Exposure Control Plan

Version: June 2013

Statement of Purpose

Alpine Insulation is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to 2 part (A&B) Polyurethane Foam Products, consisting specifically of:

Component A: Polymethylene Polyphenyl Polyisocyanate

And

Component B: General Polyols

Surfactants

Catalysts

Flame Retardants

Blowing Agents
(collectively referred to as sprayfoam chemicals in this document)

The ECP is a key document to assist our firm in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes the following:

Employer’s responsibilities:
  • Outline of Responsibilities/Program Administration
  • Risk Identification, assessment and control
  • MSDS safety sheets and supplier/producer product information
  • Symptoms of exposure for the purpose of assessment
  • Personal Protective Equipment, handling, distance and ventilation guidelines
  • Education and Training
  • Written work procedures, as required
  • Spill response measures
  • Health monitoring, when required, and
  • Documentation


  • Worker responsibilities: - Attend education and training sessions provided by the employer and maintain certifications from separate training bodies such as CUFCA.
  • Use controls and follow safe work practices outlined in the exposure control plan
  • Use available personal protective equipment (for example, airline respirators) as required
  • Know how to react to and report exposure or spill incidents


  • The methods of implementation of these elements of the standard are discussed in the subsequent pages of this ECP.

    PROGRAM ADMINISTRATION

    David Lewis is responsible for the implementation of the ECP. 250-384-0985, dlewis@alpineinsulation.ca.

    Alpine’s general manager will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. Contact location/phone number:250-384-0985 steve@alpineinsulation.ca

    Those employees who are determined to have occupational exposure to Polyurethane Foam Products consisting of the materials covered by this plan must comply with the procedures and work practices outlined in this ECP.

    Alpine’s general manager will maintain and provide all employees with access to the necessary personal protective equipment (PPE) and engineering controls (e.g. fresh air system), as required by the standard.

    Alpine’s general manager will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. Contact location/phone number:_250-384-0985 steve@alpineinsulation.ca

    Colleen Koch will be responsible for ensuring that all medical actions required are performed and that appropriate employee health and WSBC records are maintained. Contact location/phone number:250-384-0985, accounting@alpineinsulation.ca

    Alpine’s general manager will be responsible for training, documentation of training, and making the written ECP available to employees, WSBC, and others as required. Contact location/phone number:250-384-0985 steve@alpineinsulation.ca

    Hazard Identification

    Each job will have a hazard assessment sheet prepared for it and included with the daily work order.

    The following is a list of job classifications (at varied project sites) where occupational exposure exists:
  • Certified Spray Foam Technicians – call 250-384-0985 for daily locations and employee names
  • The following is a list of job classifications (at varied project sites) where employees may have some occupational exposure.
  • Spray Foam Helpers call 250-384-0985 for daily locations and employee names


  • Exposure Control Plan Administration

    Employees covered by the sprayfoam application standard receive an explanation of this ECP during their initial training session and will be provided a copy of the ECP plan upon request. It will also be reviewed in their annual refresher training. A copy of the ECP Plan will also be made available at all job sites engaged in spray foam application.

    Annual Review

    Alpine’s general manager is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

    Methods of Implementation and Control

    The risk of unsafe levels of isocyanates can be reduced through product choice, engineering practices such as ventilation, isolation controls (maintenance of safe working distances), routine inspection and maintenance of equipment, management of product storage, education, adherence to curing timeframe requirements and the proper use of PPE.

    Engineering Controls and Work Practices

    Administration controls, safe work practices and personal protective equipment will be used to prevent or minimize exposure to sprayfoam chemicals. Alpine Insulation identifies the need for changes in engineering control and work practices due to the following: Review of WSBC documentation or communications, employee interviews, product supplier or manufacturer’s communications and best practices. The specific controls used are listed below (also see attached CUFCA guidance).

    Employee Training

    All employees who have direct ccupational exposure to sprayfoam chemicals must be certified by CUFCA. (sprayers)

    All employees who may have occupational exposure to sprayfoam chemicals as a technician’s helper will receive training on the composition, application, safe handling, symptoms, and spill management of sprayfoam chemicals.

    In addition, the training program covers, at a minimum, the following elements:
  • a copy and explanation of the standard
  • an explanation of the ECP, where a copy is available for viewing, and how to obtain a copy
  • an explanation of activities that may involve exposure to sprayfoam chemicals, including what constitutes an exposure incident.
  • an explanation of the use and limitations of engineering controls, work practices, and PPE
  • fit tested and trained in the selection, use, inspection, maintenance and storage of their personal respirators.
  • an explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE
  • an explanation of the basis for PPE selection
  • information on the appropriate actions to take and persons to contact in an emergency involving sprayfoam chemicals
  • an explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available
  • information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident
  • an explanation of any signs, labels and/or color coding required by the standard and used by the company
  • an opportunity for interactive questions and answers with the person conducting the training session.


