Handling Hazardous Materials: HazCom, Solvents, Respirators, Lead, Silica, and Asbestos

Painters handle hazardous materials daily: solvents, strippers, two-component coatings and, in old buildings, the dust of the paint itself. CSLB lists "handling hazardous materials" as its own safety topic. This chapter is the longest in the book because three substances (lead, silica, asbestos) turn routine prep into regulated work, and the exam asks both the principles and a surprising number of specifics. The Cal/OSHA numbers below are from Title 8 as published on the DIR website; the EPA numbers are from 40 CFR Part 745.

19.1 Hazard Communication: Title 8 §5194

California's hazard communication standard gives workers the right to know what they handle. Its working parts:

Written program (§5194(e)). Employers maintain a written hazard communication program that describes how labels, safety data sheets and training will be handled, includes a list of the hazardous chemicals known to be present (using a product identifier that matches the SDS), and describes how employees are informed of the hazards of non-routine tasks. On a multi-employer work site (a painter working beside other trades), the program says how you will give other employers access to SDSs, inform them of precautions and tell them your labeling system.

Labels (§5194(f)). A shipped container carries: product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name, address and phone number of the responsible party. In the workplace, each container of hazardous chemicals is labeled with that information, or with the product identifier and words, pictures or symbols giving at least general hazard information that, together with other information immediately available, gives employees the specific hazards. Portable containers into which chemicals are transferred for the immediate use of the employee who performs the transfer need not be labeled. Do not remove or deface labels on incoming containers unless the container is immediately re-marked.

Safety data sheets (§5194(g)). The employer has an SDS for each hazardous chemical used, and keeps them readily accessible during each work shift to employees in their work areas (electronic access is permitted if there are no barriers to immediate access; for work at multiple locations during a shift, SDSs may be kept at a central location if employees can immediately obtain the information in an emergency). An SDS has 16 sections, in this order: 1 Identification; 2 Hazard(s) identification; 3 Composition/information on ingredients; 4 First-aid measures; 5 Fire-fighting measures; 6 Accidental release measures; 7 Handling and storage; 8 Exposure controls/personal protection; 9 Physical and chemical properties; 10 Stability and reactivity; 11 Toxicological information; 12 Ecological information; 13 Disposal considerations; 14 Transport information; 15 Regulatory information; 16 Other information, including date of preparation or last revision. If the manufacturer's SDS is missing, the employer makes a written inquiry within 7 working days of noting the missing information (§5194(g)(12)).

Training (§5194(h)). At the time of initial assignment and whenever a new chemical hazard is introduced, employees are trained on: the requirements of the standard; operations in their work area where hazardous chemicals are present; the location and availability of the written program, the list and SDSs; methods and observations to detect the presence or release of a hazardous chemical; the physical and health hazards and protective measures, including work practices, emergency procedures and PPE; and the employer's labeling system and SDSs. Employees are told of their rights, including against discharge or discrimination for exercising them. New or revised SDS information indicating significantly increased risk is passed to employees within 30 days.

Where a painter looks first. To learn the hazards and protective measures for a coating or solvent: the SDS (Section 2 hazards, Section 7 handling and storage, Section 8 exposure controls and personal protection for gloves, eye and respirator guidance, Section 5 fire-fighting, Section 6 spills, Section 13 disposal). The product data sheet covers application performance; the can label identifies the product and its hazards at a glance.

19.2 Flammable and combustible liquids

Solvent-borne coatings, thinners, strippers and cleaners burn. Title 8 sections 1930 to 1934 (Construction Safety Orders) and §5416 set the rules. From the text:

