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Summer 2024 Update

OSHA Notice of Proposed Rulemaking for Heat Injury and Illness Prevention

OSHA has issued a Notice of Proposed Rulemaking for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.


The proposed standard would require employers to create a plan to evaluate and control heat hazards in their workplace both indoors and outdoors.


NSPCA Technical Advisor Alison B. Kaelin, CQA put together the linked article that describes the proposed standard, requirements, and provisions. Click the image to download the PDF.


2024-08 OSHA Heat Rule

OSHA Enforcement in Industrial Painting & Emphasis Programs

As you may know, OSHA began hiring more compliance officers in 2021 and most regions are now vigorously enforcing their standards with a record 34,000 inspections in 2023. They are on pace to have even more in 2024.


Review of the OSHA enforcement database has found several key regulations where OSHA is targeting industrial painters during 2024 site visits. 


Alison drafted the linked article that describes enforcement issues. Click the image to download the PDF.


2024-08 OSHA Enforcement

Meet the NSPCA Team:

Alison B. Kaelin, CQA | Technical Advisor


"At NSPCA, we're focused on the ground level and really paying attention to things that affect the lives of painting contractors and technicians."

Alison B. Kaelin

Alison has served as technical advisor to NSPCA since 2015 through her company ABKaelin, LLC (ABK). ABK provides professional consulting and support services specializing in environmental health and safety (EHS), quality programs, and coatings. Alison and ABK are available to NSPCA members for advice and questions. Feel free to contact her directly via the email at the bottom of this newsletter.


After earning a degree in civil and environmental engineering from Vanderbilt University, Alison began her career with the Allegheny (Pa.) County Bureau of Air Pollution Control, where she helped write and enforce one of the nation’s first regulations for abrasive blasting. She then spent 20 years with KTA, as EHS and Quality Assurance Manager working with owners and contractors helping develop and implement many of the monitoring techniques used today. As an ASQ Certified Quality Auditor (CQA), an AMPP Senior Coating Inspector, and an original author and instructor of the C3/C5 Lead Paint/Hazardous Coatings Supervisors course, Alison has seen it all and contributes her perspective to many industry organizations. She sat on the SSPC board of directors and the initial AMPP Global Center Director, participates on the AMPP lead task force and certification and EHS committees, and has contributed dozens of articles to the Journal of Professional Coatings & Linings and Coatings Pro magazines. She regularly speaks about regulatory and other topics for IUPAT and presents at the annual Finishing Industries Forum and AMPP conference.


Outside of work, and motivated by concern for the environment, Alison has become an avid gardener and beekeeper. She enjoys spending time with her 16 nieces and nephews and traveling the world. Ask about her recent trip to the Amalfi Coast of Italy.


Connect with Alison on LinkedIn

AMPP logo

Revision to SSPC/AMPP PA-1, Shop, Field, and Maintenance Coating of Metals


On June 19, 2024, AMPP issued a mostly format revision of the 2016 version of SSPC/AMPP PA-1, Shop, Field, and Maintenance Coating of Metals. This foundational standard is referenced in nearly every coating application specification and is the AMPP/SSPC QP programs.


Some of the changes include:

  • Reformatting to the AMPP template
  • Added definition for coating
  • Not new but worth noting, Section 3.3 states, “A coating that has exceeded its shelf life shall not be used unless the contractor or applicator, with permission from the facility owner or authorized representative, has first obtained a certificate of conformance (COC) from the coating manufacturer. The COC shall verify the acceptability of that batch of coating for use for a specified period.”
  • Not new but worth noting, Section 3.3 states, “Unless otherwise specified in the procurement / specification documents, all dry film thickness determinations shall be performed as specified in SSPC-PA 2. If no coating thickness restriction level from SSPC-PA 2 is specified, Level 3 shall be the default level.” This means if PA1 is referenced in a specification, but they do not specifically require PA-2, PA-2 is still required.


If you are a QP certified contractor, make sure you download a copy of the current standard before your next AMPP audit.

2024 Disciplinary Action Criteria Revisions


The Disciplinary Action Committee (DAC) Task Force and AMPP board of directors have passed the DAC Revision.


AMPP 2024 Disciplinary Action Criteria Revisions:

  • Updated wording to address the global market.
  • Removed the Experience Modification Rate (EMR) language. 
  • Added new “Critical Fault” categories for confirmed wage and hourly worker payment violations.
  • Added new “Severe” and “Critical Fault” language for subcontracting to a non-accredited contractor without facility owner approval on a project requiring QP accreditation
  • Reorganized listing of “Faults” by category from "Serious" to "Severe" for easy comparison (e.g., listing safety practice faults from "Serious" to "Very Severe" in the same section)
  • Amended “Quality of Service” category to include failure to meet project requirements at final acceptance inspection with no resolution of “outstanding” non-conformities.


The updated 2024 DAC Revision can be downloaded by logging onto the AMPP website and searching Disciplinary Action Criteria.

QP Standard for Passive Fire Protection


NSPCA Director of Contractor Engagement Rick Matthews has been appointed by the AMPP Accreditation Program Chair, to chair a task force aimed at developing a QP Standard for Passive Fire Protection. To date, a draft of the QP standard and a draft of the auditor checklist have been developed. The task force meets bi-weekly and is in the process of editing the auditor checklist draft. Once the auditor checklist is finalized, the QP standard can be completed and finalized. The task force plans to complete the work by December 2024 and present it to the Accreditation Program Committee prior to the AMPP 2025 Conference.

AMPP Conference + Expo

Mark your calendars for the AMPP Annual Conference + Expo, April 6-10, 2025 in Nashville. Learn more at the conference website.

EEOC Update

The U.S. Equal Employment Opportunity Commission (EEOC) released a guide to help construction leaders prevent and address harassment on the job. Click to download Promising Practices for Preventing Harassment in the Construction Industry.


Construction Dive has a good recap of the guide here.

The National Steel Painting Contractors Association (NSPCA) provides a platform to help IUPAT contractors engaged in structural steel painting and industrial coatings preserve and grow market share. We are committed to our members' success.


Have an idea for a program or educational resource. Reach out to one of us:


Deborah A. Wyandt, Esq. | Executive Director | dwyandt@nspcassociation.org

Rick Matthews | Director of Contractor Engagement | rmatthews@nspcassociation.org

Alison B. Kaelin, CQA | Technical Advisor | akaelin@nspcassociation.org


Visit us online: https://nspcassociation.org/