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

2. This material was produced under grant number SH F12 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 ) 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 )
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 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 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. Hazardous Liquid Wastes
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
OSHA Construction 1926
EPA links to information on permits, storage, disposal, recycling, and identification of hazardous materials
EPA links to hazardous waste and RCRA information within EPA
Center for the Polyurethane Industry (CPI) Product Stewardship Literature