  • Universal Precautions:

    All employees will utilize universal precautions when working on or around a project where spray foam is being utilized. PPE is provided to Alpine employees at no cost to them.

    Employees not wearing the appropriate PPE will respect all areas where tape or signage has been placed identifying the application/use of spray foam. In the event that signage or tape is not present, or there is any doubt about its location, all employees without the appropriate PPE will stay a minimum of 30’ away from spray foam activities.

    Training and certification that is specific to the use of Sprayfoam is provided by specific external trainers such as CUFCA. (Alpine Insulation will provide universal training and education to other Alpine workers not directly involved in the work, who may be exposed to sprayfoam chemicals; however, certified technicians will be responsible for maintaining their certification and applying the training that they have received in a diligent and safe manner.)

    Those applying sprayfoam or their helper should inform the prime contractor if anyone crosses their barriers without the appropriate PPE.

    Any employees who have previously been sensitized to sprayfoam should notify their supervisor so that they can be allocated to projects where sprayfoam is not being used.

    Sprayfoam technicians and helpers who are exposed to the sprayfoam chemicals will follow standard procedures, as established by CUFCA, for disposing of their coveralls and any other contaminated materials at the end of the day. Sprayfoam technicians will carry the appropriate tools and take the appropriate measures to ensure that their equipment is functioning properly to reduce the escape of any chemicals in a liquid form. Once chemical containers are secured within the sprayfoam truck they are not moved other than to remove them from the truck once emptied. Specific spill procedures are identified in a future next section.

    Supervisors responsibilities:

    All supervisors will ensure that workers tasked with jobs that involve exposure to sprayfoam chemicals are qualified to conduct the work. Supervisors will ensure that an adequate supply of the required PPE is available to employees and will routinely conduct checks to ensure that it is being utilized in an appropriate manner. Supervisors will routinely check that work is being conducted in compliance with the OHS Reg, Safe Work Procedures and the ECP plan

    Specific Precautions:

    Employees who will be exposed to sprayfoam chemicals must wear the following PPE:
  • Air Supplied Respirators, unless adequate venting has been proven to enable the use of full face respirators.
  • All employees wearing respirators must be clean shaven to ensure that the respirator fits snugly to their face.
  • Chemical resistant goggles, as necessary
  • Chemical resistant gloves
  • Chemical resistant disposable coveralls
  • Safety Boots
  • Hardhats


  • Employees who will be exposed to sprayfoam chemicals must conduct the following work site preparation before they begin work:
  • Notify site superintendant of commencement and duration of work
  • Post signage indicating that spray foam operations are in progress
  • Install caution tape on entrances a minimum of 30’ from sprayfoam activities to notify others of activities being undertaken.
  • Provide a minimum of 0.3 air change per hour as per CUFCA regulations
  • Ensure that a written spill response plan is on site
  • Become familiar with and have possession of MSDS for each chemical and project.


  • Personal Hygiene

    Workers should follow these safety steps to minimize contact with isocyanates:
  • Wash hands before eating or smoking
  • Rinse any skin contaminated by isocyanates with diluted rubbing (isopropyl) alcohol to neutralize the isocyanate, and then wash with soap and water.
  • Leave contaminated clothing at the workplace to protect family members from exposure.


  • Emergency Procedures

    Isocyanates are hazardous chemicals, therefore, extreme caution and proper safety procedures must be followed. Emergency procedures will be posted wherever there is a risk of exposure to isocyanates. Workers must be trained in emergency procedures for exposures, first-aid and spills. (The MSDS for the product will also be on-site and should contain information on how to contain and clean up a spill). In a situation that would be considered a major spill of isocyanate, the following procedure is recommended:

    Clear the area of all unprotected personnel, particularly if the spill is onto or near a hot surface. If the spill has been into a waterbody that cannot be contained, contact local authorities to implement containment activities and to monitor waterways for 36 hours. If the spill is onto a hard surface or can be controlled in a pool:

