Text For Citation: 01 Item/Group: 001B 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: (a)In that the employer failed to keep the workplace free from the hazard of employee overexposure to Isocyanate containing compounds which can cause health effects such as, but not limited to, skin and respiratory sensitization, corneal damage, pulmonary edema up to and including death. The Isocyanate containing compounds included, but were not limited to, Hexamethylene diisocyanate (HDI) (Chemical Abstract Service (CAS) #822-06-0), HDI Homopolymer (Synonym; Aliphatic polyisocyanate resin) (CAS #28182-81-2), and HDI Biuret (CAS #4035-89-6). On, or about March 11, 2006 a spray painter was exposed to 0.0028 milligrams of HDI per cubic meter of air (mg/m3), 0.3766 mg/m3 of HDI Homopolymer, and 0.2605 mg/m3 of HDI Biuret for a 33 minute personal sampling period. The sampling period occurred while the employee was spray painting and coating emergency vehicle door parts in the paint spray booth with products such as, but not limited to, Dupont Performance Coatings 194S and 196S Hardeners. The employee wore a Tyvek protective suit, latex gloves, a ballcap, and a North 7700 dual cartridge half mask air purifying respirator with organic vapor cartridges during the exposure period. Among other methods, one feasible and acceptable abatement method to correct this hazard is to undertake the following steps; - Follow the coating manufacturer's hazard identification information, and exposure control and personal protection recommendations such as, but not limited to, the information and recommendations contained in Dupont Performance Coatings material safety data sheet for Isocyanate Activators, Hardeners, and Additives. - Develop a comprehensive, periodic air contaminant sampling program that utilizes methods such as, but not limited to, the National Institute for Occupational Safety and Health (NIOSH) Method 5525 in order to determine employee exposure to Total Reactive Isocyanate Groups (TRIG) that are contained in various Isocyanate containing compounds of monomer and oligomer composition such as, but not limited to, HDI, HDI Homopolymer, and HDI Biuret. - Develop a comprehensive, periodic air contaminant sampling program in order to determine employee exposure to Isocyanate containing compounds that are formulated in various brands of paint and coatings, and various formulations within each brand. - Conduct spray finishing operations in a spray booth that includes effective, enclosed, local exhaust ventilation located as close to the point of chemical release as possible in order to remove airborne Isocyanate vapors and lower workplace exposure levels. - Develop effective employee work practices to minimize employee exposure to direct spray patterns and indirect vapor clouds. Abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.