Contractor Health & Safety Partnership Program (CHSPP)
By now, most of you have heard about the Health & Safety Partnership Program that the North American Insulation Manufacturers’ Association (NAIMA) and the Insulation Contractors Association of America have entered into with OSHA. You have probably not heard much about the Contractor Health & Safety Partnership Program (CHSPP) which the NIA has entered into with OSHA. Although these programs are designed to accomplish the same end result concerning the use of synthetic vitreous fibers (SVF) in our industry, the CHSPP is significantly less onerous and it is focused for contractors in our industry.
As you can see from the following article submitted by Angus Crane, general counsel of NAIMA, NAIMA’s primary focus is the HSPP. NAIMA was the principle architect in this program and it was, as a result of working with NAIMA, ICAA, and OSHA, that the NIA Health & Safety Committee and subsequently the NIA Board of Directors determined that the HSPP, with modifications to fit our industry, would be appropriate for a working agreement with OSHA. As a result of this determination, the CHSPP was created.
The CHSPP does not create any new obligations for contractor members of the National Insulation Association. What this program does is recognize the warnings which are already contained in MSDSs issued by the manufacturers of SVF insulation materials to users of those materials when they are purchased. The MSDSs already establish a 1 f/cc permissible exposure limit for SVF materials. Under the OSHA hazard communication standard, this is sufficient to communicate the existence of a potential hazard to the users of SVF materials.
The CHSPP does create several obligations for the NIA. One of those obligations is to urge our members to cooperate with members of NAIMA in their efforts to gather data and develop information concerning the future use of SVF products. In addition, the NIA is committed to requesting that its members use and communicate information, developed and provided by NAIMA concerning the use of SVF products, to their employees. In the CHSPP, the NIA also agrees to communicate a recommended work practice to our members that they use personal respiratory protective equipment whenever they are removing SVF insulation materials which have gone to temperature and when they cannot demonstrate that their employees’ exposure to the SVF, which they are removing, is less than the PEL.
What is the CHSPP?
When the NAIMA approached NIA for it to participate in its Health & Safety Partnership Program (HSPP) concerning synthetic vitreous fibers, NIA reviewed the NAIMA proposal and determined that it was too broad and too restrictive for NIA’s contractor members. The NIA Health & Safety Committee, in conjunction with the NIA Board of Directors, drafted its own Health & Safety Partnership Program for contractors, which it designed specifically for members of NIA. The NIA program is titled “Contractor Health & Safety Partnership Program” (CHSPP) to eliminate confusion and/or misunderstandings which could have existed with NAIMA’s HSPP. The CHSPP is more advisory than it is mandatory and commits NIA to advising its members of the educational materials which will be produced by the members of NAIMA and to urging NIA members to use those materials.
What is the Health &
Safety Partnership Program (HSPP)?
The HSPP for SVF, rock wool, and slag wool is a compilation of NAIMA’s existing work practices and those of individual manufacturers into an organized information and training program. It is intended to formalize and consolidate existing industry worker protection practices by providing specific recommendations in training. Under the HSPP, NAIMA will provide work practices and training opportunities for employers and their workers. This will include training sessions and presentations at contractor events, as well as extensive promotion and development of brochures, posters, a training video, and other support materials.
What is the difference
between the CHSPP and the HSPP?
Both of these programs have been accepted and endorsed by the OSHA. The HSPP requires the manufacturers to be proactive in the development and communication of various types of training material and literature concerning the use of synthetic vitreous fibers (SVF) to the users of these products. Under the HSPP, NAIMA has also agreed to provide these materials, free of charge, to contractors and users. NAIMA has agreed to do air monitoring and other sampling with regard to SVF exposure and to develop better products which may ultimately warrant any type of work practices when using SVF unnecessary.
