Jim Maddux – Acting Deputy Director Janet Carter – Health Scientist Directorate of Standards and Guidance Construction

2. Jim Maddux – Acting Deputy Director Janet Carter – Health Scientist Directorate of Standards and Guidance Construction Roundtable Meeting 19 November 2009 Considerations for Safe Use of Isocyanates and Spray Polyurethane Foam (SPF)

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 INTERIOR WALLS courtesy Icynene

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”, “safe”…foam • “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: > over 80 million lbs. sold in a year* • - Professional – 55 gal. drums • - Do-It-Yourself – large quantities also • Retail, hardware, internet purchase • One Component: > 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/800171944