DIVISION OF OCCUPATIONAL SAFETY AND HEALTH
POLICY AND PROCEDURES MANUAL

GUIDANCE ON FEASIBILITY OF ENGINEERING CONTROLS FOR THE REINFORCED PLASTICS INDUSTRY

P&P C-39

Issue Date: 1/15/91
Revised: 8/1/94

AUTHORITY: Title 8 California Code of Regulations §5155.

POLICY: It is the policy of the Division of Occupational Safety and Health to allow manufacturers in the reinforced plastics industry to utilize a combination of protective measures to meet the permissible exposure limit (PEL) for styrene.

PROCEDURES:

A. AIR SAMPLING

  1. When conducting air sampling for styrene in hand layup and sprayup operations at a workplace in the reinforced plastics industry, compliance personnel shall note whether the measurement exceeds the PEL for styrene of 50 ppm (250 mg/M3).

  2. If the air sampling level result exceeds the PEL, compliance personnel shall determine if the item involved in the hand layup or sprayup operation is:

    1. More than 250 ft2 in surface area;

    2. More than 150 ft3 in volume; or

    3. More than 30 feet in length.

B. CITATION

If one or more of the conditions referenced in Section A.2a. through c. exists, and the employer is utilizing a mix of engineering controls, work practice and personal respiratory protection to achieve compliance with the PEL, compliance personnel shall not cite the employer for a violation of 8 CCR §5155, §5141(a) or (b), unless compliance personnel can document that compliance is feasible solely with engineering and work practice controls.