INDUSTRIAL HYGIENE SURVEY
of the
THE ART DEPARTMENT of . STOUT UNIVERSITY ~ MENOMONIE,
WISCONSIN
Monona Rossel, M.S., M.F.A., industrial hygienist
Arts, Crafts and Theater Safety, Inc. 181 Thompson St., #23, New York NY 10012-2586 212/7770062 ACTSNYC@cs.com
June 12, 2006
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TABLE OF CONTENTS
PART I. INTRODUCTION .
OSHA REGULATIONS
GENERAL INDUSTRY v. CONSTRUCTION STANDARDS..............................
STANDARDS
AVOIDING LIABILITY
ADMINISTRATORS SPECIAL ROLE
PART II. GENERAL REGULATORY RECOMMENDATIONS........................................
A HAZARD COMMUNICATION
B. RESPIRATORY PROTECTION. .
C. PERSONAL PROTECTIVE EQUIIPMENT
EYEWEAR
FACE PROTECTION
GLOVES
FOOTWEAR
PROTECTIVE CLOTHINGIDRESS CODE
D. FIRST AID, MEDICAL SERVICES & BLOODBORNE PATHOGENS............
EYEWASHES/DELUGE SHOWERS
E. FIRE PROTECTION: EMERGENCY RESPONSE, EXTINGUISHERS............
F. FOOD & DRINK/SANITATION
G. ELECTRICAL EQUIPMENT
ELECTRICAL PANELS
GUARDING OF LIVE PARTS
GROUND FAULTING
TEMPORARY WIRING
USE OF TWO PRONG PLUG ADAPTORS
H. HOUSEKEEPING.................................................................................................
I. BUILDING ACCESS
J. GRADUATE STUDIOS
K. SMOKING & DRINKING POLICIES
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4
5
6
7
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PART III. EPA REGULATIONS............................................................................................
A.GENERATORSTATUS
B. REGULATED CHEMICALS USED IN ART......................................................
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C. SINK DRAIN TRAPS
D. SOLID WASTE
E. MODEL WASTE PROGRAM.................................................
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F. WASTE TREATMENT SYSTMS
NEUTRALIZATION TANKS
BIOLOGICAL DEGRADATION
RISD: A TREATMENT SYSTEM THAT WORKS
G. CONTAINMENT& SPILL CONTROL...............................................................
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RECOMENDATIONS
PART IV. VENTILATION.................................................................................................
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A. ASHRAE STANDARDS
B. ASHRAE SYSTEM IN THE SCHOOL
C. ASHRAE & CHEMICAL USE..............................................................................
D. ACGIH STANDARDS.
I. DILUTION VENTILATION·
2. LOCAL EXHAUST VENTILATION
TABLE 1 -VENTILATION ,......................................
PROCESSES REQUIRING DILUTION/DISPLACEMENT
PROCESSESIEQUIPMENT REQUIRING LOCAL EXHAUST
E. WORKPLACE AIR QUALITY STANDARDS
F. OUTDOOR AIR QUALITY & LOCATION OF EXHAUSTS
G. VENTILATION AND LIABILITY :............................
H. GENERAL VENTILATION RECOMMENDATIONS
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15
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PART V: SPECIFIC RECOMMENDATIONS· THEATER...............................................
A. THEATER
B. SCENE SHOP......................................................................................................
C. DRESSING ROOMS..........................................................................................
D. GREEN ROOM
E. WARDROBE ROOM
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PART VI: SPECIFIC RECOMMENDATIONS· ART BUILDING.................................
A. PROCESS LAB
B. ROOM 234
C. WOODSHOP -ROOM 119
D.METALSHOPROOMI19A......................................................................
E. SCULPTURE ROOM 120................................................................................
F. CLAY MIXING ROOM 107..............................................................................
G. CERAMICS ROOM 103...................................................................................
H. PRINTMAKING................................................................................................
I. PAINTING & DRAWING ROOMS 1 &2.........................................................
J. INDUSTRIAL DESIGN ROOM 216A & 220...................................................
K. ARTMETALS ROOMS 101 & 101A...........................................................
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25
26
31
36
43
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PART VI1: PRIORITY RECOMMENDATIONS .........................................................
47
APPENDIXES .....................................................................................................
48
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INDUSTRIAL HYGIENE SURVEY: THEATER AND ART DEPARTMENTS OF
STOUT-UNIVERSITY OF WISCONSIN
Monona Rossol, M.S., M.F.A., industrial hygienist
Arts, Crafts and Theater Safety, Inc.
181 Thompson St., # 23, New York NY 10012-2586
212/777-0062 ACTSNYC@cs.com
June 12, 2006
PART 1. INTRODUCTION
This report and its recommendations are based on information obtained by Monona Rossol, of
Arts, Crafts and Theater Safety (ACTS) during a survey done on April 27 and 28, 2006. The
information on conditions and practices consists of 1) descriptions by the personnel, 2) a
previous report on this facility I wrote in 1993, and 3) observations during a walk through
survey of the department. With only these sources available, this report must not be considered
as exhaustive or inclusive of all potential hazards that may exist. ACTS and its employees and
agents are not responsible for any accident, injury or other loss that may occur as a result of any
hazard.
The evaluations and recommendations contained in this report are based on current reference
sources and accepted industrial hygiene principles and practices. The recommendations made
are advisory. ACTS is not responsible for the carrying out the recommended changes in
operations and equipment. Monona Rossol will answer any questions about the material in this
report and provide follow-up technical advice and counsel on request.
OSHA REGULATIONS. The Occupational Safety and Health Administration (OSHA) regulates
safety of workers in the US. However, Stout, like all of the University of Wisconsin schools, is
regulated under the rules of the Department of industry, Labor and Industrial Relations (DILHR).
These rules must be equal to or more protective than the federal OSHA regulations. And DILHR
has adopted the OSHA regulations. Rather than look up the citations in DILHR codes, I will refer
to the federal OSHA regulations. I leave it to the Health & Safety Office to check for differences
between the OSHA regulations and DILHR's laws, if any.
Whether they are federal or state laws, the OSHA regulations are considered minimum health
and safety precautions for the protection of adult paid employees. DILHR used to include the
students directly under these laws, but no longer do. However, since DILHR's occupational
regulations are considered minimum health and safety precautions for the protection of paid
adult employees, failure to provide equal or better protections for the unpaid, inexperienced
students can be used as evidence of negligence in personal injury lawsuits. Students actually
need more training and protection than is required for the faculty.
For this reason, the training and precautions required for the protection of faculty should be
extended to the students. In fact, OSHAIDILHR training should be part of the curriculum. This
will also provide students with information that will equip graduates for teaching or creating art
in the real world.
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GENERALINDUSTRY v. CONSTRUCTION STANDARDS. Whether the applicable regulations are
state or federal, the laws are further divided into two sets: rules for general industry and rules
for construction work.
Workers in a permanent venue, such as the various art studios and classrooms on campus, come
under the Virginia state equivalent of the General Industry Standards (29 CFR 1900-1910). But
workers on a temporary location rather than in a permanent shop come under the Construction
Industry Standard (29 CFR 1926). OSHA's definition of construction work is broad and includes
any "alterations or repair, including painting and decorating." This means that installation or
building of a large sculpture in studios or in galleries may come under the construction
standards.
Both sets of regulations will be mentioned in this text when appropriate and they will be cited in
the standard format. For example, the Hazard Communication Standard is found in the 29th part
of the Code of Federal Regulations (CFR) at: 29 CFR 1910.1200.
STANDARDS. In addition to regulations there are professional standards applicable to
ventilation (ASHRAE & ACGIH), electrical installations (NEC), fire protection (NFPA), protective
equipment (NIOSH & ANSI), and so on. These acronyms and their standards will be identified in
this report when applicable.
For example, the National Fire Protection Association (NFPA) codes are often incorporated into
local building and fire codes. And both the NFPA standards and the OSHA regulations would
prohibit building obstructions (sculptures) in egress areas. NFPA would prohibit installing fabric
or plastic sculptures that are no iIre rated in public buildings.
Occasionally, OSHA cites employers under the General Duty Clause when there is no applicable
regulation. To do this, OSHA will often cite a standard that is not actually a law. For schools,
however, it is the liability for failing to follow professional standards that is greater issue. School
risk managers and attorneys should consider the professional standards as important as
regulations when assessing liability.
AVOIDING LIABILITY. Schools and teachers can be found liable for accidents or illnesses if they
fail to meet any of five major duties: to inform, to train, to enforce, to exemplify, or to provide a
safe work environment.
1. TO INFORM. Administrators are responsible for providing teachers (employees) with
information about job site hazards. Likewise, teachers must pass safety information on to
students. The information must be complete and specific. For example, if a student is injured or
made ill because a teacher neglected to inform the class of potential hazards, the courts may
interpret this as willful and/or knowing negligence on the part of the teacher and/or school.
2. TO TRAIN. Teachers must ensure that each student knows how to work safely with hazardous
materials or equipment. Teachers must develop mechanisms to verify that students are trained
to avoid making incorrect assumptions about their comprehension. This is most often done by
observing them and their work and by giving safety quizzes. Teachers should keep records of
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their observations and copies of these quizzes to document that their students understood the
safety presentations.
3. TO EXEMPLIFY. Teachers and administrators must model safe behavior. If teachers or
administrators are observed violating safety rules, they may be liable for damages caused when
students also break the rules. In addition, teachers and administrators must demonstrate a
proper attitude toward safety. They must make it clear that safety is more important than
finishing the work, cleaning up in time, or any other objective. Administrators who show
contempt for the regulations, who glorify risk-taking, or who belittle students or other teachers
who try to follow the rules are demonstrating failure to exemplify.
4. TO ENFORCE. Administrators cannot allow teachers to violate the rules. Regulators make it
clear that without an enforcement policy, there is no safety program. Likewise, teachers must be
in. control of their students and must enforce the safety rules and administrators must support
the teachers' attempts to enforce the rules. In fact, teachers and administrators may be liable
even when students willfully break the safety rules if it can be shown that the rules' were not
enforced. And courts have held that enforcement policies must include meaningful penalties for
those that break the rules--not a slap on the wrist. The penalties for infractions of safety
regulations should be in writing as a part of every school's written safety program.
5. TO PROVIDE A SAFE STUDIO/SHOP/CLASSROOM. No amount of enforcement, training or
information will make up for teaching in an unsafe environment. If a lesson cannot be done with
all proper precautions. safety equipment. and ventilation. the project must be eliminated from
the curriculum. There is never a good enough reason for students or teachers to violate safety
laws in schools.
ADMINISTRATOR'S SPECIAL ROLE
Administrators are ultimately responsible for the efficacy of school health and safety programs.
Some administrators do not fulfill these duties under the guise of allowing teachers and students
"artistic freedoms." A common example is allowing students the freedom to work alone at night
in buildings without supervision, without security, and even without ventilation if it is turned off
after hours. Under these conditions, administrators have no good legal defense for accidents
involving chemicals or machinery, for illnesses for which emergency services were not speedily
procured, or for assaults in unsecured premises.
So-called freedoms involving risks like these must be rescinded immediately and replaced with
sound health and safety discipline. For example, students should have a sequence of deadlines to
meet during the semester so that they do not have work night and day to the point of exhaustion
to produce an entire art show or theatrical production in the last few weeks of class.
In other words, administrator~ must administer, teachers must supervise, and students must
take direction. Everyone must do his or her job or the safety of all and the liability of the school
and its teachers are at risk.
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PART II. GENERAL REGULATORY RECOMMENDATIONS
A. HAZARD COMMUNICATION (1910.1200). The faculty is much more aware of this law than
when I was here in 1993. And in the training I did for faculty and students, we reviewed the
provisions of the law which include:

a written program which includes a survey (inventory) of all potentially toxic materials
held in the schoo1;

a labeling program which insures that each container of potentially toxic materials has a
label which meets OSHA regulations;

a file of material safety data sheets (MSDSs) on all the potentially toxic materials;

regular training of all potentially exposed workers.
Labels must have the name/address of the manufacturer, the name of the product exactly as it is
on the MSDS, and any required hazard warnings. As soon as a product is separated from this vital
information is it in violation of both EPA and OSHA regulations. For example, some clay and glaze
chemicals in the pottery have been put in bins and containers only labeled with the name of the
substance. This entire inventory is in violation of the labeling regulations.
The survey and the MSDS file must be all inclusive of potentially toxic products. For this reason,
students cannot purchase and bring in their own materials unless they are of the exact brands as
those products on the survey and for which MSDSs are already on file. Most universities solve
this problem by providing a list of the materials that are permitted to be used the class (see also
the permissible list information in the Environmental regulations below).
If a student wants to use a different product, the teacher can direct the student to contact the
manufacturer and obtain an MSDS. Then the safety office can evaluate the MSDS. Lf the product is
suitable for use under classroom conditions, it can be added to the survey and MSDS file.
MSDSs. In most departments I saw MSDSs in binders, but some were not current or complete.
B. RESPIRATORY PROTECTION (29 CFR 1910.134). There are situations in which the students
and/or faculty may need respiratory protection. If this is the case, the school must:

develop a written respiratory protection program;

provide medical certification (by a health professional or doctor) to ensure that wearers
do not have health problems that may be exacerbated by breathing stress or wearing a
mask or respirator such as asthma, heart problems, etc.;

provide someone trained in one of the five OSHA-approved methods to fit test wearers;
and

