June 25, 2013, OSHA announces new National Emphasis Program for occupational  exposure to isocyanates. The official announcement can be found here, and the associated Directive found here.  This National Emphasis (aka enforcement) Program is directed at roughly 20 industries using isocyanates, including spray polyurethane foam insulation and roofing. 

"This is a major development, perhaps the most impactful regulation affecting the industry in recent memory," said SPFA Executive Director Kurt Riesenberg. "I find the intent of the NEP understandable taking into account the focus of the federal agencies on SPF specifically and Iso generally, but there are several elements of this enforcement program that are very, and surprisingly discomforting, and we are going to need some close work with OSHA to get it worked out," he continued. The concerns range from the Directive atypically casting a wide net to include targeted companies with fewer than 10 employees, the mandated minimum number of inspections OSHA regional and local offices are going to conduct and the selection process of those to be inspected, and a question over the treatment of PEL for isocyanates in the SPF installation environment. "SPFA has developed a very good working relationship with OSHA and other agencies over the past four years and looks forward to working on these issues with them and on the members’ behalf," said Riesenberg. 

Members are strongly encouraged to review the requirements and expectations of OSHA inspectors that can be found in the Directive. This is a priority for OSHA. Resources and teams of inspectors are being tasked to this, and at least one SPF contractor already had an inspection scheduled within days of the announcement. 

Check the SPFA website, member-only section, Twitter and Facebook pages along with Sprayfoam Professional magazine for up-to-date information on this subject as it becomes available.