Spray Foam Event 2013, Session A Presentations Contents List
1. Introduction to Spray Polyurethane Foam (Click to go to PDF Page 2)
2. OSHA’s Isocyanates National Emphasis Program (Click to go to PDF Page 58)
3. EOLWD On-site Consultation Program (Click to go to PDF Page 76)
4. Essential Resources and Training, American Chemistry Council (Click to go to PDF Page 109)
5. Safe Spray Foam (Click to go to PDF Page 126)
6. EPA Safe Use of Polyurethane Products (Click to go to PDF Page 137) Return to Contents List Introduction to Spray Polyurethane Foam
This presentation will provide important background information on SPF, including history, product categories and delivery methods and applications. It will also address chemical concerns and include tips for a quality installation, and briefly cover environmental impacts of the product COPYRIGHTED MATERIALS
This presentation is protected by US and International copyright laws. Reproduction, distribution, display and use of any part of this presentation without written permission of the speaker is prohibited.
© 2013 Spray Polyurethane Foam Alliance Presentation Content
1. History 2. Product Categories 3. Basic Chemistry 4. Delivery Methods 5. Chemical Concerns 6. Environmental Impact 7. Quality Installation 8. Summary History of SPF in Buildings in construction for 50 years
• Late 60’s ‐ Medium Density (agricultural and industrial) • Mid 70’s ‐Roofing ‐ Medium Density (general const.) ‐ Sealants • Mid 90’s ‐ Low Density (residential) Product Category Four general categories of SPF
Spray Foam Category Sealant LD MD Roof
Density (lb/ft3)0.6 –1.8 0.5 ‐ 1.4 1.5 ‐2.3 2.5 ‐ 3.5 Thermal Resistivity (R/in) NR 3.6 ‐ 4.5 6.2 ‐ 6.8 6.2 ‐ 6.8 Air Impermeable Material * > 3.5” > 1.0” > 1.0” Integral Air Barrier System Integral Vapor Retarder Water Resistant Cavity Insulation Continuous Insulation Roofing Structural Improvement
Product selection is application and climate dependent SPF in Residential Buildings Low‐density and Medium‐density Insulation
EXPOSED UNVENTED DUCTWORK INTERIOR ATTICS CATHEDRALIZED WALLS CEILINGS ATTIC FLOORS
DOORS WINDOWS BAND JOISTS AND SILL PLATE
EXTERIOR WALLS FLOORS UNVENTED CRAWLSPACES BELOW GRADE WALLS GARAGE BASEMENT CEILINGS BELOW SLAB WALLS FLOOR SPF in Commercial Buildings
LOW‐SLOPE DOMED ROOFS ROOFS
EXTERIOR METAL WALLS BUILDINGS
INTERIOR FRAME WALLS WALLS Other Applications
TEMPORARY TANKS AND STRUCTURES VESSELS Basic Chemistry Reaction of 1:1 mixing of two liquids
• A‐Side: Blend of monomeric and polymeric MDI (Methylene diphenyl diisocyanate) • B‐Side or Polyol – polyols – blowing agents Proprietary blend of additives affect – flame retardants cell formation and foam performance – surfactants – catalysts Basic Chemistry B-Side Formulation:
• These are the five basic categories of B‐side chemicals.
• Percentages will vary based on foam type (oc vs cc) and manufacturer.
• Some foam formulations contain small amounts of additional additives for appearance and added function, such as colorants and anti‐microbial chemicals. Basic Chemistry Open and Closed Cell Foam Differences
OPEN CELL (ocSPF) CLOSED CELL (ccSPF) • ~100x expansion • ~30x expansion • 0.5 to 0.8 lb/ft3 (soft) • 1.7‐3.5 lb/ft3 (rigid) • R‐3.6 to R‐4.5 per inch (air) • R‐5.8 to R‐6.8 per inch (low‐k gas) • Moisture permeable • Moisture semi‐impermeable Delivery Methods One-Component Low-Pressure Sealants
• 6‐15 BF/min froth • A and B pre‐mixed; cured by contact with ambient moisture • Low/high expansion • Air‐sealing of small cracks, gaps and holes • Non‐insulating
Retail DIY product for air sealing only Delivery Methods Two-Component Low-Pressure Foam
• 30‐40 BF/minute froth • A and B in separate pressurized cylinders • Mechanical mixing • Insulation and air sealing ‐ small jobs
Professionally applied product used by weatherization contractors and by SPF contractors for small jobs or repair work Delivery Methods Two-Component High-Pressure SPF
• 100‐500 BF/minute spray • A and B in unpressurized drums or totes • Chemicals heated and pressurized by proportioner • Larger insulation jobs and all roofing applications • Special training and capital investment
Professionally applied insulation and roofing SPF installed by trained contractors large jobs Chemical Concerns Known SPF Chemical Hazards
Known Published Exposure Chemical Effect Exposure Likely Exposure Hazard [1] Limits [3] Short‐Term eye and throat irritation and dermatitis choking, shortness of breath, tightness of chest Airborne during and just after dizziness and headaches high‐pressure SPF application. Dermal and Respiratory TLV ≥ 0.02 ppm A‐SIDE MDI YES abdominal pain; nausea and vomiting Users can be exposed by liquid (odorless) (OSHA) Long‐Term chemical contact with skin (high Some people can become sensitized where and low pressure SPF) repeated exposures at low levels can cause symptoms above as well as asthma‐like symptoms Polyols NO Cardiac arrhythmia (irregularheartbeat) is a Fluorocarbon Airborne during and just after NO symptom of overexposureto certain blowing Respiratory Blowing Agent high‐pressure SPF application. agents Short Term Airborne during and just after B‐SIDE Irritation fo the eyes, skin and respiratory system Dermal and Respiratory See note [2] high‐pressure SPF application. Amine Cataysts YES [2] Reversible glaucopsia (blue haze or halo‐vision) (Fishy Odor) Improper application can result in excess airborne catalyst NO Some concern about exotoxicity and CMR at high Flame Retardants exposure levels Silcone Surfactants NO
[1] ond levels an specific chemicals used in SPF [2] Based on 9/2012 report for CPSC from Versar, Inc, one of the five aminie catalysts has published exposurelimits. [3] exposure definitions TLV threshold limit value STEL short‐term exposurelimits TWA 8‐hour time weighted average Chemical Concerns Summary
• MDI –Known Chemical Sensitizer • Polyols – no known issues • Blowing Agents (closed‐cell) –ODP and GWP • Amine Catalysts –Odor Source, Irritant • Flame Retardants – unconfirmed CMR‐PBT concerns by some • Silicone Surfactants –no known issues Chemical Concerns Exposure to SPF Chemicals
• Consider each phase of the product life‐cycle • Raw Material Extraction • Raw Material Processing • Manufacturing and Blending • Packaging • Transportation • Installation • Use • Disposal and Recycling
Exposures can be mitigated by good chemical safety practices at each phase Chemical Concerns Minimizing Exposure During Installation
Engineering Controls Containment • Isolate work zone • Plastic curtains • Cover vent openings • Shut down HVAC system Ventilation • Use one exhaust or one exhaust + one supply • negative pressure in work zone (exhaust > supply) • Cross‐ventilation near applicator • 40‐50 ACH rate (?)
