On June 25, OSHA announced a new National Emphasis program on isocyanate exposure. OSHA will focus on workplaces that use isocyanate compounds in an effort to prevent work related illnesses such as occupational asthma, irritation of the skin, eyes, nose and throat, and cancer.
Isocyanates are used in materials including paints, varnishes, auto body repair, and building insulation. Industries with exposure to isocyanates include spray-on polyurethane manufacturing, products such as mattresses and car seats and protective coatings for truck beds, boats, and decks.
How Facilities Will Be Targeted for Inspection
Industries listed in Appendix A of the compliance directive can be targeted because over-exposures to isocyanates are known to occur and exposures have been demonstrated to exceed OSHA permissible exposure limits (PELs) or other occupational exposure limits (OELs) where PELs are not in place. General industry, maritime and construction industries are included in the NEP and there is no exclusion for employers with less than 10 employees.
OSHA inspection procedure will include:
- Review of OSHA logs to determine if cases of occupational asthma or other occupational illnesses related to isocyanate exposure have been recorded.
- Review of worker medical records and interview with affected employees if evidence of occupational illness exists.
- Exposure assessments including air sampling, dermal sampling, PPE sampling and other surface sampling.
- Review of PPE assessment and evaluation of PPE selected.
- Review of hazard communication program in place at the establishment.
- Review of housekeeping practices at the facility.
- Review of requirements for flammable and combustible products in place at the facility.
OSHA will issue citations under the following conditions according to the compliance directive:
- If sampling reveals that employees are exposed to isocyanates above PELs (in cases where PELs are set)
- Citations under the general duty clause will be considered when employee exposures are above other OELs when PELs are not set, or if employees are experiencing serious health effects. OSHA may also issue a Hazard Alert Letter instead of issuing general duty citations in some cases.
- Citations may be issued for violations of PPE standards, the revised Hazard Communication standard, flammable and combustible liquid and spray finishing standards.
- If poor housekeeping practices are observed, housekeeping violations can be issued.
- As always, the concept of open and obvious will apply, so any other observed serious violation will likely be cited as well.
If your facility uses isocyanates, we urge you to review the new NEP.