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CONN-OSHA Quarterly

Volume No. 45
Spring 2006


It Pays to be Safe:
By Grayson Gregory

 CONN-OSHA is responsible for ensuring that all municipal and state government employees have a safe and healthy work environment.  One component of this effort involves the inspection of public sector workplaces by CONN-OSHA’s team of compliance officers.  The compliance officers conducted nearly 2,000 inspections during the Published by the Connecticut Department of Labor, Project Management Office-year period from 1/1/96 to 12/31/05 and cited 7,385 violations of OSHA standards.  Almost 3,000 were considered serious and initial penalties associated with these violations amounted to $442,370.

The ten most frequently cited violations with the highest initial penalties are detailed in Table 1.  Three of the “top ten” involve violations of standards from the Toxic and Hazardous Substances subpart of the OSHA Standards for General Industry.  Specifically, they involve hazard communication exposure control and chemical hygiene plans. 

The standard violated most frequently in public sector workplaces that generated the highest initial penalties (see Table 2) was failure to develop, implement, and maintain a written hazard communication program.  The program must include container labeling and other forms of warning, material safety data sheets, employee training, and an up to date list of hazardous chemicals found in the workplace. 

The use of unapproved containers and portable tanks generated the second highest penalties.  Storing gasoline or other class 1B flammable liquids in containers without spill-proof lids and self-venting capabilities is considered a serious hazard.  Employers must provide safety containers that are approved for the flammable liquid that will be stored and/or dispensed from them. 

The next costliest violation concerns medical services and first aid.  Emergency eye wash facilities must be provided within the work area where employees are potentially exposed to injurious corrosive materials.  The eyewash must have adequate liquid for at least 15 minutes of flushing with tepid water.  The eye wash station should be near the hazardous work areas, clearly marked, brightly colored, well lighted and free of obstructions. 

Failure to protect employees from potential falls costs employers a significant amount of money each year.  Every open-sided floor or platform 4 feet or more above the ground must be guarded with a standard railing.  A standard railing consists of a top rail, intermediate rail, toe board, and posts, and has a vertical height of 42 inches from the upper surface of the top rail to the floor.  The completed structure shall be capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail.

Live parts of electric equipment operating at 50 volts or more must be guarded against accidental contact.  Contact with live parts can result in electric shock, burns or electrocution.  The exposed electrical parts must be guarded by using barriers, enclosures or elevation 8 feet or more above the floor or other working surfaces. 

CONN-OSHA often cites employers under Section 5(a)(1) of the Occupational Safety and Health Act.  This section, known as the General Duty Clause, requires employers to furnish a work environment that is free from recognized hazards for all employees.  Inspectors cited violations of the General Duty Clause and assessed initial penalties that made it sixth overall. 

The next most costly violation cited by CONN-OSHA was using compressed air for cleaning purposes.  The standard prohibits the use of compressed air for cleaning purposes unless the pressure is reduced to less than 30 p.s.i. and then only with personal protective equipment. 

The next two standards violated frequently involve exposure to bloodborne pathogens or other potentially infectious materials and chemical hygiene.  A written exposure control plan must be established to eliminate or minimize employee exposure to bloodborne pathogens or other potentially infectious materials.  The written plan must include exposure determination, methods of compliance, vaccination and post-exposure evaluation procedures, training of personnel, labels and signs, and record keeping.  Similarly, where hazardous chemicals are used in a laboratory, employers must develop and implement a written chemical hygiene plan.  The written program must include standard operating procedures, control measures to reduce exposure, personal protective equipment, employee information and training, provisions for medical consultation and medical examination, and decontamination procedures. 

Rounding out the “top ten” list of frequently violated standards with the highest initial penalties is the energy control program (lockout/tagout).  The employer must establish energy control procedures, employee training and periodic inspections to ensure that machines or equipment cannot become unexpectedly energized during service or maintenance. 

It is every employer’s responsibility to maintain a safe and healthy workplace.  Work-related injuries, illnesses and deaths are costly to everyone.  A safe and healthy work environment pays, in more ways than one.  Complying with OSHA standards is just one such way.

Table 1
Ten Most Frequently Violated Standards with the Highest Initial Penalties, Connecticut, Total Public Sector, 1/1/96 – 12/31/05




Initial Penalties


Hazard Communication

Written program



Flammable and

Combustible Liquids

Container and portable tank storage



Medical Services/First Aid

Eye wash facilities



Guarding Floor and Wall Openings





Guarding of live parts



General Duty Clause

Safe and healthful conditions



Hand and Portable Powered Tools

Compressed air used for cleaning



Bloodborne Pathogens

Exposure control plan



Hazardous Chemicals

Chemical hygiene plan




Energy control procedure



Table 2
Most Frequently Violated Standards with the Highest Initial Penalties, Connecticut, Selected Public Sector Workplaces, 1/1/96 – 12/31/05


