CPI - Alliance Agreement - September 13, 2017


The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) and the American Chemistry Council Center for the Polyurethanes Industry (CPI), Diisocyanates (DII) and Aliphatic Diisocyanates (ADI) Panels (hereafter known collectively as ACC) recognize the value of establishing a collaborative relationship to foster safer and more healthful American workplaces. To that end, OSHA and ACC hereby form an Alliance to provide members, occupational physicians, stakeholders, and others within the polyurethanes value chain with information, guidance, and access to training resources that will help them protect the health and safety of workers, particularly by: 1) illustrating methods for reducing and preventing exposure to aliphatic and aromatic diisocyanates (MDI, TDI, HDI, HMDI, and IPDI); 2) providing a better understanding of the health issues, routes of exposure, and medical surveillance/clinical evaluation techniques related to diisocyanates; and 3) understanding the rights of workers and the responsibilities of employers under the Occupational Safety and Health Act (OSH Act).

This agreement provides a framework and objectives for the Alliance’s activities. Alliance participants will summarize specific activities and timeframes for completion in a written work plan.

Through the Alliance, the organizations will use relevant injury, illness, and hazard exposure data, when appropriate, to help identify areas of emphasis for Alliance awareness, outreach, and communication activities. The Alliance will also explore and implement selected options, such as but not limited to member surveys, in order to evaluate the effectiveness of the Alliance and measure the impact of its overall effort on improving workplace safety for employers and workers. In developing this Alliance, OSHA and ACC recognize that OSHA’s State Plan and On-site Consultation Project partners are an integral part of the OSHA national effort, and that information about the products and activities of the Alliance may be shared with these partners for the advancement of common goals.

Raising Awareness of OSHA’s Rulemaking and Enforcement Initiatives

The Participants intend to work together to achieve the following objectives related to raising awareness of OSHA’s rulemaking and enforcement initiatives:

  • To share information on OSHA’s National Emphasis Programs, the Regulatory Agenda, and opportunities to participate in the rulemaking process.

  • To share information on occupational safety and health laws, standards, and guidance resources, including the rights and responsibilities of workers and employers.

Training and Education

The Participants intend to work together to achieve the following training and education objective:

  • To conduct effective web-based training to educate employers and workers on safe use and handling when working with diisocyanates, specifically potential routes of exposure to downstream users that will be shared with OSHA personnel and other industry safety and health professionals and incorporate learning evaluations to ensure training is effective.

Outreach and Communication

The Participants intend to work together to achieve the following outreach and communication objectives:

  • To develop information on the recognition and prevention of workplace hazards by developing medical surveillance guidance and workplace guidance documents on safe use and handling to prevent both inhalation and dermal exposure when working with diisocyanates and to develop ways of communicating such information (e.g., print and electronic media, electronic assistance tools, and OSHA’s and the ACC’s websites) to employers, workers in the industry, and health care professionals.

  • To speak, exhibit, or appear at OSHA or ACC conferences, local meetings, or other regional events.

  • To promote, through seminars and workshops, industry-wide use of medical surveillance programs, encouraging employers to develop new or enhance existing performance programs including the development of Safety and Health Management Systems.

OSHA’s Alliances provide parties an opportunity to participate in a voluntary cooperative relationship with OSHA for purposes such as raising awareness of OSHA’s rulemaking and enforcement initiatives, training and education, and outreach and communication. These Alliances have proven to be valuable tools for both OSHA and its Alliance participants. By entering into an Alliance with a party, OSHA is not endorsing or promoting, nor does it intend to endorse or promote, any of that party’s products or services.

An implementation team made up of representatives of each organization will meet to develop a plan of action, determine working procedures, and identify the roles and responsibilities of the participants. In addition, they will meet at least three times per year to track and share information on activities and results in achieving the goals of the Alliance. OSHA team members will include representatives of the Directorate of Cooperative and State Programs, the Directorate of Enforcement Programs, the Directorate of Construction, the Directorate of Standards and Guidance, the Directorate of Technical Support and Emergency Management, and any other appropriate offices. OSHA will encourage State Plan States and OSHA On-site Consultation Projects’ participation on the team.

This agreement will remain in effect for two years. Either signatory may terminate it for any reason at any time, provided they give 30 days written notice. This agreement may be modified at any time with the written concurrence of both signatories.

Signed this 13th day of September, 2017.

Loren Sweatt
Deputy Assistant Secretary of Labor
for Occupational Safety and Health

Lee Salamone
Senior Director
American Chemistry Council
Center for the Polyurethanes Industry (CPI)

Sahar Osman-Sypher
American Chemistry Council
Diisocyanates and Aliphatic Diisocyanates Panels