provide training in the use, limitations, and maintenance of the masks or respirators.
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Providing less than a full program will leave students with misconceptions about respirator use
that will cause them put themselves at risk throughout their careers. An alternative strategy is to
substitute safer materials for toxic ones and to provide good ventilation. This makes respiratory
protection unnecessary. Over time, the ventilation is cheaper than respiratory protection.
C. PERSONAL PROTECTIVE EQUIPMENT (1926.28,1910.132-133). OSHA requires written risk
assessments, written programs, and formal training about the proper use, limitations, and
maintenance of safety equipment. OSHA usually relies on the American National Standards
Institute (ANSI) for standards of care for selection and proper use of protective equipment. The
school is required to provide these OSHA and ANSI program elements for the faculty, but
students should be included in the training and programs as well.
EYEWEAR. All the eyewear should meet the ANSI Z87.1 standard for various uses. For example,
high impact eyewear with side shields should be used around machinery. But these glasses are
not be suitable protection against Chemical splash in which case a different type of eyewear is
needed.
If the school provides the eyewear to be shared by students, there must be a system for
disinfecting it between users. There are ultraviolet light cabinets which sterilize equipment
available through safety catalog outlets. Otherwise, eyewear can be purchased and cleaned by
the student as part of their kit for their individual use.
I recommend students purchase and use their own eye wear. It should be part of a "kit" that
.theater and art students develop to take with them into their classes and later into their jobs.
FACE PROTECTION such as shields also can find use in welding and some woodworking
operations. Clear face shields usually do not qualify as eye protection and eyewear must be worn
under the shield. Welding shields were seen with the welding equipment and they appeared to
be the right type.
GLOVES are needed for chemical use and hot work such as welding. During the survey we
discussed the need for having several types of chemical gloves so that the glove manufacturers'
permeation data can be consulted to determine which gloves should be used for various types of
chemicals. APPENDIX 1 provides some of the training information needed for gloves.
FOOTWEAR. Steel toed shoes should worn by anyone working with heavy objects such as in:
welding and woodworking. Students planning a careers in technical theater in particular should
own this footwear. A good pair of sneakers can be used for regular light work in the shops. Even
more important, there must be a total ban on sandals, flip-flops or other inappropriate footwear.
PROTECTIVE CLOTHING/DRESS CODE. Clothing worn in the shops should cover the body, arms
and legs to protect them from paint, and abrasions. During welding or grinding of metals, the
clothing must be of material that does sustain a flame and/or will not melt (e.g., no polyester).
Wool and tightly woven cotton are examples of such materials. Students should be warned not to
add liquid fabric softeners to the water when these items are washed (APPENDIX 2).
Clothing, jewelry, and hair should not be in any style that can get caught in machinery or get in
the way of the job. This includes body piercing jewelry.
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D. FIRST AID, MEDICAL SERVICES (1910.151) & BLOODBORNE PATHOGENS (1910.1030) I saw
some first aid kits. However, standard industrial kits with a blood borne pathogens kit (BBP)
should be in each location where machines and/or tools are used. A list of the items in the kits
should be provided to the faculty (APPENDIX 3). The school must either I) provide clear written
guidance and/or training so that the faculty can replenished items as they are used, or 2) provide
a service for restocking the kits and equipment (e.g. lee Medical Co.).
While first aid treatment should only be done by people who are certified, there are times when
body fluid accidents will require immediate handling and all workers should know how to do
this. I also recommend that some of the faculty be certified in First Aid and CPR.
All faculty and all student workers (who are left in charge when the faculty is not present) should
be provided with a short training on the use of the BBP kits and proper use of the gloves. This is
called "blood borne pathogens training for non-medical personnel" and there are good training
videos and other materials available from safety providers.
The shops in which small tools are used should have contaminated sharps containers into which
Exacto blades, needles, broken glass, and other small sharp items that have drawn blood can be
placed for disposal. The school will need management of these containers directed from the
safety office.
EYEWASHES/DELUGE SHOWERS. The school is doing a good job of meeting 1910.151 which
requires eyewash stations in all areas in which eye-damaging chemicals are used or stored such
as solvents, spray products, and paints. The ANSI standard (2358) specifies the distance from
work stations within which eyewash stations must be located and other requirements.
2358.1.6.4.2 says that eyewashes must be:
... in accessible locations that require no more than 10 seconds to reach. The eye/face wash
shall be located on the same level as the hazard and the path of travel shall be free of
obstructions that may inhibit the immediate use of the equipment. For a strong acid or
strong caustic, the eye/face wash should be immediately adjacent to the hazard (see
Appendix 5B).
Appendix 5B of the standard defines a door as an obstruction. One door can be in the pathway
only if the eye hazard is not a corrosive (like a strong acid), if the door opens in the same
direction of travel as the person trying to reach the eyewash, and if the door is equipped with a
closing mechanism that cannot be located to impede access such as a panic bar. Essentially, this
means an eyewash station must be located in every room in which corrosive chemicals are used.
The ANSI standard also requires that the eye wash be capable of being turned on with a single,
less-than-one-second movement and stay on for a minimum of 15 minutes so that both hands are
now free to hold open the eye lids. Handheld bottles or hoses are not acceptable. One type that
takes up very little space and meets the standards is seen in APPENDIX 4.
The eyewashes must be flushed weekly for three full minutes and this information recorded.
There must be eyewashes in areas such as metals, painting and printmaking. They also must
have tags near them indicating when they were run for three minutes and cleared. If corrosive
chemicals such as acids are used or if large amounts of chemicals such as solvents in gallon cans
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are present, emergency showers also should be installed. These showers should be "bumped"
once a week to clear the line as well
E. FIRE-SAFETY: EMERGENCY RESPONSE, EXTINGUISHERS, EGRESS. OSHA requires that all
employees have emergency and fire training annually and that all new hires get this training
before they begin work. Students should have the training at orientation. Some of the facilities
are sprinklered, but the sprinkler heads in some ceilings are high enough that a fire could harm
people below long before enough heat would rise to melt the plug on the sprinkler head. For this
reason, there are extinguishers in some places which also require training.
In addition, the faculty must know if the systems are wet or dry pipe systems, where the risers
are, what to do if there is an accidental release, and so on. All employees should be trained about
the system, the types of extinguishers, how to use them, escape routes, where to meet after
evacuation, and all of the aspects of the school's fire protection program. In addition, a copy of
the schools written fire protection program should be available to the faculty and the basic rules
should be posted.
Exits should never, at ¥1y time, be blocked. Aisles and walkways should never be impeded with
temporary storage. Many schools find it helpful to paint lines on classroom floors delineating
aisles so that students will learn that they cannot even temporarily place materials in these
areas.
F. FOOD & DRINK/SANITATION (29 CFR 1910.141(g)(2)/(4)). OSHA forbids eating or storing
food in areas where toxic substances are used or stored. The classrooms qualify as places where
eating must be banned. it is important to set aside an office or other clean and sanitary room
with walls and doors and separate ventilation system to isolate breaks and snacking from work
areas. These areas should be conveniently near the shops or people will not use them.
G. ELECTRICAL EQUIPMENT (1926.401-.405,1910.301-304). There are OSHA regulations about
electrical power. Also, OSHA references the National Electrical Code (NEC). This means that any
violation of the NEC code can be cited. Some of the problems seen include:
ELECTRICAL PANELS (1910J02(g)(1)(i)). Active electrical service panels must have access areas
in front of them. The areas which must be kept completely free are defined in the rules
(APPENDIX 5). Some panels did not have clearance in front of them. The floors in front of these
panels should be painted to indicate the clearance area.
GUARDING OF LIVE PARTS 303(g)(2)(i). In once case, the cover on a panel was left open.
GROUND FAULTING 1926.404(b)(1) & 1910.304 (f) (5) (v) (C) (3)-(8) .All outlets within 10 feet
of water must by CFCI such as almost all the outlets in ceramics. All shop outlets into which tools
are often plugged should be GFCI (APPENDIX 6). Whenever new extension cords are purchased,
they should have built-in GFCI units.
TEMPORARY WIRING such as extension cord were used extensively. Instead, many of these
locations should have had hard wired outlets.
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USE OF TWO-PRONG PLUGS & ADAPTORS. All the equipment in the school should be either
double insulated or grounded and equipped with a three prong plug. Using adaptors to
make the transition from double to triple pronged plugs and outlets can electrocute users
(APPENDIX 7). It's hard to convince students and faculty that the ungrounded two-prong-plug
lamps or power tools that are acceptable for home use are not technically allowed to be used in
the school. This is especially a problem in individual student studios and faculty offices where
occupants tend to "set up housekeeping."
H. HOUSEKEEPING. OSHA regulations (1910.22,1926.25) require good housekeeping:
All places of employment, passageways, storerooms, and service rooms shall be kept clean
and orderly and in a sanitary condition.
Most of the rooms I saw were in fairly good order, but some shops, hallways, studios, and even
faculty offices were cluttered and aisles were blocked..
1. BUILDING ACCESS. Allowing students to have 24 hour access to the building requires that two
issues be thoroughly considered.
1. Common sense safety practices throughout industry dictate that no person, however
well trained and motivated, should work alone with chemicals and/or machinery.
Industry relies on the buddy system, in which two fully trained workers are always
within eye contact of each other in case of sudden illness or accidents. So allowing a
student to work alone violates due care and common practice.
Work clearly should be restricted to times in which there are trained monitors are
within at least ear shot of all students using the building. The safety certification
system used in the Wood shop should be applied to all machinery and chemical use
throughout the school.
2. Twenty-four hour access also requires that the ventilation also cannot be turned off at
night. Highly energy-cost systems must run all night if even one or two students are
working with toxic substances that require ventilation. To do less is clearly put those
students at risk.
J. GRADUATE STUDIOS. The access problems are magnified in individual studios such as those
in the ceramics area. Here, visual contact is not possible and control of materials and behavior
are extremely difficult. There must be some limits on the materials and processes used in these
studios. Otherwise, there will have to be special ventilation, eye wash stations, and other costly
safety equipment in each and every studio.
Other schools (e.g., the San Francisco Art Institute) have studio monitors who follow school rules
regarding materials that are allowed in studios. They remove any materials which cannot be
safely used in the student's studio. A similar plan must be developed regarding studio activities.
Otherwise, the ventilation and safety equipment will not be adequate.
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K. SMOKING/DRINKING POLICIES The school has a "no smoking" policy and does not allow
drinking in the buildings, but I am concerned about enforcement during night time hours. There
are many flammable and -combustible materials used in the programs and dangerous
machinery.
PART III. EPA REQUIREMENTS
This report focuses on the OSHA regulation, but it is also important to coordinate these with the
EPA regulations. And the first environmental requirement is to determine the school's hazardous
waste generator status.
A. GENERATOR STATUS. Hazardous waste generators are broadly defined as any person, by
site, who creates or produces hazardous waste brings a hazardous waste into the United States.
Such generators and sites in the art and theater fields include public or private schools at the
high school and college level. Schools are classified according to quantity of waste as follows.
Large Quantity Generators (LOGs): LQGs produce more than 2,200 pounds in a calendar
month, or more than 2.2 pounds of acutely hazardous waste in a calendar month;
Small Quantity Generators (SOGs): SQGs produce less than 2,200 lbs but more than 220 lbs
of hazardous waste in a calendar month, and accumulate less than 13,200 lbs of hazardous
waste at any time; and
Conditionally Exempt Small Quantity Generators ICESOGs): CESQGs are those that
generate less than 220 lbs of hazardous waste in a calendar month, or less than 2.2 lbs of
acutely hazardous waste in a calendar month. Additionally, CESQGs must limit accumulation
to less than 2,200 lbs of hazardous waste, or 220 lbs of any residue from the cleanup of a spill
of acute hazardous waste at any time.
Determining which category the school falls into must be done on a facility-wide basis. For
example, it is not just the quantity of hazardous waste generated in the art department that
matters, but the total quantity of hazardous waste generated by the entire school which
determines the category. Included in the total will be waste from building maintenance and
cleaning, the science classes, the art department, and all other departments. So even if the art
department only generates a small amount of hazardous waste, it is subject to the requirements
of the category into which the whole school falls.
In fact, if the ceramic department disposes of only 2.2 pounds of a common ceramic colorant,
vanadium pentoxide, the whole school would be bumped up to the Large Quantity Generator
status! (Note: vanadium pentoxide is one of the highly hazardous "P" wastes.)
Based on the quantities of hazardous waste generated by a school of this size, it is expected that
the school is a Large Quantity Generator. But these categories are based on monthly generation
quantities, it is possible to be in one category during a certain month and in another category the
next month. The school needs to inform the art department of its status and the effects of this
status on their waste handling and disposal.
9
I did not see any posted Satellite Accumulation Areas in the school which should be there if the
school is meeting the Large Quantity Generator rules. These areas for waste collection in
painting, ceramics, metal and jewelry should be set up, posted, and the faculty should be trained
about the rules that apply to them.
B. REGULATED CHEMICALS USED IN ART.
Certain wastes are very tightly regulated. Included in these hazardous wastes under US EPA
RCRA (Resource Conservation & Recovery Act) are the following catagories:
Ignitable: e.g., flammable & combustible solvents
Corrosive: e.g., acids, bases
Reactive: e.g., hypochlorites, organic peroxides, perchlorates, permanganates & sulfides
Toxic: e.g., RCRA metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, &
silver. Cyanides (cyanol Prussian blue), Vanadium pentoxide ("P" listed waste).
Many RCRA chemicals listed above are commonly used in art. Examples include cyanotype
chemicals and Prussian blue pigments which are cyanides (APPENDIX 8) and cadmium and
chromium pigments in paints and ceramics. Hopefully substitutes for some of these chemicals
can be used in some cases. For example, all lead use will be discontinued in ceramics.
In addition to the federal RCRA regulations, each community has local regulations that apply to
waste water release to treatment plants (POTWs), storm sewers, or septic systems. These rules
usually include all the RCRA chemicals as well as a number of other chemicals which are toxic,
which can damage the environment, or which adversely affect the microorganisms that digest
waste in the POTW. Some of the other metals common regulated by the POTW include antimony,
beryllium, copper, manganese, iron, zinc, and nickel. With the exception of beryllium, materials
containing these metals also are used in art processes. '
C. SINK DRAIN TRAPS. Sink settling traps can only capture materials that settle quickly from
water such as plaster, clay, certain ceramic Chemicals, globs of paint, etc. It is usually a good
practice to install settling traps on all sinks in art rooms in case some of these materials gets into
the sink. The traps will also serve to monitor the efficacy of the program to see if students are
using and disposing of materials properly or if they are putting materials down the drains.
Collection of materials in the trap does not solve the discharge problem. While a substance may
collect in the trap, enough of it may solubilize to exceed discharge limits. This is particularly true
in ceramics where potters often have been taught that glaze chemicals are "insoluble." Actually,
most glaze chemicals will dissolve enough to release significant amounts of metal ions. In
addition, a varying percentage of the particles in each powdered glaze chemical are so small that
