Worker Protection
Always read and understand the spray foam manufacturer’s Material Safety Data Sheet (MSDS) before you start your SPF application. Many different variables are present during SPF application, so each case must be evaluated individually so that appropriate protection can be afforded.
Hazard Communications:
The OSHA Hazard Communications Standard was designed to provide employees with information on the identities and hazards of all chemicals used in the workplace and recommended protective measures. According to the OSHA Hazard Communications Standard (29 CFR 1910.1200), all employers are required to have a written hazard communications program to meet the requirements addressed in 29 CFR 1910.1200. Violations related to the Hazard Communications Standard are some of the most frequently cited by OSHA compliance officers. Requirements of the standard include development of a written program to address the followings components: labels and other forms of warning, MSDSs, and employee training and information.
Some questions for employers to consider include:
- Do you have a written Hazard Communication Program?
- Do you have a list of all chemicals in the workplace and their potential hazards?
- Are all Material Safety Data Sheets (MSDSs) readily accessible to every employee?
- Do you have MSDSs in a language that all employees can read and understand?
- Have your employees been trained on:
- Reading labels?
- Reading and understanding an MSDS?
- How to obtain and use hazard information?
- Appropriate work procedures?
- Emergency Procedures?
- Proper personal protective equipment for each job?
- Do you have a medical surveillance program for employees if hazardous chemicals are being used (such as respiratory and skin sensitizers)?
Labels and Other Forms of Warning:
According to the OSHA Hazard Communication Standard, chemical containers must be labeled and the information contained on the label must be legible and prominently displayed. Chemical labels identify the contents of a container used at a worksite. In addition, labels also convey information related to the toxicological, chemical, and physical properties associated with the chemical. It is good practice to maintain the original manufacturer’s label. When chemicals are transferred into unmarked containers, OSHA requires that these containers be labeled with the required information as well, except when transferred for immediate use by the employee who performed the transfer.
Many systems have been developed for labeling potentially hazardous chemicals. The two most common are the Hazardous Material Identification System (HMIS) and the National Fire Protection Association (NFPA) systems. A brief description of these follows. The HMIS refers to hazards during anticipated use while the NFPA system describes hazards under fire conditions. Therefore, the two systems may have different hazard categories for the same material.
An example of a typical HMIS hazard-warning label is shown below:
It ranks the hazard the material poses from 0 to 4 in these categories: Health (blue), Flammability (red), and Physical Hazard (yellow). A rank of 0 indicates that the material presents a minimal hazard for that category. A rank of 4 indicates a severe hazard for that category. The HMIS label also may depict the type of PPE required, but the narrative descriptions on the drum label and in the MSDS should be reviewed.
In the NFPA label, the left diamond is for the health ranking (blue), the top for the fire or flammability ranking (red), and the right for the instability ranking (yellow). The bottom diamond (white) denotes any other significant hazards associated with the material such as a chemical that is reactive with water.
Material Safety Data Sheets (MSDS):
As part of the Hazard Communications Standard, OSHA requires chemical manufacturers and importers to obtain or develop an MSDS for each hazardous chemical they produce or import. Employers are required to have an MSDS in the workplace for each hazardous chemical they use. If you do not have an MSDS for a chemical used at your worksite, contact the manufacturer.
Before using any SPF product, you should read and understand the entire MSDS for the product. The MSDS contains very important information about the product, including the chemicals constituents and the approximate concentrations; the PPE appropriate for the job; information on how to handle accidental releases; and information on storage, handling, transportation, and disposal.
Because these documents are so important, make them as readily accessible at a job site as possible. Keeping one clean copy of each MSDS in a clearly marked binder is a good practice that helps keep the information readily accessible. Many contractors like to keep several spare copies of MSDSs on hand; in the event of an emergency or incident, this allows multiple copies to be available for emergency responders. Another good practice is to review the location of the MSDS binder with all workers on the SPF jobsite before the job begins. Note that OSHA requires that all MSDS be readily available to all workers at the jobsite, which may include other trade workers.
Many MSDS are now available online, so workers with enabled mobile devices or in-truck internet service may also be able to access them electronically on site. In addition, it may be possible to obtain the MSDS in multiple languages if needed. Contact the manufacturer for more information, and refer to additional product stewardship guidance titled Have You Read the MSDS?
Employee Training and Information:
As a component of the OSHA Hazard Communication Standard, employees are provided Hazard Communication training upon initial assignment. The training includes information on the hazardous chemicals the employees are working with, the control measures to reduce the potential for exposure, and how to read the MSDS and product labels. The training also includes worksite-specific information including work practices, PPE to be used, and emergency procedures. OSHA requires that the employee have the opportunity to ask questions and be able to demonstrate comprehension.
The training must be understandable for the employee. When employees receive work instructions in languages other than English, employers are required to provide training in that language as well.
Additional training is needed when a new physical or health hazard is introduced into the work area. At multi-employer worksites, additional training may be needed so that all employees know where the MSDSs are located, details related to the labeling systems, and the hazards associated with other chemicals at the worksite they may be exposed to.
“Green” Marketing Claims and Hazard Communications:
"Green claims" are in many spray polyurethane foam advertisements, promotional materials, sales claims, and labels today. Green claims are the marketing response to consumers' increasing interest in protecting the environment. They can help consumers better understand the environmental attributes of a product or service, like its contribution to energy efficiency, and help inform purchasing decisions.
An SPF marketing claim often points out a particular product feature or benefit; for example, an SPF marketing claim may point out that a product is made using a renewable, plant-based resource. A properly qualified "green" marketing claim about a particular attribute, such as renewable content in a product, should never be confused with the toxicity profile of a product. Application and use instructions should always be consulted, including MSDS, manufacturer’s instructions, and label instructions. An SPF marketing claim should not be confused with instructions on how to safely use and apply the SPF product. See “Green Marketing Claims and SPF” for more information.