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,
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
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:
https://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.
- 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
- 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.
- Assure proper handling of isocyanate products, and properly maintain processing
equipment to minimize the potential for contamination of surfaces, equipment,
- 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
- 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
The ACC document library provides a multitude of guidance documents and
videos accessible via the following link:
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.
The American Industrial Hygiene Association (AIHA) has a web tool that
can help companies locate an industrial hygiene consultant in their area:
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.
Awal (Dave) Lall
DEMILEC (USA) LLC
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.