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OSHA 3135 4,4' Methylenedianiline (MDA) for General Industry 4,4' Methylenedianiline (MDA) for General Industry U.S. Department of Labor Occupational Safety and Health Administration OSHA 3135 1993 (Reprint) The information contained in this publication is not considered a substitute for any provisions of the Occupational Safety and Health Act of 1970 or for any standards issued by OSHA. Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission of the Federal Government. Source credit is requested but not required. This information will be made available to sensory impaired individuals upon request. Voice phone: (202) 219-8615; TDD message referral phone: 1-800-326-2577 4,4' Methylenedianiline (MDA) for General Industry U.S. Department of Labor Robert B. Reich, Secretary Occupational Safety and Health Administration OSHA 3135 1993 (Reprint) Contents Background Scope and Application Provisions of the Standard Permissible Exposure Limit Regulated Areas Labels and Signs Exposure Monitoring and Medical Surveillance Methods of Compliance Compliance Program Control Measures Respiratory Protection Hygiene Facilities and Practices Housekeeping Temporary Removal Personal Protective Equipment and Clothing Recordkeeping Training and Information Other Sources of OSHA Assistance Safety and Health Management Guidelines State Programs Consultation Services Voluntary Protection Programs (VPPs) Training and Education Glossary Related Publications States with Approved Plans Consultation Project Directory Area Offices Regional Offices Background On August 10, 1992, the Occupational Safety and Health Administration (OSHA) issued a final standard on the regulation of exposure to 4,4' Methylenedianiline (MDA) in Volume 29 of the Code of Federal Regulations (29 CFR) Part 1910.1050. Coverage of this standard applies to general industry (primary chemical manufacture, reprocessing, filament winding, potting, and encapsulating) and to the maritime industry. OSHA issued a separate standard for MDA exposure in the construction industry in 29 CFR 1926.60. In September 1983, OSHA and the Environmental Protection Agency (EPA) jointly published an advanced notice of proposed rulemaking (ANPR). EPA later issued a notice under section 4(f) of the Toxic Substances Control Act (TSCA) indicating that exposure to MDA presents a significant risk to humans as a carcinogen. EPA based this conclusion on studies performed by the National Toxicology Program (NTP) and on data collected by the Oak Ridge National Laboratories that supported findings of MDA as a carcinogen in test animals.1 The ability of MDA to induce tumors in animals-suggestive evidence that MDA may induce bladder tumors in humans and data indicating that MDA interacts with genetic material led to the conclusion that this chemical is an animal carcinogen and is a possible carcinogen to humans. On July 5, 1985, EPA referred all MDA rulemaking to OSHA under section 4(f) of TSCA. In response, OSHA determined -- based on the previously cited studies -- that there is a reasonable basis to believe that the manufacture and use of MDA presents a significant risk to the health of exposed workers and that risk may be eliminated or reduced to a significant extent by a workplace standard that regulates workers' exposure. Routes of exposure to MDA include skin absorption, inhalation, and ingestion. Short-term (acute) overexposure to MDA may produce fever, chills, loss of appetite, vomiting, and/or jaundice; direct contact may irritate skin, eyes, and mucous membranes. Long-term (chronic) overexposure may cause cancer, even at relatively low concentrations, and/or damage to the liver, kidneys, blood, and spleen. OSHA found thereto be no nonregulatory alternatives that adequately protect most workers from the adverse health effects associated with MDA exposure. MDA is a light brown crystalline solid with a faint amino-like odor. It is slightly soluble in water and very soluble in alcohol and benzene. MDA is produced commercially by the condensation of aniline and formaldehyde. Crude MDA, (40-60 percent) is either a liquid or a hard wax-like substance. Purified MDA (99 percent) is either light yellow crystalline flakes or white granules. Ninety-eight percent of MDA currently produced is used directly in the manufacture of 4,4' Methylenediphenyl diisocyanate (MDI). 2 The remaining 2 percent of MDA is used as a precursor for the manufacture of plastic fibers, antioxidants, dyestuff intermediates, corrosion preventatives, and special polymers. Purified MDA is used in manufacturing epoxy resin curing agents, wire coating applications, polyurethane co-reactants, pigments and dyes, and defense applications. U.S. production of MDA totaled approximately 600 million pounds per year in 1986. According to 1985-1986 figures, 3,836 workers were potentially exposed in 11 sectors of industry with an additional 189 maintenance workers in these areas as well.3 The following sections discuss the MDA standard as it pertains to general industry. OSHA also has developed a separate booklet that discusses the MDA standard's application to the construction industry. Scope and Application This publication discusses OSHA's standard (29 CFR 191 0.1050) as it applies to all occupational exposures to MDA in general