Keep non‐essential personnel outside of contained work zone http://www.epa.gov/dfe/pubs/projects/spf/ventilation-guidance.html Chemical Concerns Minimizing Exposure During Installation
Personal Protective Equipment Respiratory Protection • SAR or APR Skin Protection • Cover all exposed skin
For complete information on SPF Chemical Safety, visit www.spraypolyurethane.com Chemical Concerns Exposure During Occupancy
• No significant VOC emissions from SPF (ULe‐GreenGuard)* • No known chemical hazards from dust* • Safe MDI levels within several hours by natural decomposition and forced ventilation just after installation* • Residual SPF chemicals may be present (catalysts, BA, FR) and may require extended ventilation • Exposure test methods and studies for specific foam chemicals currently in progress • Residual chemicals most likely caused by incomplete reaction from improperly installed SPF • Always follow re‐occupancy guidelines • Experienced, trained applicators are a must
Occupant exposure to SPF chemicals can occur if SPF is not properly installed *when properly installed Environmental Impact Life‐Cycle Assessment
• ISO‐Compliant Life‐Cycle Assessment (LCA) • Industry‐Level LCA completed November 2012 by SPFA using third‐party consultant –ISO compliant • Environmental Product Declaration (EPD) completed November 2013 by UL Environment following Insulation Product Category Rules (PCR): http://productguide.ulenvironment.com/SearchResults.aspx?includeWords=spfa • Includes ‘Cradle‐to‐Grave’ Analysis
SCOPE IMPACT
• Raw Material Extraction • Global Warming Potential (GWP) • Raw Material Processing • Eutrophication Potential (EP) • Manufacturing and Blending • Acidification Potential (AP) • Packaging • Photochemical Ozone Creation • Transportation Potential (POCP) • Installation • Ozone Depletion Potential (ODP) • Use • Primary Energy Demand (PED) Positive environmental impact achieved • Disposal and Recycling a few within months of use Quality Installation Factors that Affect Installation Quality
Ambient Conditions: Substrate: • Temperature • Air Temperature • Moisture content • Relative Humidity • Cleanliness Application Technique: • Maximum Thickness • Geometry
Materials and Equipment: • Chemical Storage • Temperature setting • Pressure setting Gun: • Cleanliness • Impingement Mixing • Tip Selection
SPF products are formulated to accommodate a wide range of installation variables. Experienced and trained applicators know how to manage them. Quality Installation What the Customer Can Do
• Select Proven SPF Chemicals • Know the brand and type of products being installed • Get copies of product data sheets, MII, MSDS from supplier or distributor • Confirm foam supplier provides training and technical support • Follow Manufacturer’s Installation Instructions (MII) • Ask for a copy of the MII • Include MII as part of contract
Use SPF materials from a reputable source, whose products are documented and well‐ supported Quality Installation What the Customer Can Do
• Hire Trained, Experienced Applicators • Assure one experienced applicator is on jobsite at all times • Applicator should have experience using the product installed as well as the equipment used • Reputable suppliers and distributors offer training. Confirm applicator has been properly trained • Request that applicator is enrolled in a SPF accreditation or certification program (e.g., SPFA Certification)
Hire SPF contractors with trained and experienced installers SPFA Professional Certification Program Overview Mass. State SPF Workshop 11 December 2013 Stow, Mass. About SPFA
• About SPFA. The Spray Polyurethane Foam Alliance (SPFA) is the premiere organization representing contractors, manufacturers, and the complete value chain of SPF on safety, technical, educational, advocacy, promotional and other issues. SPFA is a 501(c)6 membership‐based technical trade association comprised of the leading SPF companies in the United States and abroad. SPFA offers superior new professional certification opportunities to the industry’s installers and contractors. SPFA delivers an annual convention and expo serving SPF professionals, maintains a variety of technical programs, utilizes its exceptional partnerships in industry to deliver various services for its members, and provides a unified voice for SPF on insulation, roofing and other installations. SPFA PCP Program Objectives
• To provide an established set of criteria through which individuals and companies can demonstrate their commitment to professionalism in the spray polyurethane foam industry.
• To identify and recognize those individuals and companies whom, by fulfilling prescribed requirements of education, examination and experience, meet a high standard of professionalism.
• To encourage individuals and companies to support the professional development of their industry by taking personal responsibility for the value of their work through education and testing. SPFA PCP Vision & Mission
Vision
• That the SPFA QAP professional certification is the most rigorous, extensive and defining program for SPF professionals in the world. That it be consistent with all industry standards, best practices and known building science, and accessible and affordable among our intended constituency. That it be the measure of personal and professional accomplishment in the industry, and a demonstration among professionals of the essential knowledge, skills and abilities inherent among the highest class of sprayfoam professional.
Mission
• To deliver and operate a focused, consistent and attentive, world‐class professional sprayfoam certification program. Continuously raising, establishing, and raising again the bar on safety, performance, quality and professionalism among SPF industry professionals. For the benefit of their businesses, personal safety, safety and satisfaction among customers, and to create the most solid of foundations for future growth, personal and industry distinction. SPFA PCP
• Establishes Clear Path to Professionalism • Establishes Expectations – Industry of Its Own People – Among Customers – Among Partners (Arch / Design Build / GC / Etc) • Standards‐Driven (ANSI/ISO 17024) • Uniform and Consistent Measures • Consequences for Failure (Enforcement) • Regular Continuing Education Required for Recertification • Provides Further Market Differentiator for Company and Individuals • Heavy Focus Upon H+S Throughout Basis & Origins
Observations
• High performance industry and product, requires high performance field installation • Exceptional SPF benefits and performance are impacted by quality of installation • Paramount importance of Health & Safety for installation crews, adjacent trades, customer • SPF goes on easy, comes off hard. Must be right. • Changes behavior of the building it is in, building science implications Basis & Origins Observations
• Transportation and proper handling, including installation, of chemicals used in SPF require specialized KSAs • SPFA historically maintained “Accreditation” program. Updated to “Certification” based upon decades of experience and lessons • OSHA National Emphasis Program (NEP) highlighted need for proper training and proficiency • Four years of close work with Federal Interagency Task Force on SPF (EPA, OSHA, NIOSH, CPSC, FTC) • Customers, especially professional customers (builders, architects, designers, general contractors, etc) desire a level of comfort with, and verifiable credibility among, their professional SPF sub‐ contractors PCP Development
