Considerations for Safe Use of 

Spray Polyurethane Foam (SPF): 

An OSHA Perspective

Janet Carter

Health Scientist

Directorate of Standards and Guidance

Polyurethanes 2009 Technical Conference

12 November 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 existing 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 varies widely

– Recommendations on respiratory protection vary

– Only a few MSDSs mention the possible need for respiratory 

protection for “adjacent workers.”

– MSDSs indicate that adequate ventilation is needed but provide 

no guidance or suggestions on ventilation methods or what 

constitutes adequate ventilation

– Few MSDSs mention that skin contact may cause an allergic 

reaction/sensitization

– Several MSDSs mention that dust can be generated during 

cutting or abrasive processes, however, 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 website: 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