• Containers (§1930). Only approved containers and portable tanks are used for storage and handling of flammable liquids. Approved safety cans or DOT-approved containers are used for quantities of 5 gallons or less; for one gallon or less the original container may be used. Maximum container sizes are set by table (for example, safety cans up to 2 gallons for Category 1 and 5 gallons for Categories 2 to 4).
• Storage quantity (§1930(a)(4)). Not more than 25 gallons of flammable liquids may be stored in a room outside an approved storage cabinet; storage in excess of 25 gallons is within cabinets constructed to NFPA 30. A cabinet holds not more than 120 gallons of Category 1 to 4 flammable liquids, of which not more than 60 gallons may be Category 1, 2 and 3; not more than three such cabinets in one fire area (with an exception for industrial occupancy). Flammable liquids are not stored so as to limit use of exits, stairways or egress routes.
• Quantity near spraying (§1931(g)). The quantity kept in the vicinity of spraying operations is the minimum required, not more than a supply for one day or one shift.
• Inside storage rooms (§1931): electrical equipment approved for Class I, Division 1 hazardous locations; ventilation giving a complete change of air at least 6 times per hour; at least one clear aisle three feet wide; containers over 30 gallons not stacked.
• Fire control (§1933). Fire extinguishing devices are available where flammable liquids are stored. At least one portable extinguisher rated not less than 20-B is located outside, but not more than 10 feet from, the door of any storage room; for outside storage areas, an extinguisher rated 20-B is located between 25 and 75 feet from the area. (An extinguisher "rated for flammable liquids" is the exam's class-B answer.)
• Dispensing (§1934). Bond containers for Category 1, 2, 3 liquids; no transfer by air pressure; separate transfers over 5 gallons by 25 feet or 1-hour construction and keep vapor at or below 10% of the lower flammable limit (Chapter 16).
• Vapor concentration (§5416). Ventilate so concentrations of flammable vapors in buildings and rooms do not exceed 25 percent of the lower explosive limit; no source of ignition is permitted where the concentration exceeds or may reasonably be expected to exceed 25 percent of the lower explosive limit; smoking is forbidden where vapors above 25 percent may reasonably be expected.
• Storage on a trailer: in an approved flammable liquid storage cabinet, away from ignition sources (the generator, compressed gas cylinders, open flames).
• Rags (§1513(e)): flammable or hazardous wastes go into covered containers separate from normal debris; solvent- and oil-soaked rags are kept in a closed metal container until properly disposed of.
• Flash point. An SDS flash point well below job-site temperature means vapors can ignite at ordinary temperatures. Know the flash point before choosing the solvent, the storage and the ignition-source plan.

19.3 Toxic solvents and airborne contaminants: §5155

Title 8 §5155 sets limits for airborne contaminants in Table AC-1 for places of employment. Terms: PEL (permissible exposure limit): the maximum permitted 8-hour time-weighted average; STEL: a 15-minute TWA not to be exceeded at any time during the workday even if the 8-hour average is below the PEL; ceiling limit: the maximum concentration to which an employee may be exposed at any time; "S" skin notation: a substance readily absorbed through skin; protective clothing is provided and used as necessary. Where it is reasonable to suspect exposures above the limits, the employer monitors.

TWA calculation (§5155 Appendix, verified). TWA = (C₁T₁ + C₂T₂ + ... + CₙTₙ) ÷ 8, where C is concentration and T is duration in hours; the divisor is 8 regardless of the length of the workday. The standard's own example: a substance with a PEL of 100 ppm; exposure of 150 ppm for 2 hours, 75 ppm for 3 hours and 50 ppm for 4 hours in a 9-hour day gives (150×2 + 75×3 + 50×4) ÷ 8 = 725 ÷ 8 = 90.6, which the standard rounds to 91 ppm, below the PEL.

Worked variation. A painter is exposed to a solvent with an assumed PEL of 100 ppm at 120 ppm for 3 hours, 60 ppm for 4 hours and 0 ppm for 1 hour. TWA = (120×3 + 60×4 + 0×1) ÷ 8 = (360 + 240) ÷ 8 = 75 ppm, below the PEL. (The PEL here is an assumption; the real figure for any substance is in Table AC-1.)

Chemical strippers and highly volatile chlorinated solvents have caused fatal overexposures in small unventilated rooms. The correct response is substitution with a lower-hazard product, or the ventilation and protection that the SDS specifies; never a closed door, a dust mask, or a space heater. The SDS and §5155 govern; specific stripper chemicals may also be restricted by other law, so check the SDS and current rules.

Isocyanates in two-component polyurethanes are respiratory sensitizers (the SDS and the manufacturer say so): once sensitized, a worker can react to very low exposures. Use the controls the SDS requires (supplied-air respiratory protection and ventilation are commonly specified).

19.4 Respiratory protection: §5144

The exam asks the program elements and the common wrong answers.

