OSHA Issues National Emphasis Program on Occupational Exposure to Isocyanates

Until recently, research on exposures to diisocyanates has focused on occupational exposures. However, there is growing evidence that exposures to diisocyanates may also be occurring to other populations, including homeowners, school occupants, residents living near plants where isocyanates are being manufactured, DIYers, workers not covered by OSHA regulations, and many others. Many of the incidences of non-occupational exposures reported in the literature thus far have been anecdotal; however, they indicate the importance of collecting exposure data and focusing research on potential consumer exposures, especially since they pose many questions that cannot be answered by data collected in occupational settings.

 By James L. Curtis and Craig B. Simonsen – Seyfarth & Shaw

OSHA has just released a new Instruction for its Field Operations Manual that describes policies and procedures for implementing a National Emphasis Program to identify and reduce or eliminate the incidence of adverse health effects associated with occupational exposure to isocyanates.

The Instruction, (Download PDF Here:) National Emphasis Program – Occupational Exposure to Isocyanates, CPL 03-00-017, is intended to combine “enforcement and outreach efforts to raise awareness of employers, workers, and safety and health professionals” of the health effects associated with occupational exposure to isocyanates. According to OSHA, “workers in a wide range of industries and occupations are exposed to at least one of the numerous isocyanates known to be associated with work-related asthma.”

Isocyanates: Do You Have Work-Related Asthma? A Guide for You and Your Doctor [417 KB PDF^*, 2 pages]. OSHA Fact Sheet (OSHA FS-3707), (2014).

Employers that are now under scrutiny by this new National Emphasis Program include:

• Manufactures and handlers of polyurethane products, including polyurethane foam, insulation materials, surface coatings, car seats, furniture, foam mattresses, under-carpet padding, packaging materials, shoes, laminated fabrics, polyurethane rubber, and adhesives.

The Instruction provides a “site selection system” that targets multiple industries and will focus on evaluating inhalation, dermal, and other routes of occupational exposure to isocyanates. Appendix A provides the following industry list “where isocyanate exposures are known or likely to occur.”

Appendix A

Industries Where Isocyanate Exposures are Known or Likely Occur

Automotive – paints, glues, insulation, sealant and fiber bonding, truck bed lining Casting – foundry cores Building and construction – sealants, glues, insulation material, fillers Electricity and electronics – 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 – adhesives, lacquers, upholstery stuffing and fabric Textiles – synthetic textile fibers Medical care – PUR casts Mining – sealants and insulating materials Food industry – packaging materials and lacquers

Employers in these industry groups should look carefully at their current policies, procedures, and training programs to ensure compliance — or put themselves at risk of an OSHA citation.

OSHA Isocyanates Information & Regulation Page: https://www.osha.gov/SLTC/isocyanates/

Source: Seyfarth & Shaw