OSHA Safety and Health Regulations Related to SPF Applications Module Two: Hazard Communication

1. OSHA Safety and Health Regulations Related to SPF Applications Module Two: Hazard Communication

2. This material was produced under grant number SH210031060F12 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.

3. Chapter 2: Chemicals • Hazard Communication • Chemical Labeling • MSDS (Material Safety Data Sheets) • Health Concerns • Storage • Shipping • Disposal • Spills

4. Hazard Communication • Ensure that the hazards of all chemicals produced or imported are evaluated, • Information concerning their hazards is transmitted to employers and employees. • Comprehensive hazard communication programs, which are to include: • Container labeling • Material Safety Data Sheets • Employee training.

5. Main Chemicals Used in SPF Applications • SPF Chemicals • A side (polymeric diisocyanate) • B side (polyol resin) • Solvents • DPM (dipropylene glycol monomethyl ether) (used as gun cleaner) • Mineral Spirits (used in silicone coatings) • Xylene/toluene (used in polyurethane coatings) • MEK (methyl ethyl ketone, used in polyurethane coatings)

6. Material Safety Data Sheets (MSDS) • MSDS Required by OSHA (29 CFR 1910.1200) for each chemical used • Includes name of chemicals, physical hazards, health hazards, exposure routes, permissible exposure levels (PEL), appropriate PPE, handling, storage, spills, transportation, disposal information • Must be readily accessible to all employees in the work area

7. Hazardous Material Identification System (HMIS) • Uses scale of 0 to 4 (0 is lowest hazard; 4 is the highest • Categories rated: • Health (blue rectangle) • Flammability (red rectangle) • Reactivity (yellow rectangle)

9. NFPA Labeling System • Uses scale of 0 to 4 • 0 is lowest hazard; 4 the highest • Left diamond: Health • Top diamond: Fire • Right diamond: Reactivity • Bottom: Special/specific hazards

10. Environmental Reporting • Title III of SARA - known as EPCRA • SARA – Superfund Amendments and Reauthorization Act • EPCRA – Emergency Planning and Community Right-to-know

11. EPCRA Requirements • Section 311 requires MSDS for any hazardous chemical on site in quantity > 10,000 lbs. go to: • Local fire department • LEPC (Local Emergency Planning Committee) • SERC (State Emergency Response Commission

12. EPCRA Requirements • Reporting requirement must be met within 90 days of any new chemical being on-site at or above the threshold quantity. • For extremely hazardous chemicals, threshold quantity is 500 lbs.

13. Penalties • Up to $25,000 per day • Criminal penalties and jail time for willful violations

14. Environmental Reporting • EPCRA uses OSHA HAZCOM standard definitions of hazardous chemicals. • Diisocyanates are deemed hazardous.

15. SPF Chemicals A-side, Diisocyanates (Polymeric MDI) B-Side, Polyol Resins w/ additives

16. Transporting SPF Chemicals • B-Side Components unregulated • A-Side Components (PMDI) require hazardous material regulations if transporting 10,000 lbs or more of bulk liquid • NOTE: Other hazardous materials may have different threshold quantities beginning at 100 lbs.

17. Transporting More Than 10,000 lbs of Bulk PMDI (Tank Trucks) • Tank Truck designed to specifically carry MDI • Record keeping mandatory for all shipments • Hazardous placards on truck • OSHA safety training for drivers (CFR 49.383) • Commercial drivers license for all drivers

18. A-Side Methylene Diphenyl Diisocyanate (MDI) • MDI is classified as “hazardous” for shipping & storage purposes • Reacts with Water • Persons can be sensitized by inhaling vapors or by skin contact • OSHA PEL .02 ppm • ACGIH TLV-TWA 0.005 ppm • Requires PPE specific to job task • Empty containers require special handling for disposal

19. A-Side Main Health Hazards • Over exposure can cause • sensitization • coughing; • chest-tightness/discomfort; • shortness of breath; and • reduced lung function • Respiratory sensitization can result from: • One massive overexposure • Repeated exposure to airborne concentrations above the exposure limit

20. A-Side Main Health Hazards Skin exposure can cause skin irritation Skin exposure may also cause lung sensitization Eye contact can cause tearing and burning