they will not settle in a sink trap and are flushed into waste water.
Traps should be the type that are easy to access so the waste can be collected. The disposal
company will need to determine the composition of sink trap sludge with the toxicity
characteristic leach procedure or TCLP test (US EPA method SW-846). If it is over the EPA limits,
the settled material from the trap must be disposed of a toxic waste.
10
D. SOLID WASTE. The TCLP test is used by toxic waste disposal companies to determine
whether or not solid wastes contain significant amounts certain metals:
Antimony
Cadmium
Lead
Selenium
Arsenic
Chromium
Manganese
Zink
Barium
Copper
Mercury
Beryillium
Iron
Nickel
*Note that most of these metals are common is artists paints, photographic toners, and glaze
chemicals
E. MODEL WASTE MANAGEMENT PROGRAM. An example of a model EPA program developed
by the Rhode Island School of Design (RISD) can be found on EPA's website (APPENDIX 9). Note
that this program requires the Painting Department to use only two low odor alternatives to
turpentine (Gamsol and Isopar L) and prohibits use of paints pigmented with high levels of
cadmium and chromium. In addition, a list of "Permissible Materials" was developed which limits
the materials students and teachers can use.
F. WASTE TREATMENT SYSTEMS. Types of on-site treatment systems include:
1. NEUTRALIZATION TANKS. These are usually large tanks full of marble or limestone chips
which will raise the pH of acids closer to neutral. However, the acids and ferric chloride
from etching and the photographic darkroom liquids will not be rendered acceptable for
discharge by this tank, because neutralization has no effect on the metal ions in etching
liquids such as copper or zinc from etched plates or silver ion. They also will have no
effect on the high levels of iron from ferric chloride.
Neutralization also will have no effect on paint and ink pigments, ceramic chemicals
containing regulated metals, waste containing fluorides (e.g., glaze chemicals such as
cryolite), cyanides such as in Prussian Blue or cyanotype photochemicals, and more. The
tanks also are useless if the waste is caustic (has a pH higher than 7).
2. 2. BIOLOGICAL DEGRADATION. Bacterial degradation and/or fields containing plants that
absorb and use toxic substances usually will not work on art material waste because of
the large amounts of toxic substances used in paints, inks and ceramic glazes. It is not
uncommon for art paints and inks to contain between 40 and 60 percent metal pigment.
Ceramic chemicals also will contain high percentages of metals. Many of these metals are
toxic to bacteria and plants such as copper, zinc, and silver. Other toxic metals are not
removed by biological processes such as chromium, cobalt, cadmium and lead.
The organic pigments in paints and inks have not been well studied in these systems. EPA
still has no restrictions on using such systems for organic colorants. However, many
organic dyes and pigments will degrade to release known carcinogens based on their
structure. It is for this reason that Europe has banned use of many dyes for use next to the
skin (APPENDIX 10). Art schools should be aware that regulation of organic pigments and
dyes in waste water will one day be instituted in the US. The school should plan al1ead for
control of all pigments and dyes.
11
3. 3. RISD: A TREATMENT SYSTEM THAT WORKS. RISD developed an approved waste
treatment system for printmaking rinse water. It pretreats the waste with a neutralization
tank because RISD still uses some acids. Then .the waste goes a strainer, a filter, activated
carbon, chelating ion exchange resin, and weak base ion exchange resin columns. This is
an incredibly expensive system to set up and to maintain. (Details of the system provided
on request.) If, instead, a policy of waste collection from each studio is instituted, this
expense can be avoided.
G. CONTAINMENT & SPILL CONTROL
All tanks, vats, silver recovery units, cabinets containing bottles of liquid chemicals,
photochemical cubitainers, and any storage unit containing liquid chemicals must have
containment trays underneath or be stored in chemical storage rooms with containment floors.
Containment trays must be large enough to contain 110% of the volume of the liquid being
contained so that spills or breakage will not result in release of the liquids. In areas such as
photography or ceramic glazing areas, floor drains should not even be planned.
Dispensers of products such as Hazorb® or other chemical sorbants should be in areas where
solvents, paints, dyes or other toxic chemicals are used or stored. These can be used to soak up
spills and then the sorbant/spill mixture can be disposed of as waste.
RECOMMENDATIONS.
1. Training. Train the faculty about the RCRA and other applicable EPA regulations and review
the products that contain the RCRA chemicals. Substitute other products for these when possible.
Proviae containment for their liquid wastes, and follow proper procedures for disposal.
2. Set up and post Satellite Accumulation Areas for waste collection in each department in which
toxic, corrosive, flammable, or reactive wastes are generated.
3. Encourage departments to discard their outdated, improperly labeled, expired, and hazardous
materials.
12
PART IV. VENTILATION
To specify ventilation systems for various processes, it is necessary to delineate the differences
between the two major standard setting organizations: ASHRAE and ACGIH.
A. ASHRAE STANDARDS. The American Society of Heating Refrigerating and Air conditioning
Engineers (ASHRAE) sets the standards for indoor air quality and ventilation. Their standard for
indoor air quality, 62-2001, says:
The purpose of the standard is to specify minimum ventilation rates and indoor air quality that
will be acceptable to human occupants and are intended to minimize the potential for adverse
heal th effects. (p.3)
In order to avoid adverse health effects, ASHRAE 62-200I's minimum rates are a certain number
of cubic feet per minute per person outside fresh air (not recirculated) delivered to the level at
which people breathe (not what is supplied and exhausted at the ceiling). Some applicable rates
from Table 2 include:
TABLE I
ASHRAE INDOOR AIR REQUIREMENTS (from table 2, ASHRAE-62)
2.2 Education outdoor air requirements
Classrooms
15 cfm/person
Laboratories
20*
Training shops
Libraries
20
20
Locker rooms
0.50 cfmlft2
Corridors
0.10 cfm/ft2
Auditoriums
15
2.1 Commercial outdoor air requirements
Offices
20*'
Reception areas
15 Telecommunication ctrs
13
& data entry
20
.Conference rooms
20
* The standard notes "Special contaminant control systems may be required for processes or
functions.... " In fact, if these "laboratories" are actually art studio rooms in which toxic
substances are used, they will have dilution ventilation and/or local exhaust systems and will not
recirculate air.
** The standard notes "Some office equipment may require local exhaust." This could apply to
machines such as diazo copiers and business machines that generated heat. Most of the major
manufacturers of large copy machines suggest a minimum of 6 room exchanges per hour to
dilute to ozone from these machines.
B. ASHRAE SYSTEM IN THE SCHOOL. Some of the ASHRAE systems are planned with the supply
and exhaust are right next to each other which short circuits the air flow. A good example was
seen in Dressing Room #1 in the theater. Such systems will not provide a good exchange of air.
C. ASHRAE & CHEMICAL USE. ASHRAE standards apply to classrooms, offices and other areas in
which airborne chemicals are not generated. ASHRAE standards never apply to shops which use
toxic substances. This is explained in ASHRAE 62-2001 's scope:
This standard applies to all indoor or enclosed spaces that people may occupy, except where
other applicable standards and requirements dictate larger amounts of ventilation than this
standard. (p. 3)
These larger amounts of air to which they refer are those required for removal or dilution of
toxic substances in the air. And in this regard, ASHRAE 62-2001,5.6 says that: "Contaminants
from stationary local sources within the space shall be controlled by collection and removal as
close to the source as practicable (See Reference 7, 'Industrial Ventilation--Manual of
Recommended Practice.')" This manual is published by the American Conference of
Governmental Industrial Hygienists (ACGIH), and it is these standards that must be followed
when planning ventilation for processes which release or exhaust toxic substances.
D. ACGIH STANDARDS. The American Conference of Governmental Industrial Hygienists
(ACGIH) sets internationally accepted standards for workplace air quality and for industrial
ventilation in Industrial Ventilation: A Manual of Recommended Practice (Bibliography). The
ACGIH sets standards for both types of industrial ventilation:
1) dilution ventilation, and
2) local exhaust ventilation.
1. DILUTION VENTILATION does exactly what its name implies. It dilutes or mixes contaminated
workplace air with large volumes of clean air to reduce the amounts of contaminants to
acceptable levels'. Then the diluted mixture is exhausted (drawn by fans or other devices) from
the workplace. Although often cheap and easy to install, dilution ventilation has limited uses. For
14
example, only vapors or gases of low toxicity or very small amounts of moderately toxic vapors
or gases are removed effectively by dilution ventilation.
"Displacement" ventilation systems are a subset of dilution systems that do not depend on
mixing the air well before exhausting it. Instead, these systems locate supply and exhaust so that
a steady, non-turbulent movement of air will transport the contaminant away from the work and
toward the exhaust. These systems often require less air to accomplish the task.
2. LOCAL EXHAUST VENTILATION is the best means by which large amounts of airborne
substances, or substances of moderate to high toxicity are removed from the workplace. The
Table below lists processes which require local exhaust ventilation.
Local exhaust systems consist of I) a hood enclosing or positioned very close to the source of
contamination to draw in the air, 2) ductwork to carry away the contaminated air, 3) if needed,
an air-cleaner to filter or purify the air before it is released outside, and 4) a fan to pull air
through the system. Because local exhaust ventilation captures the contaminants at their source
rather
than after they have escaped into the room air, exhaust ventilation systems remove smaller
amOlIDts of air than dilution systems. These systems cost less to run because less replacement
air must be heated, cooled, or air-conditioned.
TABLE 1
PROCESSES REOUIRING DILUTION or DISPLACEMENT VENTILATION
Oil painting or using solvent-based paints by many students in a classroom. Classroom use of
small amounts of solvent-containing adhesives, varnishes, shellacs, resins, etc. Laser printing and
copy machine use
PROCESSES AND EOUIPMENT REOUIRING LOCAL EXHAUST VENTILATION
Dusts from:
Mists from:
abrasive blasting and etching
dry hand sanding
powered sanding, grinding, polishing
dry mixing of plaster, dyes, pigments
woodworking machinery
Vapors and/or Gases from:
aerosol spraying
air-brushing
wet grinding, abrading, polishing
power spraying (all types)
hot dye baths
hot wire cutting of plastics
torching and burning plastics, wood, etc.
metal soldering, melting, and casting
welding and brazing
acid etching, mixing, etc
photochemical processes
color, toning, photo etching film cleaning, etc
plastic resin casting
screen printing (solvent based)
Heat. Fumes. Other Emissions from:
15
E. WORKPLACE AIR QUALITY STANDARDS. The ACGIH also sets workplace air quality standards
called Threshold Limit Values (TLVs) which are designed to protect nearly all healthy adult
workers. Volunteers, students, interns and members of the general public are not "workers," may
not be adults, and may not be healthy. The Americans for Disabilities Act requires
accommodation of such people, even those who may be especially sensitive to airborne
chemicals.
For this reason, non-workers require air that meets indoor air quality standards. The standard
for indoor air quality, ASHRAE 62-2001, recommends the general use of one tenth the TLV for air
contaminants not directly covered by the standard. In some cases, contaminant levels may need
to be lower.
F. OUTDOOR AIR QUALITY & LOCATION OF EXHAUSTS. There also are limits on the amounts of
toxic substances which may be emitted into outdoor air by such stacks. Usually, these stacks
must be permitted by local environmental authorities. ACGIH standard and the EPA regulations
affect the design of the stacks which expel contaminants in the air stream above the roofline of
the building (APPENDIX 11), for example stacks that exhaust combustion gases (e.g., from gas
kilns).
G. VENTILATION AND LIABILITY. Building ventilation must not only meet building codes and
laws, they also must design to professional standards of practice. The ACGIH's Industrial
Ventilation: A Manual of Recommended Practice, 24 Edition, is the standard reference for local
and dilution ventilation system design.
If these' standards are not incorporated, it can be interpreted to mean that in the expressed and
expert opinion of ACGIH and ASHRAE. the building cannot be used safely for the purpose for
which it was intended. I have personally participated in a legal action which was settled by
payment of large sums by architects and engineers who designed an art building that did not
meet ACGIH industrial ventilation standards.
TI1is is also the basis on which I will suggest ceasing certain activities until proper ventilation
can be provided.
H. GENERAL VENTILATION RECOMMENDATIONS
TI1ere !f1any more ventilation systems now than when I was here in 1993. But many of the new
systems fall short. In some departments, such as in the Art Metals, small changes to the systems
couId make them work much better. I suggest retaining a top flight industrial ventilation
engineer familiar with art processes to redesign and upgrade some of these systems. One of the
best is:
David Gordon
Gordon Air Quality Consultants, Inc
P.O. Box 5239 Billerica MA 01821-5239
978-663-9213 davegordon@comcast.net
David also worked on the ventilation at the new art building at the University of Minnesota in
Minneapolis. I highly recommend him.
16
PART V. SPECIFIC RECOMMENDATIONS -THEATER
A. THEATER
RIGGING. Reportedly the last rigging inspection was in 1987. Theater rigging should be inspected
at least every 5 years and sooner if in-house inspections not any irregularities. This is an older
hemp system with a wooden grid and needs checking. Two places to start looking for a
mbanvard@sapsis-rigging.com
STAIRS & PLATFORMS. The stairs to access the stage are five steps high plus the additional step
Up' to the platform level. 1910.23(d) Stairway railings and guards, (1) says that the rule applies
to "Every flight of stairs having four or more risers." The rule describes in detail the
specifications for both wood and metal rails. They must have a top trail with a vertical height not
more than 34 inches nor less than 30 inches from the upper surface of top rail to surface of the
tread. The top rail must be able to withstand 200 pounds applied in any direction.
For rigging areas, catwalks, mezzanines, pits, traps, and other changes in elevation, there are
other rules found in 910.21 through 24.
During set construction, the OSHA Construction standards apply. Section 1926.1052(c)(I) on
Stair rails and handrails applies to "stairways having four or more risers or rising more than 30
inches (76 cm), whichever is less." These stairways shall be equipped with: (i) At least one
handrail; and (ii) One stair rail system along each unprotected side or edge. Sections (2) to (12)
detail requirements for stairs. And (5) requires the top rails withstand a force of at least 200
pounds. This is different from the platform guardrails which must withstand 300 pounds on the
top rail and 150 pounds at the mid rail. 1926.502(b)(5).
Fall protection rules apply to set construction, the performances, and the strike. So even actors
on finished sets cannot be put at risk of falls. APPENDIX 12 explains application of these rules.
Every student in technical theater design and building should have a copy.
ASBESTOS CURTAIN/LIGHT CORDS. The asbestos curtain has not been painted which means
that it is easy for fibers to become airborne.
Recent case of union theatrical electrician who died at age 50 leaving a 6 year old and a 9 year
old child behind. She died of mesothelioma allegedly from working for years around asbestos
curtains and asbestos covered wires on instruments. I was an expert witness in this case and the
theaters involved paid a heavy settlement.
Some old asbestos wired lights were still seen in the crawl space under the seats. They
reportedly are only used as demonstrations and then the wires are bagged in plastic. This may
not be much of a hazard, and this is a good project if the purpose is to show students what they
should not tolerate working with in their professional lives.
My recommendations regarding lighting instruments still stands that off-campus companies
should remove the asbestos cords. It is clear from the OSHA Asbestos regulations, that the cost of
personally monitoring, training the workers, and doing the work in special containment
17
enclosures is not economically feasible. No responsible lighting sales and service companies will
not replace asbestos cords on these instruments. Instead, there are really only two options:
•
Double bag the old asbestos-wired instruments and call a toxic waste disposal company.
In some cases the wires are connected to a cap which can be disposed of and the rest of the
instrument saved. Lenses and bulbs also may be able to be saved.
•
Send the old instruments to a special asbestos abatement company. This is more
expensive, bu.t will allow you to save the old instrument for period pieces or museum
collections. One company that will do this work is:
A & S Environmental
2261 East 15th Street
Los Angles CA 90021
213/623-9443
The asbestos in the curtain should be periodically monitored with air sampling when the curtain
is raised and lowered. Some samples of the theater dust near the curtain should be analyzed for
asbestos as well. As long as there is asbestos present here, the risk of a claim from someone with
mesothelioma exists even many years from now.
The curtain should be lowered and raised before each new production's first night to be certain
that no element of scenery blocks the dropping of the curtain. We did not lower the curtain