industry where it is produced, released, stored, handled, used, or transported. Exceptions include -- the processing, using, and handling of MDA products where initial monitoring or objective data indicate the product is not capable of releasing MDA in excess of the action level under expected conditions, and where no dermal exposure can occur; 4 the storing, transporting, distributing, or selling of MDA in intact containers sealed to contain MDA dusts, vapors, or liquids; materials in any form that contain less than 0.1 percent MDA by weight or volume; and finished articles containing MDA. Provisions of the Standard Permissible Exposure Limit Time-Weighted Average and Short-Term Exposure Limit The employer must ensure that no employee is exposed to MDA above the permissible exposure limit (PEL) of 10 parts per billion (ppb) as an 8-hour time-weighted average (TWA) or a short-term exposure limit (STEL) of 100 ppb averaged over a 15-minute sampling period. Action Level The action level for a concentration of airborne MDA is 5 ppb as an 8-hour TWA. Employers must begin compliance activities such as exposure monitoring, medical surveillance, or temporary removal as soon as the action level is reached or exceeded. Regulated Areas The employer must establish regulated areas where airborne concentrations of MDA exceed or may reasonably be expected to exceed the PEL and where employees handle or use non-airborne MDA liquids or mixtures. Regulated areas must be demarcated from the rest of the workplace so that potential exposure is limited. Only authorized personnel may enter regulated areas. All persons who enter must be supplied with, and required to use, personal protective equipment and clothing. No eating, drinking, smoking, chewing of tobacco or gum, or applying of cosmetics is permitted in regulated areas. Warning signs must be posted in each regulated area and at all entrances or accessways to the areas. These signs must bear the following information: Labels and Signs The employer must ensure that labels or other appropriate forms of warning are provided for containers of MDA anywhere in the workplace. The labels shall comply with the requirements of OSHA's Hazard Communication Standard, 29 CFR 1910.1200(f)5 and include the following legends: Labels for containers of Pure MDA must contain the following information: Warning labels for containers of Mixtures containing MDA must include the following information: Exposure Monitoring and Medical Surveillance Each employer who has a workplace or worksite covered by this standard must perform initial monitoring for all employees who are, or may reasonably be expected to be, exposed to airborne concentrations of MDA at or above the action level. If the required initial monitoring reveals employee exposure at or above the action level, but at or below the PEL, the employer must repeat monitoring at least every 6 months. If exposure is above the PEL, the employer must repeat monitoring at least every 3 months. If initial monitoring reveals employee exposure to be below the action level, the employer may discontinue the monitoring for those employees whose exposures are represented by such monitoring. The employer must reinitiate monitoring when there has been a change in production process, chemicals, control equipment, personnel, or work practices that may result in new or additional exposures to MDA or when there is any reason to suspect a change that may result in new or additional exposures. Routine inspections of employee dermal areas (hands, face, forearms) potentially exposed to MDA must be performed by the employer. Other potential dermal exposure must be referred to medical personnel for observation. If the employer determines an employee has been exposed to MDA, the employer must locate the source, implement protective measures for correction, and maintain records of corrective actions. Employees must be notified in writing, either individually or by posting of results in an accessible location, within 15 days after the receipt of results of any monitoring performed. The written notification must contain corrective action being taken to reduce employee exposure to or below the PEL, whenever the PEL is exceeded. The employer also must institute a medical surveillance program for employees who -- are exposed to MDA at or above the action level for 30 or more days per year; are subject to dermal exposure for 15 or more days per year; are exposed in emergency situations; and the employer has reason to believe are being dermally exposed or who show signs or symptoms of MDA exposure. Each employee must receive an initial medical exam within 150 days of the effective date of this standard or before the time of initial assignment. The physical exam must include all routine exam parameters and exams for signs of liver disease and skin exposure. Lab tests must include liver function tests and urinalysis as well as additional tests necessary in the opinion of the physician. All medical exams and procedures must be performed by or under the supervision of a licensed physician, provided at no cost to the employee, and given at a reasonable time and place. Follow-up medical exams must be provided at least annually after the initial exam. Also, if an employee is exposed to a potentially hazardous amount of