Most Frequently
Violated Standard

2nd Most Frequently
Violated Standard

3rd Most Frequently
Violated Standard

Total Municipal Government

Written hazard communication program

Container and portable tank storage

Eye wash facilities


Bloodborne pathogens- methods of compliance

Bloodborne pathogens- information and training

Bloodborne pathogens- exposure control plan


Fire brigade -
training and education

Emergency response to hazardous substance releases

Written hazard communication program

Street & Highway

Protection of employees in excavations

Container and portable tank storage

Construction safety training and education

Public Utilities

Protection of open-sided floors, platforms, and runways

Container and portable tank storage

Process safety management of highly hazardous chemicals

Parks &


Written hazard communication program

Bloodborne pathogens-exposure control plan

Container and portable tank storage

Total State


Written hazard communication program

Lead exposure

Container and portable tank storage

Social Services

PPE hazard assessment and equipment


Written hazard communication program

Requirements for exit routes

Health Services

Emergency action plan

Eye wash facilities

Automatic sprinkler system




Container and portable tank storage

Compressed air used for cleaning

Machine guarding

Justice, Public

Order & Safety

Lead exposure

Respiratory protection

Respiratory Fit Testing


Table 3
Ten Most Frequently Violated Standards Overall, Connecticut, Total Public Sector,
1/1/96 – 12/31/05




Total Violations


General electrical requirements

Examination, installation, and use of equipment



Wiring methods

Flexible cords and cables



Portable fire extinguishers

Inspection, maintenance, and testing



Hazard Communication

Written program



Hazard Communication

Labels and other forms of warning



Hazard Communication

Information & training



Walking-working surfaces

Floor loading protection



Hazard Communication

Material safety data sheets



Wiring methods

Cabinet boxes



Flammable and Combustible Liquids

Container and portable tank storage



Special Emphasis Programs:
By Richard Crans and Catherine Zinsser

Special Emphasis Programs (SEP) were developed to provide programmed inspections in facilities with high injury and/or illness rates or in establishments with specific hazards that might not be covered under the standard inspection selection criteria.  These emphasis programs select operations to visit using factors such as: specific industry, trade/craft, substance or other hazard, type of workplace operation, type/kind of equipment, or other identifying characteristic.  The SEP may include employers with ten or fewer employees.


Industrial operations typically have hazards that manifest themselves through employees’ injuries and illnesses.  Using this information, OSHA develops emphasis programs in which one or more regional or area offices may participate.


Each emphasis program is comprised of two elements.  The first is to eliminate overexposure to the physical and/or chemical hazard.  The second is educating employers and employees to the hazards associated with the physical and/or chemical hazard and methods that can be used to reduce worker exposure.  CONN-OSHA along with the Hartford and Bridgeport area offices, jointly provide outreach worker training on these emphasis programs and their associated hazards. The following is the first in a series of articles that will highlight emphasis programs currently in place that may affect Connecticut employers.


Region 1 Emphasis Program:  Methylene Diphenyl Isocyanate (MDI)


In February 2005, a Local Emphasis Program (LEP) for Methylene Diphenyl Isocyanate (MDI) was initiated.  MDI falls within a group of highly reactive and toxic compounds used to make urethane, polyurethane or polyurea coatings.  Hazards related to exposure to MDI may result from chemical inhalation or skin contact.  Reactions to exposure can range from irritation of the skin, eyes, nose, throat, and lungs to a reduction in lung function, asthma and hypersensitivity.  In extreme cases, death can occur from the severe asthma attacks in sensitized individuals.


This LEP addresses the use of MDI, specifically in the sprayed-on truck bed lining industry.  This industry has grown rapidly over the past several years and is primarily composed of small companies, which may be unaware of the significant hazard.  Federal OSHA offices have developed a list of establishments known or likely to conduct this type of operation.  Inspections are based upon this list.


An adequately trained workforce, including management and employees, is the first step in reducing or eliminating the hazards associated with the use of isocyanate containing materials.  The Hazard Communication standard requires that employers provide their employees with information and training concerning chemical hazards and controls.


Ventilation is probably the most important engineering control when combating exposure to an isocyanate or other air contaminants.  Unfortunately, the way this spraying process takes place, utilizing ventilation controls alone may not be adequate.  Spraying takes place in the truck bed and the flow of air controlled by the spray booth may not be able to adequately remove the vapors.  As a result, selection and proper use of Personal Protective Equipment (PPE) is necessary.


When selecting PPE it is critical you understand the process as well as the hazards of the chemicals.  In the case of MDI, you want to protect the skin from having any contact with the chemical.  This may necessitate the use of gloves, coveralls, head, face, eye, and foot protection.  You may also need to supplement the ventilation controls with appropriate respiratory protection.


Good work practices can help to reduce hazardous exposures.  Some recommendations are:

  • Where possible, completely enclose operations and use local exhaust ventilation at the site of chemical release.

  • Wear protective clothing and clean or dispose of it in accordance with manufacturers’ recommendations.  Do not store PPE or respiratory protection in spraying areas.

  • Wash thoroughly and immediately after exposure to MDI.

  • Post hazard warning information in the work area and regularly assess any potential impact on surrounding operations.

  • Eye/Face/Body washes should be provided in the immediate work area for emergency use.