    1. Evacuate anyone in the area who is not involved in the cleanup or does not have proper PPE.
    2. Immediately cover the isocyanate spill with a dry absorbent such as vermiculite or sand. Do not use sawdust or shredded paper because of the fire hazard.
    3. Shovel the waste into a metal container, cover it, and place the container outside in a shaded, dry area prior to disposal.
    4. Make sure that the container is not sealed tightly so any pressure buildup can escape.
    5. Chemical reactivity – Isocyanates react vigorously with water, ammonia, or strong bases to produce heat and carbon dioxide (CO2) gas. If this reaction occurs in a sealed container, the container may rupture or explode, releasing isocyanate vapour and CO2.
    6. Disposal – Before disposing of empty isocyanate containers, they must be decontaminated by leaving them uncovered (for at least 48 hours) to allow CO2 gas to escape. (The containers should be disposed of in a manner to ensure that they are not reused.
    7. Fires – Isocyanates, and most substances containing them, are flammable. They will burn and release toxic gases such as carbon monoxide, nitrogen oxides, and hydrogen cyanide. Burning polyurethane products made with isocyanates may release a number of hazardous substances, including benzene, toluene, carbon monoxide, nitrogen oxides, and hydrogen cyanide. Isocyanates should be treated as a Class C fire hazard, do not use water or foam-containing fire extinguishers. Use a CO2 or dry chemical extinguisher to put out flames. In the case of a major fire, firefighters must wear self-contained breathing apparatus (in positive-pressure mode) to protect them from toxic fumes. In the event of a fire involving sprayfoam chemicals make sure to notify fire authorities about their presence.

    Post Exposure Evaluation and Follow-up

    Should an exposure incident occur, contact Alpine Insulation at: 250-384-0985.

    The exposed party should be assessed for the following symptoms of exposure:
  • Sore eyes
  • Running nose
  • Sore throat
  • Coughing
  • Wheezing (asthma)
  • Chest tightness


  • If any of the proceeding symptoms are present, emergency assistance should be sought, immediate first aid should be provided, and if possible the individual should be taken immediately to a licensed health care professional for a full examination.

    FIRST AID

    Washing and eyewash facilities must be available near areas where isocyanates are handled, and all workers must know how and when to use these facilities. Soap and water should be available at these facilities to treat contaminated skin.

    If isocyanates enter the eyes, follow these steps:
    1. Flush the eyes with lukewarm water immediately, for at least 30 minutes.
    2. Remove contact lenses after the eyes have been irrigated with water for a few minutes, and then resume irrigation.
    3. See a doctor.

    If isocyanates contact the skin, follow these steps:
    1. Remove contaminated clothing. Contaminated clothing can be treated with a neutralizing mixture (10% isopropyl alcohol and 1% ammonia in water) and sent for laundering.
    2. Wash skin with soap and water. Shower if necessary.
    3. Discard contaminated items such as leather watch straps and shoes.
    4. See a doctor if there is a chemical burn.

    If isocyanates are swallowed, follow these steps:
    1. Do not induce vomiting.
    2. Have the worker drink water or milk to dilute the material in the stomach.
    3. Transport the worker to the nearest hospital as soon as possible.

    If a worker is overcome by inhaling isocyanates, follow these steps:
    1. Move the worker to fresh air, and give the workers oxygen, if available.
    2. If the worker is having trouble breathing or is not breathing, start assisted ventilation using a pocket mask. Add oxygen to the mask, if available.
    3. Transport the worker to the nearest hospital as soon as possible.

    Following the provision of initial first aid an investigation will be conducted to determine the cause of the exposure and any remedial activities that should be undertaken before work commences again. The investigation will look at but not be limited to:
  • engineering controls in use at the time
  • work practices followed
  • a description of the device being used (including type and brand)
  • protective equipment or clothing that was used at the time of the exposure incident
  • location of the incident
  • activity being performed when the incident occurred
  • employee’s training


  • Administration of Post-Exposure Evaluation and Follow-up

    Colleen Koch will ensure that health care professional(s) responsible for employee’s treatment, post-exposure evaluation and follow-up are given a copy of the sprayfoam chemical standard. Colleen Koch will ensure that the health care professional evaluating an employee after an exposure incident receives the following:
  • a description of the employee’s job duties relevant to the exposure incident
  • location and duration of exposure
  • circumstances of exposure
  • any symptoms or observances from the initial first aid that was provided
  • any relevant employee information


  • Colleen Koch will seek a copy of the evaluating health care professional’s written opinion within 15 days after completion of the evaluation.

    Record Keeping

    Training Records: Alpine will retain a copy of each sprayfoam technician’s certification and training record. A record will be kept of all training provided to sprayfoam helpers as it is completed. These documents will be maintained in the Alpine office.

    The training records will include:
  • the dates of the training sessions
  • the contents or a summary of the training sessions
  • the names and qualifications of persons conducting the training
  • the names and job titles of all persons attending the training sessions


  • Employee training records will be provided upon request to the employee or the employee’s authorized representative within 15 working days. Such requests should be addressed to Colleen Koch.