MDA in an emergency situation, the employer must provide a medical exam at that time. The employer must provide the examining physician the following information: a copy of the OSHA MDA regulation and its appendices; a description of the affected employee's duties as related to potential exposure to MDA; the current actual or representative MDA exposure level; a description of personal protective equipment currently in use or recommended; and information from previous employment-related medical exams. The employer must provide a written copy of the examining physician's opinion to the affected employee within 15 days of receipt. The report should include -- occupationally pertinent results of the exam and test; the physician's opinion on detected medical conditions that would place the employee at an increased risk of material impairment of health from exposure to MDA; physician recommended limits upon the employee's exposure to MDA or upon use of personal protective equipment and clothing and respirators; and a statement that the employee has been informed by the physician of results of the medical exam and medical conditions resulting from MDA exposure, which require further explanation or treatment. The physician, however, is not to reveal in the written opinion given to the employer any specific findings or diagnoses unrelated to occupational exposure to MDA. Methods of Compliance Compliance Program A written compliance program must be established and implemented to reduce employee exposure to the PEL or below by the use of engineering and work practice controls and by the use of respiratory protection where permitted. The plan must include a schedule for periodic maintenance and a written plan for emergency situations. The emergency plan must specifically provide that employees engaged in correcting emergency conditions be equipped with the appropriate required personal protective equipment and clothing until the emergency is abated. A provision for alerting and evacuating affected employees also must be included. Employees who face potential exposure (direct and indirect) to MDA must be alerted promptly. Those employees not engaged in correcting the emergency must be evacuated immediately. The written plans must be reviewed at least once every 12 months to ensure they reflect the current status of the program. The written compliance program must be made available for examination and copying to the Assistant Secretary for OSHA, the Director of the National Institute for Occupational Safety and Health (NIOSH), and affected employees and their designated representatives, upon request. Control Measures Engineering and work practice controls are the primary methods used to reduce occupational exposure to MDA. Engineering controls and work practices must be instituted to reduce and maintain employee exposure to MDA at or below the PEL except when the employer can establish that these controls are not feasible. Engineering controls reduce employee exposure in the workplace either by removing or isolating the hazard or isolating the worker from exposure. Local exhaust ventilation, general ventilation systems, and special isolation devices or enclosures are examples of engineering controls. Engineering controls must be examined and maintained, or replaced, on a scheduled basis. In circumstances where engineering controls alone do not reduce MDA exposure to the PEL, however, respiratory protection must be used as well. Proper work practice controls reduce the likelihood of exposure by altering the manner in which a task is performed. Safe work practices required under the MDA standard include, but are not limited to, maintaining separate hygiene facilities (i.e., lunchrooms, change areas, and shower facilities) and requiring proper housekeeping practices (visual inspection program, clean-up methods, waste removal practices). Under the MDA standard, the administrative control of temporary removal may be instituted to remove the worker from the hazard in the workplace, when appropriate. Worker rotation, however, cannot be used to reduce exposures to MDA. Respiratory Protection Where feasible engineering controls and work practices are not sufficient to reduce MDA exposure to the PEL or below, the employer must use them to reduce employee exposure to the lowest achievable levels and supplement them through the use of respirators. Respirators must be used in the following circumstances: while feasible engineering and work practice controls are being installed or implemented; in work operations for which engineering and work practice controls are not feasible; in work situations where feasible engineering and work practice controls are not yet sufficient to reduce exposure to or below the PEL; and in emergencies. Respirators must be selected from among those approved by the Mine Safety and Health Administration (MSHA) and NIOSH. Where respiratory protection is required, the employer must develop a respiratory protection program. Respirators and the respiratory protection program must be provided at no cost to the employee. If employees cannot wear negative-pressure respirators, they must be given the option of wearing a positive-pressure respirator or a supplied-air respirator operated in continuous flow or pressure demand mode. Where air-purifying