• ISO 17024 Compliant • Operated under a 17024‐Accredited Provider (BP) • Process – Thorough Job Task Analysis (JTA) – Establish Knowledge, Skills, Abilities (KSAs) – Translated to Learning Objectives • Committees Firewalled – Quality Assurance Program Committee – Certification Scheme Committee – Training Committee • Roofing AND Insulation Tracks PCP Development
• Contractor –led • Value chain direct involvement (Mfg | Contractors | Distributors) • Ability to “test‐out” of each level to accommodate long‐time industry professionals • Lower level completion requirement to move to higher levels • Multiple certification levels accommodating various field positions • Accessible, Affordable, Standards‐Driven • Wallet Cards + Mark Issued After Completion • Annual renewal | 5 Year Recertification • Developing CEU Requirements & Framework Levels & Requirements of PCP Certification
Assistant | Installer | Master Installer | Project Manager PCP ‐ Handbook
• Ref Handbook @ www.sprayfoam.org • Contains process, requirements, enrollment packages, etc. • Checklists demonstrate compounding Knowledge, Skills & Abilities (KSAs) Assistant KSA / LOs Introduction to Spray Polyurethane Foam Task A.1 History of Spray Polyurethane Foam Task A.2 What is Spray Polyurethane Foam? A‐Iso / B‐‐Resin Task A.3 Types of SPF and Cell Content Open / Closed Cell, Low / Med / High Density Task A.4 Physical Properties Compressive Strength Task A.5 Reaction, Time Factors and Ratio Chemistry of Materials & Reaction Health and Safety ‐ Chemicals Task B.1 Potential for Chemical Exposure Inhalation / Sensitization Task B.2 Hazard Communications (HMIS) Labeling / MSDS / Training Task B.3 Engineering Control/Site Isolation Ventilation / Re‐Occupancy / Signage Task B.4 Work Practices Chemical Storage / Handling / Clean Up / Spills / Disposal Task B.5 Personal Protective Equipment (PPE) Hand / Eyes / Skin / Respiratory Health and Safety ‐ General Task C.1 Reasons for Practicing Safety Task C.2 Understanding OSHA and Requirements Task C.3 Written Safety Management Program Jobsite Safety Task D.1 Electrical Hazards Task D.2 Hand and Power Tools Task D.3 Pressurized Equipment/Air Compressor Task D.4 Lock Out/Tag Out Task D.5 Confined Spaces Task D.6 Elevated Work Surfaces Fall Protection / Ladders / Scaffold / Lifts Task D.7 Fork Lifts and Cranes Task D.8 Lifting Task D.9 Vehicle and Transportation Safety (DOT) Task D.10 Fire Protection and Safety Task D.11 Occupational Noise Task D.12 Temperatures (Heat Stress) Task D.13 Slips and Trips Task D.14 Personal Protective Equipment (PPE) (Non‐Chemical) Task D.15 Lighting Assistant Checklist Installer KSA / LOs
Pre‐Job Planning Task E.1 Pre‐ Job Logistics Task E.2 Safety Requirements –In the Pre‐Planning Stage Task E.3 Truck Loading/Equipment Check Jobsite Set‐Up Procedures Task F.1 Jobsite Arrival Task F.2 Set‐Up Task F.3 Safety Procedures During Job‐Site Set‐Up Substrate Preparation Task G.1 Preparation for Different Substrates Task G.2 Priming Task G.3 Masking Overspray Control Start‐Up Procedures Task H.1 Verify Conditions Before Spray Start‐Up Task H.2 Equipment/Material Start‐up Task H.3 Site Secure and Safe For Start‐up Task H.4 Spray Start‐Up Installation Methodology Task I.1 Equipment Set‐Up Task I.2 Application QC Check Thickness / Cell Structure / Mix / Gaps / Voids Task I.3 Spray Techniques Pattern / Distance / Picture Framing Task I.4 Communication with Assistant Task I.5. Restaging and job progression Task I.6 Ensuring continuous material supply Task I.7 Spraying Breaks Task I.8 Trimming Tools Task I.9 Heat Break Requirements. Shut Down and Job End Procedures Task J.1 Sort Term Shut Down Task J.2. End of Day Shut Down Task J.3 End of Job Shut Down Task J.4 Air Management Continued Ventilation / Re‐Occupancy Task J.5 Trimming and Unmasking Task J.6 Close Out Communication Insulation Certificate / Checklist Installer Checklist PCP – Field Examiner
• Separate training and certification test • Only PCP program where training is REQUIRED • Trained in documentation, field examinations – Field exams ONLY for use within the context of SPFA PCP – Not commercial or public service • Field Exam performance requirements available in Field Examiner Handbook PCP Deployment
• March 2012 – Announcement & Scoping Sessions • Oct 2012 – Federal Interagency Task Force on SPF review & comment • November 2012 – 1st Pilot Session • January 2013 – 2nd Pilot Session • February 2013 – Program Roll‐Out @ SPFA Annual Convention • November 2013 – SPFA 1000th Test Milestone PCP Deployment
• Administration & ISO Compliance – Building Professionals • Manufacturers incorporate into training, drive to test • Training & Certification of Field Examiners • Training of ISO‐compliant “Written Examiners” (proctors) • Spanish test translation complete (Assistant Master) • Online training and testing in‐process (ISO‐compliant) Current Status ‐ PCP
• Over 1000 Exams Completed YTD • Several manufacturers and distributors have endorsed PCP • Center for the Polyurethanes Industry (CPI) Sprayfoam Coalition endorses PCP 2013 • Several states already considering acknowledgement of PCP certifications • Developing model CSI spec for SPF including references to SPFA PCP Current Status ‐ Adoption
• Example: Gaco Western announces May 2013 that all installers will be SPFA PCP certified by January 2015 Current Status ‐ Adoption
• Example: Sprayfoam Nation offers PCP training and testing • Offers tests every Friday July –Sept. 2013 Current Status –States (CT)
• 5908 | June 2013 Veto Current Status –States (MA)
• Working to develop 4 state organized workshops on SPF & Certification for 2013 ‐ 2014 Current Status –States (LA)
• SPFA was requested to meet June 2013 with LA state Home Builders Association (HBA) to present upon SPF performance, H+S, Certification • SPFA was requested to meet June 2013 with LA State Code Council to present upon SPF performance, H+S, Certification • Possible state bill requiring professional SPF certification • SPFA hosts July 2013 webinar on SPF & ventilation practices presented by Louisiana State University Current Status –Company Accreditation • SPFA developing Contractor and Manufacturer Accreditation Programs • Work in progress • Various roles & responsibilities directed at further deploying the PCP • Allows for blanket recognition at company level for completing various requirements – Easier bid reference Current Status ‐ International
• Several countries have requested to use the SPFA PCP – Mexico – Canada – Scandinavian Region – South Africa – Australia • Working to identify and develop addendums, international deviations, companion documents on building codes and safety Current Status – Advisory Council
• SPFA Board (July 2013) approves creation of SPFA PCP Advisory Council • Role to assist SPFA PCP in outreach, expansion, program accommodation • Major partners being solicited for participation – ACC/CPI, ACCA, AIA, AGC, BPI, ICAA, NAHB, NRCA, RESNET, others • Planned for January 2014 Current Status –OSHA NEP
• July 2013 OSHA announces National Emphasis Program (NEP) on Isocyanates • Targeted inspections and regulatory enforcement nationwide – New: Includes companies with <10 employees • Proper handling, PPE use, medical documentation, respiratory safety plans • Requires demonstration of training for employees
