## Considerations **for Safe Use of Spray Polyurethane**  **Foam (SPF): An OSHA** 

**Perspective Janet Carter**  **Health Scientist**  **Directorate of Standards and Guidance**  **Poly urethanes 2009**  **Technical Conference 12**  **Nov ember 2009** 

# Discussion Outline • OSHA roles and responsibilities • Concerns with SPF • OSHA Applicable Standards • Employer responsibilities – Communications – Training – Exposure control and PPE

## OSHA’s Role and Responsibilities • Agency Mission – “assure safe and healthful working conditions for working men and women” – Safety and Health Standards – Enforcement of Standards – State assistance – Provide research, training, education, information

# OSHA Concerns with SPF • Isocyanates have been reported to be the leading attributable chemical cause of workrelated asthma (WRA) – Causal - link for developing occupational asthma – Exacerbates ex isting asthma conditions – Other health effects attributed to isocyanate exposure 

### • Hazard information **not** reaching all users across the entire value chain • Inconsistent worker protection

# OSHA Applicable Standards • 3 PELS for isocyanates – 29 CFR 1910 subpart Z (Air contaminants) 

### • General duty clause

# OSHA Applicable Standards • 29 CFR 1910.1200; 1915.1200; 1917.28; 1918.90; and 1926.59 (Hazard Communication) • 29 CFR 1910.134 (Respiratory Protection) • 29 CFR 1910 Part I, 1926.95 (Personal Protective Equipment) • 29 CFR 1910.94; 1915.51; 1918.94; 1926.57 (Ventilation)

# Employer Responsibilities • Full Hazard Communication • Provide worker training • Appropriate Exposure Control System – PPE for **ALL** exposed workers – Adequate and appropriate containment and/or ventilation

# Hazard **Communication** • Communicate all hazards via: – MSDS – Labeling of all hazardous substances – Warning signs of hazards 

### • Employee training

## Hazard Communication **- MSDS**  • Material Safety Data Sheets – Integral part of communication strategy – Must be readily available to **all** affected workers – Must be comprehensive 

### • Issues with accuracy, consistency and completeness

## Hazard Communication **- MSDS**  **MSDS –**  **current deficiencies and inconsistencies** – **Hazard and exposure control information v aries**  **wi dely**  – **Recommendations on respiratory protection v** **ary** – **Only a few M**  **SDSs mention the possible need for respiratory protection for “adjacent w** **orkers.”**

– **MSDSs indicate that adequate v entilation**  **is needed but prov ide**  **no guidance or suggestions on v** **entilation methods or w hat**  **constitutes adequate v entilation**  – **Few M**  **SDSs mention that skin contact may cause an allergic**  **reaction/sensitization** – **Sev eral**  **MSDSs mention that dust can be generated during cutting or abrasiv** **e processes, how** **ev er, hazards are identified**  **as “mechanical irritation” and do not mention the possible presence of MDI** 

## Hazard Communication **- MSDS**  **MSDS –**  **more complete information** – Identify known hazards and exposure routes • Includes skin and other relevant health effects beyond asthma – Identify appropriate first- aid and medical measures – Identify appropriate exposure controls and PPE (skin and respiratory) – Address need for adequate containment and ventilation • Includes use of filters (bed - liner guidance) • Generation of dust – may contain isocyanates

# Hazard **Communication** • MSDS from manufacturers – Information should **not** be deleted down the supply chain – User accepts liability if change information 

### • What if a worker or adjacent person is harmed because of inadequate or altered information?

## Hazard Communication **- Training**  • Employers need to train workers on: – Hazards associated with use of **ALL** hazardous chemicals including Isocyanates and SPF – Proper control measures – Proper use of PPE – Protecting those in adjacent areas – Appropriate ventilation

## Hazard Communication **- Training**  • Training should be available to all appropriate workers • Training material is available on web: – OSHA – NIOSH – ACC/Polyurethane Industry

## Hazard Communication **– New Communication**  **Rule** • **Current** - Hazard Communication – 29 CFR 1910.1200 (general industry) – Others apply for construction; maritime; long shore • **New** - Global Harmonization System (GHS) – Proposed rulemaking • For MSDS – ANSI 400 standard – 16 Section format » Already in use with current standard – Comment period ends December 29 – Announcement for public hearings soon

# Appropriate Exposure Control • Exposures should be controlled whenever possible – PPE should be last resort – Problems with compliance • Need for education and training 

### • Develop best practices for work activities – Enclosures or partitions – Dust control measures – Proper air circulation and ventilation

# Appropriate Exposure Control • Consider all phases of operation – Start to finish, including clean - up – Consider use of PPE for clean - up crew • Same as operator/helper 

### • Training is essential – Consider developing checklist to ensure compliance

## Appropriate Exposure **Control -**  **Proper Use of PPE** • Primary worker (spray applicator): – Full saran - coated body cover (no exposed skin) – Gloves – Appropriate respirator with full face mask • Helpers (need to evaluate on case - by- case basis) – Full skin protection and gloves (no skin exposed) – Full face mask • Adjacent workers • Train **ALL** workers

## Appropriate Exposure **Control -**  **Ventilation Considerations** • Ventilation crucial for worker safety • Only vent to outside using approved filter – Protect workers or passer- by’s outside – Similar methods can be adapted from measures used in truck bed - liner industry

## Summary/Concluding **Remarks** • Communication and training is key to safe use and handling of SPF • OSHA issued publications in alliance with API for Truck Bed - liners: – “ Spray on Truck Bed Liner Applications Using MDI/PMDI; Seven Important Points” and “ Considerations for the Application of Spray

- On Truck Bed Liners TBL” – Developed for employers, the document includes information on how to recognize MDI - related hazards and reduce employees' exposure to MDI – Similar hazards – Similar remedies

# Additional Information • **OSHA assistance** – **OSHA has free consultation**  **program** • Small and medium sized businesses – **All 50 states**  **participate** – **“Full service consultation"**  • Covers all working conditions, includes assistance in establishing effective workplace safety and health programs, with emphasis on preventing worker injuries and illnesses. Assistance may also include training and education for the employer and his or her employees and supervisors as well. – **“Limited service consultation”**  • Consultant focuses on more specific workplace problems or specific issues or hazardous processes relating to a particular business – **Information available on w** **ebsite: www.osha.gov** 

# Additional Information • Regions have been alerted – Will continue to send message 

### • DOL and OSHA are working to include safety and health as key message in “Green” jobs training programs – Promote safe use of these materials in the workplace