respirators are used, the air-purifying element must be replaced as needed, to maintain effectiveness. Respirator fit testing must be performed and the results recorded at the time of initial fitting and at least annually thereafter for negative-pressure respirators. Hygiene Facilities and Practices Employees required to work in regulated areas must be provided clean change rooms, shower facilities, and lunchrooms. Separate storage of personal protective equipment and clothing and street clothes must be maintained. Employees must shower at the end of a work shift and may not leave the worksite wearing any protective equipment or clothing worn during the work shift. Where dermai exposure to MDA occurs, materials spilled on the skin must be removed as soon as possible by methods that do not facilitate the dermai absorption of MDA. Separate lunchroom facilities located within the workplace and in areas of potential airborne exposure to MDA must have a positive-pressure, temperature controlled, filtered air supply. Lunch areas may not be located in areas within the workplace where the potential of dermal exposure to MDA exists. Employees must wash their hands and faces prior to eating, drinking, smoking, or applying cosmetics. No employees may enter the lunchroom with protective equipment or clothing. Housekeeping All surfaces must be maintained as free as possible of accumulations of MDA. A regular visual inspection program must be instituted to detect MDA leaks, spills, or discharges. All leaks must be repaired, and liquid or dust spills promptly cleaned. Compressed air may not be used to clean contaminated surfaces. Shoveling, dry sweeping, and other methods of dry clean-up maybe used where HEPA6 -filtered vacuuming and/or wet cleaning are not feasible or practical. All waste, scrap, debris, bags, containers, equipment, or clothing contaminated with MDA must be collected and disposed of in a way that prevents re-entry of MDA into the workplace. Temporary Removal An employee must be removed from work environments in which exposure to MDA is at or above the action level or where dermal exposure to MDA may occur following an initial exam, periodic exams, an emergency situation, or an additional examination when the employee exhibits signs and/or symptoms indicative of acute exposure to MDA; or the examining physician determines that an employee's abnormal liver function tests are not associated with MDA exposure but that the abnormalities may be exacerbated as a result of occupational exposure to MDA. Following a final medical determination that the employee has a detected medical condition that increases the risk of material impairment of health from MDA exposure, the employer must remove the employee from work environments in which exposure to MDA is at or above the action level or where dermal exposure to MDA may occur. Employees may return to former job status when they no longer show signs or symptoms of exposure to MDA; upon the advice of the physician; or when a subsequent final medical determination results in a medical finding" that employees no longer have a detected medical condition that puts them at risk. Personal Protective Equipment and Clothing The employer must provide, at no cost to the employee, and ensure use of personal protective equipment and clothing to prevent contact with MDA where: employees are subject to dermal exposure to MDA; liquids containing MDA can be splashed into the eyes; and airborne concentrations of MDA are in excess of the PEL. Recommended personal protective equipment and clothing includes, but is not limited to aprons, coveralls or full-body work clothing, gloves, head and foot coverings, face shields, and splashproof safety goggles. Employees must remove MDA-contaminated protective equipment and clothing in change rooms at the end of the work shift. Contaminated work clothing or equipment must be stored in closed labeled containers. Only authorized employees may take contaminated equipment or clothing out of change rooms for laundering, maintenance, or disposal. The employer must ensure that personal protective equipment and clothing is laundered, cleaned, repaired, or replaced to maintain its effectiveness. Contaminated clothing must be transported in properly labeled, sealed, impermeable bags or containers. Any person who launders or cleans MDA-contaminated clothing or equipment must be informed of the potentially harmful effects of exposure. The employer also must make known that removal of MDA by blowing or shaking is prohibited. Recordkeeping The employer must establish and maintain an accurate record of all monitoring data as well as objective data used to demonstrate that the processing, use, or handling of products is exempt from requirements of the standard for initial monitoring. The employer must keep for 30 years an accurate record of all measurements taken to monitor employees' exposure to MDA. This record must include: the date of measurement, number, duration, and results of each sample taken, including a description of the procedure used to determine representative employee exposures; identification of the sampling and analytical methods used; a description of the type of respiratory protective devices worn; and the name, social security number, job classification, and exposure levels for each