during the survey because no one familiar with the procedure was there at the time. There is a
fusible link that doesn't appear to be still in condition to function.
SPECIAL EFFECTS used on stage during productions.
Theatrical fog. smoke. and haze are produced by suspending small particles of glycols, mineral
oil, or glycerin in the air. These effects also have been associated with health effects and a
number of lawsuits and workers' compensation claims for damages from singers and musicians.
Even the manufacturers of these products say that excessive exposure is hazardous and the
Entertainment and Services Technology Association (ESTA) has set standards for the use of
theatrical fog. It involves purchasing an instrument to measure airborne concentrations. Faculty
members who want to use or approve the use of these products must become familiar with the
ESTA standards and meet them. Their website is www.esta.org.
Faculty need to meet the ESTA standards not only for the safety of the students and the audience,
but for the education of the students. Students should not graduate without knowing about the
hazards and precautions that should be taken when using these effects.
It is also important for teachers to know that even if the precautions are taken, there can be
highly sensitive students or asthmatics that will have health effects from these effects. They need
to be vigilant to complaints or physical responses seen in those exposed.
18
Pyrotechnics should not be used in this theater at all with its hemp system, wooden grid and
other features.
Fire effect so fall types should be prohibited on stage. Fake candles now look and work better
than real ones. Beautiful flaming torch effects that utilize a battery light, tiny fan, and waving silk
are available. Even smoking on stage should be eliminated. If it is not, there must be a fire
watcher in each wing the entire time that the effect is used and all costumes, wigs and set pieces
need to be fire' retarded. And wardrobe should not use fabric softener (APPENDIX 2).
VENTILATION There is a belt driven very old working system for supplying air to the stage area.
This is good for most purposes but it will force any special effect on stage into the audience. This
is another good reason to restrict the use of these effects.
FIXED LADDERS. There are 15 foot fixed ladders on each side of the stage leading to the grid.
These are supposed to be caged at 7.5 feet. But this is a huge project. Perhaps a method of tieing
off and harnessing could be used to prevent falls.
PROJECTOR. A projector connected to the outside of the balcony is currently serviced by hanging
over the balcony to adjust it. But this is an OSHA fall protection violation. There is no place for
5000# anchorage for harnesses and lanyards.. So a way must be found to reach the area from the
floor. This is also difficult because of the raked seating area, but it can be done.
ADA ACCESS. The theater still does not have full accessibility for disabled students. I refer
readers to the 1993 report for a fuller explanation of these problems.
CONFINED SPACE UNDER SEATING AREA. This area is still not secured. It is a potentially
attractive nuisance hazard and locks need to be placed on the doors. The floor under the
insulation is lath and plaster which look like they could be stepped through. If people are going
to go here on occasion, those lath and plaster areas should be covered with flooring that will
support weight.
This is also where some asbestos-corded lights are stored. This means any shed asbestos will
remain here to be inhaled when the dust is stirred up.
FOLLOW SPOT PLATFORM. I didn't see the follow spot platform in the balcony on this trip. I'm
hoping it is gone forever.
EGRESS. There still should be exists on each side of the back stage area.
CATWALK. It would be a big job to change the rails on the access stairs and rails, but they do not
quite meet OSHA requirements. They have 2.5 inch toe boards when 4 inches is required. It
might be possible to add an extension. The top rail should be 42 inches and it is 40.5 which is
pretty close. The other rail is 36 inches and stair rails are required to be between 30 and 34
inches-again pretty close.
Some of the pain in the catwalk area is chipping. This could be lead paint underneath. The chips
should be tested before the area is renovated so the lead paint rules can be met if necessary.
B. SCENE SHOP
19
STAIRS. The stairs leading to the scene shop looked weak and on stair has cracks in it and should
be replaced before it breaks.
ASBESTOS. Here the tiles are likely to be asbestos. This was noted in the 1993 report at well.
The tiles are damaged and need to be removed properly.
FIRST AID KIT. A small kit was here, but there should be a full sized industrial kit (see Part II, D
above).
GRIND WHEEL. This piece of equipment probably needs to be replaced. In any case, it needs
break out plates and the wheel must be dressed. Under the OSHA regulation, the surface ofthe
wheel must always be squared and flat and break out plates must be adjusted within 1/4 inch of
the wheel, the tool rest must be 1/8 inch away from the wheel. These rules are in found at
1910.215 (APPENDIX 13). Grind wheels were designed to grind flat metal chisels and similar
tools. This is the only purpose to which they should be put. For other types of grinding jobs,
other tools such as large Dremel® grinders should be used. And in the scene shop, grinding
should be taken outdoors until there is a ventilation system to collect the dust. DRILL PRESS. The
drill press here is not bolted to tlle floor. When manufacturers place bolt holes in the base of a
tool, this is their notice indicating it needs to be bolted to the floor for stability.
DELTA CONTRACTOR SAW. This still has an unguarded drive belt. But there was a blade guard.
This tool also should be capable of being locked out so that it can only be used when teachers are
there to supervise.
SATELLITE ACCUMULATION AREA (SAA). There was an empty hazardous waste container here,
but no SAA set up. This should be set up and posted.
ELECTRICAL. There was an electric panel which was left open and there was a counter built in
front of it in violation of the clearance regulations. This counter should be dismantled and the
area kept free. I realize that the scene shop is too small and this effectively makes it smaller, but
the panel needs to be accessible (See Part II, G above).
All the outlets should be ground faulted here and the amount of temporary wiring should be
reduced, perhaps by overhead reels.
Protective eyewear has been assigned to each worker rather than sharing them as was the
practice in 1993.
C. DRESSING ROOMS
The passageway leading to the dressing rooms must be entered in the dark in order to reach the
light switch. There should be a switch at the entrance.
There is a heavy fire door exit here that would be a hindrance in any emergency evacuation. It is
also in an unfortunate location in relation to the stairs so that it can't be made to open in the
outward direction as fire laws require. At least a lighter fire-rated door should be installed so
that it is manageable by everyone.
20
There are other routes out of this area, and they should all be marked and during fire training,
these routes should be discussed with students and faculty.
The basement dressing rooms have ordinary supply and return ventilation. This often is not
sufficient for the hair sprays and other solvent products used.
Dressing room #1. The supply and exhaust are only inches apart in the ceiling here. This was
easy to determine because missing ceiling tiles made the ductwork visible. This means that the
supply will short circuit to the exhaust without providing much air to the room. We also do not
know the percent of fresh air in the cycle. But students should be discouraged from using a lot of
spray products or solvents here. Airbrush make up is also unacceptable here or anywhere else
on campus (APPENDIX 14).
There is also a "hiddy hole" closet here for props that is too crowded to walk into easily. This is
only a matter of cleaning, throwing some things way, and reorganizing. It should be done.
Dressing room #2. It appears that this room only has a supply diffuser and no return. This may
have happened if this was a larger area divided by a wall which separated the two diffusers. But
it means that when the door is closed, this room will have essentially no exchange of air at all.
D. GREEN ROOM
This room was flooded twice in the last the last two years from an overhead pipe. The room
should be monitored for mold problems which commonly affect buildings with this history.
E. WARDROBE ROOM.
I didn't see any major issues here accept there is too much temporary wiring. The driers are now
vented. See also APPENDIX 2 on fabric softeners mentioned above.
21
PART VI. SPECIFIC RECOMMENDATIONS -ART BUILDING
A. PROCESSES LAB
Susan Hunt has instituted one of the best machine safety program I've ever seen. Some 800
students may use this area and there are 10 classes of 24 students that are run through the safety
program. Even faculty must qualify on each of the machines before they can be carded for
eligibility to use them. Color-coded badges make it clear at a glance which people can use the
machines.
I have already recommended another university contact Susan Hunt and Dean Sankey about this
program since the Stout is willing to share their successful program with others.
B. ROOM 234
Foundation room has double slot hoods that draw 1000 £1m at their face which is only Y, of the
ACGIH recommended air flow (APPENDIX 15) But this still is enough to make useful local
exhaust areas for the room.
There was one paper cutter without a guard missing.
C. WOODSHOP 119
The tag on the eye wash was up to date. One student has been hired to run these each week and
this seems to be working.
There was an unbolted drill press here.
Students were working here and each one had their eyewear on. We couldn't enter without
eyewear which is just as it should be. This program is clearly working well.
SUMMARY OF RECOMMENDATIONS FOR WOODSHOPS
1. Continue the good work on the woodshop training and safety program.
2. Dilution ventilation should be provided which exhausts 100% to the outside so that wood dust
will not be deposited in the rest of the building. Have ductwork checked and cleaned regularly.
Clean all beams and surfaces in the woodshop frequently and before significant amounts of
visible dust have accumulated. Wood dust can flash ignite in a fire.
3. The table saw and all woodworking machinc3 should be fully guarded and chosen for safety
and reduced noise. If a new table saw is purchased, make it the SawStop type APPENDIX 16).
4. All woodworking machines should have lock out switches and they should be locked out
whenever supervision cannot be provided.
5. An emergency electrical shut-off switch for power to all machines should be easily accessible.
6. A central wood dust collection system probably cannot be provided since it must be located
outdoors. Each machine should be connected to either a vacuum collection or a small bag-type
collector such as the one that is currently in the shop.
22
7. An eye wash could be installed. However, if no solvent-containing products are used, simple
eyewash bottles could be used rather than the full plumbed-in station.
8. A first aid kit, bloodborne pathogens kit, and contaminated sharps container should be
available.
9. Continue with the provisions for providing protective eyewear. Make sure that the equipment
has the small "+" sign next to the ACS or Z87. I standard number which indicates that the
eyewear meets high impact standards
D. METAL SHOP 119A
It appears that oxylacetylene, arc, MIG, TIG and plasma arc cutting are done here. The door
should be posted to be closed when weldingis being done so that no combustible wood shop
materials. OSHA rules prohibit combustible materials such as wood dust from within 35 feet of
welding operations (1910.252(a) (iii)(1)&(2» unless separated by walls. Wood, other
combustibles, flammable solvents, and spray cans cannot be present in the welding area.
There are two double slotted welding bench-type hoods with almost the required 2000 flm draw
at the slots. On the other side of the room above head level are two grill which appear to be the
supply for the hoods which will mean that there is a good turnover of air through the breathing
zones of people working in the room.
There is a Rockwell grind wheel with Delta instructions on the wall, which is fine because the
rules will be relatively the same. The tool rest was not adjusted exactly, but pretty close.
There are compress gas cylinders here and oxylacetylene set ups and other compressed gases.
There must be MSDSs on all mild steel, welding and brazing rods and wire. Failure to have
MSDSs, labels and appropriate warnings were also key issues in a recent trial in which
manganese exposure in mild steel was linked to Parkinson's disease in welders (APPENDIX 17).
There are no MSDSs on junk or found metals. If these sources of metal are used, the school must
insure that there is absolutely no exposure of the welder to the fumes. They must he used at the
hoods. If large sculptures must be worked on out on the floor, such as the chair-like work being
built at the time of the survey, then the school should:
a) purchase and use a flexible duct portable welding unit (APPENDIX 18); or
b) develop an OSHA respiratory protection program that includes air-powered or airsupplied respiratory equipment. Gas cylinders. OSHA's rule at 1910.253(b)(4)(iii)
requires the cylinders of oxygen and acetylene that are not be used up during a
single shift be removed from the cart set up each day and stored in accordance
with this reg. Oxygen cylinders shall not be stored near highly combustible
material or near reserve stocks of carbide and acetylene or other fuel-gas
cylinders. Oxygen cylinders in storage shall be separated from fuel-gas cylinders or
combustible materials by a minimum distance of 20 feet or by a noncombustible
barrier at least 5 feet high having a fire-resistance rating of at least one-half hour.
23
It is also not acceptable to OSHA to leave the tanks tethered to the cart, without regulators, and
only valve protection caps. A careful review of the Compressed Gas Association Pamphlet (P-!,
1965) reveals that for safe handling, cylinders that are not in use should be placed in storage and
securely attached to a fixed object to prevent the movement of the cylinders. (Also reference in
OSHA 1910.101, Compressed Gases standard.)
SUMMARY OF RECOMMENDATIONS FOR WELDING
1. The ventilation in the welding area is compatible with the welding processes done here except
when floor sized pieces must be done. In this case, a flexible duct welding hood or two (e.g.
Nederman or Torit) should be provided (APPENDIX 18) for welding operations, especially junk
metal welding.
2. Keep the door closed during welding and make sure there are no combustibles or flammables
in the room.
3. Simple eyewash bottles may be acceptable for welding if no solvent products are used or
stored here (they shouldn't be), and no patinas, degreasers, or other corrosive chemicals are
used.
4. A deluge shower might be installed for clothing ignition-a rare instance, but it has happened.
5. First aid and blood borne pathogens kits should be available.
6. Lag bolts for securing oxygen and acetylene cylinders to the walls must be provided and
located 20 feet apart.
7. Compressed air may be used, but not for cleaning clothing or surfaces (APPENDIX 19).
8. Get MSDSs on all consumables and compressed gasses.
E. SCULPTURE ROOM 120
There is a lot of potentially good ventilation equipment in this room that is not being used. Barrel
filling vents used for wax pots (APPENDIX 20) and a small slot hood for wax crock pot warming.
Reportedly, the room is not being used for wax materials which is safer, but this equipment
should be considered for other possible uses.
A baby in a stroller was wheeled into this room while we were there. This is absolutely the
wrong environment for young children. They must not be in the art building in any are where
machinery or toxic substances are used or stored. Reportedly there are a number of teachers
who bring their children into the art building in this manner. The school's risk managers need to
reassess this practice.
F. CLAY MIXING ROOM 107
The department mixes its own clay. The Soldner mixer is unguarded which is dangerous. And to
properly vent the mixers currently used would cost tens of thousands of dollars. It would be
better to purchase premixed wet clay. The benefits of buying premixed clay include:
24
1. Cheaper. The argument that schools save money by mixing their own clay is only true if
they mix clay illegally--that is without required ventilation and precautions. Clay mixing is
by far more expensive when you add up the cost of the ventilation systems and the
maintenance they require, the regular air-monitoring for silica required by OSHA, a
written OSHA respiratory protection program which includes provisions for mandatory
medical exams and fit testing, and the special clean up required for silica-contaminated
area.
2. More space. All that clay storage and mixing space can be used for activities that actually
are legal and safe. It takes much less space to hold a single pallet of mixed clay. And the
large amount of space taken up by drying out of leather hard clay could be eliminated.
3. Less cleaning. The amount of clay dust on floors and surfaces will be reduced
dramatically. Overall studio cleanliness and dust control will be easier to achieve.
4. Safer for teachers. Teachers will add less silica to their lungs. Sadly, there are teachers
who have health problems from this unnecessary activity. Well-known Minnesota
University potter/teacher Warren MacKenzie was recently diagnosed with silicosis and I
know of three other potters with the disease.
5. Safer for students. Students will not inhale free silica and other clay minerals that are
destined to remain in their lungs for the rest of their lives.
6. More time. Teachers and student interns can find better use for the time devoted to this
hazardous activity.
7. Better curriculum. There are more mentally challenging activities than mixing clay. Once
your students have figured out that dry clay powder mixed with water becomes pliable
wet clay, the learning process is over. If students want to see clay mixed, take them on a
field trip to the clay supplier. Or provide an understanding of the process by taking them
on a field trip where they can dig some clay from the ground.
Reclaiming clay. There are three basic ways to reclaim clay:

