Isocyanates National Emphasis Program CPL Sven J. Rundman III Directorate of Enforcement Programs Office of Health Enforcement

Similar documents
Questions and Answers (Q&A) about OSHA s National Emphasis Program (NEP) Occupational Exposure to Isocyanates

Glutaraldehyde Policy

National Emphasis Program on Amputations. OSHA NEP on Amputations CPL

Emergency Telephone (800)

PERSONAL PROTECTIVE EQUIPMENT HAZARD ASSESSMENT, EQUIPMENT SELECTION AND TRAINING DOCUMENTATION

Particularly Hazardous Substances (PHS) Standard Operating Procedure (SOP)

Trade Name of this Product Isopropyl Rubbing Alcohol 91% USP. Corporate Compliance Team 1666 East Touhy Avenue

OSHA REGIONAL ABSTRACT. This notice applies to the jurisdiction of the Englewood Area Office.

Tungsten Heavy Alloy. Densimet, Mallory Metal, Densalloy, High Density Tungsten Alloy

Material Safety Data Sheet

Material Safety Data Sheet

XYZ Contract Company Industrial Hygiene Program

OSHA Compliance Checklist ASC

Des Moines Area Community College Hazard Communication Program for OSHA Standard 29CFR (Hazcom 2012 / GHS)

CeramClean II Aluminum Safe

The following is a six-step approach for complying with the standard. Although there are only six main steps, each involves many smaller steps.

MATERIAL SAFETY DATA SHEET

Personal Protective Equipment (PPE) Blitz Stakeholder Webinar September 15, 2011

Calculations and OELs

PRODUCT SAFETY DATA SHEET Product name: SOFT LEAD PRODUCTS

Training Requirements for the Revised Hazard Communication Standard

EOSMS 204C Effective Date: 12/8/2014 Page 1 of 8

DOW CORNING CORPORATION Material Safety Data Sheet

PALMOLIVE ULTRA SPRING SENSATION LAVENDER

OSHA Regulation and the Growing Popularity of Employee Leasing Programs. Including Temporary Worker Services and Professional Employer Organizations

Exposure and Control of Ten High Priority MSHA Contaminants in Metal Mines. Presented by: Shannon E. Newton, MPH, CIH

MATERIAL SAFETY DATA SHEET PRODUCT: CFW Uncoated, CFW Coated (UL-15), CFW Coated (A-12) REVISION DATE: December 9 th, 2008

Sandblasting & Silica Exposure Control Plan

COMPOSITION / INFORMATION ON INGREDIENTS

EGIO AL OTC,. lj:~. DEPARTMENT OF. LABOR ' Occupational Safety and Health Administration

SDS. GHS Safety Data Sheet. Wechem, Inc. Extract All PRODUCT AND COMPANY IDENTIFICATION. Manufacturer HAZARDS IDENTIFICATION

Health and Technical Assistance for the World Trade Center (WTC) Dust Cleaning Program OSHA Activity Final Report

Loss Control TIPS Technical Information Paper Series

Material Safety Data Sheet

/pdf/ Thu Aug 22 09:51: HFGR30S8 MATERIAL SAFETY DATA SHEET

Sample Hazard Communications Program for Spray Polyurethane Foam Applications

MATERIAL SAFETY DATA SHEET Page 01 of 05

OSHA 2012 Revised Hazard Communication Standard. USC Upstate OSHA Employee Training September 2013

/pdf/ Mon Nov 24 12:32: HFHR38T1 MATERIAL SAFETY DATA SHEET

GEORGIA INSTITUTE OF TECHNOLOGY ENVIRONMENTAL HEALTH AND SAFETY PERSONAL PROTECTIVE EQUIPMENT

Workplace Silica Hazards

Material Safety Data Sheet

OSHA Policies Regarding Mold. Fred Malaby, CIH, CSP Industrial Hygienist NEAIHA/NECOEM Meeting, September 28, 2007

Version /30/2006

Sodium Aluminum Tetrafluoride

MATERIAL SAFETY DATA SHEET

Lead Management. Presented by: Gary Chinn (815) President, Best Technology Systems

(616) Ann Street N.W. Emergency Phone Grand Rapids, MI 49504

Alaska. Occupational Safety and Health Standards. quick guide to. hazard communication for general industry. What you should know and not a word more!

