"Furthermore, because there is no technically and economically feasible alternatives to the use of unreacted MDI in SPF available on the market, the trade group proposed an "alternative pathway to DTSC". This, it says, would have enlisted the SPF industry to undertake a multi-year, California-focused product stewardship and safety campaign focusing on workplace safety regulations, product stewardship materials, training programmes, and general health and safety information. However, in responding to consultation comments, the DTSC says it is concerned with exposure that could occur among those who "do not employ safety measures and those for whom the measures fail". In its proposal the California agency stresses that eliminating the chemical hazard entirely, or substituting a less hazardous chemical, is the most effective means of minimising potential occupational exposure. It cites the Occupational Safety and Health administration (Osha), which estimates that only about 64% of construction workers wear proper personal protective equipment (PPE) on a regular basis. "Worker exposure that can lead to injuries or illness is often a consequence of failing to use PPE, using it improperly or failing to follow administrative controls," the DTSC proposal says."
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