The CHSPP is a program developed specifically for NIA contractors. The CHSPP recognizes the efforts of NAIMA and the commitments made by NAIMA to further employee health issues. In the CHSPP, NIA has agreed to advise its members of NAIMA’s efforts and recommend to its members that they should use the materials made available by NAIMA when educating their employees concerning SVF. NIA has also agreed to encourage its members to continue to use engineering controls, work practices, and respiratory protection, or a combination thereof, to keep employee exposure to SVF below 1 f/cc over an 8-hour time-weighted average. Finally, NIA has agreed to recommend certain work practices to its members to employ when working with SVF products. Whereas the HSPP creates some mandatory obligations on the part of insulation manufacturers, the CHSPP is totally advisory with regard to making recommendations to NIA members.
Who was involved in the
development of the CHSPP and the HSPP?
The CHSPP was developed through the efforts of the NIA Health & Safety Committee and the NIA General Counsel. The position taken by NIA has been endorsed by both the Executive Committee and the Board of Directors. The HSPP was developed through the joint efforts of NAIMA, ICAA, and NIA.
Why do we need a CHSPP?
As a result of information developed from non-inhalation studies concerning SVF, SVF was identified as a potential carcinogen by different national and international organizations in 1993. Although no evidence existed to raise the level of concern for SVF beyond the potential carcinogen designation, this ranking came to the attention of OSHA, which put SVF on its regulatory agenda in December 1995. At that time, OSHA identified SVF as being a priority for rulemaking.
NAIMA approached OSHA with a concept of creating a voluntary standard or program to avoid the necessity of formal rulemaking for SVF. OSHA had taken the position that SVF should be treated much like asbestos for both insulation and removal purposes. After it was approached, OSHA agreed to permit NAIMA to develop a voluntary program to address OSHA’s concerns with regard to the SVF exposure.
In March 1998, NAIMA approached the NIA Health & Safety Committee with its proposal, which was identified at that time as a voluntary standard. The NIA Health & Safety Committee, General Counsel, and representatives of ICAA, reviewed this proposal and rejected it as not being supported by substantial medical documentation, and being overly broad and restrictive with regard to SVF insulation contractors. Although the road between March, 1998 and May 18, 1999, was at sometimes rocky, all participants finally agreed that some sort of voluntary guidance or program was needed to convince OSHA that formal rulemaking was not necessary.
Why does the CHSPP recommend exposure limit of 1 f/cc of air over an 8-hour time-weighted average?
The NIA Health & Safety Committee determined that it was in the best interest of SVF insulation workers to adopt an exposure limit that has been on most material safety data sheets that accompany SVF products for some time. Upon polling NIA members, we found the recommendation to be a relatively easy exposure level to meet and should not result in any hardship by NIA members.
Are there any situations where a respirator is recommended under the CHSPP?
There is only one situation in which the NIA agrees to recommend to its members that a respirator be used when working with SVF. This situation occurs during significant repair or demolition activity. Under these circumstances, NIA has agreed to recommend to its members that employees wear an NIA certified dust respirator, N95 series. This type of activity is defined as those actions involving removal of SVF that has gone to temperature or when the insulation has become unbonded. An exception to this is built into the CHSPP in which “respirators need not be worn when employees are performing noted demolition work, when the contractor is able to demonstrate, through appropriate air monitoring, that its employees are not exposed to respirable SVF in excess of the permissible exposure limit of 1 f/cc.” This exposure level must be demonstrated to a high degree of statistical confidence through a series of air monitoring data checks under similar working conditions. In addition, NIA recommends that its members require the use, by their employees, of the N95 series dust respirators whenever they are working with SVF and are exposed to more than 1 f/cc over an 8-hour time-weighted average.
Will this new Health & Safety Partnership Program change the enforcement power that OSHA has over contractors?
No. Neither the CHSPP nor the HSPP changes expand OSHA’s enforcement power over contractors.
Does the establishment of
a CHSPP or a HSPP mean that the historic products were unsafe?
No. NAIMA member companies stand behind the safety of their products when appropriate work practices are followed. Over 60 years of animal inhalation and human epidemiological studies have shown no causal association between cancer in humans and exposure to the synthetic vitreous fibers manufactured by NAIMA member companies.