MATERIAL SAFETY DATA SHEET NAME OF PRODUCT MSDS DATE: 04/01/11

Material Safety Data Sheet. Chemical Product and Company Identification Product Name or Number:

Version /29/2006

INTRODUCTION TO OSHA PRESENTATION

1. Chemical Product and Company Identification. 2. Hazardous Ingredients

Page Number:

MATERIAL SAFETY DATA SHEET

Division of Public Health Administrative Manual

Introduction to Industrial Hygiene for the Safety Professional

/pdf/ Tue Jul 02 08:58: PFLR04S7 MATERIAL SAFETY DATA SHEET

FABULOSO MULTI SPRAY ALL PURPOSE CLEANER LIQUID LAVENDER

Dacarbazine for Injection, USP Dacarbazine Antineoplastic

************************************************************************ *** SECTION 1 PRODUCT IDENTIFICATION

Material Safety Data Sheet Wix Diesel Fuel Additive

Revision Number: Issue date: 12/16/ PRODUCT AND COMPANY IDENTIFICATION 2. HAZARDS IDENTIFICATION

Material Safety Data Sheet

Ingredient CAS Number Weight % ACGIH TLV PEL STEL Phosphoric Acid mg/m3 1 mg/m3 3 mg/m3

Revision Number: Issue date: 07/31/ PRODUCT AND COMPANY IDENTIFICATION. IDH number: HAZARDS IDENTIFICATION

Material Safety Data Sheet

PAY TO PLAY: OSHA ISSUES NEW GUIDANCE ON EMPLOYEE PERSONAL PROTECTIVE EQUIPMENT (PPE) AND EMPLOYER DUTY TO PAY

Hazard Communication/Globally Harmonized System (GHS) Program

Version /29/2006

MATERIAL SAFETY DATA SHEET High Pressure Laminate Fire Retardant

MURPHY OIL SOAP LIQUID - ORIGINAL

Safety Data Sheet SONOLASTIC NP1 CARB WHITE PPK Revision date : 2010/09/07 Page: 1/8

Version: 1.0 Revision Date: 06/25/2013 Print Date: 06/25/2013 POOL TIME D.E. FILTER POWDER

1. IDENTIFICATION 2. HAZARDS IDENTIFICATION. Serious eye damage/eye irritation Category 2. Physical State Liquid

OSHA REGIONAL. Billings, Bismarck, Denver and Englewood Area Offices

Safety Data Sheet InVade Hot Spot Release Date: 5/27/2015 Print Date: 5/28/2015 Version 1.0

AJAX CLEANER POWDER-OXYGEN BLEACH

Material Safety Data Sheet

EMERGENCY PHONE: or (651) (24 hours)

MATERIAL SAFETY DATA SHEET "LIQUID FIRE" DRAIN LINE OPENER 09/2007 PHYSICAL/CHEMICAL CHARACTERISTICS:

A SELF-EVALUATION CHECKLIST of BEST PRACTICES for AUTO REFINISH SHOPS and SCHOOLS

DIRECTIVE NUMBER: (CPL 02) EFFECTIVE DATE: 03/06/2014 ABSTRACT

LEGAL REVIEW & UPDATE

MATERIAL SAFETY DATA SHEET COPPER ALLOYS 101, 102, 103, 104, 110, 122, 151, XP5

MATERIAL SAFETY DATA SHEET 3M(TM) Marine Adhesive Sealant 5200, 5210 Tan; PN 06501, 6501E 08/21/09

INGREDIENTS CAS No. CONTENTS(%) OSHA ACGIH

WHMIS Material Safety Data Sheet Product Information VP-TECH CHEMICAL PRODUCT AND COMPANY IDENTIFICATION. Water Soluble Metalworking Fluid Concentrate

Version 1.4 Print Date 01/14/2008 Revision Date 01/14/2008. Component CAS-No. Weight %

MATERIAL SAFETY DATA SHEET

BBQ Master Hong Kong Limited

Material Safety Data Sheet

SAFETY DATA SHEET FILE NO.: , DRY CIDER VINEGAR SDS DATE: 05/05/15

MATERIAL SAFETY DATA SHEET

TREMPRO 638 SSL GRAY - 15 SSG CS Version 3. Print Date 12/22/2011 REVISION DATE: 12/20/2011