  • Do not eat, drink or smoke where MDI is handled, processed, or stored.

All small high-hazard establishments are eligible for free consultation services provided by the CONN-OSHA Consultation Program.  This program can help you evaluate your work practices, engineering controls, PPE, and employee exposure.  If you would like more information about MDI, contact the CONN-OSHA office at (860) 263-6900, or visit the OSHA web site


Hazard Corner

The Hazards of Spray on Bed Liners
By Erin Wilkins

Pickup truck beds are often protected with either a slide in bed liner or a liner that has been sprayed on.  These spray-on polyurethane coatings are very popular due to their strength, abrasion, chemical and corrosion resistance, waterproof nature, and skid-resistant surface.  However, they also contain toxic chemicals that need to be handled correctly during the application process. 

It is common for small detailing shops to spray on truck bed liners.  In 2003, a store manager in his mid-forties was spraying polyurethane coating on the floor and sides of a cargo van.  This was the first van lining that was sprayed at this location.  When finished, he turned off the spray liner mixer and walked to a side pedestrian door.  The door was open and had a small portable fan to provide air circulation to the general shop area. He disconnected his airline from the respirator and proceeded to walk around the outside of the building to the front of the store where he collapsed. 

A co-worker found him in respiratory distress and rushed him to the hospital.  He was dead within the hour from an acute asthmatic reaction due to inhalation of chemicals.  Spray-on truck bed liners contain a very toxic chemical, Methylene Diphenyl Isocyanate(MDI).  As a liquid, MDI produces a vapor which is a potent respiratory sensitizer that also irritates the eyes, mucous membranes, and skin.  It can also cause pulmonary edema. 

The investigation determined that the building was not properly ventilated and that the employees had not been trained on the hazards of MDI.  The victim had been previously exposed to high levels of MDI but did not recognize the exposure symptoms.  He was also unaware that another exposure could increase his sensitivity to the chemical and could cause a severe allergic reaction.  He was wearing the appropriate type of respirator for the task - a positive pressure respirator with supplied fresh air – but he had modified the respirator and was using an air hose that was too long.  This modification would have voided the National Institute for Occupational Safety and Health (NIOSH) certification.  This fatality may have been prevented if the following had been in  place:

  • Sufficient ventilation inside a spray room or booth,
  • Respiratory protection that was properly used, and maintained.  The respiratory protection selected must be certified by NIOSH,
  • Adequate training of employees on the hazards of isocyanate exposure,
  • Medical surveillance program for employees exposed to isocyanates.


CONN-OSHA ~ Training Update... 

Breakfast Roundtable Discussion Group -   Third Tuesday of every month   These free 90-minute workshops discuss safety and health issues in a supportive and informal environment.  The roundtable meetings are held from 8:15 am to 9:45 am. 

Pre-registration is required.  The location varies, so be sure to call concerning the discussion subject and the location.

Recordkeeping OSHA 300 -   April 28, 2006   The purpose of this workshop is to introduce the requirements and procedures related to the OSHA 300 Log.   The presentation will cover the recording requirements, including a discussion of the employee/employer relationship, which pre-existing cases can be limited in the OSHA forms, and exceptions for some categories of injuries and illnesses.

Powered Industrial Trucks -   May 2, 2006  and  August 8, 2006    Learn how to meet OSHA’s Powered Industrial Truck Standard, 29 CFR 19Published by the Connecticut Department of Labor, Project Management Office.178.  This 3-hour workshop introduces participants to OSHA’s Powered Industrial Truck Standard and includes in-depth review of operator training.   Safe work practices will be covered, as well as other topics not specifically addressed in the standard, including training tips and hazard recognition.   Written handout materials will be provided to assist in the development of a site specific powered industrial truck training program.

Chemical Hazard Communication -    June 6, 2006   The purpose of Hazard Communication (29 CFR 19Published by the Connecticut Department of Labor, Project Management Office.1200), Right-to-Know, or HazCom as it is sometimes called, is very simple:   Employees have both a need and a right to know the hazards and identities of the chemicals to which they are exposed and the necessary protective measures to prevent injury or illness.  This session will help attendees develop an effective Hazard Communication Program.

Lockout/Tagout –The Control of Hazardous Energy Sources -   July 11, 2006    The Occupational Safety and Health Administration (OSHA) has a standard for locking out and tagging out equipment.   It is known as 29 CFR19Published by the Connecticut Department of Labor, Project Management Office.147, and it presents a minimum performance standard for the control of hazardous energy.   This introductory class will take you through the various required sections of an effective written lockout/tagout program from beginning to end. 

Classes are free and will be held at 200 Folly Brook Boulevard, Wethersfield, CT in Conference Room A from 9 am - 12 noon, unless otherwise noted.  To register for any of these sessions, call John Able at (860) 263-6902 or send an email to

Pre-registration is required.   Visit for more training information.

CONN-OSHA Quarterly Index

Last Updated: April 17, 2018

200 Folly Brook Boulevard, Wethersfield, CT 06109 / Phone: 860-263-6000

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