employee monitored and all other employees whose exposure measurement it represents. The employer must maintain an accurate record for each employee subject to medical surveillance. The record must include: the name, social security number, and description of duties; a copy of the examining physician's written opinion on initial, periodic, or special exams -- including results of medical exams and all tests, opinions, and recommendations; results of airborne exposure monitoring done for the employee and the representative exposure levels supplied to the physician; and any employee medical complaints related to exposure to MDA. All required, maintained records must be made available, upon request, to the OSHA Assistant Secretary and the Director of NIOSH in accordance with Access to Employee Exposure and Medical Records, 29 CFR 1910.20. If the employer ceases to do business and there is no successor to receive the records, the employer must notify the Director of NIOSH, at least 90 days prior to termination, and transmit the records to the Director within that period. Training and Information In addition to the warning signs and labels required in regulated areas and on MDA containers, employers must provide material safety data sheets (MSDSs) and training and written information on MDA. MSDSS must comply with OSHA's Hazard Communication Standard, 29 CFR 1910.1200. Also, the employer must develop a training program for all employees exposed to airborne concentrations of MDA in accordance with provisions of the Hazard Communication Standard. Training must be provided at the time of initial assignment and at least annually thereafter. The content of the training program is intended to inform employees of the hazards to which they are exposed; the necessary steps to protect themselves, including those to be taken during emergency situations; limitations and the proper use of respirators and protective equipment; a description of medical examinations and their purpose; and implementation of work practices and the use of available engineering controls. The employer also must provide an explanation of the contents of the MDA standard and where a copy is available; describe the required medical surveillance program; and describe the medical removal provision. All training materials, including a copy of the MDA standard, must be available in writing to all employees without cost and to the Assistant Secretary of OSHA and the Director of NIOSH, upon request. Other Sources of OSHA Assistance Safety and Health Management Guidelines Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and illnesses and their related costs. To assist employers and employees in developing effective safety and health programs, OSHA published recommended Safety and Health Management Guidelines (January 26, 1989, 54 FR: 3908-3916). These voluntary guidelines apply to all places of employment covered by OSHA. The guidelines identify four general elements that are critical to the development of a successful safety and health management program: management commitment and employee involvement, worksite analysis, hazard prevention and control, and safety and health training. The guidelines recommend specific actions, under each of these general elements, to achieve an effective safety and health program. State Programs The Occupational Safety and Health Act of 1970 encourages states to develop and operate their own job safety and health plans. OSHA approves and monitors these plans. There are currently 25 state plan states; 23 of these states administer plans covering both private and public (state and local government) employment; the other 2 states, Connecticut and New York, cover the public sector only. The 25 states and territories with their own OSHA-approved occupational safety and health plans must adopt standards identical to, or at least as effective as, the federal standards. Until a state standard is promulgated, OSHA will provide interim enforcement assistance, as appropriate, in these states. A listing of states with approved plans appears at the end of this booklet. Consultation Services Consultation assistance is available on request to employers who want help in establishing and maintaining a safe and healthful workplace. Largely funded by OSHA, the service is provided at no cost to the employer. Primarily developed for smaller employers with more hazardous operations, the consultation service is delivered by state government agencies or universities employing professional safety consultants and health consultants. Comprehensive assistance includes an appraisal of all mechanical, physical work practices, and environmental hazards of the work-place and all aspects of the employer's present job safety and health program. No penalties are proposed or citations issued for hazards identified by the consultant. For more information concerning consultation assistance, see the list of consultation projects listed at the end of this publication. Voluntary Protection Programs (VPPs) Voluntary protection programs and onsite consultation services, when coupled with an effective enforcement program, expand worker protection to help meet the goals of the OSH Act. The three VPPs -- Star, Merit, and Demonstration -- are designed to recognize outstanding achievement by companies that have