OSHA NEP for Isocyanates

Posted By DEMILEC || 22-Jul-2013

The Occupational Safety and Health Administration (OSHA) has announced a new National Emphasis Program (NEP) developed to focus OSHA resources on occupational exposure to isocyanates. Demilec (USA) LLC has prepared this summary guidance document to assist our customers in understanding the NEP and to aid in your preparation for an OSHA NEP inspection.

OSHA’s goal for this NEP is to reduce employee exposure to isocyanates that potentially cause work-related asthma, sensitization (respiratory, skin) and other occupational health effects. OSHA plans to accomplish this by a combined effort of inspection targeting, outreach to employers and compliance assistance.

According to the new NEP, workers in a wide range of industries and occupations are exposed to a number of isocyanates known to be associated with work-related asthma. OSHA has identified jobs that may involve exposure to isocyanates to include painting, spray foam insulation, and the manufacture of many polyurethane products such as polyurethane foam, insulation materials, surface coatings, car seats, furniture, foam mattresses, under-carpet padding, packaging materials, shoes, laminated fabrics, polyurethane rubber, adhesives, etc.

This NEP is effective June 20, 2013 and will be in effect for three (3) years.

What is an OSHA National Emphasis Program (NEP)?
OSHA develops NEPs to focus outreach efforts and enforcement on specific hazards in a particular industry for a three-year period. This program was developed to focus on the reduction of worker dermal and respiratory exposure to isocyanates which are known to potentially cause work-related asthma, sensitization (respiratory, skin) and other occupational health effects. The Isocyanates NEP will combine enforcement and outreach efforts to raise employers’, workers’, and safety and health professionals’ awareness of the health effects associated with occupational exposure to isocyanates.

Which industries are targeted for inspection under the Isocyanates NEP?
OSHA stated that inspections under this NEP will target all workplaces under the jurisdiction of Federal OSHA, including general industry, construction and maritime industries where exposures to isocyanates are known or are likely to occur, including establishments with fewer than 10 workers. A list of relevant industries (by Standard Industrial Classification (SIC)/North American Industry Classification System (NAICS) codes) where isocyanates are to be used is in Appendix A of the NEP. Among the relevant industries are automotive, casting, building and construction, electricity and electronics, mechanical engineering, paints, plastics, printing, timber and furniture, textile, medical care, mining, and food industry.

What to expect from the OSHA inspections?
Each OSHA Area Office is to conduct at least three (3) inspections per year. Area Office locations can be found here: http://www.osha.gov/html/RAmap.html. These inspections will be unannounced.

OSHA compliance officers will inspect the employer’s:

  • injury and illness records to determine if injuries and illnesses related to isocyanate exposures have been recorded, including any work-related cases of asthma,
  • controls (engineering controls, administrative and work practice controls, and personal protective equipment (PPE)) where potential exposures to isocyanates are present,
  • hazard communication program,
  • methods for ensuring adequate housekeeping,
  • compliance where chemical components of an isocyanate process or operation contain flammable or combustible materials.

During the inspections, air samples will be collected and wipe samples may also be obtained to determine dermal exposure. If wipe sampling reveals surface contamination or dermal exposure, OSHA may issue citations under the PPE or housekeeping standards. Furthermore, the NEP states that an OSHA compliance officer may expand the scope of the inspection beyond the isocyanate-related work operations or activities if other workplace hazards or violations are observed and/or brought to their attention.

Citation Guidelines

  • Where inhalation exposure to an isocyanate exceeds the OSHA PEL set forth in 29 CFR 1910.1000(a), Table Z-1, without regard to the use of respiratory protection, the compliance officer shall generally issue a “serious” citation.
  • Where an overexposure exists and feasible engineering and/or administrative controls were not utilized or were ineffective, the compliance officer shall generally issue another citation under 29 CFR 1910.1000(e) and group it with the overexposure citation.
  • Where workers are exposed to a particular isocyanate having an established OEL, but no OSHA PEL, the compliance officer may consider issuing a citation for exposure in excess of the OEL under the General Duty Clause, Section 5(a)(1) of the OSH Act.

