OSHA Inspection: PHILLIPS & SONS BODY SHOP

Issued

Jun 28, 2005

Abate by

Dec 1, 2005

Penalty

Initial $375 · Current $188 Reduced

Hazardous substances H130

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:
The employer did not furnish employment and a place of employment
which were free from recognized hazards that were causing or likely
to cause death or serious physical harm to employees in that
employees were exposed to excessive airborne concentrations of
isocynate air contaminants during spray paint operations:
Paint Spray Room - An employee was exposed to excessive
airborne concentrations of isocynate air contaminants during
the spray painting of a tractor-trailer truck cab on May 5,
2005.
During spray painting on May 5, 2005, an employee was exposed
isocynates in aliphatic poly isocynate resin (CAS 28182-81-2)
at airborne concentrations of 8.95 mg/M3 (milligrams per cubic
meter of air) during 18 minutes of spraying and at average
concentrations of 13.0 mg/M3 during 23 minutes of spraying.
These levels exceeded the recommended concentrations listed on
the DuPont Material Safety Data Sheet (MSDS) for Imron 5000
Polyurethane Enamel of 1.0 mg/M3 over 15 minutes Short Term
Exposure Limit (STEL).
The paint sprayed was a white Imron 5000 Polyurethane enamel,
N0006HN (3 parts), with 193S hardener (one part).
The OSHA Laboratory reported the exposure as 1,6-Hexamethylene
Diisocynate Homoploymer (OSHA Substance Code H130) which had
the same CAS# 28182-81-2 as the aliphatic poly isocynate resin
listed on the Dupont MSDS for Imron 5000 Polyurethane enamel
and 193S hardener.
The hazard warning on the Dupont MSDS of potential health
effects from aliphatic poly isocynate resin read as follows:
"Overexposure may cause asthma-like reactions with shortness
of breath, wheezing, cough, which may be permanent; or
permanent lung sensitization... Potential skin sensitizer that
may cause allergic reactions and contact dermatitis resulting
in severe irritation, dryness, and cracking of the skin. Skin
or eye contact may cause any of the following: irritation."
Adequate mechanical ventilation was not provided.
One of the feasible methods of controlling these exposures was
to install a commercially designed spray booth in which the
truck cabs being sprayed would fit into the face of the booth.
Abatement Dates:
STEP 1:  Provide proper respiratory protection by implementing
a complete written respiratory protection program by August 1,
2005.
STEP 2:  Submit a plan for abatement--installing the new spray
booth--by September 1, 2005. STEP 3:  Complete installation of the new
DeVilbiss spray
booth and verify the effectiveness of the booth by conducting
and having the results of personal air sampling for isocynates
by December 1, 2005.
Note:  OSHA defines employee airborne exposure as that
exposure which would occur if the employee were not using a
respirator.  The employee was wearing a DeVilbiss Type C
Continuous Flow respirator.

Issued

Jun 28, 2005

Abate by

Aug 1, 2005

Issued

Jun 28, 2005

Abate by

Dec 1, 2005

Hazardous substances H130

Issued

Jun 28, 2005

Abate by

Jul 21, 2005

Penalty

Initial $225 · Current $112 Reduced