The safest way to reclaim clay is to have a local suppliers take it back and reclaim it for a
reasonable fee.

The second safest way is to dry clay waste completely, add water so the clay becomes a
slurry, place the slurried clay in plastic bats to absorb excess water, roll out the clay and
wedge it.

Using a pug mill to reclaim clay on a daily basis with one of the new Bailey pug mills can
be done without adding powdered clay to achieve the right consistency. Even leather hard
clay can be put in this mill so there is no need to wait until all the clay is completely dry.
In this case, I think the last option is the best. If the school is willing to purchase a safer and
smaller pug mill for reclaiming clay such as one of the Bailey pug mills, they can keep up daily
with the discarded clay and they will not need any of the other bulky equipment currently in the
25
clay mixing room (APPENDIX 21). This equipment is not even effective as is clearly seen by the
dust in the room. They won't need respiratory protection. And they won't need to store pallets of
dry clay and expose students to the dust.
GRADUATE STUDENT AREAS
There are small jerry-built partitioned spaces here. The structural integrity of these walls is
suspect. Mostly clay is used here, which is how it must be. There should be no glazes used or
stored because there is a drain in the floor which may go to a sanitary sewer (see "glaze waste"
below). Every outlet must be GFCI because of the proximity of water. Electric wheels are here
some are kick wheels. An electrical panel did not have proper clearance in one of the cubicles.
The student in whose cubicle it is located must give up the yard square space in front of the panel
and maintain an access aisle to it.
G. CERAMICS ROOM 103
STUDENT LOCKERS are abundant in this area. The teacher and safety people need access to
these. The locks should have a master key.
WEDGING TABLES are a now known to be a source of silica exposure. A NIOSH study of a high
school potter found levels of silica "that did not exceed recommended limits on the sampling
date, [but] it appeared likely that higher airborne levels would be generated during periods of
greater use of the wedging table." NIOSH recommends installing a local exhaust system at the
table or by cleaning the table with a HEPA vacuum cleaner frequently (APPENDIX 22).
DUST CONTROL. For control of silica dust, NIOSH also recommends wet or HEPA cleaning
surfaces regularly, substituting commercial' glazes for dry mixing glazes, laundering student
aprons frequently to remove dry clay, and instituting an effective Hazard Communication
program for both teachers and students. These are all recommendations this report makes as
well.
GLAZE MIXING DUST. The double slotted hood with the small flexible duct leaving the main duct
at right angles is almost funny. To work properly the flexible duct should draw at least 1500 flm
at the face (APPENDIX 23). And the double slotted hood draws almost no measurable air when
the velometer is even a foot away.
The ideal system for glaze mixing is to install two 4-foot, double-slotted hoods at the back of the
glaze mixing counter similar to a double welding bench (APPENDIX 24). The slot hoods will
provide a local exhaust area in which all glaze mixing activities can be done including the
opening the bags of powdered materials, weighing out the chemicals in a triple beam balance,
and mixing the dry powders with water. This can only work if the glaze chemicals are purchased
in 50 pound bags or smaller so the whole bag can be lifted to the counter. See the next section on
"glaze chemical storage" for information on proper storage of ceramic chemicals.
Since there already are hoods in the ceramic area with chases to the location of their stacks, it
would not be a big job to install these hoods here. Until there is ventilation for tins process, care
must be taken to avoid exposure to the dust from the glaze chemicals.
26
GLAZE CHEMICAL STORAGE. A common OSHA violation in ceramic departments is the improper
labeling of materials resulting from the transfer of glaze chemicals from their original containers
to containers or bins with only the name of the chemical on them written by hand. Under the
OSHA regulations, toxic chemicals require not only the name of tile chemical, but hazard
warnings (including target organs) and the name/address of the manufacturer. This kind of
documentation is also required by EPA. Unfortunately, most of the glaze chemicals I saw were in
containers labeled only with the identity of the chemical. Technically, these are all "toxic waste"
under both EPA and OSHA regulations.
Bins. The glaze chemical bins are not only improperly labeled, using them safely is
impossible for the following reasons:
-Dumping glaze chemicals into tile bins results in clouds of chemical dust.
-Putting the whole bag of glaze chemical in the bin does not solve the problem because
the label cannot be read without hauling the bag back up and creating more dust.
-Transferring the label information onto the front of tile bin is time-consuming and likely
to result in missing of some OSHA required information.
-Scooping glaze materials out of the bins results in getting the glaze chemicals allover
hands and sleeves creating more dust and contaminating the skin and clothing. The lower
the level of the chemicals in the bins, the deeper the person has to reach into the bin, the
greater the contamination of skin and clothing.
-The bins open by tipping out and down so that the open top of the bin is below the level
of the counter top. This means that a slot vent at the back of the counter cannot capture
any of the dust created when glaze chemicals are scooped from the bin.
-Emptying and cleaning the bins is cumbersome and can result in more creation of dust.
Storage of the chemicals in their original containers should be planned. One of the best ways is to
buy stackable plastic containers (like Tupperware®) for convenience and protection from
breakage and spills. These can be stacked on shelves or under counters neatly and hand labeled
on the outside for quick identification. But inside, the chemical would remain in its original
container. And simply lifting the lid would enable the full label to be read. It is also important to
purchase from companies that provide the OSHA-required labels.
(NOTE: Minnesota Clay Co. and several other suppliers were providing chemicals in paper
bags with the name of the chemical written on them with a marker! This is a violation of
OSHA regulations to use these and a violation of the DOT regulations to ship chemicals
labeled this way. I did expert witness against this company recently and have photos of such
packages. Do not accept improperly labeled materials in the new building.)
WET GLAZE STORAGE. If large containers of liquid glaze are mixed, they should be stored in
containment trays. There are containment trays that will fit under counters and others that are
on wheels for easy movement, which might be considered (APPENDIX 25).
27
GLAZE SPRAY BOOTH. The spray booth draws rather well, but unevenly. The top is in the range
Of 200-225 £i'm. The center area is in the range of 150 f/m. But it drops to about 50 flm near the
bottom. I suggest that flat pieces be raised on a turn table and that no work be sprayed that is on
the floor of the booth.
This booth is also a place where glazes could be mixed.
GLAZE WASTE. In July, 2005, EPA proposed a $107,165 penalty against the Maine College of Art
in Portland for violating numerous hazardous waste regulations that are part of the federal
Resource Conservation and Recovery Act (RCRA). According to the complaint, one of the
infractions was putting waste glaze and related floor sweepings in the trash or washing them
down the sink. It is clear that floor sweepings and spills containing glaze waste must not get into
drains, sinks, or general trash. This material usually contains RCRA regulated metals.
And working floor drains in the glaze areas should be capped for this reason. It is important to
consider the pathway that glaze chemicals take from the loading dock to the glaze area, to glaze
storage, and to the kilns. These areas must not have drains down which spills and dusts can go.
This includes the graduate studios if the students are allowed to use glazes in their spaces.
The clay areas do not need this special care of they are kept separate from glaze activities. The
exception is if clays colored with metal oxides such as chromium and cobalt are used. Then all
the waste from the clay areas will also have to be collected as toxic waste. Instead, students who
want to experiment with colored clays should do it in the glaze area and collect their waste.
Floor sweepings from areas where glazes are used, spilled, or stored will need to be collected.
The fewer spaces where glazes are used, the less toxic waste collection in needed. Areas where
only clay is used do not need special waste collection.
UTILITARIAN WARE. A lot of the pottery is used for food. It is This is not a good idea unless
special glazes are used for the ware that contain no potentially toxic substances which can leach
into food. APPENDIX 26 covers the ways that school's can protect themselves from producing
ware that leaches toxic metals.
HOT WAX. Currently, hot wax is used as a glaze resist. There is a small double slot hood behind
the wax pot which should control the emissions. Hot wax emits formaldehyde, acrolein, paraffin
fume and many toxic substances. It will also release these when the wax is burned off during
firing. If a lot of resist is used, even negative pressure kiln exhausts will not control the
emissions.
KILN ROOM AREAS. There was a partly block electrical panel here. There was yellow tape on .
the floor marking off the clearance area, but it was mostly worn off. It should be retaped and the
area cleared.
There are 6 canopy hoods here over the electric and gas kilns. The one I tested drew the required
100 f/m at the face. The problem with the canopies is that they will not capture the contaminants
during the early phases of the firing when the temperatures are too low to drive emissions up to
the hood. These are some of the nastiest emissions-the wax resists, sulfur compounds and
28
organic contaminants. However, with all of these hoods in the area, there should be a fairly good
turn over of air, which will help.
The canopy hoods also will not do a good job during gas kiln reduction. For this reason, a couple
of carbon monoxide detectors should be in the area to determine when there significant amounts
of contaminants escaping the system. The detectors should not be household types unless they
are ones which will read out in parts per million (ppm) to levels as low as 20 ppm (APPENDIX
27).
If money is allocated for improving kiln ventilation:
Gas kiln ventilation systems should I) take the combustion gases up a passive flue to a
stack on the roof which exhausts into moving airspace and 2) to provide secondaryexhaust via slot hoods at the front of the kiln for combustion gases that escape the flue
especially during reduction (APPENDIX 28). It is important for the passive chimney of the
kiln to go almost straight up to the stack on the roof rather than bend in order to avoid
heat damage to the chimney.
Electric kiln ventilation canopy hoods should be extended down over the kiln. In the
front it should be close to the level of the top of the door. On the sides and back, the
further down the better the capture. For round or octagonal kilns, the systems should be
equipped with a negative pressure exhaust system. These are off the shelf items and not
very expensive (APPENDIX 29). There only needs be an opening through the outside wall
for the ducts in a location that will not let emissions reenter.
CLEANING. The floors are of concrete, but they are dusty, pitted, and will not be easy to keep
washed down. The hallway outside the ceramics room was full of clay dust footprints illustrating
that this dust is getting tracked throughout ceramics and even into other departments.
If the glaze and clay areas are separated, clay only areas can be hosed down into drains regularly.
I have seen systems like this used very effectively and hosed down twice a day. Tiles that will
clean easily and yet are not slippery when wet should be used.
The school we will have to consult with local authorities, though, because many regulations limit
the amounts of solids such as clay that can be discharged to storm sewers. Sometimes settling
chambers will be needed first. If this wash water cannot be disposed of in a drain system, a wet
pick up HEPA vacuum can be used.
The glaze area should be wet mopped and the water should be collected and disposed of as toxic
waste or should wash down into a collection tank. No floor drains should be here.
GRINDING. I didn't see a grind wheel in the pottery, but I assume there was one. Glaze drips on
the bottoms of fired pots must be removed. Grind wheels are often misused in ceramics for this
application. To get the pot to the wheel, the guard must be lifted up and the tool rest displaced.
These are serious OSHA violations (1910.215 -APPENDIX 13). Instead, grind wheels always must
have their guards in place, tool rests adjusted to 1/8 inch from the wheel, and breakout plates
must be in place and adjusted to 1/4 inch of the wheel.
29
Grind wheels were designed to grind flat metal chisels and similar tools. This is the only purpose
to which they should be put. If there is a grind wheel in the pottery, it should be discarded. It
should be replaced with large Dremel® types of grinders. Grinding dust will contain silica and
other toxic components. Grinding should be done in the spray booth to capture the fine dusts.
SUMMARY OF CERAMIC RECOMMENDATIONS
1. To make the ventilation in this areas compatible with ceramics, the areas should be redesigned
to provide:

