Refinishing Projects and Government Compliance

Removal and restoration of wood finishes has grown more complex in recent years due to federal, state and local government agencies strict regulation of employee exposures, use of solvent materials for finishing and waste disposal.

Project owners may be subject to fines and other legal liabilities that could stem from improper practices used by contractors for whom they have hired. Complaints or legal actions can be made by government agencies or employees who work or worked on their specific project.

Following is an overview of the various agencies and their requirements along with a questionnaire that can be used by owners to help determine potential contractor viability.   

Overview

OSHA concerns relating to furniture restoration revolve around the use of Methylene Chloride (MC) for finish removal. MC is slowly reaching the regulatory level of asbestos and lead paint as the Potential Exposure Level (PEL) has been reduced from 550 ppm to 25ppm. OSHA requires that employers use engineering controls to achieve this level. Thus, properly ventilated and regulated areas of containment are needed. Simple organic vapor masks and filters are not allowed as respiratory protection, fresh air respirators are needed. Eye wash systems must be made available and medical surveillance is required for all who work in areas of high exposure. Employers are required to have written programs for Respiratory, Hazardous Materials and Methylene Chloride to be completed prior to beginning work.

MC cannot be allowed to enter the waste stream, therefore the DNR requires proper containment and disposal of materials removed from wood. Records and documentation/proof of hazardous waste disposal actions must be kept. Licensed haulers and EPA approved processes must be used. Rags generated in shop with MC contamination must be washed by EPA approved vendors who use a "clean water" process.

Most communities have concerns regarding fire safety and shop conformance. Storage of flammable materials and good physical layout are primary concerns.