https://www.osha.gov/OshDoc/Directive_pdf/CPL_03‐00‐017.pdf PCP Challenges
• New Program Mid‐Industry Acceptance – Integrating a new professional certification program into an existing industry framework – Community not oriented to classroom training / paper tests • Cost – Not comparatively high cost but challenging for small –medium sized contractor businesses – Many manufacturers considering incentivizing or discounting for their customers • Accessibility – Many contractors geographically dispersed – Developing options for online training and testing • Promotion / Awareness – Need outreach partners to recognize program and assist with benefits messaging PCP Opportunities
• No Competition – SPFA PCP only standards‐based, non‐proprietary, unbiased certification program for all SPF types and installations in the world • Growing Interest – Contractors and manufacturers beginning to realize respective benefits of certification • Existing Demand – Homeowners, professional customers (builders, GCs, etc) desire one point of reference for demonstration of proficiencies and KSAs of SPF contractors • Engaging Partnerships – Example: Carpenters Union interest to possibly use 900k sqft training center in Las Vegas, and 250 national centers for testing – Mtg Aug 2013 Other SPFA Activities
• Industry Quarterly Trade Publication • Annual Convention & Expo – 1200+ Attendees ( 40% increase over 5 years) • Technical Programs – Example: SPF Model LCA & EPD –only insulation industry to publish • NAHB Builder’s Checklist –In Development PCP Contacts & Info
• SPFA PCP Online Info – www.sprayfoam.org • CPI H+S Online – www.spraypolyurethane.com • SPFA PCP Program Administration – Kelly Marcavage, PCP Director [email protected] – Administrative & Registration [email protected] | 1.866.222.5000 Thank You
Kurt Riesenberg SPFA Executive Director [email protected] Return to Contents List OSHA’s Isocyanates National Emphasis Program
Safe Spraying and Intelligent Insulation Seminar December 11, 2013 Amee Bhatt, CIH OSHA/Region 1
JFK Federal Building, Room E340 Boston, MA 02203 617-565-9859 [email protected] • National Emphasis Program – Occupational Exposure to Isocyanates, CPL 03-00-017 – Effective date June 20, 2013 – http://www.osha.gov/SLTC/isocyanates/index. html
Most Commonly Used
• Methyl isocyanate - MIC NCO • Methylene Bis (phenyl isocyanate) – MDI CH2
• Toluene diisocyanate – TDI OCN • Hexamethylene diisocyanate – HDI MDI • Naphthalene diisocyanate – NDI • Methylene bis-cyclohexylisocyanate – (HMDI) • Isophorone diisocyanate - (IPDI) TDI • HDI biuret • HDI isocyanurate Exposure Limits • OSHA Permissible Exposure Limits – MIC, MDI, TDI • Other Occupational Exposure Limits – NIOSH, ACGIH Occupational Exposure Limits Isocyanate (OEL) 1 ® 2 CAS no. Vapor OSHA PEL NIOSH REL ACGIH TLV OSHA IMIS no. Synonyms Pressure ppm mg/m3 ppm mg/m3 ppm mg/m3 Methyl isocyanate 348 mmHg 0.02 0.05 0.02 0.05 0.02 624-83-9 MIC; Isocyanatomethane @ 68 °F T T T T T 1773 4,4-Diphenylmethane Methylene diisocyanate; MDI; 0.005 0.050 bisphenyl 0.000005 0.005 4,4-Diisocyanadiphenyl-methane; 0.02 0.2 T T isocyanate mmHg T Methylene bis(4- C C 0.02 0.2 101-68-8 @ 77 °F phenylisocyanate); Methylene C C 1073 Bis(Phenyl Isocyanate) Toluene-2,4- 0.0055 2,4-Diisocyanato-1- diisocyanate (TDI) 0.01 mmHg 0.02 0.14 T methylbenzene; TDI; 4 584-84-9 @ 77 °F C C 0.02 2,4-TDI; 2,4-Toluene diisocyanate 2470 STEL
NIOSH – National Institute for Occupational Safety and Health ACGIH – American Conference of Governmental Industrial Hygienists Health Effects
• Occupational asthma • Dermatitis* • Irritation of mucus membranes • Hypersensitivity pneumonitis • Chest tightness • Some are classified as potential human carcinogens
* Studies indicate that dermal exposure is a significant cause of respiratory sensitization. Used in the Formation of Many Polyurethane Products • Paint • Blowing foam insulation • Polyurethane foam • Insulation materials • Surface coatings • Car seats • Furniture • Foam mattresses • Under-carpet padding • Packaging materials • Laminated fabrics • Adhesives Workplace Health*
• Occupational Exposure • Respiratory Limits Protection – Overexposure requires – Medical evaluation, fit- engineering or test, training administrative controls • Personal Protective • Hazard Equipment Communication – PPE hazard assessment – Training, labeling, – Protective clothing, safety data sheets eye/face protection, hand protection, • Recordkeeping respiratory protection – OSHA 300 Injury and Illness logs
*not comprehensive Personal Protective Equipment
General requirements 29 CFR 1910.132
Eye and face protection 29 CFR 1910.133
Head protection 29 CFR 1910.135
Foot protection 29 CFR 1910.136
Hand protection 29 CFR 1910.138
PPE Topics Page: http://www.osha.gov/SLTC/personalprotectiveequipment/index.html (for standards, fact sheets, eTools and other information) Personal Protective Equipment
• Conduct a hazard assessment and select appropriate PPE to protect employees from hazards • Must ensure PPE is used and maintained • Must be provided at no cost to employees (some exceptions) • Provide training on PPE Respiratory Protection 29 CFR 1910.134 • Selection – Select and provide appropriate respirator based on respiratory hazards • Medical evaluation – Medical questionnaire and/or physical conducted by a licensed health care professional • Fit testing – Quantitative or qualitative – Performed on the same make, model and size of respirator to be used by employee Respiratory Protection 29 CFR 1910.134 • Use – Ensure faceseal protection for tight-fitting respirators (e.g. no facial hair) • Maintenance and care – Proper cleaning and disinfecting, storage, inspection, and repair • Breathing air quality and use – Supplied air respirators and SCBAs • Training • Program Evaluation
Topics Page: http://www.osha.gov/SLTC/respiratoryprotection/index.html for standard, training videos, Small Entity Compliance Guide Hazard Communication 29 CFR 1910.1200 • Revised on March 26, 2012 to align with GHS (Globally Harmonized System of Classification and Labeling of Chemicals)
• All employers with hazardous chemicals in their workplaces are still required to have a hazard communication program, and provide information to employees about their hazards and associated protective measures
• Written hazard communication program requirements, worker training, and trade secret provisions are all largely unchanged from the existing rule Hazard Communication 29 CFR 1910.1200 Notable changes: • Labels are more defined and will now require: A product identifier, pictogram, signal word, hazard statement (s), precautionary statement(s), name, address and telephone number • Using “safety data sheet” rather than “material safety data sheet” – 16 section format
Topics Page: https://www.osha.gov/dsg/hazcom/index.html for standard, fact sheets, briefs, presentations and other information Recordkeeping 29 CFR 1904 • Maintain records of serious workplace injury and illnesses using OSHA 300 Injury and Illness Log and 301 Injury and Illness Incident Report • Required to post Form 300A, the Summary of Work-Related Injuries and Illnesses every year from February 1 to April 30 • Forms, Recordkeeping Handbook, standard and guidance available at: https://www.osha.gov/recordkeeping/index.ht ml
Workplace Safety*