general dilution exhaust for the kiln room to control heat being especially careful not to
create negative pressure which will backdraft the gas kilns;

extend the canopies over the electric kilns to be as close to the top of the kiln door and
down the back and sides are far as possible;

both stacks and secondary hoods for capture of emissions from the gas kilns;

local exhaust for the glaze mixing bench consisting of two 4-foot long triple slotted hoods
at the back;

a glaze spray booth that exhausts properly above the roofline; and

Clay mixing room ventilation. But no ventilation is needed if premixed clay is obtained
and a pugmill that will mix discarded clay daily without the addition of dry clay is used.
2. Each electric kiln should have two shut off mechanisms, e.g. a timer and a cone kiln sitter.
3. Continuous reading monitors for carbon monoxide should be installed in the kiln room.
4. Purchase glaze chemicals in bags light enough to be lifted to this counter for opening and using
and stored in stackable plastic containers.
5. Compressed air for spraying glazes must not be used to also clean surfaces or clothing.
6. Floors should be cleaned well enough that tracking of the clay into the hall does not occur. A
door mat could be used to help keep dust on shoes from tracking into the hall.
7. Drains in the glaze area or any other area where glaze chemical waste or spills could
conceivably occur should be capped. Drains in clay only areas can be used for cleaning waste.
8. Sinks in the clay and glaze rooms should all have standard settling traps.
9. OUTLETS throughout the pottery should be GFCI.
10. Use Dremel® grinders at the vented glaze mixing bench or the spray booth. Discard grind
wheels.
11. Eye washes/emergency showers are not needed unless solvent lustre glazes or similar
products are used. I suggest simple eye wash fluid be added to the first aid kit. .
30
12. Make infrared-blocking eyewear available for kiln gazing.
13. Containment trays should be used for large containers of liquid glaze.
14. Paint the clearance areas in front of electrical service panels in the kiln room, in the graduate
student area, and any other panel that is in the ceramics department.
15. Set up an SAA for glaze chemical waste.
(16. Construct raku kilns from refractory brick and dispose of the ceramic fiber as you would
dispose of asbestos. I didn't see the raku kiln, but I know it’s there.)
H. PRINTMAKING This area is over-crowded with and somewhat cluttered. There are also
ceiling tiles stained from leaks that should be replaced and other general maintenance and
housekeeping problems.
EYEWASH/SHOWERS. The hand-held eye wash hoses here do not meet the ANSI Z87.1 standard
and one of the hand-held units is broken (see Part II, D). If acids are purchased in gallon
quantities, a deluge shower is also needed. Since acids are extremely corrosive, the eye wash
needs to be where these acids are stored and diluted. Organization of the work is needed so that
acids are stored very near where they are diluted rather than having to transport them from one
place to another in the studio. (See acid room below)
SMALL DARKROOM. This darkroom is not much used any more. It is for photo plate developing
for lithography processes. If another place could be found for the equipment in this room, it
would free up more space and help with the clutter.
DARKROOM VENTILATION. The louver that supplies the air is large and the majority of
the air coming through it will be at the top of the louver-the area closest to the exhaust
which it on the ceiling at the opposite side of the room. This means that most of the air
will not go over the baths to exhaust their emissions, but will travel above the heads of
people standing at the sink.
WASTE DISPOSAL. The fix and silver waste is collected here and taken away rather than
using a silver recovery unit. This is usually the cheapest method of waste disposal for
small operations.
SCREEN CLEANING AREA. Powered water is used to spray water based inks from screens. This is
a very hard area to vent. The spray contains water and some of the pigments are toxic. But it is
less hazardous than many other areas in printmaking. If there is a building project in the future,
there are ways to capture this spray to keep this area safe and clean, but it is not a priority.
There is a broken hand-held eye wash here that should be replaced with a proper eye wash.
However, if the only hazard is water and ink, this eye wash may be sufficient. It isn't suitable if it
will also be used for solvent exposure. And small amounts of solvent may be used here to release
resists from the screen.
31
PRINTMAKING MAIN ROOM. This is roughly Y, of a large room, the other Y, being used for
lithography. Ventilation in both halves of the room appear to be a general recirculating system. If
so, it is not suitable for the activity. It is also important to look at the mechanical drawings for
this area to see all of the areas that will be impacted by the toxic airborne emissions from this
department. It especially should not get into offices and other non-printmaking areas,
FLAMMABLE STORAGE CABINET. There were about 15 gallons of solvent here. There was
no MSDS on the major brand of solvent used which made it difficult to assess the hazards.
MSDSs on every product must be obtained.
PARTS WASHER. A parts washer using mineral spirits was here. Many good water-based
part., washing fluids are on the market since California banned the solvent-based
washers.. One fluid used at several art schools is AquaWorks (google for more
information). In general, faculty do not like them as much, but students who have never
used the solvent based ones are perfectly happy to take a few seconds more to clean
plates.
The new fluids still contain small amounts of solvents and must be used with gloves and
care. But it is important that solvent parts washing not be done here because the
ventilation will not support it.
AQUATINT BOX. This rosin powder box is like a grain elevator full of organic dust. It is a
potential explosive or fire hazard. There are other methods of doing aquatint today:
a) replaced by an aquatint screen method. The plate can be covered with an
emulsion, the screen placed over it, the plate is exposed to light and washing will
leave the plate with an aquatint pattern ready for etching.
b) take the plate to one of the spray booths in the building and give it a light spray
with aerosol can paint leaving lots of uncovered areas and etch the plate.
HOTPLATE. Since the hotplate will be used for fusing rosin aquatint, the temperatures are
high enough to require ventilation. The ventilation consists of a canopy hood 3.5 to 4 feet
above the plate which is absolutely useless for the purpose.
If one of the other methods is used for aquatint, the hot plate may only be used at lower
temperatures for heating plate oil and the like. In this case, the hotplate will not need
ventilation.
SECOND FLAMMABLE STORAGE CABINET. Some of the substances here can be disposed
of For example, there is stainless steel mesh preparation and this type of screen is no
longer used here. There was also ashphaltum, lithotine, lacquer thinner, denature alcohol,
patinas, and more. Each student purchases a quart of solvent and stores it here. It is
important that the exact brand of solvent the students purchase be specified and the
MSDS on that solvent be in the binder.
INTAGLIO PRESS. Intaglio presses should not need ventilation. Any press cleaning can be
done with mineral and vegetable oils if necessary.
32
LITHOGRAPHY PRESS. Lithography presses should have flexible duct exhausts that can
reach the center of the press where stones will be modified with acids and solvents. This
is not something for which there are simple substitutes and ventilation of the presses
should be put in the budget.
LOCAL VENTILATION SYSTEMS. Three local systems are on the same main: a slot hood, a
canopy hood, and a flexible duct exhaust.
SLOT HOOD. The slot hood performs strangely, drawing arow1d 2000 flm on the
top slot and only about 200 on the bottom slot. Adjustments should be made.
CANOPY HOOD. This hood is completely useless for any purpose and should be
taken out of the system so that more draw can go to the slot hood and the flexible
duct.
FLEXIBLE DUCT EXHAUST. This hood is drawing about 1600 flm at the fact. This is
almost enough to use as a litho press hood. But some duct work needs to be added
to get the duct to the hood. Supports for suspending the hood over the press must
also be added. If the draw without the canopy is too strong, two flexible ducts
could be put in the system.
ACID ROOM. This is currently where plates are etched, acids are stored and diluted.
FLAMMABLE STORAGE CABINET. Incompatible acids were stored here together.
This must be changed at once as I pointed out during the survey. There were 5
gallons of glacial acetic acid, about three gallons of nitric acid, some hydrochloric,
phosphoric and other acids.
Glacial acetic acid (-99% pure) should be eliminated from the program. It is
both flammable and reactive with common solvents and must be stored
alone. The department should buy acetic acid in a more dilute form (e.g.
50% or less) which can be stored in acid cabinets with other acids.
Nitric Acid is reactive with many other acids and also must be stored
completely alone.
Reportedly some of these acids are only for lithography and used in eye dropper
quantities. But the storage and use of gallon bottles of these acids requires eye
wash stations and other precautions. Much could be saved by buying the acids in
small quantities to begin with and ordering more frequently.
In addition, I was told that they are currently etching copper plates, and when they
go back to etching zinc, they will use the much safer ferric chloride etches. Ferric
chloride still is a corrosive and its use requires tile presence of an eye wash.
The presence of hydrchloric acid concerns me. While I did not see any potassium
chlorate, I suspect it may be presence. It is used with hydrochloric acid to make an
historic etch called Dutch Mordant. Potassium chloriate is highly reactive and can
33
become a shock sensitive explosive when old or contaminated. It is a common
pyrotechnic and explosive ingredient.
I suggest that ferric chloride (without citric acid added) will be used for etching in vertical tanks
with bubbling agitation-for all etching processes. This will greatly reduce the number and
amount of acids held here and save a great deal of space that would be taken up by flat baths.
The faculty should participate in tile design of the container for holding the tanks. They will
know the number and size of the tanks they want and how low the counter should be so that
removal of the plates will not be cumbersome.
While ventilation for toxic substances is usually not needed for ferric chloride, there is still and
odor and there is a chance that someone will want to speed up tile process with citric acid (which
essentially converts the active ingredient in the bath to hydrochloric acid). For this reason, I
would prefer to have a triple slot hood at the back of this bath whose width will depend on the
size and number of the tanks the faculty wishes to have.
EYEWASH/SHOWER. There is an eyewash/shower combination here with a drain underneath.
This drain must be capped if the room contains all these acids and the unit must be tested using a
container for the water. This also is another 'good reason to go to ferric chloride etching
permanently. If there is good containment for the ferric chloride etching baths and the acid
cabinet has containment built into it, they can leave the drain for the small bottles (not gallon
bottles) of acid in the cabinet.
RECOMMENDATION SUMMARY
1. To properly vent this area for printmaking would require a major project. There should be:

dilution ventilation for the rooms exhausting 100% to the outside; ~ local exhaust slot
ventilation for at least one counter;

flexible duct ventilation for the litho press;