• Written program with worksite-specific procedures, administered by a suitably trained program administrator, wherever respirators are necessary to protect health or required by the employer (§5144(c)). It includes selection procedures, medical evaluation (§5144(e)): a medical evaluation to determine ability to use a respirator before the employee is fit tested or required to use it; fit testing for tight-fitting respirators; use procedures; maintenance; training; program evaluation.
• Fit testing (§5144(f)): same make, model, style and size as will be used; before initial use, whenever a different facepiece is used, and at least annually; and again when physical changes could affect fit.
• Facial hair between the sealing surface and the face, or any condition that interferes with the seal, prohibits wearing a tight-fitting respirator (§5144(g)(1)). The accommodation is a loose-fitting powered or supplied-air respirator, not tightening the straps. Users perform a seal check each time.
• Selection: the respirator must suit the contaminant's chemical state and physical form. For gases and vapors (solvent vapor) an air-purifying respirator must have a NIOSH-certified end-of-service-life indicator or the employer implements a cartridge change schedule based on objective information or data (§5144(d)(1)(C)); you do not rely on the worker smelling the solvent. A filtering facepiece (dust mask) is a particulate respirator; it does not protect against vapor. For particulates (lead dust, silica dust, asbestos) the respirator and filter are selected under the exposure assessment, with high-efficiency particulate filters (commonly designated P100 in respirator practice).
• Training (§5144(k)): before use, comprehensive, and annually.
• Voluntary use has its own (lighter) requirements; a worker who wants a respirator when none is required still needs medical ability and a clean, maintained respirator.

19.5 Lead: the two rulebooks side by side

Both apply on the same job. A contractor may not pick one.

EPA RRP, summarized

Covered earlier: applicability and the exclusions (Chapter 1), pamphlet timing (Chapter 1 and 4), containment distances (Chapter 8), prohibited practices (Chapter 6), cleanup and cleaning verification (Chapter 9), waste (Chapter 18). Additional facts from 40 CFR 745:

• Firm certification (§745.89): firms apply to EPA; the certificate has an expiration date no more than 5 years from approval; re-certification every 5 years; the application for re-certification is timely if submitted 90 days or more before expiration.
• Renovator certification (§745.90): complete an EPA- or authorized-state-accredited renovator course; refresher within 5 years of the initial course; a refresher without hands-on training gives certification for 3 years and the next refresher must include hands-on training to maintain certification.
• Renovator duties (§745.90(b)): be responsible for compliance at assigned renovations; perform the cleaning verification; either perform or direct the workers who perform the work-practice tasks; provide on-the-job training to workers in the work practices they will use; be physically present at the work site when warning signs are posted, while containment is established and while cleaning is performed; regularly direct the work to keep containment intact; be available on site or by telephone whenever renovation is being conducted; and carry copies of the initial and most recent refresher course certificates.
• Crew: workers do not need individual renovator certification; they must be trained on the job by a certified renovator (EPA-RRP page: employees trained "either as a certified renovator or on-the-job by a certified renovator").
• Do-it-yourself: the rule generally does not apply to homeowners working on their own pre-1978 homes, but does apply if you rent all or part of the home, operate a child-care center in it, or buy, renovate and sell homes for profit (EPA-RRP page); a homeowner who hires a painter is covered through the painter.
• Abatement is a different category with its own certification and clearance; renovation is not abatement.
• Emergency renovations: exempt from the information-distribution, warning sign, containment, waste-handling, training and certification requirements to the extent necessary to respond, but not from the cleaning and cleaning-verification requirements (§745.82(b)).
• Hazard levels (§745.65): a paint-lead hazard includes lead-based paint on a friction surface where lead dust on the nearest horizontal surface is at the hazard level; damaged lead-based paint on an impact surface; chewable painted surfaces with teeth marks; and other deteriorated lead-based paint. Dust-lead hazard: before January 12, 2026, wipe-sample levels of 10 µg/ft² (floors) or 100 µg/ft² (interior window sills); on or after January 12, 2026, the hazard is any reportable level of lead for floors or interior window sills, analyzed by an NLLAP-recognized laboratory. Soil-lead hazard: bare soil with total lead at or above 400 ppm in a play area, or an average of 1,200 ppm in the rest of the yard.