ZEISS Lens Cleaner. SAFETY DATA SHEET OSHA HCS (29 CFR ) - GHS Classification

MATERIAL SAFETY DATA SHEET

Ingredient CAS No Percent Hazardous Aluminum Oxide % Yes

SECTION 2: HAZARDS IDENTIFICATION Classification of the Substance or Mixture Classification (GHS-US) Not classified

Transcription:

Isocyanates National Emphasis Program CPL 03-00-017 Sven J. Rundman III Directorate of Enforcement Programs Office of Health Enforcement

Objectives This presentation will enable attendees to: Know signs/symptoms with routes of exposure to isocyanates. Understand site selection. Understand inspection procedures including various exposure assessments. Understand OSHA enforcement. Know available outreach efforts.

Background OSHA develops National Emphasis Programs to focus inspections and outreach efforts on specific hazards in a workplace. Approved June 20, 2013. by Dr. Michaels, Assistant Secretary for OSHA First intended as an NEP on Asthmagens. Developed to focus OSHA resources on the workplace serious health effects associated with occupational exposure to isocyanates. Combines enforcement and outreach efforts to raise awareness to employers, workers, and safety and health professionals.

Most Commonly Used Methyl isocyanate - MIC Methylene Bis (phenyl isocyanate) MDI Toluene diisocyanate TDI Hexamethylene diisocyanate HDI Naphthalene diisocyanate NDI Methylene bis-cyclohexylisocyanate (HMDI) Isophorone diisocyanate - (IPDI) HDI biuret HDI isocyanurate TDI OCN MDI NCO CH 2

Used in the Formation of Many Polyurethane Products Paint Blown foam insulation Polyurethane foam Insulation materials Surface coatings Car seats Furniture Foam mattresses Under-carpet padding Packaging materials Laminated fabrics Adhesives

Health Effects from Workplace Exposure Occupational asthma Dermatitis Studies indicate that dermal exposure is a significant cause of respiratory sensitization. Irritation of mucus membranes Hypersensitivity pneumonitis Chest tightness Few are classified as potential human carcinogens (e.g., TDI reasonably anticipated by NTP)

Exposure Limits OSHA Permissible Exposure Limits MIC, MDI, TDI Other Occupational Exposure Limits -NIOSH, ACGIH Isocyanate CAS no. OSHA IMIS no. Methyl isocyanate 624-83-9 1773 Methylene bisphenyl isocyanate 101-68-8 1073 Synonyms MIC; Isocyanatomethane 4,4-Diphenylmethane diisocyanate; MDI; 4,4-Diisocyanadiphenyl-methane; Methylene bis(4- phenylisocyanate); Methylene Bis(Phenyl Isocyanate) Vapor Pressure 348 mmhg @ 68 F 0.000005 mmhg @ 77 F Occupational Exposure Limits (OEL) OSHA PEL NIOSH REL 1 ACGIH TLV 2 ppm mg/m 3 ppm mg/m 3 ppm mg/m 3 0.02 T 0.02 C 0.05 T 0.2 C 0.02 T 0.005 T 0.02 C 0.05 T 0.050 T 0.2 C 0.02 T 0.005 T Toluene-2,4- diisocyanate (TDI) 584-84-9 2470 2,4-Diisocyanato-1-0.01 mmhg methylbenzene; TDI; @ 77 F 2,4-TDI; 2,4-Toluene diisocyanate 0.02 C 0.14 C 4 0.005 5 T 0.02 STEL

Program Procedures NEP applies to General Industry, Maritime, and Construction. NEP applies to ALL isocyanates Master targeting list for General Industry and Maritime. Area Offices are required to make three (3) inspections per year. NEP covers a three year period.

Site Selection GI/Maritime Appendix A Primary targeting list compiled using NIOSH HHE evaluations, inspection sampling data (SLTC) known overexposures, and available workers compensation data. SIC SIC Title NAICS NAICS Title 2599 Furniture and Fixtures 3442 Millwork/Metal Window and Door Manufacturing 3792 Travel Trailers and Campers 339950 Sign Manufacturing 332321 Wood or Metal Framed Windows and Door Mfg 336214 Travel Trailer and Camper Mfg Secondary targeting list similar for settings known to use isocyanates but no documented overexposures.

