Division of Labor and Industry

 

MOSH Instruction 15-9 - Focused Inspections

 
Subject: MOSH Instruction 15-10 National Emphasis Program - Occupational Exposure to Isocyanates
   
Effective Date: April 15, 2015
   
Issuance Date: April 15, 2015
   
Cancellation: None
   
Expiration Date: This instruction will expire three (3) years from the issuance date.
   
Purpose: This Instruction adopts the OSHA National Emphasis Program - Occupational Exposure to Isocyanates. This instruction describes policies and procedures for implementing the NEP to identify and reduce or eliminate the incidence of adverse health effects associated with occupational exposure to isocyanates.
 
Scope: MOSH-wide.
   
Reference: OSHA Directive CPL 03-00-017 National Emphasis Program - Occupational Exposure to Isocyanates
   
Contact: Chief of MOSH Compliance Services
See MOSH Website for Current Information
   
By and Under the Authority of: Eric M. Uttenreither, Assistant Commissioner
 

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:

  1. 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.
     
  2. Supervisors shall ensure that this instruction is reviewed with all compliance officers and consultation staff.
     
  3. Wherever the OSHA Directive reference job titles and officers, the equivalent MOSH job title or office shall apply.
     
  4. Program Procedures
     
      1. 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.
         
      2. 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.
         
      3. 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.
         
  5. 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.
     
  6. 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.
     
  7. 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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