• Fire protection and prevention – Fire extinguishers, storage of flammable liquids • Electrical safety – Hazardous locations, intrinsically safe equipment • Fall protection, scaffolds, ladders • Powered hand tools
*not comprehensive Transitioning to Safer Chemicals: A Toolkit for Employers and Workers
• Step-by-step toolkit to provide employers and workers with information, methods, tools and guidance on using informed substitution
http://www.osha.gov/dsg/safer_chemicals/index.html OSHA Area Offices - MA
Braintree Area Office Andover Area Office (a.k.a. Boston Area Office - (a.k.a. Boston Area Office – South) North) 639 Granite St., 4th Floor Shattuck Office Center Braintree, MA 02184 138 River Road, Suite 102 Tel. (617) 565-6924 Andover, MA 01810 Tel. (978) 837-4460
Springfield Area Office 1441 Main Street, Room 550 Springfield, MA 01103-1493 Tel. (413) 785-0123 http://www.osha.gov/html/RAmap.html Return to Contents List
Marvin Lewiton, M.S., CIH On-Site Consultation Program Industrial Hygiene Supervisor
Deval L. Patrick, Governor Rachel Kaprielian, Secretary ` Massachusetts ` United States Department of Department of Labor Standards Labor ` Occupational ` On-Site Safety and Health Consultation Administration (OSHA) ` Consultation operates in every state ` Most of funding from OSHA, but separate
6 Safety Professionals 6 Industrial Hygienists
Offices in Taunton, Westboro, & Springfield ` Free! ` Confidential ` Provided at the employers request ` Primary focus on small, high hazard businesses ` Manufacturing, construction, healthcare ` No penalties or fines ` On-Site Surveys ` Technical information via phone/email ` Training for employers/employees ` Provide model safety and health programs ` Assist in evaluating, developing or maintaining an effective Safety and Health Program ` Issue citations or propose penalties
` Tell OSHA where we go, what we see, who we talk with, etc.
` Guarantee workplaces will “pass” an OSHA inspection
EARTHANE is green. As a product, EARTHANE is about as environmentally green as a foam insulation can get. It is water that makes this crucial difference. In place of chemical blowing agents like Freon and other highly reactive materials, EARTHANE uses water to make it turn from a liquid to a foam. With over 20 years experience in home technologies, GreenSeal is Southern New England's leader for home energy solutions. GreenSeal provides a comprehensive package of planet- friendly energy solutions that includes: Spray Foam Insulation, Cellulose Insulation, Home Energy Audits, and energy-saving Replacement Windows.
Foam insulation has been used as a specialty product in the building industry for over 50 years. It is widely known to be a safer, more effective alternative to other insulators (e.g. fiberglass and cellulose). So while all spray foam systems have some degree of “green bio-content” in their composition, it comes down to the level of bio-based and renewable materials in their polyol mixture that distinguishes which SPF product is truly greener than the other.
“We think Spray Foam is the 'Greenest' Insulation” SprayFoam.com Section 3: COMPOSITION / INFORMATION ON INGREDIENTS
` Polymeric Diphenylmethane Diisocyanate (pMDI) 50–60 %
` 4, 4’ Diphenylmethane Diisocyanate (MDI) 35–45 % (monomer)
` 2, 4’ Diphenylmethane Diisocyanate (MDI) 1–5 % (monomer) ` Irritation of eyes, skin, pulmonary system
` Respiratory sensitization (asthma)
` Dermal sensitization
` Hypersensitivity pneumonitis
` Inhalation (vapor and particulate)
` Dermal
` Ingestion (unlikely) ` No HazCom training (non-English-speaking employees) ` Inconsistent PPE use ` Ladder safety issues ` Trip and fall hazards ` Other trades working in space ` No respirator program ` No medical evaluation ` No training ` Beards ` No cartridge changeout schedule ` Removing respirators inside while working ` Air supplied respirators should always be used for spraying, APRs probably OK for trimming (with daily cartridge changeout) ` OSHA PEL: 20 ppb (ceiling) for MDI monomer
` No dermal exposure limits
` No mixed isocyanate exposure limits except for Great Britain ` Spraying: 3X PEL ` Trimming: 1.5X PEL ` Me: 0.1X PEL
` Variables: enclosure, distance, ventilation, work practices, etc.
“All organic foam insulations, regardless of whether they contain fire retardants, should be considered combustible and handled accordingly.
Certain precautions must be taken to minimize any potential for fire through accidental ignition in handling, storage, and use.” Alliance for the Polyurethanes Industry (API)
Trades performing hot work should comply with the National Fire Protection Association document, NFPA 51 B, as described by OSHA Standard 29 CFR 1910.252.
Trades performing hot work are required to observe the following restrictions: • No open flames, cutting and welding torches, high intensity heat sources, and smoking materials are permitted in storage and application areas. From MSDS:
Do not mix liquid waste components together for disposal convenience. Mixed “A” and “B” components can create pressure within closed containers causing rupture or explosion.
Conditions also could exist for spontaneous combustion by improperly mixing “A” and “B” components. ` Questions? Spray Polyurethane Foam Insulation: Essential Resources and Training
Return to Lee Salamone, ACC Center for the Contents List Polyurethane Industry Manufacturers Supporting the Spray Polyurethane Foam Value Chain
• CPI is the voice of the polyurethanes industry in North America
Image • Supports manufacturers of polyurethanes and materials to make polyurethanes
• Works collaboratively with downstream users and their customers
• Focus on product stewardship, research and industry promotion, and advocacy Image
Industry-led Product Stewardship
Primary Goal To increase understanding of safe installation practices regarding use, handling and disposal of spray polyurethane foam. Industry-led Product Stewardship: Three-Pronged Approach
Program focuses on practices and communications that can help to minimize potential for overexposure of workers and building occupants to SPF chemicals. • Worker Performance and Training – develop a health and safety training program for professional SPF applicators. • Outreach- Educate DIY’ers, consumers and the building/construction sector about best practices on key issues including the importance of consulting a professional SPF contractor; different types of SPF products; health and safety considerations for DIY’ers and consumers during and after product installation. • Research- Develop research and support testing programs to improve understanding of potential exposure to chemical components for workers applying SPF and potential consumer/occupant exposure to SPF emissions.
Worker Information and Training
• Posters
• Guidance Image • Training
• Website
Spray Polyurethane Foam: Posters www.spraypolyurethane.com Spray Polyurethane Foam: Guidance www.spraypolyurethane.com Spray Polyurethane Foam: Guidance www.spraypolyurethane.com CPI SPF Health and Safety Training Programs: High-Pressure
High-pressure health and safety training launched in Dec. 2010.
The program provides free online health and safety information for SPF contractors, applicators or helpers who work with two- component high-pressure SPF systems.
More than 9,800 users have accessed the training program either online or in an instructor-led capacity.