successfully incorporated comprehensive safety and health programs into their total management system. They motivate others to achieve excellent safety and health results in the same outstanding way as they establish a cooperative relationship between employers, employees, and OSHA. For additional information on VPPS and how to apply, contact the OSHA national, regional, or area offices listed at the end of this publication. Training and Education OSHA's area offices offer a variety of informational services, such as publications, audiovisual aids, technical advice, and speakers for special engagements. OSHA's Training Institute in Des Plaines, IL, provides basic and advanced courses in safety and health for federal and state compliance officers, state consultants, federal agency personnel, and private sector employers, employees, and their representatives. OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace training and education in subjects where OSHA believes there is a lack of workplace training. Grants are awarded annually, with a 1-year renewal possible. Grant recipients are expected to contribute 20 percent of the total grant cost. For more information on grants, training and education, contact the OSHA Training Institute, Office of Training and Education, 1555 Times Drive, Des Plaines, IL 60018, (708) 297-4810. For further information on any OSHA program, contact your nearest OSHA regional or area office listed at the end of this publication. Glossary Authorized person - Any person specifically authorized by the employer and whose duties require the person to enter a regulated area, or any person entering such an area as a designated representative of employees, for the purpose of exercising the right to observe monitoring and measuring procedures. Container - Any barrel, bottle, can, cylinder, drum, reaction vessel, storage tank, commercial packaging or the like, but does not include piping systems. Emergency - Any occurrence such as equipment failure, rupture of containers, or failure of control equipment that results in an unexpected and potentially hazardous release of MDA. Finished article containing MDA - A manufactured item formed to a specific shape or design during manufacture; that has end -- use function(s) dependent in whole or part upon its shape or design during end use; and that is fully cured by virtue of having been subjected to the conditions (temperature, time) necessary to complete the desired chemical reaction. Dermal exposure to MDA - Exposure to the skin that occurs where employees are engaged in the handling application, or use of mixtures or materials containing MDA, with any of the following non-airborne forms of MDA: liquid, powdered, granular, or flaked mixtures containing MDA in concentration greater than 0.1 percent by weight or volume; and materials other than "finished articles containing MDA" in concentration greater than 0.1 percent by weight or volume. 4,4' Methylenedianiline or MDA - The chemical, 4,4'-diaminodiphenylmethane, Chemical Abstract Service Registry number 101-77-9, in the form of a vapor, liquid, or solid. The definition also includes the salts of MDA. Regulated areas - Areas where airborne concentrations of MDA exceed or can reasonably be expected to exceed the permissible exposure limits or where dermal exposure to MDA can occur. STEL - Short-term exposure limit as determined by any 15-minute sampling period. Related Publications Single free copies of the following publications can be obtained from the OSHA Publications Office, 200 Constitution Avenue, NW, Washington, DC 20210. Send a self-addressed mailing label with your request. All About OSHA - OSHA 2056 Chemical Hazard Communication - OSHA 3084 Consultation Services for the Employer - OSHA 3047 How to Prepare for Workplace Emergencies - OSHA 3088 OSHA Employee Workplace Rights - OSHA 3021 OSHA Inspections - OSHA 2098 Personal Protective Equipment - OSHA 3151 Respiratory Protection - OSHA 3079 The following publications are available from the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402, (202) 783-3238. Include GPO Order No. and make checks payable to Superintendent of Documents. Hazard Communication - A Compliance Kit (OSHA 3104) (A reference guide to step-by-step requirements for compliance with the OSHA standard.) Order No. 929-022-00000-9; cost $18.00 domestic; $22.50 foreign. Hazard Communication Guidelines for Compliance (OSHA 3111 ) Order No. 029-016-00127-1; cost $1.00. Principal Emergency Response and Preparedness Requirements in OSHA Standards and Guidance for Safety and Health Programs (OSHA 3122) Order No. 029-016-00136-1; cost $2.50. Training Requirements in OSHA Standards and Training Guidelines (OSHA 2254) Order No. 029-016-00137-9; cost $4.25. States with Approved Plans States administering their own occupational safety and health programs through plans approved under section 18(b) of the Occupational Safety and Health Act of 1970 must adopt standards and enforce requirements that are at least as effective as federal requirements. There are currently 25 state plan states; 23 cover the private and public (state and local government) sectors and 2 cover the public sector only (Connecticut and New York). COMMISSIONER Alaska Department of Labor 1111 West 8th Street Room 306 Juneau, AK 99801 (907) 465-2700 