an enclosure and ventilation for the screen wash area; and

a slot hood system for the acid room. This can be a very small hood just over the ferric
chloride bath if they switch completely to ferric chloride.
2. Until better ventilation can be provided, only use ferric chloride etching, solvent-free parts
washing fluids, and reduce solvent use as much as possible.
3. Provide immediate pick up for the glacial acetic acid (order a dilute replacement), most of the
nitric (only keep. enough for lithography), and pick up other solvent products no longer used.
4. Provide separate storage for a small amount nitric. This can be a polyethylene insert in the
acid cabinet (APPENDIX 30).
5. The drain in the acid room can remain only if ferric chloride and eye-dropper amounts of acids
used in lithography are stored here. Otherwise, it should be capped and containment found for
34
all of the chemicals in the room. If large amounts of acids continue to be used, a containment
floor with curbs on the sides should be installed.
6. Drains throughout the rest of the rooms should be assessed for spill potential.
7. The combination eye wash shower should remain in the acid room.
8. A standard eyewash/shower should be available in the main room as well.
9. Use the spray booth for spray paint aquatint or use the photoprint darkroom for the
photoprint aquatint method. Then eliminate the aquatint box and free up this space.
10. Continue using flammable storage cabinets, but cut down on holdings. Continue using the
acid cabinet, but cut down on holdings.
11. Provide a first aid kit & bloodborne pathogens kit.
12. A supply of chemical sorbants should be both the main room and the acid room (APPENDIX
31).
1. PAINTING & DRAWING ROOM #1 & #2
Recirculating ventilation will not support the use of solvent-based products here in any of these
studios. Reportedly Liquitex and other water based materials are used here. There is are spray
booths in each of the three rooms in which drawings can be fixed or spray varnished.
EYEWASH STATIONS. In the drawing area were two eye washes with tags that were out of date.
Since there are spray booths here and the possibility of using solvent sprays exists, these eye
wash stations must be kept up.
SPRAY BOOTHS. The three booths were measured first when they were "off." Amazingly, they
still drew in the range of 100 to even 225 flm in places. This means there is some kind of problem
with dampers and fans that allows changes in air pressure and building air to drive air up the
ducts. TI1is also means that there is a constant energy draw from these rooms.
When we turned the one "on" in drawing studio #2 it drew a hefty 200 at the bottom and 375
£1m at the top. If this is how well all of the booths perform when on, they will be more than
adequate for any spray operations that need to be done.
The care must be taken after spray operations are done. For example, taking freshly sprayed
materials into the rooms will result in strong solvent odors throughout the room and in other
rooms on the recirculating circuit. It is important to leave items in the booth until they are
through off gassing solvents vapors.
There is an old opaque projector stored in the spray booth in Drawing studio #I and it should be
removed. These booths should not be used for storage.
MATERIALS CAN BE USED IN ASHRAE VENTILATION SYSTEMS. The program should not suffer
by using only water based materials. There are so many choices today. This section will address
each category of art product and will list any precautions that are needed. Only occasionally will
35
actual manufacturers be referenced. Manufacturer's companies change hands. Formulas for
materials change without notification to customers. The only way to keep up with product
changes is to keep checking MSDSs and labels. However, the information below should ma1<e it
easy to check on these products.
ACRYLIC PAINTS (WATER-BASED EMULSIONS) are composed of synthetic acrylic resins and
pigments with many small amounts of additives usually including an ammonia containing
stabilizer and formaldehyde or some other preservative. Formaldehyde is a carcinogen, but
without a preservative like formaldehyde, the paint will support bacterial and mold growth.
Diluting the paint and leaving it stand a while will demonstrate this fact.
The small amounts of ammonia and preservative released during drying can cause respiratory
irritation and allergies, but so will emanations from mold and bacteria.
1. Purchase acrylics from companies that you can trust to tell you all about the pigments
and additives. One such company is Golden Artist Colors whose owners also refuse to use
the word non-toxic on the paints that contain pigments that are untested for chronic
toxicity.
2. Under normal conditions, the small amount of ammonia and formaldehyde should not
even be noticed by 1\10st people. However, teacher should inform students that it is
present.
3. Warning known asthmatics or people with severe allergies is prudent. There is
essentially no hazard to pregnant women because ammonia and formaldehyde are not
expected to get into the blood stream to affect the baby.
4. The amount of paint drying will affect the amounts of al11ffionia and preservative in
the air so use on huge canvases should be avoided.
5. Do not dilute the paint and leave it around or mold and bacteria will grow in it.
Note: there are solvent-containing acrylics and alkyd paints that cannot be used safely in
this environment.
CASEINS are made from dried milk, pigments, and preservatives. Some contain
ammonium hydroxide which can be irritating to the skin and eyes and dust from the
powdered paint should not be inhaled. There are usually very strong preservatives added
because the casein is a good source of food for microorganisms.
1. Only buy premixed liquid caseins, not the powders.
2. Warn students that they can be irritating to the eyes and skin. Students with sensitive
skin may want to wear gloves. Since these paints are water diluted, almost any thin glove
should work, but it is good practice. to stay away from natural rubber gloves which cause
allergies.
CHALKS, CONTE CRAYONS, OIL PASTELS. These are made of pigments and binders and
chalk (calcium carbonate), talc, barytes (barium sulfate mineral), or other powdered inert
36
minerals. Oil pastels also contain oil or wax which keeps the dust from getting airborne
and they are the safest to use. "Dustless" chalks and conte crayons will create some dust,
but they contain binders which prevent creation of the very fine respirable dust particles.
1. .Use Oil Pastels whenever possible over other chalks.
2. Warn students with respiratory problems small amounts of dust are associated with
use of chalks and conte crayons. Ifgood techniques are used, exposure should be
insignificant. For example, do not use hands to smooth the material or blow the dust off
the paper.
3. The pigments in these chalks are likely to be trade secrets.
Note: Dry pastels cannot be used safely here. They create a dust that is a combination of
an extender such as talc or barium sulfate and dry pigment. The pigments expose users to
compounds of toxic metals such as cobalt, manganese, and chromium. Some oft he organic
pigments are also toxic. A large percentage 'of pastel dust particles are respirable size-many under 0.1 microns. They can be inhaled deep into the lungs and cannot be captured
effectively by ordinary vacuums and cleaning.
CHARCOAL has no known significant hazards except that dust of any type can cause
symptoms in some people with severe respiratory problems such as asthma. COLORED
PENCILS contain the same pigments as artists paints with the addition of some fugitive
dyes in some colors. The amount of dust of these pigments is very small and should be
manageable. However, cleaning out the pencil sharpener or working on very toothy
surfaces will result in some pigment exposure. Use common sense if visible dust is noticed
during any activity.
CONSUMER LATEX PAINTS are primarily pigments and water emulsions of various plastic
resins. Some teacher use them because they are "water based" or are labeled as "low
VOC." The low VOC label is not relevant because it only lists solvents that damage the
ozone layer or participate in smog reactions. Solvents such as acetone or ethyl acetate are
not included in this list. Most consumer latex paints contain between 5 and 15 percent
solvents. On occasion, these solvents are the highly toxic glycol ethers which can be skinabsorbed and inhaled.
I. Do not use latex consumer paints for art processes if the MSDSs indicate they contain
small amounts of solvents.
2. Do not use for important work because the colorants in the household paints are not
lightfast art pigments and the quality of the work will suffer.
Note: Consumer oil paints, enamels, two part epoxy or urethane paints, etc., contain
significant amounts of solvents and also should not be used in recirculating ventilation.
CRAYONS are pigments in wax. Most have no significant hazards during normal use
because the pigments are contained. But it is disturbing that the manufacturers consider
all their pigments to be trade secrets. Mothers of children who eat crayons or teachers
37
attempting to protect sensitive children will not be able to identify these pigments. The
manufacturers assure us they are safe to ingest, but the pigments obviously are not food
dyes approved by FDA for ingestion. We ought to at least know what they are.
These manufacturers often also endorse are projects in which crayons are melted or
ironed onto fabric and the like. This certainly produces toxic emissions from wax. It is also
likely that some of the pigments can decompose to release toxic substances as well. And
the teachers probably should know about recent findings that asbestos-contaminated talc
hardeners in the wax were used in crayons (APPENDIX 32).
I. Buy US made crayons. Fewer of these have been recalled for lead and other hazards
than those made in China.
2. Do not do projects that involve heating or melting of the wax. (Note: This also means
that encaustics cannot be used safely in this room.)
DRAWING INKS & INDIA INK may contain hazardous dyes and solvents-usually ethyl
alcohol. However, the amounts of ink used in most drawing techniques use such small
lines of ink, that the inks usually can be used with out a problem.
GOUACHE is an opaque water color which contains pigments, gums, water, preservatives,
glycerin, opacifiers, and other ingredients. The opacifiers may be chalk, talc, and other
substances. Formaldehyde may be used as a preservative. Ordinary comfort ventilation
should be sufficient ventilation w11ess very large amounts are used.
I. Purchase gouache from companies known to tell identify their pigments and additives.
2. Under normal conditions, the amount of formaldehyde or other preservatives should
not even be noticed by most people but training should inform students that it is present.
3. Warning known asthmatics or people with severe allergies is prudent. There is
essentially no hazard to pregnant women because formaldehyde does not get into the
blood stream to affect the baby.
4. The amount of paint used or left drying on art works will affect the amounts of
preservative in the air. Use on huge canvases should be avoided.
5. Do not dilute the paint and leave it around or mold and bacteria will grow in it.
MARKING PENS contain pigments or dyes in a liquid. The liquid may be water, solvent, or
a mixture of water and solvent.
I. Get the MSDS and look for markers that contain only water or small amow1ts of the
least toxic solvents such as ethyl alcohol
2. The colorants in the markers are trade secrets, so use caution. Keep them off the skin.
PENCIL AND GRAPHITE drawing usually exposes artists to such small amounts of dust
38
that they are not hazardous. Very large amounts of graphite theoretically can cause black
lung disease similar to that which afflicts coal miners. But you would have to use enough
to come out of the studio looking like a minor (an occasionally I have see such use).
TEMPERA PAINTS are pigments suspended in emulsions of substances like oils, egg, gum
casein, and wax. Preservatives are added to kill microorganisms. If no solvents are used in
these paints, ordinary comfort ventilation should be sufficient for working with premixed
liquid paints (not the powdered paints).
WATERCOLORS (dry cakes) are composed of the same pigments found in all artists
paints, preservatives (often paraformaldehyde) and binders such as gum Arabic or gum
tragacanth.
Liquid watercolors may also contain water, glycerine, glucose, and other materials. Both
liquid and dry watercolors may give off small amounts of formaldehyde, but these
materials generally do not need exhaust ventilation.
WATER WASHABLE OILS are relatively new on the market. Manufacturers have modified
the oils used in traditional artist's oil paints by chemically bonding water-loving chemical
groups to the oil molecule. This enables the paint to be thim1ed and cleaned up with
water. The finished works look like traditional oil paintings and the paints can be used in
very similar ways. It is even possible to do a "turp wash" using water as the solvent for the
technique.
The paints contain the same toxic pigments that all of the art materials contain. These
pigments are also archival and lightfast, so the quality of the paints is not compromised by
the chemical change in the oil. The oils may also have the ability to spontaneously
combust on rags, so air tight containers should be used for the rags just as one would use
for traditional oil paint rags.
A number of schools have switched to the water washable oils and I have heard very good
reports about them, especially from students. Complaints are more likely to come from
faculty who have set ways to work with traditional oils that have more difficulty in
adapting to a new medium. These paints are probably the best answer for schools who
want to teach oil painting but do not have exhaust ventilation to support the use of
solvents.
ARTISTS OILS are made by mulling pigments into oils such as pre-polymerized linseed oil.
There usually are no volatile ingredients, but oil paints are commonly thinned and
cleaned up with solvents such as paint thiill1er. (See also Water-washable Oil above.)
The oils used in oil painting usually are not hazardous in themselves, but they all contain
chemical driers based on toxic metals such as lead, cobalt, and manganese. Linseed oil is
the most common oil, but poppy seed, walnut, sunflower, and some synthetic oils also
have found use in oil painting. Since most come from plants and trees, allergies to the oils
are not uncommon. Rags and paper towels damp with these oils can spontaneously ignite.
39
Some thick painting techniques can be done without using solvents and by cleaning
brushes with baby oil, soap and water. Some art teachers have switched to walnut oil
which is thinner than linseed oil and allows the paint to be thinner without solvents.
Varnishes for oil paintings clearly can only be used in the spray booth.
1. Purchase oil paints from companies that identify their pigments by Colour Index nan1e
right on the tube. It is best to find a company you can talk to-not a foreign company with
only a distributor in the US. One such company is Gan1blin Paint in Oregon. Explain to the
manufacturer that the paints must contain absolutely no solvents since some
manufacturers add small amounts of solvents to some colors that get too thick during
manufacture.
2. Explain the function of driers to students and the fact that they are toxic. 111ey do not
get airborne, but keep the oils off the skin as much as possible.
3. Cover the hazards of spontaneous combustion and provide air-tight rag containers
which are emptied daily. 'The amount of driers in the oil paints, or mixing the oil with
colors that contain drier metals such as manganese or cobalt can speed up the
spontaneous ignition.
4. Be certain there are no solvents in the art room so students must to rely on baby oil,
soap and water, and other cleaning methods.
5. The oils have an odor, but you can assure students that the odor is not from significant
amounts in the air. Still, some highly sensitive people have claimed reactions to the oils.
RULES FOR PAINTING & DRAWING IN ASHRAE VENTILATION SYSTEMS
1. Be sure the ASHRAE ventilation system is doing its job. A certain amount of fresh air is
necessary for health. If the room feels stuffy or odors linger over long, check with the building
maintenance people.
Be especially vigilant in the winter months if the supply diffusers and the return grills are both
located at the ceiling or well above head level. This means that the majority of the fresh air will
not get into the breathing zones of the people in the room, but will go more directly from supply
to exhaust above head level. This is especially true in the winter when the supply air will be
warm and will rise.
2. Studio floors, tables, and shelving should be made of materials which can be easily cleaned and
should be wiped down daily. Never let paint remain on the floors to be tracked around or ground
underfoot into a dust. Another method is to Work on paper which can be discarded when the
project is finished.
3. Provide a sink in the room to facilitate cleaning and good hygiene.
4. Isolate the studio totally from areas where food is eaten, coffee is brewed, etc. Ban eating,
drinking or smoking in the studios. Bottles of water also should not be in the studio.
40
5. Only buy materials that state "Conforms to ASTM D-4236" on the label. While this does not
guarantee a safe product, it should mean that the manufacturer is at least following the U.S.
labeling laws.
6. Obtain Material Safety Data Sheets (MSDSs) on all paints, inks, and other products. If paint
pigments are not identified by Color Index names or numbers, ask your supplier for this
information. Some catalogs list the Color Index names of their paint pigments. These suppliers
should be favored over less informative ones.
7. Use water-based products but do not assume that water-based products contain no solvents.
Check the MSDS.
8. Buy premixed paints and avoid working with powdered materials.
9. Any spraying or airbushing should be done in the spray booth. However, it only draws in the
range of 100 flm which means that some blow back will occur. Spraying should be very light or
respiratory back up will be needed.
10. Do not sand dry paints, sprinkling dry pigments and dyes onto surfaces or do any other
techniques which raise dust. One source of dust often overlooked is when paint splashes dry on
the floor and people walk on the paint. This grinds the paints into a dust which is distributed
where ever people walk. (See also #2.)
11. Rags damp with setting oils like linseed, walnut, and poppy oil will spontaneously ignite.
Place them in an air tight metal container or in water.
12. Avoid skin contact with paints and pigments by using techniques that keep the paint from
getting on your skin, or by wearing gloves. Avoid natural rubber latex gloves in favor of nitrile or
vinyl gloves.. Wash off paint splashes on the skin with safe cleaners like a) baby oil followed by
soap and water, b) nonirritating waterless hand cleaners, or c) plain soap and water. Never use
solvents or bleaches to remove splashes from your skin.
13. Students and teachers should wear protective clothing such as full-length smock or coveralls.
If these are contaminated with paint, leave these garments in your studio to avoid bringing dusts
home. Wash clothing frequently and separately from other clothing.
14. Do not allow students to point brushes with their lips or hold brush handles in their teeth.
Observe students during work for habits which get materials on the skin or in the mouth.
15. Practice and teach good hygiene. Have students wash their hands before eating, smoking,
applying make-up and other personal hygiene procedures.
16. Keep containers of paint closed except when you are using them.
17. Dispose of waste solvents, paints, and other materials in accordance with health, safety, and
41 42 environmental protection regulations. Since solvents are not used, most of the paints and
materials can go in the trash. They may not be true of paints containing lead, cadmium, or barium
compound pigments. Consult your Environmental Health and Safety office.
41
18. Always be prepared to provide your doctor or a student's doctor with precise information
about the chemicals used in your class and the ways in which they are used. Arrange for regular
blood tests for lead for anyone who uses lead-containing paints or pigments.
J. INDUSTRIAL DESIGN ROOMS 216A &220
FLAMMABLE STORAGE CABINET, In addition to solvents, there was the curing agent for two
component polyester resin (methyl ethyl ketone peroxide -MEK-P) in small tubes. No one knew
how old they were. They were distended and tight which may mean that they have degraded.
These products should be logged in and out due to their potentially explosive nature (APPENDIX
33).
There also was ammonia in the cabinet. Only flammables belong here.
LOCAL VENTILATION in 216A consists of a spray booth, 5 slot hoods, and 3 downdraft tables.

