KPA talks VOC risks, testing, regulations

KPA cites the Occupational Safety and Health Administration (OSHA)’s top 10 most frequently cited standards last year to remind collision repairers about volatile organic compound (VOC) risks and testing requirements.

OSHA’s respiratory protection standard (29 CFR 1910.134) requires employers to make “a reasonable estimate of employee exposures,” a KPA press release states. If they can’t, KPA says “they’re required to treat the air as immediately dangerous to life or health, likely forcing the use of [the] most protective and expensive respirator approved for these conditions.”

“OSHA has not established exposure limits for the certain isocyanates in automotive clearcoats and hardeners, though NIOSH has warned for decades that exposure to diisocyanates can cause occupational asthma and, in documented cases, death,” KPA says.

And KPA notes the same need for evidence applies to hazardous waste, such as Environmental Protection Agency (EPA) rules. 40 CFR 262.11 requires businesses to support their own waste determinations and retain the records for at least three years, with penalties reaching $93,058 per day, per violation.

“Regulators are paying attention: respiratory protection was OSHA’s fifth most cited standard in fiscal year 2025,” the release states.

The top 10 most frequently OSHA-cited standards last year were:

1. 1. Fall protection, general requirements (29 CFR 1926.501)
   2. Hazard communication, general industry (29 CFR 1910.1200)
   3. Ladders, construction (29 CFR 1926.1053)
   4. Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147)
   5. Respiratory protection, general industry (29 CFR 1910.134)
   6. Scaffolding, construction (29 CFR 1926.451)
   7. Fall protection training, construction (29 CFR 1926.503)
   8. Powered industrial trucks, general industry (29 CFR 1910.178)
   9. Eye and face protection, construction (29 CFR 1926.102)
   10. Machine guarding, general industry (29 CFR 1910.212)

KPA now offers Volatile Organic Compound (VOC) Air Monitoring and Hazardous Waste Analysis to the automotive industry. The analysis is managed as one program and includes sampling, certified laboratory analysis, interpretation, and the documentation regulators require, according to KPA’s release.

“Backed by certified laboratory partners and KPA’s in-house environmental, health, and safety consultants, the services give dealerships, collision centers, and auto care businesses lab-verified data on what employees are breathing and what their business waste contains; the proof OSHA and EPA look for when a respiratory program or waste determination gets questioned,” KPA states in the release.

KPA says the analysis program launch builds on expanded EHS solutions it introduced in July, and is the latest addition to its automotive EHS program this year.

“Every compliance program gets tested eventually, either by an inspector, an insurer, or an injured employee’s attorney,” said Wayne Curtis, KPA CEO, in the release. “What matters at that point is the evidence behind your decisions. The assumptions that fail are rarely dramatic: a respirator picked for a hazard nobody measured, or a drum labeled non-hazardous because that is how it was labeled last year. Repeated across dozens of rooftops, that stops being a paperwork problem and becomes dozens of employees breathing something nobody checked. No one had built this end-to-end for automotive, so we did. It protects the business, and more to the point, it protects the people in the shop and the communities around them.”

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