This program was recently upgraded and translated into Spanish (Dec 2012).
CPI SPF Health and Safety Training Programs: Low-Pressure
Low-pressure health and safety training launched in Dec. 2012 in English and Spanish.
This training was supported by grant funding from OSHA.
The Low-Pressure Training provides information for weatherization professionals, applicators or helpers who work with one-component SPF or two-component, low- pressure SPF kits for sealing and insulating.
More than 1,200 users have accessed the training program either online or in an instructor-led capacity.
Key Outreach Tool www.spraypolyurethane.org
Research and Testing Initiatives
Development of research and testing projects for SPF raw materials, engineering practices, and analytical methods • Evaluate Airborne SPF Chemical Concentrations While Varying Air Flow Rates During Application – SPF Ventilation Study • Develop a Standard Method to Evaluate SPF Chemical Emissions After SPF Application – Indoor Air Quality Study
Spray Foam Coalition
Formed at CPI in 2010 as a forum for manufacturers of spray foam systems and their suppliers to:
• Champion the use of spray polyurethane foam
• Support the safe manufacture, transport, and application of spray polyurethane foam
• Promote the economic, environmental and societal benefits of SPF
• Provide a forum to help shape public policy on issues critical to the industry Spray Foam Coalition
• Guidance documents • Support for CPI Product Stewardship efforts • Support for development of SPFA Contractor Certification • Research to better understand SPF characteristics • Promote improvements to Building Codes, ASTM Standards, and Acceptance Criteria for SPF (AC377) Spray Foam Coalition
• Outreach to Users, Builders, and Homeowners • SPF use information Promotion of SPF and its benefits Spray Polyurethane Foam Can Save Energy in Buildings
• SPF is a product that is manufactured on site, which creates unique advantages and safety considerations
• Use a trained professional contractor
• Use the right product for the right job – understand building science
• Look to the spray polyurethane foam industry for support in understanding, choosing, installing and promoting the use of spray polyurethane foam in buildings
• Visit www.spraypolyurethane.org and www.whysprayfoam.org for more info Thank You!
Lee Salamone [email protected] Office of Technical Assistance and Technology (OTA) Commonwealth of Massachusetts
Safe Spray Foam Return to Contents List and Intelligent Insulation workshop Bill Meehan National Technical Manager BPI ACCREDITATION AND CERTIFICATION ACCREDITATION
BPI Accredited Company – An entity that complies with the requirements set by BPI to enhance the delivery of consistent, quality focused home performance services. BPI Accreditation – A credentialing process for companies, administered by BPI, that evaluates key business practices, technical operations and quality management systems necessary to ensure the delivery of home performance services while conforming to BPI Standards. CERTIFICATION
BPI Certification – A rigorous, credible, and defensible written and field examination process administered to individuals by BPI approved proctors, to verify knowledge, skills and professional competency in the building performance industry designations.
BPI Certified Professional – An individual who successfully passes the BPI written and field examination requirements for certification. Alternative Path BPI has expanded its accreditation paths by recognizing other Industry certifications that can serve as prerequisites to become BPI accredited. The BPI Accreditation: Alternative Path for Spray Foam Policies and Procedures explains the process your company or organization will need to follow in order to acquire BPI accreditation with alternative path credentials. BPI accepts and recognizes the following Spray Foam Certifications to establish the conditions under which a Spray Foam company will meet the necessary qualifications required to apply for BPI accreditation through an alternative path from: Spray Polyurethane Foam Alliance, (SPFA), Air Barrier Association of America, (ABBA) Building Professional Training, (BPT). The Alternative Path For Spray Foam The alternative path is comprised of a BPI Building Analyst (BA) certification, plus one of the following: The Alternative Path Continued
Spray Polyurethane Foam Alliance (SPFA) A training and independent certification program, administered by the Spray Polyurethane Foam Alliance (SPFA) with a minimum designation in Spray Polyurethane Foam Insulation Project Manager
The Alternative Path Continued Air Barrier Association of America (ABBA) A training and independent certification program, administered by ABBA; an installer of air barrier materials and/or systems who, in view of ABBA or its designate, has successfully completed the requirements for an Installer as set out in the QAP and has signed a license agreement with ABBA with respect to the use of the Certification Mark. The Alternative Path Continued Building Professional Training (BPT) Canadian Urethane Foam Contractors Association Installer Certification: Installers are required to be certified to apply the product. They are issued a photo identification, which is renewed yearly and may be revoked or suspended at anytime. Contractors Licensing: Contractors are required to meet the strict standards of the SPF Quality Assurance Program. They shall have at least one certified installer on each job site at all times. The license must be renewed yearly and may be revoked or suspended at anytime.
Questions Presented by: MaryBeth Smuts, EPA Region I for Carol Hetfield, Environmental Protection Agency
Katherine Sleasman, Return to Environmental Protection Contents List Agency EPA’s Concerns for Isocyanates and Polyurethane Products y Many polyurethane products are mixed, applied, and/or manufactured on‐site in a home, school, or other buildings. y Isocyanates are recognized as leading attributable cause of occupational asthma. y Diisocyanates in vapors, aerosols, and dust can cause: y Asthma, respiratory & breathing problems, and in severe cases fatal reactions have been reported (see NIOSH ALERTS), y Skin, eye, and dermal irritation, y Sensitization (potent inhalation & dermal sensitizers), and y Can trigger severe asthma attacks in sensitized persons, even at very low levels. y Amine catalysts, flame retardants, blowing agents and other ingredients or reaction products, such as aldehydes, may also cause health and environmental effects. EPA Office of Pollution Prevention & Toxics 2 Partnerships
y Federal Partnership: y US Environmental Protection Agency y Occupational Safety and Health Administration y National Institute for Occupational Safety and Health y The Consumer Product Safety Commission (CPSC) y The Agency for Toxic Substances and Disease Registry (ATSDR) y Engagement with Industry Representatives: y American Chemistry Council (ACC) y ACC’s Center For Polyurethanes Industry (CPI) y Spray Polyurethane Foam Alliance (SPFA), representing applicators y Individual Chemical and Polyurethane Product Manufacturers
EPA Office of Pollution Prevention & Toxics 3 Stewardship Goals
• Avoidance of misleading and/or deceptive marketing claims. • Accurate & comprehensive communication of hazards, as well as benefits of polyurethane products. y Develop & adopt practices to prevent harmful exposures: y Ensure workers are trained on hazards, processing and equipment, curing rates, performance, as well as communicating with others. y Ensure worksite isolated and restricted to workers wearing appropriate personal protective equipment (PPE). y Provide guidance on safe re‐occupancy times/ventilation. y Address research needs and data gaps on different types of polyurethane product formulations and applications. EPA Office of Pollution Prevention & Toxics 4 Challenge – Misleading and/or Deceptive Marketing Claims y “No off‐‐gassing”, “non—toxic”, “green“, “environmentally friendly”, “plant‐based”, “made from soy beans”, etc. y Little is revealed about chemical ingredients and potential hazards/risks. y DIY programs showing improper protection. y On‐line videos showing untrained/unprotected application of products. y Lack of balance between potential performance benefits and hazards.
