Considerations for Applications Using Spray Polyurethane Foam Insulation: OSHA Perspective

1
(No Transcript)
2
Considerations for Safe Use of Isocyanates and
Spray Polyurethane Foam (SPF)

• Jim Maddux Acting Deputy Director
• Janet Carter Health Scientist
• Directorate of Standards and Guidance
• Construction Roundtable Meeting
• 19 November 2009

3
Discussion Outline

• Background information
• Concerns with use of Isocyanates and SPF
• Federal Workgroup on SPF
• OSHA Applicable Standards
• Employer responsibilities
• Communications
• Training
• Exposure control and PPE

4
Background Information

• American Resource and Recovery Act (ARRA) of 2009
  is investing billions of dollars to promote green
  jobs energy efficiency
• Use of SPF has increased 60 in the last five
  years
• With widespread use of SPF to retrofit buildings
  to conserve energy, the entire industry needs to
  ensure that SPF installation is carried out in a
  safe manner to protect workers, helpers, building
  occupants, and consumers

5
Effective Green Building Practices

• Green Building Goal- To facilitate the
  mainstream adoption of effective green building
  practices
• Why Spray Polyurethane Foam is valuable
• An important tool to help achieve energy
  efficiency
• Numerous performance attributes
• 3-6x R-value of other insulation
• Vapor barrier
• Moisture barrier (closed cell)
• Structural strengthener (closed cell)
• Fills all gaps and crevices
• Stops air infiltration
• Thermal break
• Reduces noise
• Can be made, in part, from sustainable resources
• (e.g. soy polyols)

6
Advertising and Marketing Claims

• Examples
• No off-gassing, non-toxic, safefoam
• green and environmentally friendly
• is plant-based, Made from soy beans
• Principles of Sound Marketing
• FTC Act / FTC Green Guides
• Substantiate Green claims
• Deception occurs when there is a representation,
  omission or practice that is likely to mislead
  the consumer

7
Types of SPF Insulation/Sealants

• Two-Component gt over 80 million lbs. sold in a
  year
• - Professional 55 gal. drums
• - Do-It-Yourself large quantities also
• Retail, hardware, internet purchase
• One Component gt Over 50 mil. lbs. sold in a
  year (or over 60 mil. cans) fills, seals, and
  insulates gaps
• - Consumer
• 12 oz. can (market leader) also 16 oz., 20 oz.
• Plastic straw applicator included
• - Professional Do-It-Yourself
• 20 oz., 24 oz., 26 oz., 30 oz., 33 oz.
• Typically gun delivery or applicator tool for
  precise control, sold separately
• Data Courtesy CPI

8

• Industries where Isocyanate exposures occur
• Automotive - paints, glues, insulation, sealants
  and fiber bonding, truck bed lining
• Casting - foundry cores
• Building and construction - in sealants, glues,
  insulation material, fillers
• Electricity and electronics - in cable
  insulation, PUR coated circuit boards
• Mechanical engineering - insulation material
• Paints lacquers
• Plastics - soft and hard plastics, plastic foam
  and cellular plastic
• Printing inks and lacquers
• Timber and furniture - adhesive, lacquers,
  upholstery stuffing and fabric
• Textile synthetic textile fibers
• Medical care PUR casts
• Mining sealants and insulating materials
• Food industry packaging materials and lacquers

(List taken from International . Consensus Report
on Isocyanates, 2001)
9
Common Isocyanate Monomers
10
OSHA Concerns use of Isocyanates and SPF

• Isocyanates have been reported to be the leading
  attributable chemical cause of work-related
  asthma (WRA)
• Causal-link for developing occupational asthma
• Exacerbates existing asthma conditions
• Other health effects attributed to isocyanate
  exposure
• SPF contains Isocyanates
• Hazard information not reaching all users across
  the entire value chain
• Inconsistent worker protection

11
The Federal SPF Workgroup

• EPA
• OSHA
• NIOSH
• CPSC
• FTC

12
The Industry Workgroup

• American Chemistry Council (ACC) Center For
  Polyurethane Industries (CPI)
• Spray Polyurethane Foam Alliance (SPFA)

13
OSHA Responsibilities
14
OSHA Applicable Standards

• 3 PELS for isocyanates
• 29 CFR 1910 subpart Z (Air contaminants)
• General duty clause

15
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)

16
Employer Responsibilities

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

17
Hazard Communication

• Communicate all hazards via
• MSDS
• Labeling of all hazardous substances
• Warning signs of hazards
• Employee training

18
Hazard Communication - MSDS

• Material Safety Data Sheets
• Integral part of communication strategy
• Must be readily available to all affected workers
• Must be comprehensive

19
Hazard Communication - MSDS

• MSDS should contain the following
• 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 (if
  applicable)

20
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

21
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

22
Training

• Training should be available to all appropriate
  workers
• Training material is available on web
• OSHA
• NIOSH
• ACC/Polyurethane Industry

23
Exposures Spray Application

• Vapor, mist, particulates (isocyanates, amines)
  can migrate to other rooms or floors

24
Exposures Trimming Foam

• Cutting, scraping foam that is not fully cured
  generates dust that may contain isocyanates

25
Other Considerations

• Long term stability of polyurethane foam
• Fully cured polyurethane foam is not considered a
  problem unless disturbed
• Heating, welding, or grinding generates free
  isocyanates and other hazards
• Fires and thermal degradation can generate and
  release hydrogen cyanide, carbon monoxide,
  amines, and isocyanates

26
Evidence of Isocyanate Exposures in Adjacent Areas

• Information from Bayer
• Isocyanate vapors drifted throughout building
  after application of SPF w/i 20 minutes
• Mostly lower floors
• Exposure levels above the PEL in adjacent areas
• More than 20 feet away from applicator
• Also found in truck trailer

27
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

28
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

29
Appropriate Exposure Control - Proper Use of PPE

• Primary worker (spray applicator)
• Full saran-coated body cover (no exposed skin)
• Gloves, over-boots
• 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

30
Appropriate Exposure Control - Ventilation
Considerations

• Ventilation crucial for worker safety
• Only vent to outside using approved filter
• Protect workers or passers-by outside
• Similar methods can be adapted from measures used
  in truck bed-liner industry

31
Controls used at SPF sites
Use air movers to exchange air in the spray
zone - Reduce airborne chemical concentrations -
Air supply and exhaust needed - Exhaust to
unoccupied location
32
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

33
Additional Information

• December 2nd Webinar
• What You Need to Know About the Safe Use of Spray
  Polyurethane Foam
• visit https//www1.gotomeeting.com/register/800171
  944

34
(No Transcript)