Cal/OSHA §1532.1 in detail

• Scope: all construction work where an employee may be occupationally exposed to lead, including painting and decorating; it includes removal or encapsulation of lead-containing materials, renovation of structures, lead emergency cleanup and the transportation, storage and containment of lead on the site.
• Altering or disturbing includes scraping, sanding, abrading, grinding, drilling, spraying, torch cutting and welding.
• Action level: 2 µg/m³ (8-hour TWA, without regard to respirators). PEL: 10 µg/m³ (8-hour TWA). Exception: until January 1, 2030, no employee conducting abrasive blasting shall be exposed to more than 25 µg/m³. The action level triggers monitoring, training and medical surveillance duties; the PEL is the ceiling. Both are enforceable.
• Exposure assessment: the employer determines whether any employee may be exposed at or above the action level. Trigger tasks (Chapter 6) are presumed to exceed certain levels until an assessment shows otherwise: Level 1 (presumed above the PEL: manual scraping, heat gun, manual drywall demolition); Level 2 (presumed above 100 µg/m³, ten times the PEL: manual sanding, power tool cleaning with dust collection, spray painting with lead paint); Level 3 (presumed above 500 µg/m³, fifty times the PEL: power tool work without dust collection, abrasive blasting, torch burning, welding, torch cutting, cleanup with dry expendable abrasives). Until the assessment, interim protection is provided: appropriate respirators, protective clothing, change areas, shower facilities for Level 3 tasks, eating areas, regulated areas, a cap on dry abrasive blasting time (5 hours per day, and 2 hours per day after January 1, 2030), medical surveillance and training.
• Objective data about the paint (a lead analysis of each unique coating): paint at 0.06% lead dry weight (600 ppm) or more demonstrates lead that may be a health hazard; paint below that concentration can support a negative initial determination. But objective data cannot be used in place of an exposure assessment for the listed trigger tasks.
• Monitoring frequency: at or above the action level but below 30 µg/m³: at least every 12 months; the standard sets longer-interval and discontinuation rules (consecutive measurements at least 7 days apart below the action level). Employees are notified of results.
• Respirators and PPE: respirators under §5144; protective clothing; no compressed air to remove lead from surfaces unless used with a ventilation system that captures the dust (§1532.1(h)(5)); vacuums fitted with HEPA filters; shoveling, dry or wet sweeping and brushing not used unless vacuuming has been tried and found ineffective (§1532.1(h)).
• Hygiene (§1532.1(i)): no food, beverage, tobacco or cosmetics in lead areas; washing facilities; workers wash hands, arms and face before eating and at the end of the shift; clean change areas with separate storage for protective clothing and street clothes; workers do not enter personal vehicles or leave the workplace wearing required protective clothing; showers for those above 50 µg/m³ and for Level 3 trigger tasks (unless shown infeasible); eating areas; regulated areas. Contaminated clothing is handled and laundered under employer control, so lead is not taken home to children and household members.
• Medical surveillance (§1532.1(j)): initial blood lead testing before assignment to work with exposure at or above the action level (with exceptions for infrequent exposure: under 30 days in 12 consecutive months and never above 10 µg/m³, or under 15 days and never above 20 µg/m³), and as interim protection before trigger tasks. Blood lead testing schedule: at least every 2 months for the first 6 months and every 6 months after; every 2 months if the last level was 10 to under 20 µg/dL until two consecutive results at least 30 days apart are below 10; monthly if the last level was 20 µg/dL or higher and during removal.
• Medical removal protection (§1532.1(k)): the employer removes an employee from lead exposure when the last blood lead test is 30 µg/dL or higher; and, effective January 1, 2026, when the last two results are 20 µg/dL or higher, or the average of all tests in the last 6 months is 20 or higher (unless the last test is below 15). Return to former job when two consecutive tests at least 30 days apart are both below 15 µg/dL. The employer maintains total normal earnings, seniority and benefits during removal (so workers do not hide results).
• Communication and training (§1532.1(l)): lead is part of the hazard communication program (§5194); workers are trained before initial assignment and at least annually; training covers the standard, operations that expose, hygiene, respirators, medical programs, health effects including reproductive effects, and take-home contamination, with a recommendation to shower immediately upon returning home. Where certification is required, the training provider is accredited by the California Department of Public Health.