DIRECTOR Industrial Commission of Arizona 800 W. Washington Phoenix, AZ 85007 (602) 542-5795 DIRECTOR California Department of Industrial Relations 455 Golden Gate Avenue 4th Floor San Francisco, CA 94102 (415) 703-4590 COMMISSIONER Connecticut Department of Labor 200 Folly Brook Boulevard Wethersfield, CT 06109 (203) 566-5123 DIRECTOR Hawaii Department of Labor and Industrial Relations 830 Punchbowl Street Honolulu, HI 96813 (808) 586-8844 COMMISSIONER Indiana Department of Labor State Office Building 402 West Washington Street Room W195 Indianapolis, IN 46204-2287 (317) 232-2378 COMMISSIONER Iowa Division of Labor Services 1000 E. Grand Avenue Des Moines, IA 50319 (51 5) 281-3447 SECRETARY Kentucky Labor Cabinet 1049 U.S. Highway, 127 South Frankfort, KY 40601 (502) 564-3070 COMMISSIONER Maryland Division of Labor and Industry Department of Licensing and Regulation 501 St. Paul Place, 2nd Floor Baltimore, MD 21202-2272 (301) 333-4179 DIRECTOR Michigan Department of Labor Victor Office Center 201 N. Washington Square P.O. Box 30015 Lansing, Ml 48933 (517) 373-9600 DIRECTOR Michigan Department of Public Health 3423 North Logan Street Box 30195 Lansing, Ml 48909 (517) 335-8022 COMMISSIONER Minnesota Department of Labor and Industry 443 Lafayette Road St. Paul, MN 55155 (612) 296-2342 Nevada Department of Industrial Relations Division of Occupational Safety and Health Capitol Complex 1370 S. Curry Street Carson City, NV 89710 (702) 687-3032 SECRETARY New Mexico Environment Department Occupational Health and Safety Bureau 1190 St. Francis Drive P.O. BOX 26110 Santa Fe, NM 87502 (505) 827-2850 COMMISSIONER New York Department of Labor State Office Building Campus 12-Room 457 Albany, NY 12240 (518) 457-2741 COMMISSIONER North Carolina Department of Labor 4 West Edenton Street Raleigh, NC 27601 (919) 733-0360 ADMINISTRATOR Oregon Occupational Safety and Health Division Oregon Department of Insurance and Finance, Room 160 Labor and Industries Building Summer and Chemeketa Streets, NE Salem, OR 97310 (503) 378-3272 SECRETARY Puerto Rico Department of Labor and Human Resources Prudencio Rivera Martinez Building 505 Munoz Rivera Avenue Hato Rey, PR 00918 (809) 754-2119 COMMISSIONER South Carolina Department of Labor 3600 Forest Drive P.O. BOX 11329 Columbia, SC 29211-1329 (803) 734-9594 COMMISSIONER Tennessee Department of Labor 501 Union Building Suite "A" - 2nd Floor Nashville, TN 37243-0655 (615) 741-2582 ADMINISTRATOR Utah Occupational Safety And Health 160 East 300 South P.O. BOX 5800 Salt Lake City, UT 84110-5800 (801 ) 530-6900 COMMISSIONER Vermont Department of Labor and Industry 120 State Street Montpelier, VT 05620 (802) 828-2288 COMMISSIONER Virgin Islands Department of Labor 2131 Hospital Street Christiansted St. Croix, VI 00840-4666 (809) 773-1994 COMMISSIONER Virginia Department of Labor and Industry Powers-Taylor Building 13 South 13th Street Richmond, VA 23219 (804) 786-2376 DIRECTOR Washington Department of Labor and Industries General Administration Building 11th & Columbia Streets Room 334-AX-31 Olympia, WA 98504-0631 (206) 753-6307 DIRECTOR Department of Employment Division of Employment Affairs Occupational Safety and Health Administration Herschler Building, 2nd Floor East 122 West 25th Street Cheyenne, WY 82002 (307) 777-7672 OSHA Consultation Project Directory Consultation programs provide free services to employers who request help in identifying and correcting specific hazards, want to improve their safety and health programs, and/or need further assistance in training and education. Funded by OSHA and delivered by well-trained professional staff of state governments, consultation services are comprehensive, and include an appraisal of all workplace hazards, practices, and job safety and health programs; conferences and agreements with management; assistance in implementing recommendations; and a follow-up appraisal to ensure that any required corrections are made. For more information on consultation programs, contact the appropriate office in your state listed below. State Telephone      Alabama (205) 348-3033      Alaska (907) 264-2599      Arizona (602) 542-5795      Arkansas (501) 682-4522      California (415) 703-4441      Colorado (303) 491-6151      Connecticut (203) 566-4550      Delaware (302) 577-3908      District of Columbia (202) 576-6339      Florida (904) 488-3044      Georgia (404) 894-8274      Guam (671) 646-9244      Hawaii (808) 548-4155      Idaho (208) 385-3283      Illinois (312) 814-2337      Indiana 317) 232-2688      Iowa (515) 281-5352      Kansas (913) 296-4386      Kentucky (502) 564-6895      Louisiana (504) 342-9601      Maine (207) 289-6460      Maryland (301) 333-4218      Massachusetts (617) 727-3463      Michigan (517) 335-8250(H) (517) 322-1809(S) Minnesota (612) 297-2393      Mississippi (6Ol) 987-3981      Missouri (314) 751-3403      Montana (406) 444-6401      Nebraska (402) 471-4717      Nevada (702) 486-5016      New Hampshire (603) 271-2024      New Jersey (609) 292-7036      New Mexico (505) 827-2885      New York (518) 457-2481      North Carolina (919) 733-3949      North Dakota (701) 221-5188      Ohio (614) 644-2631      Oklahoma (405) 528-1500      Oregon (503) 378-3272      Pennsylvania (412) 357-2561      Puerto Rico (809) 754-2171      Rhode Island (401) 277-2438      South