Text For Citation: 01 Item/Group: 001A Hazard: CHEMICAL

Section 5(a)(1) of the Occupational Safety and Health Act of %% 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to: a.Painter was exposed to the hazards of skin and respiratory allergic sensitization which are associated with excessive levels of 1,6-Hexamethylene diisocyanate homopolymer, a HDI polyisocyanate, in a spray painting operation. Employee was exposed to HDI polyisocyanates at short term intervals which exceeded the recommended guideline for a 15 minute short term exposure limit (STEL) established as 1.0 mg/m3. These exposures were derived from 4 of 8 samples collected over an 125 minute period. Employee was exposed to STEL levels of 4.1 mg/m3 over a 16 minute period, 3.1 mg/m3 over a 19 minute period, 5.6 mg/m3 over a 15 minute period, and 1.4 mg/m3 over a 13 minute period. Feasible and useful abatement methods for reducing or eliminating this hazard, among other methods are: 1.Substitution with paint systems which do not contain diisocyanates. 2.Design and build a paint spray booth/room. 3.Modify the existing area to increase ventilation. Investigate the possibility of lowering the existing fan along the southeast wall and add an additional fan along the northeast wall. This might require adding a new exit door on the north wall of the spray area. Consideration should be given to ignition sources at the point of exhaust if the fans are lowered. Installation of a false ceiling above the track of the overhead crane could also reduce the volume of air to evacuate and result in increased air flow. If this approach is taken, consideration should be given to installing partitions to isolate any light fixtures in the false ceiling and the overhead crane should be moved out of the area during painting activities. 3.Use of a different paint application system to reduce the amount of overspray generated. Abatement Schedule Step 1 - Effective respiratory protection shall be provided by 09/29/94 and used by exposed employees as an interim protective measure until feasible engineering and/or administrative controls can be implemented or whenever such controls fail to reduce employee exposure to within permissible exposure limits. Step 2 - A written detailed plan of abatement shall be submitted to the Area Director by 10/28/94 outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to hazardous substances as referenced in this citation. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the dates required by this citation: (1)Evaluation of engineering/administrative control options; (2)Selection of optimum control method and completion of design; (3)Procurement, installation and operation of selected control measures; (4)Testing and acceptance or modification/redesign of controls; All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person. 30-day progress reports are required during the abatement period. Step 3 - Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls. Verification of their effectiveness in achieving compliance shall be submitted by 11/29/94.