EPA Office of Pollution Prevention & Toxics 5 Progress in Addressing Misleading Marketing Claims y US Federal Trade Commission (FTC) Green Guides, see http://www.ftc.gov/os/2012/10/greenguides.pdf y As part of the its Green Guides compliance program, FTC recently took action against companies for making false environmental marketing claims. The proposed consent orders prohibit the companies from making claims unless the representations are true and supported by competent and reliable scientific evidence. y Enhanced Energy Star Residential Insulation Partnership Requirements (see separate slide). y Industry guidance ‐ see http://www.spraypolyurethane.org/ GreenMarketingClaims ; and, http://spraypolyurethane.org/Guidance‐ for‐Videos‐or‐Images‐Showing‐SPF‐Application
EPA Office of Pollution Prevention & Toxics 6 Challenge – Deficiencies in Hazard Communication y Hazard and exposure control information varies widely. y Availability of Safety Data Sheets (SDSs) – some on‐line, others made available only after request by federal Agency. y Recommendations on respiratory protection vary, while only a few mention the possible need for protection for “adjacent workers.” y Indicate that adequate ventilation is needed but provide little guidance what constitutes adequate ventilation and methods. y Few SDSs mention that skin contact may cause an allergic reaction and sensitization. y Several SDSs mention that dust can be generated during cutting or abrasive processes, however, hazards are identified as “mechanical irritation.”
EPA Office of Pollution Prevention & Toxics 7 Progress in Addressing Hazard Communications y Federal –US EPA Spray Polyurethane Foam website, OSHA’s Green Jobs site and National Emphasis Program, NIOSH ALERTS, numerous resources and information pages across federal Agency websites on isocyanates and other chemical hazards (see resources). y Industry ‐ Product stewardship activities: y Fact sheets, technical bulletins, websites & portals, see http://spraypolyurethane.org/default.aspx y Other ‐ Spray Foam Magazines, industry newsletters, blogs, Green Building webinars, technical panels at conferences, goals in product sustainability standards.
EPA Office of Pollution Prevention & Toxics 8 Why Best Practices are Important
y Airborne contaminants may be generated during application processes, including y Vapors, aerosols, and mists generated during spraying. y Dusts/particulates during trimming/cutting/grinding. y Vapors also emitted during curing process. y Workers and others in the area can breath harmful airborne contaminants or get them on the skin/eyes. y Best Practices can help reduce exposures to contaminants.
EPA Office of Pollution Prevention & Toxics 9 EPA’s Approach to Best Practices y Identify established practices for engineering or process efficiencies & control technologies to reduce exposures and environmental releases, y Review existing worker training materials & practices addressing the use of PPE and control technologies, and y Solicit recommendations for innovative practices from industry and field experts, capturing the following: y Identify job related tasks. y Safe work practice(s). y Exposure reduction/prevention potential of the safe work practice. y Other relevant information (i.e., pros and cons) associated with the safe work practice.
EPA Office of Pollution Prevention & Toxics 10 EPA Guidance y Checklists for installers and communicating with homeowners. y Ventilation Guidance for SPF Applications/Automotive Shops. y Self‐evaluation tool for contractors of practices and strategies to protect workers and promote the safe use of polyurethane products. • Periodic assessment tool of their current practices and identify areas for improvement. • Includes the following: y Over 175 Activities (safer workplace practices). y Potential for exposure & impact on worker exposure. y Four key‐operation phases: on‐going, pre‐application, application, EPA Office of Pollution and post‐application. Prevention & Toxics 11 Challenge ‐ Training
y Ensure that all workers receive comprehensive training on hazards, curing rate, performance, equipment and processing, as well as communicating with others, including homeowners. y Ensure premises are restricted to workers wearing appropriate personal protective equipment (PPE). y Innovative solutions to prevent chemical migration should continue to be developed and shared to ensure industry‐wide practice. y Ensure homeowners, teachers and students, and the general public are not exposed to hazardous chemicals during and after polyurethane product applications.
EPA Office of Pollution Prevention & Toxics 12 Progress in Training
y Industry –ACC’s on‐line H&S training & testing courses: y Low Pressure SPF Chemical Health and Safety Training y High Pressure SPF Chemical Health and Safety Training y See http://spraypolyurethane.org/SPF‐Chemical‐Health‐and‐ Safety‐Training y SPFA certification and accreditation program: y SPF Professional Certification Program (PCP) for assistants, installers, master installers, program managers, and field examiner, see http://www.sprayfoam.org/index.php?page_id=4557 y Training courses at conferences/conventions y Chemical or Product Manufacturer‐Contractor training EPA Office of Pollution Prevention & Toxics 13 Challenge ‐ Assessing Exposures
y Data are needed to accurately assess the potential for exposures with variable applications & product formulations: y Measuring total isocyanates exposure during application y Measuring indoor air emissions/off‐gassing of isocyanates and other polyurethane product ingredients (amines, SVOCs, flame retardants, etc.) and reactants. y Answering the questions: y When can other trade workers, building occupants, residents, and school children safely re‐enter the premises after product application or installation? y What are post‐occupancy ventilation (H‐VAC needs)?
EPA Office of Pollution Prevention & Toxics 14 Progress in Addressing Exposure Assessment Needs & Data Gaps y Comparative study to validate total reactive isocyanate groups (TRIG) monitoring method. y Developing ASTM Methods (D22.05) for measuring chemical emissions from Spray Polyurethane Foam (see next slide). y Evaluating the impact of incremental changes in ventilation rates on the concentration of Spray Polyurethane Foam vapor & particulates emitted. Included the development of a generic formula for evaluating Spray Polyurethane Foam emissions. y Evaluating dust from trimming operations. y International Research Conference (Isocyanates & Health: Past, Present, & Future, convened in April 2013, at the Bolger Center in Potomac, MD), see http://www.isocyanates2012.org/content/home.cfm y Curing letter data submissions –see separate slide EPA Office of Pollution Prevention & Toxics 15 15 MDI and TDI Action Plans
y Diisocyanates: y Recognized as dermal and inhalation sensitizers y May cause asthma, lung damage, and in severe cases, fatal reactions y EPA is concerned about potential exposures to consumers and/or those commercial workers not covered under OSHA regulations, and the general population that could result from the use of products containing unreacted MDI, TDI, and related compounds. y e.g., application of spray‐applied sealants and coatings when such products are used in or around buildings such as homes or schools
EPA Office of Pollution Prevention & Toxics 16 MDI Action Plan
y Based on EPA’s screening‐level review of hazard and exposure information EPA will consider the following actions: y Initiate TSCA section 8(d) reporting for unpublished health and safety studies for uncured MDI. y Consider initiating a TSCA section 4 test rule to require exposure monitoring studies in representative locations where commercial products are installed, including on‐site application of insulation, sealants, coatings, and adhesives, and, exposure monitoring studies representatives of polyurethane products installed in the home (i.e., insulation) or used by the consumer (i.e., foam mattresses).