21. A-Side HMIS

22. B-Side Polyol Resin • Not labeled hazardous for shipping and storage • Consists of 5 main ingredients: • Polyether and polyester resin • Fire retardents • Catalysts • Blowing agents • Surfactants

23. B-Side Main Health Concerns • Inhalation overexposure may cause respiratory irritation • Skin or eye contact may cause irritation at the site • Foggy / halovision known as “blue haze” or “halovision.” (Vision restored within a few hours after exposure ceases) • Amine catalysts associated with fishy odor • Neither OSHA nor ACGIH has established exposure limits for polyols

24. Solvents • Most are classified as “hazardous” for shipping and storage purposes • Most are classified flammable (red label) • Types of Solvents typically used • DPM (dipropylene glycol monomethyl ether) (gun cleaner) • MEK (methyl ethyl ketone) (Polyurethane coatings) • Mineral spirits (silicone coatings) • Toluene/xylene (polyurethane coatings)

25. Solvent Main Health Hazards (Can vary depending on solvent) • Route of exposure • Inhalation • Skin contact or absorption • Health hazards • Irritation of eyes, nose and throat • Chemical pneumonia • Dizziness • Nausea • Severe skin irritation • Liver, kidney damage, etc

26. Waste & Disposal Containers • Three Options for Empty A-Side Containers • 1. A container reconditioner • 2. A scrap metal dealer • 3. An approved landfill

27. Waste and Disposal Containers • Decontamination can prevent exposure to residual MDI in containers destined for a scrap dealer or landfill • Empty MDI containers can be decontaminated by filling them with water or decontamination solution (5-10% sodium carbonate) and allowing them to stand, unsealed for at least 48 hours • Decontamination solutions and rinse water should be disposed of properly according to federal, state and local laws and regulations

28. Empty A-Side Containers • Should not be used to store other materials • Storing other materials in containers that previously held MDI could lead to a chemical reaction and potential worker safety issues • NO cutting or hot torches to cut used MDI containers • Punctured or crushed containers prevent reuse

29. Hazardous Waste & Disposal • EPA defines hazardous waste in 40 CFR Part 261 • 3 classes of hazardous waste generators: • Large Quantity Generators (LQG) – unlimited quantities • Small Quantity Generators (SQG) – 100 to 1000 kilos/month • Conditionally Exempt Small Quantity Generators (CESQG) – less than 100 kilos/month • Most SPF contractors would be considered small quantity generators

30. Hazardous Waste Generated by Sprayfoam Operations • A-side (PMDI) • Solvents • Coatings with solvents

31. Waste & Disposal Hazardous Liquid Wastes • Disposal of hazardous wastes • Ship to a permitted hazardous waste treatment, storage or disposal facility (TSDF) • Containers marked clearly as “hazardous” • Containers accompanied with a hazardous waste manifest

32. Disposal of Waste A-Side Components • Excess A-side and B-side components may be reacted to form a non-hazardous solids that may be disposed as regular trash. • (check with disposal facility before using this option) • SUGGESTION: • Mix in small amounts to minimize a possibility of the mixture producing excessive exothermic heat (possible spontaneous combustion)

33. Handling Spills • Transport containers outdoors and treat with neutralizing solutions • Waste MDI may be neutralized by reacting the product with water or caustic solution • NOTE:MDI can react with water, resealing a diisocyanate container when it has become contaminated with moisture could cause the container to swell and potentially rupture.

34. Handling Spills (cont.) • Contain spill with sand, wet earth or absorbent clays (e.g., vermiculite, Oil-Dri or kieselguhr • Spill workers to use appropriate PPE • Barricade spill area from public or unprotected workers • Add neutralizer to the absorbent materials and safely transfer materials into an open top container • Dispose of materials in accordance with local, state and federal regulations

35. Websites for Additional Information OSHA General Industry 1910 http://osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1910 OSHA Construction 1926 http://osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=Construction EPA links to information on permits, storage, disposal, recycling, and identification of hazardous materials www.epa.gov/epaoswer/osw EPA links to hazardous waste and RCRA information within EPA www.epa.gov/estpages/wasthazardouswaste.html Center for the Polyurethane Industry (CPI) Product Stewardship Literature http://polyurethane.org/s_api/sec.asp?CID=885&DID=3561