Summary: This instruction combines enforcement and outreach efforts to raise awareness of employers, workers, and safety and health professionals of the serious health effects associated with occupational exposure to isocyanates, in the construction, maritime, and general industries. The health effects of occupational exposure to isocyanates include occupational asthma, irritation of the skin (dermatitis) and mucous membranes (eyes, nose, and throat), hypersensitivity pneumonitis, and chest tightness. Isocyanates include compounds also classified as potential human carcinogens and known to cause cancer in animals. This instruction sets forth a site selection system that focuses on multiple industries and will aim on evaluating inhalation, dermal, and other routes of occupational exposure to isocyanates.
Action:
- MOSH Compliance and consultation personnel shall ensure they utilize OSHA Directive CPL 03-00-017 while preparing for and performing on-site inspections and
visits in industries where occupational exposure to isocyanates is possible.
- Supervisors shall ensure that this instruction is reviewed with all compliance officers and consultation staff.
- Wherever the OSHA Directive reference job titles and officers, the equivalent MOSH job title or office shall apply.
- Program Procedures
- Industry Focus
Maritime establishments under MOSH jurisdiction, and general industry establishments with NAICS identified in Appendix A of the OSHA Directive with potential isocyanate exposure will be included in a randomized primary inspection list for the purposes of conducting this instruction. Inspections conducted on construction sites that include industries within the NAICS listed in Appendix A of the OSHA Directive will also be covered by this instruction.
- Site Selection
The Chief of Compliance or his designee will generate a master list that will then be randomized. This list will contain only those establishments with NAICS identified in Appendix A of the OSHA Directive. The list will be assigned in cycles consisting of 10 establishments. Establishments may be removed from the list by the Chief of Compliance, or designee, if it is known that the facility does not likely have isocyanate hazards or are no longer in business. An establishment may also be removed if it has had a comprehensive or focused health inspection that addressed isocyanate hazards, conducted within the current or previous three (3) fiscal years with no serious citations related to this
NEP, or where such citation(s) were issued but either a follow-up inspection documented appropriate and effective efforts (e.g., air sampling, install engineering controls) by the employer to abate serious hazards cited or where MOSH received notice and confirmed that all cited serious hazards had been abated. Any comprehensive/programmed planned inspection conducted under this instruction, by any
IH, will result in the company being removed from any inspection
list(s) created from this instruction. This does not preclude referrals to/from Safety or joint inspections.
- Inspection Scheduling
Within the specified cycle, inspections may be scheduled in any order that promotes efficient use of resources. Inspections conducted from the inspection list will generally focus only on the
operation(s) creating the potential occupational exposure to
isocyanates; however the inspection may be expanded to a comprehensive inspection if other serious workplace hazards or violations are observed. CSHOs shall contact their supervisor before expanding the scope of the inspection. Complaints and referrals received by MOSH Operations alleging potential exposure to isocyanates will be handled in accordance with MOSH FOM Chapter IX.
- Potential exposure to isocyanates identified during the course of any other inspection will be evaluated using the OSHA NEP as guidance. All inspections where isocyanate exposure is evaluated will be coded properly.
- This list will also serve as a state specific Isocyanate list for Consultation coding and focus efforts for
VPP, CCP, SHARP, Alliances, and Training and Education activities.
- The IMIS identifier code to be used will be "ISOCYAN8" and it must be entered in the appropriate OIS fields on the OIS form.
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