How to prepare for the NEP?
During an inspection under this NEP, the OSHA compliance officer may review five areas. Listed below are actions that can be taken which may provide assistance in the event of an NEP-related inspection:

  • Injury and illness recordkeeping; Assure that you have recorded on the OSHA 300 and 301 forms any injury or illness records related to isocyanate exposures, including any work-related cases of asthma.
  • Controls (engineering controls, administrative and work practice controls, and personal protective equipment (PPE); conduct a workplace exposure assessment to identify potential airborne and/or dermal exposures to isocyanates. This might consist of air sampling, wipe testing (i.e., surface, dermal and PPE), and/or visual inspections. If the exposure assessment indicates that there may be an isocyanate overexposure, ensure that engineering and administrative controls have been implemented. If feasible engineering and administrative controls cannot eliminate overexposure to isocyanates, ensure that appropriate personal protective equipment is available and used. If personal protective equipment is used, ensure that the company PPE program is in compliance with the requirements of the applicable OSHA Standards:
  • 1910.132, Personal Protective Equipment
  • 1910.133, Eye and Face Protection
  • 1910.134, Respiratory Protection

3. Hazard Communication Program

  • Assure that a written hazard communication program is in place.
  • Assure that the hazardous chemical inventory includes any isocyanate products in use at your facility.
  • Complete isocyanate hazard communication training for all applicable employees.
  • Assure that SDSs (Safety Data Sheets) formerly call MSDS are on site and readily available to employees.
  • Properly label any containers of isocyanate products.

4. Housekeeping

  • Assure proper handling of isocyanate products, and properly maintain processing equipment to minimize the potential for contamination of surfaces, equipment, clothing, etc.
  • Institute a periodic housekeeping inspection program to identify and correct sources of isocyanate contamination (e.g., handling practices, equipment leaks, etc.) in a timely manner.
  • Consider using wipe testing as a means to confirm possible isocyanate contamination of surfaces, equipment, tools, etc. SWYPEs™ test kits have been used for this purpose; information can be found at http://www.clilabs.com/products/surface-swypes.html.
  • When contamination is identified through visual inspection and/or wipe testing, promptly decontaminate surfaces, equipment, tools, etc.

5. Isocyanate processes or operations containing flammable or combustible materials

  • Determine whether or not the isocyanate-containing products being handled are flammable (flash point at or below 93 °C) by consulting the SDS
  • If materials are flammable, ensure compliance with OSHA Flammable Liquids and Spray Finishing Using Flammable and Combustible Materials Standards (1910.106 and 1910.107).

Where do I get additional information and assistance?

1. American Chemistry Council

The spray foam industry is strongly committed to the safe and responsible use of their products through the American Chemistry Council (ACC) organizations:

The ACC has conducted extensive research and developed industry guidance documents and programs to educate and workers and consumers. The ACC Center for Polyurethanes Industry has published best practices guides for safe use and handling and for ventilation of the work zone. These were developed to assist companies and workers in all phases of the supply chain with industry vetted guidance for safe use and handling of all SPF products including isocyanate.

The ACC document library provides a multitude of guidance documents and videos accessible via the following link: http://polyurethane.americanchemistry.com/Resources-and-Document-Library#EHS.
ACC has also prepared a Q&A document on the Isocyanate NEP, available from Demilec (USA) LLC upon request.

2. Occupational Safety and Health Administration (OSHA)

Small business owners who are concerned about the cost of professional help can contact the OSHA Consultation Project Office in their state for a free consultation service. The OSHA Consultation Program can help employers evaluate and prevent hazardous conditions in their workplace that can cause injuries and illnesses, including the hazards associated with exposures to isocyanates. For more compliance assistance information, please visit OSHA’s Small Business web page at http://www.osha.gov/dcsp/smallbusiness/index.html.

  • Other Resources

The American Industrial Hygiene Association (AIHA) has a web tool that can help companies locate an industrial hygiene consultant in their area: http://www.aiha.org/about-ih/Pages/Find-an-Industrial-Hygienist.aspx.

Please contact your Territory Manager or Technical Service Rep for more information, and watch for future announcements from Demilec (USA) LLC regarding additional information concerning this NEP and other import health and safety issues.
Sincerely,

Awal (Dave) Lall
CEO
DEMILEC (USA) LLC

DISCLAIMER
These guidelines are for informational purposes only. You remain solely responsible for complying with all necessary safety and other legal requirements. The manner in which you use and the purpose to which you put and utilize this information (whether verbal or written) or technical assistance, are beyond our control. Therefore, it is imperative that you test this information and any technical assistance provided to determine to your own satisfaction whether the technical assistance and information are suitable for your intended uses and applications. All information and technical assistance is given without warranty or guarantee and is subject to change without notice. It is expressly understood and agreed that you assume and hereby expressly release us from all liability, in tort, contract or otherwise, incurred in connection with the use of our products, technical assistance, and information. Any statement or recommendation not contained herein is unauthorized and shall not bind Demilec (USA) LLC.

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