Carolina (803) 734-9599      South Dakota (605) 688-4101      Tennessee (615) 741-7036      Texas (512) 440-3834      Utah (801) 530-6868      Vermont (802) 828-2765      Virginia (804) 786-6613      Virgin Islands (809) 772-1315      Washington (206) 586-0963      West Virginia (304) 348-7890      Wisconsin (608) 266-8579(H) (414) 521-5063(S) Wyoming (307) 777-7786      H - Health S - Safety OSHA Area Offices Area Telephone Albany, NY (518) 464-6742 Albuquerque, NM (505) 766-3411 Allentown, PA (215) 776-0592 Anchorage, AK (907) 271-5152 Appleton, WI (414) 734-4521 Augusta, ME (207) 622-8417 Austin, TX (512) 482-5783 Avenel, NJ (908) 750-3270 Baltimore, MD (410) 962-2840 Baton Rouge, LA (504) 389-0474 Bayside, NY (718) 279-9060 Bellevue, WA (206) 553-7520 Billings, MT (406) 657-6649 Birmingham, AL (205) 731-1534 Bismarck, ND (701) 250-4521 Boise, lD (208) 334-1867 Bowmansville, NY (716) 684-3891 Braintree, MA (617) 565-6924 Bridgeport, CT (203) 579-5579 Calumet City, IL (708) 891-3800 Carson City, NV (702) 885-6963 Charleston, WV (304) 347-5937 Cincinnati, OH (513) 841-4132 Cleveland, OH (216) 522-3818 Columbia, SC (803) 765-5904 Columbus, OH (614) 469-5582 Concord, NH (603) 225-1629 Corpus Christi, TX (512) 888-3257 Dallas, TX (214) 320-2400 Denver, CO (303) 844-5285 Des Plaines, IL (708) 803-4500 Des Moines, 1A (515) 284-4794 Englewood, CO (303) 843-4500 Erie, PA (814) 833-5758 Fort Lauderdale, FL (305) 424-0242 Fort Worth, TX (817) 885-7025 Frankfort, KY (502) 227-7024 Harrisburg, PA (717) 782-3902 Hartford, CT (203) 240-3152 Hasbrouck Heights, NJ (201) 288-1700 Hato Rey, PR (809) 766-5457 Honolulu, HI (808) 541-2685 Houston, TX (713) 286-0583 Houston, TX (713) 591-2438 Indianapolis, IN (317) 226-7290 Jackson, MS (601) 965-4606 Jacksonville, FL (904) 232-2895 Kansas City, MO (816) 483-9531 Lansing, Ml (517) 377-1892 Little Rock, AR (501) 324-6291 Lubbock, TX (806) 743-7681 Madison, Wl (608) 264-5388 Marlton, NJ (609) 757-5181 Methuen, MA (617) 565-8110 Milwaukee, WI (414) 297-3315 Minneapolis, MN (612) 348-1994 Mobile, AL (205) 441-6131 Nashville, TN (615) 781-5423 New York, NY (212) 264-9840 Norfolk, VA (804) 441-3820 North Aurora, IL (708) 896-8700 Oklahoma City, OK (405) 231-5351 Omaha, NE (402) 221-3182 Parsippany, NJ (201) 263-1003 Peoria, IL (309) 671-7033 Philadelphia, PA (215) 597-4955 Phoenix, AZ (602) 640-2007 Pittsburgh, PA (412) 644-2903 Portland, OR (503) 326-2251 Providence, RI (401) 528-4669 Raleigh, NC (919) 856-4770 Salt Lake City, UT (801) 486-8405 San Francisco, CA (415) 744-7120 Savannah, GA (912) 652-4393 Smyrna, GA (404) 984-8700 Springfield, MA (413) 785-0123 St. Louis, MO (314) 425-4249 Syracuse, NY (315) 451-0808 Tampa, FL (813) 626-1177 Tarrytown, NY (914) 682-6153 Toledo, OH (419) 259-7542 Tucker, GA (404) 493-6644 Westbury, NY (516) 334-3344 Wichita, KS (316) 269-6644 Wilkes-Barre, PA (717) 826-6538 U.S. Department of Labor Occupational Safety and Health Administration Regional Offices Region I (CT,* MA, ME, NH, RI, VT*) 133 Portland Street 1st Floor Boston, MA 02114 Telephone: (617) 565-7164 Region II (NJ, NY,* PR,* VI*) 201 Varick Street Room 670 New York, NY 10014 Telephone: (212) 337-2378 Region III (DC, DE, MD,* PA, VA,* WV) Gateway Building, Suite 2100 3535 Market Street Philadelphia, PA 19104 Telephone: (215) 596-1201 Region IV (AL, FL, GA, KY,* MS, NC,* SC,* TN,*) 1375 Peachtree Street, N.E. Suite 587 Atlanta, GA 30367 Telephone: (404) 347-3573 Region V (IL, IN,* MI,* MN,* OH, WI) 230 South Dearborn Street Room 3244 Chicago, IL 60604 Telephone: (312) 353-2220 Region VI (AR, LA, NM,* OK, TX) 525 Griffin Street Room 602 Dallas, TX 75202 Telephone: (214) 767-4731 Region VII (IA,* KS, MO, NE) 911 Walnut Street, Room 406 Kansas City, MO 64106 Telephone: (816) 426-5861 Region VIII (CO, MT, ND, SD, UT,* WY*) Federal Building, Room 1576 1961 Stout Street Denver, CO 80294 Telephone: (303) 844-3061 Region IX (American Samoa, AZ,* CA,* Guam, HI,* NV,* Trust Territories of the Pacific) 71 Stevenson Street Room 415 San Francisco, CA 94105 Telephone: (415) 744-6670 Region X (AK,* ID, OR,* WA*) 1111 Third Avenue Suite 715 Seattle, WA 98101-3212 Telephone: (206) 553-5930 Footnote(1) Preamble to Occupation/ Exposure to 4,4' Methylenedianiline (MDA); Final Rule, as cited in section 4(f) of the Toxic Substances Control Act (TSCA) on April 27, 1983 (48 FR 19078), (FR 57(154):35631, August 10, 1992). (Back to Text) Footnote(2) (FR 57(154):35633, August 10, 1992). (Back to Text) Footnote(3) (FR 57(154):35641, August 10, 1992). (Back to Text) Footnote(4) The employer must maintain records of the initial monitoring results or the objective data that support the exemption. (Back to Text) Footnote(5) Under the provisions of 29 CFR 1910.1200, employers are responsible for informing employees of the hazards and the identities of workplace chemicals to which they are exposed to when working. (Back to Text) Footnote(6) High efficiency particulate air (HEPA) filter. (Back to Text) Footnote(*) These states and territories operate their own OSHA-approved job safety and health programs (the Connecticut and New York plans cover public employees only). States with approved programs must have a standard that is identical to, or at least as effective as, the federal standard. (Back to Text)

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