OSHA Inspections Are Now Targeting the SPF Industry
Sprayfoam.org just published an interesting article that everyone needs to read and take proper action on.OSHA's Directorite of Enforcement spoke at the SPFA convention in 2015 and noted that the top violations in the SPF field are:1. Improper or lack of ventilation in the work space.2.
Slip/fall issues related to becoming entangled in hoses.3. Exposure to trimming foam.4.
Lack of PPE (Personal Protective Equipment)5. PPE that is damaged and not cleaned - DAILY6. Hazard Communication (MSDS sheets, proper signage in the work space, controlled entry point)7.
Flammable Liquids not properly stored.8. Electrical wire violationsAs of December-2014, OSHA has conducted 386 inspections and cited 1351 violations. Fines on violations can start as high as $10,000 each.
This makes it more important than ever that you are familiar with the PPE program, Fit Test procedures and simple code corrections you can make that are very inexpensive to do.Here is a link to the OSHA directive on the SPF industry and the concerns they have with exposure to Isocyanates: https://www.osha.gov/OshDoc/Directive_pdf/CPL_03-...
Here is a list of the top violations found and the OSHA code you need to become familiar with.1: OSHA 29 CFR 1910.134 Respiratory Protection: http://www.ehso.com/OSHA1910_134.htm2: OSHA 29 CFR 1910.1200 Hazard Communication: http://www.ehso.com/OSHA1910_134.htm2: OSHA 29 CFR 1910.132 PPE Equipment: http://www.ehso.com/OSHA1910_134.htm2: OSHA 29 CFR 1910.107 Flammable Liquids: http://www.ehso.com/OSHA1910_134.htm2: OSHA 29 CFR 1910.305 Electrical Wiring:https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9882
If you are uncertain on what you need, there are consultants that are familiar with the OSHA reg's and they can come to your work place and point out what needs to be done in order to comply. The consultants do not fine you or write up violations to report to OSHA. They are truly there to help you.
As mentioned in the Sprayfoam article, you can call OSHA and ask about onsite consulting for small/medium businesses. I equate that to calling the IRS and asking for an audit to help you find improper book keeping procedures. I would prefer a private consultant and OSHA may be able to supply a list of them in your region.We had a consultant come to our office to discuss the program. Some general violations people have are in the electrical section. Extension cords as a permanent for of power are not permitted. If you have extension cords tied up in your trailer or in your shop, you need to run conduit and have a proper junction box. Also, surprising - Power Strips are a big NO-NO.
I know - everyone has a power strip with 5 cords plugged in. You are required to have proper junction boxes with an outlet for each cord to plug into. No power strips allowed. All electrical lines have to be in electrical conduit - not PVC pipe. Buy a steel cabinet for storing flammables in that is properly labeled and its best to not have a gallon can of gas in your trailer.
MSDS books have to be current. MSDS can be confusing. Its required for everything you have in your trailer, but I have never heard of an MSDS for water and Gatorade, but we do have them for hand soap. Procedures for spills have to be documented for the dumbest of all people to be able to read and follow the procedure. Ladders have to be stored out of the way, secured to the wall to prevent falling or creating a trip hazard. For work sites, you need a controlled entry point, signage that clearly states its a restricted area that requires proper PPE equipment.The list could go on forever. Bottom line is - you need to be familiar with the code and follow it.Link to the Sprayfoam.org article to read in its entirety: http://www.nxtbook.com/naylor/SPFQ/SPFQ0215/index.php#/46