Authors note February 2017
Originally written as an advice column for the trade. Regulations may vary by area, please consult your state and local requirements.
Ordinarily, one would be concerned at the arrival of any number of inspectors, from the local Fire department, Department of Building and Safety, or OSHA, or EPA. Why the concern? Fear of the unknown of course!
Knowledge solves these worries. When you know what is required it is fairly easy to comply. The bench jeweler in a retail store has less to watch than a major factory, but many lessons carry right across the levels of manufacturing small to large. Understand the concepts laid out below and relax. Daniel’s guide to the fundamentals of code requirements for jewelers in cities large and small follows.
My first advice is for every shop and factory to have excellent housekeeping. Sweeping the floor, dusting all areas and putting all that into a designated bin will save you both money and trouble. When a high rise jewelry manufacturing building got into trouble in LA, one of the big issues was metallic dust that had accumulated for years. This gave an exaggerated reading of the levels of metallic dust created day in and day out in this controversial location. California EPA moved to close the entire [1]building! A good cleaning would have saved money and avoided much of the trouble from the inspectors. Cleanliness makes money (via your refiner) and reduces workplace exposures to metallic dust.
Next-Be kind and cooperative with any and all officials. Just like us, they have jobs to do and are NOT personally responsible for the laws and codes. If they err, a supervisor can put things right with a minimum of fuss. Most fines come from a lack of understanding or a lack of willingness to comply. Here we go.
There are some basic factors that all jewelers should be aware of. Who is expected to spend time in your location? If you are in a retail store you expect the public. Are you in a free standing store with its own ventilation and plumbing? Or are you in a mall where your ventilation and plumbing are shared with others? If you are in a pure manufacturing facility in an industrial park, you only expect your employees and the occasional visitor. For obvious “public safety” concerns, you may undertake far more processes in a factory than a retail store. Of course, the details of your store or factory location make a difference within the other factors. The amount of available ventilation is another big factor. That affects public and worker safety in a highly regulated way. More detail can be found within your city or county official occupancy code book usually available at your local city hall. All of these details alter the requirements you face.
Zoning laws determine what is allowed in a given area. Exceptions are rare. You need to know your zone and its limits. Residential? Commercial? Light or heavy manufacturing? Be sure your zone allows the “occupancy” you need.
Occupancy codes are about each building within a zone. Each building is required to be licensed by local authorities for its occupancy and or actual use. A church or theatre for example is a “public assembly”. Open flame is generally forbidden in assembly occupancies.
A small shop in a strip mall may be good for customers to enter in front and still allow “light manufacturing” [i]in back with certain limitations. Most processes or materials such as cyanide or anhydrous ammonia trigger a much stricter kind of occupancy category for their location. For example more than ten pounds of cyanide within the whole building triggers the requirement of an “H” occupancy which stands for hazardous. That means special ventilation, no high rise buildings need apply, and probably either an isolation cabinet and/or a cyanide gas leak detection system regardless of your location. Occupancy codes are generally consistent nationwide. This is generally known as the “Uniform Building Code”. Special needs are handled on a local basis. Florida has special winds related rules, and my home in So Cal has earthquake related rules. You need only learn the codes that apply to your address, keeping the learning curve manageable.
Most jewelers have corrosive liquids, like acid for pickling, and flammables like alcohol. Store them properly (as per local ordinances) and separate corrosives from flammables, from alkaline or “base” materials. Many of these can react with one another if they spill onto the same surface. Special cabinets are available that suit this purpose very well.
Many chemicals are not permitted in a retail environment in more than very tiny amounts, such as a few ounces. Some are forbidden, and for good reason! Enforcement varies widely in these matters. Nevertheless you should use proper storage habits and store in approved cabinets. Remove only enough from the cabinet for the days work, no more. MJSA has or will soon have some top notch reference materials available to members.
An ability to explain the uses for the chemicals shows your real needs. This is where the flexibility in enforcement works to your advantage. Having the organized (like in a binder) MSDS sheets are crucial to any visit by Fire or other inspectors.
It should be clear that everyone who works with a tool or chemical is well trained and attentive to safety. If you are in an enclosed mall, hazardous material limits will be small and strict. Probably no casting allowed, and certainly no large open flame ovens or torches. You should stock the practical minimum of any hazardous substance. By “approved” we usually mean UL listed. All of your shop equipment should be either UL approved or some similar authority. If no such is available, your locality will approve safe devices properly used on a case by case basis. Usually a fee applies.
If you are doing small or medium scale manufacturing, be aware that open flame devices from casting torches to ovens need a lot of ventilation compared to their electric counterparts. Generally, retail areas do not have adequate ventilation for much open flame use. A small torch at the repair bench is allowed nearly everywhere, including shopping malls, but they are small and few within any given retail area. Resistance and induction are electric methods to melt precious metals are very safe, clean, and do not require huge amount of ventilation, compared to a blow furnace, gas oven or large casting torch.
A typical bench jeweler has a torch and most likely a compressed oxygen tank which must be properly secured. Most jewelers chain the tank to a substantial wall. The workbench surface and surrounding immediate area should be fire resistant material. The best fuel gas for him may be natural gas from the utility. That is not heavier than air, and is not stored on the premises. That is a very safe configuration. Gold and silver smelting or casting works well with natural gas. Tanked gas stores a lot of energy (imagine a very loud boom) close to you. Heavier than air gases like acetylene and propane can accumulate if leaked and detonate later. So, gases like methane and hydrogen may be a better idea than heavier than air fuel gasa. Again, enforcement varies, but the codes are reasonably consistent state to state.
Once we address the torch and chemicals needed by a bench jeweler the next issue is the polishing lathe.
Your dust collection from this machine should be very good. Be sure to clean filters often. A enclosed hood is helpful for safety and good dust control. Polishing sweeps are worth from $50 per pound to over $100 depending on how much grinding goes on. That dust is considered hazardous material. The rouge we typically use contains very tiny particles of metals that are hazardous if inhaled. So keep your dust collector in good condition for your sake and the living breathing people around you.
The operating basics here are largely about housekeeping and safe organized storage and use of dangerous or hazardous materials. Throw in a portion of good documentation of materials and equipment. Understand where you work and what that means via your local codes. Train your people and yourself in good habits.
As long as you follow the above, and do not exceed the allowed capacity for your zone or building occupancy you will sleep well the night before and after a visit by a government official.
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