Overview

In the vehicle customization industry, there is a trend to apply rubberized coatings (‘wraps’) to painted surfaces of vehicles or vehicle components (for example, rims and spoiler). The coating protects the painted surface or changes the vehicle’s appearance.

The coating is cost-effective and can be easily removed by peeling it off in sheets, just like removing an adhesive sticker. It may be used by workers at any workplace where automotive finishes are done, including:

  • automotive detailing
  • body shops
  • service garages

Hazards

This rubberized coating is applied by spraying a flammable liquid using an air gun or aerosol can onto the surface of the vehicle. The hazards associated with these coatings include:

  • The vapour from flammable liquids can ignite when exposed to heat, or sources of ignition such as sparks, flames or static electricity resulting in injury or death.
  • Liquid rubber coatings may produce toxic vapours.

Ways to prevent injuries

The following are some safety measures that can help protect workers from hazards associated with the application of flammable liquid rubber:

  • Ensure the operation is carried out in accordance with the Ontario Fire Code.
  • Use and store the flammable liquid rubber in an area free of any source of ignition, including heat, sparks, flame or static electricity. 
  • Containers for dispensing flammable liquids must be bonded and grounded.
  • Use the product outdoors or in a well-ventilated area.
  • Wear gloves, protective clothing, eye and face protection, if required, as per safety data sheets.
  • When not required for immediate use, store the flammable liquid rubber in sealed containers.
  • Always follow the manufacturer’s instructions and read and follow safety data sheets for the use, care and storage of the flammable liquid rubber.

Occupational health and safety legal requirements

The Occupational Health and Safety Act (OHSA) sets out the general duties of workplace parties, includes requirements for dealing with workplace hazards and provides for enforcement by the Ministry of Labour, Immigration, Training and Skills Development where compliance is not achieved voluntarily. The general duties for employers, supervisors and workers may apply to protect workers from the hazards associated with liquid rubber coatings. The following are some examples of employers’ and supervisors’ general duties under the OHSA.

Information and instruction

The OHSA requires employers to provide information, instruction, and supervision to a worker to protect their health or safety. Depending on the circumstances, this may include information and instruction on:

  • engineering controls
  • use of personal protective equipment (PPE)
  • safe work practices
  • emergency response procedures
  • first aid

Every precaution reasonable in the circumstances

The OHSA also requires employers and supervisors to take every precaution reasonable in the circumstances for the protection of a worker.

Applicable regulations under OHSA

The following are examples of requirements in regulations made under the OHSA that may apply to protect workers from hazards associated with flammable liquid rubber coatings.

Regulation 851 – Industrial Establishments

Read Regulation 851 to review the provisions that may be applicable to hazards associated with liquid rubber coatings in industrial establishments.

For example, under sections 22, 23, 63, 81, 82, 84, 127, 128, and 130 of Regulation 851 – Industrial Establishments, there are requirements that include, among other things, the following.

Storage and dispensing

Where not required for immediate use, safely store flammable liquids in sealed containers either:

  • outdoors and remote from any means of egress
  • in a building not used for any other purpose
  • in a room meeting all the requirements described in Regulation 851

A maximum of 235 litres of flammable liquids may be stored in either:

  • sealed containers of not more than twenty-three litre capacity each
  • a metal cabinet of double walled construction meeting all the requirements in Regulation 851

Ensure containers and dispensing equipment are bonded and grounded when flammable liquid is dispensed and ensure that an area where flammable liquids are dispensed has mechanical ventilation from floor level to the outdoors at the rate of eighteen cubic metres per hour per square metre of floor area.

Ensure that portable containers being used to dispense flammable liquids are made of material suitable to provide for the safety of workers with a spring-loaded cap and flame arrestor.

Personal protective equipment

Wear eye, foot and skin protection that is appropriate in the circumstances.

Ventilation and work area

Carry out a process that is likely to produce a vapour that may ignite, like the application of liquid rubber coatings, in an area that meets each of the following requirements:

  • is isolated from other operations
  • has a ventilation system adequate to ensure the vapours do not reach a hazardous concentration
  • has no potential sources of ignition
  • has provision for explosion venting
  • has, where applicable, baffles, chokes or dampers to reduce the effects of any explosion

Ventilation

Adequately ventilate an industrial establishment by either natural or mechanical means so that the atmosphere does not endanger the health and safety of workers.

Provide replacement air to replace air exhausted, in accordance with certain prescribed requirements set out in Regulation 851.

Training

Train a worker who may be exposed to a chemical, such as flammable liquid rubber coatings, that may endanger a worker’s safety or health:

  • to use the precautions and procedures to be followed in the handling, use and storage of the product
  • in the proper use and care of required PPE, and
  • in the proper use of emergency measures and procedures

Regulation 833 – Control of Exposure to Biological or Chemical Agents

Where it applies, employers have a duty under Regulation 833 - Control of Exposure to Biological or Chemical Agents to take all measures reasonably necessary in the circumstances to protect workers from exposure to a hazardous chemical agent because of the storage, handling, processing, or use of the chemical agent in the workplace. This duty applies to flammable liquid rubber coatings. The measures to be taken include the provision and use of:

  • substitution of the hazardous chemical agent (where reasonable and practical)
  • engineering controls
  • administrative controls, including work practices
  • hygiene facilities and practices
  • personal protective equipment (in specific circumstances as set out in Regulation 833)

An employer must protect workers from exposure to a hazardous chemical agent, without requiring them to wear and use a respirator, unless specific circumstances set out in Regulation 833 apply, in which case an employer shall provide, and a worker shall wear and use, a respirator appropriate in the circumstances to protect the worker from exposure to the agent. An employer who provides a worker with a respirator must comply with the Respiratory Protection Program provisions set out in Regulation 833 (sections 9 to 13).

The above is not an exhaustive list of the requirements related to hazards associated with liquid rubber coatings. Read Regulation 833 for more information on relevant requirements.

Regulation 860 – Workplace Hazardous Materials Information System (WHMIS)

The Workplace Hazardous Materials Information System Regulation (R.R.O. 1990, Regulation 860) sets out in detail the employer's duties respecting labels and safety data sheets for hazardous products such as liquid rubber coatings and prescribes the content and delivery of worker education programs. Read Regulation 860 and Workplace Hazardous Materials Information System - A guide to the legislation for more information.

Resources

Fire safety legislation and Ontario’s Fire Code

NFPA (National Fire Protection Association Standard) 33 Standard for Spray Application Using Flammable or Combustible Materials

NFPA 77, Recommended Practice on Static Electricity

CSA C22.1:21 Canadian Electrical Code, Part I (25th Edition), Safety Standard for Electrical Installations

This resource does not replace the Occupational Health and Safety Act (OHSA) and its regulations and should not be used as or considered legal advice. Health and safety inspectors apply and enforce these laws based on the facts they find in a workplace.

Mention of any organization or tool does not mean the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) endorses them. Citations to websites external to the MLITSD do not constitute MLITSD endorsement of the organizations or their programs or products as OHSA compliant. The MLITSD is not responsible for the content of these websites.