AMPP Guide 6 – Major Changes Effecting Abrasive Blasting Enclosures

AMPP Guide 6 – Major Changes Effecting Abrasive Blasting Enclosures


November 15, 2022

Alison B. Kaelin, CQA ABKaelin, LLC

If you are bidding work now, be careful that you have read and understand the most recent version of AMPP Guide 6, Guide for Containing  Surface Preparation Debris Generated During Paint Removal Operations (Approved October 27, 2021).  The revision completely changes all categories of Table A, including introducing new containment and ventilation system components and cautions regarding 29 CFR 1926.57, Ventilation.

Major Changes:

5.3.5 Entryways – Uses revised definition of airlock and resealable entryways, and all are required for abrasive blasting to meet the Ventilation standard

Type E1 – Entryway Through Airlocks with Resealable Doors: This entry system includes access doors that are flanged, tight when closed, operable from both inside and outside, and capable of being repeatedly resealed. Air locks are used in addi­tion, in order to minimize air exchanges and air losses through the entryways.

Type E2 – Entryway Through Resealable Doors: The use of doorways that are tight when closed, operable from both inside and outside, and capable of being repeatedly resealed.

5.4.1 Air Make-up – Introduces 2 types of Controlled Air Supply (Intake)

Type F1A – Controlled Air Supply (Intake): The use of slit abrasive-resistant baf­fles in multiple sets at all small access openings where dust might escape that are inspected regularly and replaced when needed to preclude inadvertent escape of abrasive and debris. They may or may not be used in combination with fans (see 5.4.2.1 ). The optimum direction for airflow should be evaluated when selecting air in­take points relative to exhaust (e.g., along bridge stringers rather than across them). Type F1 B – Controlled Air Supply (Intake): The use of flap seals, filters, and ducts on supply air points to preclude inadvertent escape of abrasive and debris. They may or may not be used in combination with fans (see 5.4.2.1 ). The optimum di­rection for airflow should be evaluated when selecting air intake points relative to exhaust (e.g., along bridge stringers rather than across them). CAUTION: Does not meet ventilation standard CFR 1926.57(f)(3)(i)(A).

Type 11 – Minimum Air Movement is Specified – Notes that there are no values for updraft ventilation.

Achieving air movement through the containment requires the use of mechanical ventilation. Air movement may be specified by establishing a minimum velocity of air at 100 feet per minute in cross-draft or 60 feet per minute in down-draft velocity. There are no updraft calculation or values to be used.

6. NOTES – Provides updated ANSI and other References related to ventilation system design and recommended levels of air velocity.

Watching your (Hazardous) Waste!

The most major change to the Resource Conservation and Recovery Act (RCRA) occurred in 2018 through the Hazardous Waste Generator Improvement Regulations. These revisions included some major clarifications and changes to:

  • How waste is characterized as hazardous
  • How waste is tracked, and generator categories managed
  • Changes to Preparedness, Prevention and Contingency Plan and notification of local authorities
  • Land Disposal restrictions
  • Containers, Packaging, Labeling and Records
  • Personnel training
  • Closure

You can get a summary of the federal requirements, fact sheets, etc. at:  https://www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements

Most of the 50 states have adopted them “as is” but some states have established stricter state regulations.  For a list and links, see: https://www.epa.gov/hwgenerators/table-noting-which-states-have-hazardous-waste-generator-categories-are-same-federal

Also, several Northeastern states have begun to develop guidance on compliance as well as performing site visits and enforcement.

Pennsylvania has a website, compliance guide, FAQs and other links at: https://www.dep.pa.gov/Business/Land/Waste/SolidWaste/HazardousWaste/Pages/Information-for-Hazardous-Waste-Generators.aspx

New Jersey has guidance available including a compliance starter kit at:  https://www.nj.gov/dep/enforcement/hw.html

New York has guidance available at:  https://www.dec.ny.gov/chemical/121582.html#Current

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