Last week I met with a Compliance Assistance Specialist from the Boston (Braintree) Region 1 OSHA office for an update on OSHA outreach/education initiatives. OSHA reached out to me to assist with getting the word out about a new National Emphasis Program on Isocyanates (Spray Foam Insulation) and the new Global Harmonized System (Hazardous Communication aka. Haz-Com).
You say what?
Guys and Gals, please stick with me and I will try to help you understand what is going on and what you need to do to keep up with the non-stop programs.
We also discussed OSHA's progress and continued focus on Fall Protection Training and compliance in the residential construction industry.
1. Global Harmonized System (Hazardous Communication)
Hazardous Communication is an OSHA Standard required for all employers. It is the standard that gives workers the right to know about hazardous chemicals, gases and materials used in their daily work and work place. The revised standard will improve the quality and consistency of hazard information for workers and employers. The Hazard Communication Standard is now aligned with the Globally Harmonized System of Classifications and Labeling of Chemicals. (GHS). Here are the highlights of the changes:
Major changes to the Hazard Communication Standard
Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Safety Data Sheets: Will now have a specified 16-section format.
Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding.
This is a Pictogram for Health Hazards.
Link to OSHA Haz-Com Page: http://www.osha.gov/dsg/hazcom/index.html
In keeping with the new GHS standard OSHA has issued a NEP on the hazards from isocyanates. Isocyanates are commonly found in products such as spray foam insulation, building insulation, paints, varnishes and sprayed bed liner materials. Exposure can cause irritation of the skin, eyes, throat and nose. In addition isocyanate exposure can cause acute and chronic respiratory and asthma conditions, cancer and death. Workers can suffer debilitating health problems for months or even years after exposure.
The recent focus on green methods to conserve energy have lead to an increase in spray foam insulation (SPF) use. In states with aggressive new energy codes like Massachusetts, SPF application is increasing at a break neck pace. Another significant development is the use of low skilled labor amongst weatherization companies that sprung up after the stimulus package. Many weatherization program workers come from the pool of the unemployed and are trained to perform energy related work.
All contractors who use SPF's on new homes, deep energy retrofits or remodeling projects need to make sure that the applicators are properly certified and trained to safely apply SPF's. Note there are huge potential hazards for other workers, trades and occupants in or adjacent to the application area.
Here are a few items to think about applying SPF's or when hiring company's who apply SPF's.
Hazardous Communication Training Program for Isocyanates for all workers working with or around SPF's. Training must be certified and documented. (Note; be sure to verify training and certification of your insulation sub contractors)
Job hazard assessment before SPF application.
Completely close of all areas where SPF's are to be applied.
Provide mechanical ventilation for the local work area. Exhaust must be filtered to prevent exposure to adjacent areas. This process should be documented in the hazard assessment.
Respiratory written program and training for all applicators and personnel exposed to the work area.
Applicators need to wear the appropriate respirators to apply SPF's.
An air quality assessment must be made after application and clean up prior to allowing other workers or occupants into the work area.
Fall Protection Update; progress but a long way to go
OSHA tells me they are seeing a lot more ropes and harnesses on workers up on heights in the residential sector. However they acknowledge that there are too many contractors still working unsafe while up on roofs, ladders, scaffolding and more. The recent death of a roofer on the Cape is evidence of how far the residential construction industry has to go. Falls are still the major cause of deaths in residential single family home and home improvement construction.
Number one OSHA violation; failure to provide fall protection and training
The number one most cited OSHA violation again this year is fall protection in the residential construction industry. Three years ago OSHA ran hundreds of outreach meetings on fall protection. Now it appears they are spending less time on outreach and more effort on enforcement. Until the deaths and injury statistics go down OSHA CHSO's will continue to cite any contractor and their subs if applicable for not following safe fall protection practices.
Need help navigating the OSHA changes? Contact me.