When will actual
implementation of the CHSPP begin?
NAIMA and its member companies are currently developing the written support materials needed to educate key customers and their employees about the program. Complete implementation of the program will occur over a three-year period and NAIMA will continually provide written reports to OSHA updating the agency on the program’s progress. The CHSPP became effective on May 18, 1999, when it was signed by representatives of NIA and Mr. Charles Jeffress, OSHA Administrator.
NIA and NAIMA – Educating Contractors, and Users of Insulation through General work Practices
As part of the effort to communicate the provisions of the CHSPP, NIA and NAIMA have developed recommended work practices that will help industry participants understand the scope of the voluntary provisions regarding the handling of synthetic vitreous fibers (SVF).
1.0 General Work Practices Applicable to all Work Involving Synthetic Vitreous Fibers (SVF)
These recommended work practices are in addition to all applicable OSHA requirements. In accordance with OSHA’s HAZCOM Standard, employees must receive training for the safe handling of SVF insulation.
Limiting contact with fibers will reduce potential irritation; limiting exposure to SVF will reduce potential health risks. The following practices describe several methods that will make the handling of SVF safer and more comfortable.
2.0 Minimize Dust Generation:
2.1 Keep the material in its packaging as long as practicable and if possible.
2.2 Tools that generate the least amount of dust should be used. If power tools are to be used, they should be equipped with appropriate dust collection systems as necessary.
2.3 Keep work areas clean and free of scrap SVF material.
2.4 Do not use compressed air for clean up unless there is no other effective method. If compressed air must be used proper procedures and control measures must be implemented. Other workers in the immediate area must be removed or similarly protected.
2.5 Where repair or maintenance of equipment that is either insulated with SVF or covered with settled SVF dust is necessary, clean the equipment first with a HEPA vacuum or equivalent (where possible) or wipe the surface clean with a wet rag to remove excess dust and loose fibers. If compressed air must be used proper procedures and control measures must be implemented. Other workers in the immediate area must be removed or similarly protected.
2.6 Avoid unnecessary handling of scrap materials by placing them in waste disposal containers and equipment kept as close to working areas as possible which prevents release of fibers.
3.1 Unless other proper procedures and control measures have been implemented, dust collection systems should be used in manufacturing and fabrication settings where appropriate and feasible.
3.2 Exhausted air containing SVF should be filtered prior to recirculation into interior workspaces.
3.3 If ventilation systems are used to capture SVF, they should be regularly checked and maintained.
4.0 Wear Appropriate Clothing:
4.1 Loose fitting, long-sleeved and long-legged clothing is recommended to prevent irritation. A head cover is also recommended, especially when working with material overhead. Gloves are also recommended. Skin irritation cannot occur if there is no contact with the skin. Do not tape sleeves or pants at wrists or ankles.
4.2 Remove SVF dust from the work clothes before leaving work to reduce potential for skin irritation.
5.0 Wear Appropriate Personal Protective Equipment:
5.1 To minimize upper respiratory tract irritation, measures should be taken to control the exposure. Such measures will be dictated by the work environment and may include appropriate respiratory protective equipment. See OSHA’s Respiratory Protection Standard.
5.2 When appropriate, eye protection should be worn whenever SVF products are being handled.
5.3 Personal protective equipment should be properly fitted and worn when required.
6.0 Removal of Fibers From the Skin and Eyes:
6.1 If fibers accumulate on the skin, do not rub or scratch. Never remove fibers from the skin by blowing with compressed air.
6.2 If fibers are seen penetrating the skin, they may be removed by applying and then removing adhesive tape so that the fibers adhere to the tape and are pulled out of the skin.
6.3 SVF may be deposited in the eye. If this should happen, do not rub the eyes. Flush them with water or eyewash solution (if available). Consult a physician if the irritation persists.
7.0 Safe Handling Procedures for Specific SVF Applications
7.1 Blown SVF In Attics:
*7.1.1 The installer blowing insulation in the attic must always wear a NIOSH certified dust respirator (certified N95 or greater). See OSHA’s Respiratory Protection Standard.