The spray booth was drawing a respectable 200-300 f/m. It has its own air supply
provided by a perforated duct nearer the ceiling and extending the width of the booth. It
provides an even flow of air in the booth.

There is a sprinkler head in the booth and a shut off for this hear at the side of the booth
in case there is an accidental release. It is important to check every time the booth is used
to see that this valve is open and the head is operable. When a shut off valve is this easy to
close and students are involved, stuff happens.

The slot hoods were drawing the required 2000 £1m or more.

The three Delta down draft tables were not working well because their filters were so full
that they were essentially not operating. There must be a schedule for checking these
filters and cleaning the filters. I could not tell if the slots at the backs of the down draft
tables were on a separate line or not, but it seems likely that they were or they would
have been drawing all ofthe air.
If the slots are connected to their own exhaust fan, then there is a separate fan drawing
air through the filters and recirculating this air. If this is the case, it is important to know
what particle size the filters can efficiently capture and where uncaptured material will be
exhausted back into the space.
LARGE STUDENT LOCKERS~almost walk in size cabinets, were here, but we were unable to see
what was in them because the students have the keys. It's important for the school to have
control of these spaces with master keys.
ELECTRICAL OUTLETS were the type that is on the floor,. The cap on one left up and it was a trip
hazard. These outlets are only useful if they are in areas where people don't walk.
ROOM 220's floor had squares of carpet which were obviously samples, but were being used as
little throw rugs. These could cause people to slip, and they should be removed. And there was a
group of wall panels from a previous accreditation display which were not set up in a stable way.
42
Industrial design students should be taught a sense of appropriate use of materials, balance and
safety as part of their curriculum. This should extend to the environment in the school as well.
RECOMMENDATION SUMMARY
I. Put the ventilation systems on a maintenance schedule so that air flow can be checked and
filters can be cleaned.
2. Put a check list near the spray booth to insure that the rules for use are being met and include
checking the shut off valve for the sprinkler head is open.
3. Provide immediate pick up for the old tubes of organic peroxide curing agent and date any
new tubes this material so tl1ey can be disposed of regularly.
4. Drains throughout the area should be assessed to see if potential spills could violate EPA
regulations..
5. A combination eye wash shower is the ideal system for this room.
6. Make sure the flammable storage cabinet only contains flammables.
7. Provide a first aid kit & bloodborne pathogens kit.
8. Teach students general safety in storage and use of materials.
K. ART METALS ROOMS 101 & lOlA
SPAREX BATHS. I tested the slot hood over the bath and it was drawing about 1300 flm which is
acceptable for collection of the sparex emissions (primarily sulfur dioxide).
BURNOUT KILNS. These kilns were not vented when I was here last time. They now have canopy
hoods over them, but these hoods are way to high to be effective. The sides of these canopies
should he extended to just below the top of the kiln. Otherwise, they are still unvented.
ABRASIVE BLASTING CABINET. Reportedly, silica is no longer used. But these cabinets still
release dust. Evidence of blasting dust was in the area. Ideally, secondary ventilation of these
cabinets should be provided near the top where the dust is released. Until it is vented, it is
important not to blast items that will contaminate the grit with lead, cadmium, or any of the
other highly toxic metals. In any case, when the grit is spent it will need to be disposed of as toxic
waste..
SLOT HOOD TABLES. There are three slot hood providing vented counter space for small torch
work and other processes. The slots draw about 1200 f/m. They should draw closer to 2000 flm
and the slots should actually be larger so that they draw a greater volume of air. The
specifications for the design of these hoods should be check to see if they are operating as
designed or if they need maintenance.
BUFFERS. Each buffing wheel has a local exhaust hood behind it. There are four ducts and three
buffers all on one system. These should be checked to see why the draw is so low. They should
meet the ACGIH standards for duct velocity and cfm (APPENDIX 34).
43
GRIND WHEEL. The Qella grinder was readjusted while there to bring the breakout plate to 1/4
inch from the wheel. There should be a regular check on these pieces of equipment.
ACID CABINET. The acid cabinet contained both acids and items that did not belong here. The
sulfuric acid here also contained formaldehyde and methanol. This is because it is a reagent for a
particular chemical process. This should be replaced with plain sulfuric acid.
Nitric acid was here, but it needs to either be in a separate cabinet or in a polyethylene liner to
keep it separate from other acids (APPENDIX 30).
There were gloves in the cabinet. Not only should they not be here, they will degrade much faster
when left here in contact with vapors and gases released from acid containers.
Patinas for silver and other metals were also here. Some of these can be very toxic. Their MSDS
should be checked, because some are also reactive with acids.
RECOMMENDATIONS.
I. Check the slot hoods, buffing wheels and other ventilation systems to see if they need
maintenance. If they are in good condition and this is all the draw they can normally achieve, an
engineer should be engaged to upgrade them. Until they are upgraded, a box-like hood can be
build around the slots to direct the aid more strongly through the counter work area (APPENDIX
35).
2. Lower the canopy hoods over the burn out kilns. They are useless where they are currently.
3. The hoods for the Sparex probably operate well enough. They could be improved by enclosing
the Sparex bath in a box-like hood around the slots (APPENDIX 35).
4. Go through the acid cabinet and check the MSDSs of each item to see if it is appropriate for
storage here. If there are enough products that are alkalis, provide a small alkali cabinet.
5. Drains throughout the area should be assessed to see if potential spills could violate EPA
regulations.
6. A combination eye wash shower is the ideal system for this room.
7. Make sure the flammable storage cabinet only contains flammables.
8. Provide a first aid kit & bloodborne pathogens kit.
44
PART VII. PRIORITY RECOMMENDATIONS
A. IMMINENT HAZARD PRIORITIES.
Bring in a rigging inspector to survey the theater's rigging (see page 17 for contact information).
B. REGULATORY & POLICY PRIORITIES
1. Hazard communication, Establishment of this program and the regular required training of
faculty is the cornerstone of making everything else work. If the faculty does not understand the
hazards and the regulations, all the other efforts are wasted,
2. Inform and train students, This can be done by any or all of the following ways:

provide safety and environmental training during orientation

develop a required course on the subject

develop training modules for each teacher to use in the hazards of their particular
materials

require student projects to also satisfy safety and environmental requirements,
3. Set up clearly defined and posted Satellite Accumulation Areas in each department that needs
it and train faculty and students in waste disposal procedures.
4. Develop a list of permissible materials which can be used in the school and for which MSDSs
are on file,
5. Write an enforcement policy into the general safety program, With no penalties for breaking
the safety and environmental rules, there is no program.
6. Use course descriptions and promotional materials to emphasize the advantages of using the
safer "green" materials both for the health of students and teachers and for the environment.
(Check out the RISD website and see how they have used this issue in promotion,)
7. EPA OSHA Asbestos program -Survey the buildings for asbestos and make the surveys
available to faculty. If the tiles are asbestos, do not buff them,
8. Do not allow students or faculty to bring young children in the art building,
C. MATERIAL CHANGES
1. Eliminate solvent use in locations where the ventilation will not support the use. In painting,
the program will not be adversely affected by switching to some of the new water washable oils
and other types of paints. Switch to water based parts washing fluids, etc,
2. Eliminate use of nitric acid and other acid etches until or unless there is ventilation and safety
equipment appropriate for their use. Many schools etch exclusively with ferric chloride and their
printmaking programs do not suffer.
45
D. VENTILATION IMPROVEMENTS.
Hire David Gordon or another art-experienced industrial ventilation engineer to redesign and
renovate some of the systems in ceramics and metal working (See page 16 for Contact
information).
46
APPENDIXES
1. Glove training materials (3 pages)
2. Liquid fabric softeners article (2 pages)
3. First Aid Kits for Art Classes, 2 pages
4. Ad for side of sink eyewash' (l page)
5. Electrical Service Panel Clearance (l page)
6. GFCI rules (2 pages)
7. Common Electrical Problem Kills Univ. Prof,article (I page)
8. Cyanides in Art, data sheet (4 pages)
9. RlSD's EPA waste management program (3 pages)
10. The European Dye Directive (4 pages)
11. Airflow Around Buildings, fig 5-28, ACGIH Manual," (I page)
12. Fall protection in theater, issue settled at SF Opera, ACTS FACTS (4 pages)
13. Grindwheel accidents/rules, data sheet (2 pages) .
14. Tanning booths set rules for air brush make up ACTS FACTS (2 pages)
15. Slot'hood, fig 3-13, ACGIH manual'" (l page)
16. Article about SawStop (l page)
17. Article, Welding & Parkinson's Linked (I page)
18. Nederman portable flexible duct system,' (I page)
19. Compressed Air for Cleaning Clothing/Surfaces (1 page)
20. Barrel filling hood, ACGIH Manual'" VS-15-01 (1 page)
21. Ad, Bailey Pugmills,' (l page)
22. NIOSH study ofHS pottery, Clay Times, (2 pages)
23. Movable Exhaust hoods for welding, ACGIH Manual, VS-90-02 (I page)
24. Welding Bench, VS-90-01, ACGIH Manual," (I page)
25. Ad Containment trays,' (I page)
26. Ceramic ware hazards, data sheet (7 pages)
47
27. Carbon Monoxide Detectors, data sheet (3 pages)
28. Ohio State U gas kilns ventilation systems (4 pages)
29. Bailey Negative Pressure fume vent system,' (I page)
30. Ad nitric acid separator for Acid Cabinets,' (1 page)
31. Ad chemical sorbants,' (I page)
32. Asbestos in crayons articles, ACTS FACTS, (3 pages)
33. Hazards of peroxide resin curing agents, (2 pages)
34. Manual Buffing & polishing wheels, ACGIH Manual, VS-80-30 (I page)
35. Sketch of enclosing slot hoods for better capture, (l page)
• Pictures from supply catalogs are for illustration only and do not constitute an endorsement of
any particular product.
" The American Conference of Governmental Industrial Hygienists, Industrial Ventilation: A
Manual of Recommended Practice, 24th Edition (2001)
48