EPA Office of Pollution Prevention & Toxics 17 TDI Action Plan
y Based on EPA’s screening‐level review of hazard and exposure information EPA will consider the following actions: y Initiate rulemaking under TSCA section 5(a)(2) for a Significant New Use Rule (SNUR) designating certain uses of TDI in a consumer product as a new use requiring prior notice to the Agency. y Initiate a TSCA section 8(d) rule for reporting of unpublished health and safety studies. y If information indicates further actions are warranted, EPA would then consider initiating a TSCA section 4 test rule to require exposure monitoring studies in representative locations where commercial products would be used.
EPA Office of Pollution Prevention & Toxics 18 Other Potential Regulatory Actions y Consider issuing a data call‐in under TSCA section 8(c) Allegations of Adverse Effects y Consider TSCA section 6 action that gives EPA the authority to protect against unreasonable risk of injury to health or the environment ‐ y If EPA finds that there is a reasonable basis to conclude that the chemical's manufacture, processing, distribution, use or disposal presents an unreasonable risk. y Actions could include but are not limited to: prohibiting or limiting manufacture, processing, or distribution in commerce of a chemical; requiring warnings and instructions with respect to use, distribution, or disposal; and/or, recordkeeping requirements. EPA Office of Pollution Prevention & Toxics 19 Information Request Authority
y For the purposes of carrying out TSCA, EPA requested companies voluntarily provide certain information to the Agency ‐ y EPA specifically requested information on the curing time required to chemically react all diisocyanate functional groups, and y The amount of time required to safely re‐occupy or use an area where diisocyanates have been reacted y The Agency is reviewing the information to determine what it tells us about consumer and worker exposure to polyurethane products.
EPA Office of Pollution Prevention & Toxics 20 Types of Information or Data Received from the Information Request
y EPA received the following types of data as a result of our request including: y Formulation Data y Safety Data Sheets y Industrial Hygiene Studies y Curing information
EPA Office of Pollution Prevention & Toxics 21 Challenge –Development of Test Methods to Measure Emissions y Need methods and data that paint the picture of “source‐to‐ exposure”, over the life‐cycle of the polyurethane product. y Recognize as complex undertaking and its important to keep that in mind as develop specific test systems and protocols to address aspects of the larger goal. y Need multiple approaches to characterize stage‐specific emissions for the product(s). y Need to develop/demonstrate methods that capture the “normal” cure phase emissions because that is a benchmark for evaluating emissions and off‐spec conditions, wherein – y A methodology is a tool that industry uniformly uses to evaluate product formulations, and y Federal and/or state Agencies have access to data to better assess the potential for exposures, including modeling exposures under EPA Office of Pollution different scenarios. Prevention & Toxics 22 Progress ‐ Test Methods Development
y EPA’s Office of Research and Development is developing test methods and protocols to generate reliable data to fill knowledge gaps related to polyurethane products, including y What is emitted and for how long? y What factors impact emissions? y This work supports the ASTM Committee D 22.05 Spray Polyurethane Foam Insulation (SPFI) emissions test method development task, which is a component of a broader strategy to develop test methods specific to SPFI, as well as tool and models to relate product emissions to potential exposures. y Test method development could be used in exposure monitoring studies for uncured diisocyanates to allow for better understanding of potential exposures in uncontrolled settings.
EPA Office of Pollution Prevention & Toxics 23 Significant New Use Rules (SNURs)
y TSCA section 5(a) authorizes EPA to determine that a use of a chemical substance is a “significant new use.” EPA must make this determination by rule after considering all relevant factors, including those listed in TSCA section 5(a)(2), i.e., y The projected volume of manufacturing and processing of a chemical substance. y The extent to which a use changes the type or form of exposure of human beings or the environment to a chemical substance y The extent to which a use increases the magnitude and duration of exposure of human beings or the environment to a chemical substance y The reasonably anticipated manner and methods of manufacturing, processing, distribution in commerce, and disposal of a chemical substance y A SNUR requires that manufacturers and processors of the chemical subject to the SNUR notify EPA at least 90 days before beginning any activity that EPA has designated as a "significant new use”
EPA Office of Pollution Prevention & Toxics 24 Proposed SNUR for TDI and Related Compounds
y The Action Plan covered toluene diisocyanates (TDI) and TDI‐related compounds, and stated that EPA would initiate a rulemaking under TSCA section 5(a)(2) for a Significant New Use Rule (SNUR) designating certain uses of TDI in consumer products as a new use requiring prior notice to the Agency. y EPA plans to issue a proposed SNUR for TDI and related compounds in 2014.
EPA Office of Pollution Prevention & Toxics 25 Federal Agency Coordination
y Since 2009, these federal agencies have pursued actions related to workers and consumers: y On June 25, 2013, US OSHA announced a three year National Emphasis Program on isocyanates that will focus outreach efforts and inspections on specific hazards for workplaces, construction, and maritime industries. OSHA is also revisiting isocyanate PELs. y On June 24, 2013, NIOSH published a request for information on TDI and other TDI‐based isocyanate products to develop a Criteria Document to establish an updated Recommended Exposure Limit (REL) for TDI. y On April 23, 2013, CPSC announced new guidance to clarify the definition of “strong sensitizer” under the Federal Hazardous Substances Act (FHSA), which would require cautionary labeling.
EPA Office of Pollution Prevention & Toxics 26 Summary y The CASE industry needs to ensure: y There is comprehensive and clear hazard communication for all CASE users – applicators, assistance, other trades, do‐it‐yourselfers, consumers, and other decision‐makers (i.e., building managers, etc.). y Consumers need clear hazard and use warnings, such as through product labeling and communications with commercial contractors. y The work site is restricted to only those wearing appropriate personal protective equipment. y Quality control ‐ avoid installation of off‐spec, poor performance polyurethane materials. (see saferproducts.gov for complaints of off‐ gas persistence). y Guidance is provided on re‐occupancy time & long‐term ventilation (H‐VAC) needs. y Marketing claims are accurate and balanced. EPA Office of Pollution Prevention & Toxics 27 Where to Get More Information?
y EPA’s DfE SPF website at http://www.epa.gov/dfe/pubs/projects/spf/ spray_polyurethane_foam.html y NIOSH Alert on Spray‐on Truck Bed Lining Operations at http://www.cdc.gov/niosh/docs/2006‐149/default.html y OSHA’s isocyanates website at http://www.osha.gov/SLTC/isocyanates/index.html y OSHA’s Green Jobs Hazards website at http://www.osha.gov/dep/greenjobs/index.html y EPA’s Action Plan website for MDI: http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/mdi.pdf y Docket MDI http://www.regulations.gov/#!docketDetail;rpp=10;po=0;D=EPA‐HQ‐OPPT‐ 2011‐0182 y American Chemistry Council—Center for the Polyurethanes Industry website at http://www.spraypolyurethane.org/ y Spray Polyurethane Foam Alliance’s website at http://www.sprayfoam.org/
y Project Coordinators: y Carol Hetfield; 202‐564‐8792; [email protected] y Katherine Sleasman; 202‐564‐7716; [email protected] y MaryBeth Smuts; 617‐918‐1512; Regional contact at [email protected] EPA Office of Pollution Prevention & Toxics 28