*7.1.2 No workers, unless they are wearing a NIOSH certified dust respirator (certified N95 or greater), should be permitted in the attic during or immediately after the SVF application. .
7.1.3 The blower should not use a bare hand to direct the insulation stream as it emerges from the blowing hose. A gloved hand or a deflector should be used instead.
7.2 Cavity Fill Insulation:
*7.2.1 The blower in this operation must always wear a NIOSH approved dust respirator (certified N95 or greater). See OSHA’s Respiratory Protection Standard.
*7.2.2 Other exposed workers who are in the immediate area when SVF is being applied to a cavity should wear a NIOSH approved respirator.
7.3 Batt, Blanket, and Roll Insulation:
7.3.1 Where possible, avoid tearing or ripping the product by hand. The materials should be cut with a sharp knife.
7.3.2 Workers installing batts overhead should wear appropriate personal protection equipment.
7.4 Pipe Board and Other Fabricated Products:
7.4.1 In locations which power saw, rout, sand, grind or employ other operations which generate dusty conditions, local exhaust ventilation should be used.
7.5 Ceiling Tiles:
7.5.1 Cut or trim ceiling tile with a razor knife or a keyhole saw. Operations such as power cutting, power kerfing or using compressed air to remove dust is not recommended. The use of power tools with a dust collection system to cut ceiling tiles is acceptable.
7.5.2 Surfaces where SVF dust collects should be appropriately cleaned.
7.5.3 Workers should wear appropriate eye and head personal protection.
7.6 Spray Applied Fireproofing:
7.6.1 Practice good housekeeping procedures.
7.6.2 When the PEL of 1 f/cc on an eight hour TWA is exceeded, use a NIOSH certified dust respirator (certified N95 or greater).
7.6.3 When spraying mineral fiber fireproofing, wear appropriate personal protection equipment.
7.7 Bulk Unbonded Products (Manufacturing)
*7.7.1 Workers dumping or pouring unbonded, bulk, specialty filtration fiber products where engineering controls are absent should wear a NIOSH certified dust respirator (certified N95 or greater). See OSHA’s Respiratory Protection Standard.
7.8 SVF Product Removal
7.8.1 These recommended work practices are applicable for workers removing SVF products during significant repair or demolition activity [definition of “significant repair” and “demolition” to be supplied after discussion with NIA]. Additional precautions may be required if workers are also exposed to other products or substances. In such circumstances, follow any more stringent recommendations that apply to those products.
*7.8.2 Workers should wear a NIOSH certified dust respirator (certified N95 or greater) when removing SVF products as described in section 7.8.1. See OSHA’s Respiratory Protection Standard.
7.8.3 Practice good housekeeping procedures.
7.8.4 Where appropriate (i.e., in situations where an appreciable amount of dust is generated), dust collection systems may reduce the exposure to dust. If a dust collection system is used, follow the recommended work practices for ventilation.
7.8.5 Follow recommended work practices for selecting work clothing and appropriate personal protective equipment to be used during removal activity.
7.8.6 Use a light water mist on the SVF to minimize airborne dust during product removal and disposal.
*EXCEPTION FOR CHSPP
Respirators need not be worn when employees are performing the above indicated tasks when the contractor is able to demonstrate through appropriate air monitoring, that its employees are not exposed to respirable asbestos fibers in excess of the PEL. In addition, air monitoring data taken on previous jobs which are substantially similar to the job presently being performed by the contractor may be used to determine the necessity for wearing personal respiratory protective equipment. Substantial similarity in jobs shall exist when same type (bonded or unbonded) SVF insulation is being used, the methods for blowing the insulation or feeding the insulation into the blowers are the same, and general conditions of the work environment are the same.
Should you have any questions with regard to these programs and the implications they may have with regard to your business, please do not hesitate to contact NIA at (703) 683-6422, any member of the NIA Health & Safety Committee, or NIA’s general counsel, Gary W. Auman, at 937-223-6003.