Site Selection - Construction Inspections are made whenever a complaint/referral is received; or a CSHO observes an activity where potential isocyanate exposures are suspected. Where potential exposure exists: Document the status and condition of the work operation

Site Selection An area office has a broad flexible approach to the targeting list, similar to other NEPs. NEP maintains flexibility for an area office to use their judgment in adding sites based on local knowledge where exposure would be anticipated. For example SIC/NAICS 7500 Auto repair If the establishment is not one of the listed establishments but the CSHO has verified that the facility is using Isocyanates, an inspection following the NEP should be initiated.

Inspection Procedures Hazard Communication Check employer s chemical inventory list and SDSs to confirm that the employer is using Isocyanates. Inspection may be discontinued if CSHO can verify no chemicals containing isocyanates used in a process/activity. May need to make site walk-around and/or interview workers Check for adequate training on hazards associated with isocyanates. Review OSHA 300 Injury and Illness logs for potential occupational illnesses due to isocyanate exposure. Check for effective respiratory protection program including fit-testing, medical evaluation, training, and respirator cleaning.

Inspection Procedures Review employer s PPE hazard assessment. Evaluate the effectiveness of PPE during use of isocyanates: Clothing adequate to prevent contamination of employee s personal clothing or skin Eye/Face adequate to protect eyes and face from Isocyanate contact Respiratory Protection - adequate to handle poor warning properties ( e.g. change schedule for APRs) Chemical resistant gloves (e.g. butyl, nitrile) Information on PPE in Appendix G

Inspection Procedures Health Surveillance Form (non-mandatory). Available to CSHO when interviewing worker. Appendix C (non-mandatory) Health Surveillance Form (Non-mandatory) Isocyanate Exposure Interviewer: Date: Worker Name: 1. What was the month and year that you were hired at this company? 2. What is your job title? 3. Please describe your job duties: 4. How many hours per week do you work on average? 5. In what area or areas of the plant do you work? 6. Have there been any recent changes to your immediate work environment or processes in your worksite? YES NO

Inspection Procedures The CSHO will be prepared to take personal air samples on the first day of the inspection. Follow sampling protocol which includes field extraction procedure. Wipe samples may be collected to determine surface, dermal, and/or PPE contamination. Using direct-reading colorimetric wipes.

Exposure assessments Wipe sampling Surface Dermal PPE Expected and unexpected areas

Exposure assessments Expected Work benches Tool handles Cleaning areas Beverages in the workplace

Exposure assessments Unexpected Drinking fountains Door knobs Locker rooms Keyboards Inside PPE

OSHA Enforcement Exposure > PEL No PEL, but > OEL, < PEL, but > OEL, Issue Citation Consider 5(a)(1) violation see FOM, Chapter 4, Section XIII.B.1.e Consider HAL If 5(a)(1) not issued or elements not met If 5(a)(1) not issued or elements not met Reported illnesses/health effects (even if no overexposures have been documented) If serious illnesses/or health effects present and employer recognizes the hazard If 5(a)(1) not issued or elements not met 5(a)(1) elements: (1) The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed; (2) The hazard was recognized; (3) The hazard was causing or was likely to cause death or serious physical harm; and (4) There was a feasible and useful method to correct the hazard.

Outreach Letters to stakeholders Speeches Isocyanates Safety & Health Topics page http://www.osha.gov/sltc/isocyanates/index.html

Appendices Appendix A - Industries Where Isocyanate Exposures are Known or Likely to Occur Appendix B - Isocyanate Sampling, Field Extraction, and Sample Shipment Procedures Appendix C Health Surveillance Form (Non-mandatory) Isocyanate Exposure Appendix D Sample Isocyanates Hazard Alert Letter Appendix E Publications and Resources Appendix F Sample General Duty Clause Citation Language Appendix G General Guidance for Employers on Personal Protective Equipment(including respiratory protection) for Worker Exposures to Isocyanates Appendix H General Guidance for Employers on Medical Surveillance Program Information for Worker Exposure to Isocyanates

Summary Isocyanates causes many health effects including occupational asthma. NEP applies to General Industry, Maritime, and Construction. Targeting list built on NIOSH HHE evaluations, inspection sampling data (SLTC), and available workers compensation data. Exposures can occur in expected and unexpected areas. Employer may be subject to citation if workers exposed above PEL or OEL where documented. Various compliance assistance material available.

Questions? Contact number Office of Health Enforcement 202-693-2190