and health issues surrounding their use have warranted official action.
The OSHA standard regarding MC took effect in April 1997 and was to be implemented over a three-year period. The final rule for Methylene Chloride, 29 CFR Part 1910, was published in the Federal Register in September 1998. Final compliance with the entire standard must be achieved by April 2000. The OSHA web site at www.osha.gov offers a table with compliance dates, as well as the final rule for methylene chloride.
Training for the health of it
Both Gulfstream and BizJet provide extensive training for their staff in safety and health matters.
Rettler says, "We give a full overview of all chemicals that they're going to be using as far as making sure they handle them in a proper manner. They are also trained to know the difference as to when to use which respirators for specific processes."
Gulfstream offers leadership training, which includes training in "right to know" requirements, material safety data sheets, and emergency situations.
"All personnel, including the office people, know where to find the material safety data sheets," says Rettler. "In an emergency situation, we would take a copy of the MSDS pertaining to that chemical to the doctor so that he or she knows how to treat the injured employee."
Designing the "operating room"
Probably the most obvious consideration in designing any maintenance facility, is what size aircraft do you need to get inside the hangar and be able to close the door? Considerations for present customers and those you would like to woo in the future need to be addressed before breaking ground or moving walls.
Gulfstream-Appleton's addition has approximately 18,000 square feet in the paint booth and is set up to accommodate GVs and Globals.
After the initial size is determined, the rest of the details can be incorporated.
Safety and quality factors warrant that a paint hangar maintain clean air and a clean, dust-free environment. One of the first things Rettler needed to decide upon was how exhaust in the hangar was to be managed — the two main exhaust systems being either cross-flow or down-draft.
"We chose cross-flow," says Rettler, "because we work on many different types of aircraft. Predominantly, most booths that I've looked at in the U.S. use cross-flow. The big guys like Cessna that are painting very similar aircraft all of the time, use downdraft, because it's easier to control for the same type of aircraft over and over."
Another decision to be made was the choice of overhead fall-restraint system. Rettler decided to have 5 I-beams installed with trolleys for workers to tie into as opposed to installing a cable system. Though more economical, a cable system was not feasible for the new design of the hangar.
With respect to personnel and their individual equipment, Rettler offers, "There are 23 painters on staff, split into two shifts, and all are personally fit with and given fresh air breathing apparatus gear, organic vapor respirators, and uniforms."
"We also installed the appropriate air compressors so that we had Grade D breathing air throughout the entire facility," explains Rettler. "And, we upgraded the pneumatic system — the entire pneumatic system in our paint facility is made out of copper tubing that is brazed together so that there is no lead in the joints. These are all things we learned about while designing the facility."
With Parnell's 14 years experience in painting, he designed the shop from a painter's perspective. The first thing he considered was not the actual building, but rather the comfort of the painters.
"Painting is a hot and dirty job," he explains. "With that in mind, the equipment (safety and personal) needed to provide the maximum comfort for the staff." Parnell continues, "Painters are all fitted with their own gear — we don't use a 'one-size fits all' approach to equipment."
The BizJet facility itself has 165 feet by 165 feet outside dimensions, inside dimensions of 140 feet by 140 feet, and has a ceiling height of 43 feet. This size hangar would be able to accommodate a 727-200 for servicing. "Think of it as a hangar within a hangar," says Parnell.
Some of the shop equipment includes creepers designed by the staff to help them do their jobs more efficiently and comfortably.
"Because our people may need to be under the aircraft's wings during the job, says Parnell, "we have designed creepers that are four to five feet off the ground so that they don't have to reach so far when doing their job."
A paint hangar has a whole host of safety issues to address. Anything that might produce a spark has to be considered. BizJet uses non-explosive lifts in the hangar — an EE-rated scissorlift in the stripping area and an articulating boom lift in the painting area.
Overhead lights are installed and replaced via a "buffer zone" outside of the paint booth — the 25 foot difference between the outside wall of the entire building and the outer wall of the paint booth.
"We can't even have a paging system — it's electrical, and might produce a spark," warns Parnell. "This is my 'operating room' and it needs to be as clean and as safe an environment as possible."