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DOL Regulatory Update: What Small Business Owners Need to Know About the 4,4′-Methylenedianiline Standard

The Department of Labor recently submitted a new information collection request (ICR) to the Office of Management and Budget regarding OSHA’s standard on 4,4′-Methylenedianiline (MDA) for general industry. If your business uses or manufactures chemicals, this update could directly impact your compliance obligations. Here’s what you need to know.

Understanding the 4,4′-Methylenedianiline Standard

4,4′-Methylenedianiline is an industrial chemical used in the production of polyurethane foams, resins, and coatings. The OSHA standard establishes permissible exposure limits (PEL) and requires employers to implement controls, monitoring, and record-keeping procedures to protect workers from exposure to this hazardous substance.

The DOL’s recent submission to the OMB seeks approval for the paperwork and documentation requirements associated with this standard. This includes employee exposure monitoring records, medical surveillance documentation, and hazard communication materials. The agency is collecting public comments on the burden and necessity of these information collection activities.

Which Businesses Are Affected?

This regulation primarily impacts companies in these industries:

• Polyurethane foam manufacturers
• Chemical production facilities
• Spray polyurethane foam (SPF) contractors
• Coating and adhesive manufacturers
• Composite material producers
• Any facility where MDA is manufactured, imported, processed, or used

If your business handles MDA or operates in these sectors, compliance is mandatory under OSHA regulations.

What Employers Must Do to Comply

The MDA standard requires employers to:

• Assess Exposure: Determine if employees are potentially exposed to MDA at or above the action level (10 ppb as an 8-hour TWA)
• Implement Controls: Use engineering controls, work practices, and personal protective equipment to minimize exposure
• Maintain Records: Document exposure monitoring results, medical examinations, and training activities
• Provide Medical Surveillance: Offer baseline and periodic medical examinations for exposed employees
• Communicate Hazards: Ensure proper labeling, safety data sheets, and employee training on MDA hazards

Three Practical Compliance Steps for Your Business

Step 1: Conduct a Chemical Inventory Audit

Review all materials, products, and processes in your facility to identify where MDA is present. Document exposure levels and employee job duties. This foundational step determines your compliance obligations and helps you prioritize resources effectively.

Step 2: Implement Documentation Systems

Establish organized record-keeping for exposure monitoring, medical exams, and training. Using an HR management system like BambooHR HR software can streamline documentation, making it easier to track compliance activities and respond to OSHA inspections.

Step 3: Develop and Update Safety Procedures

Create written procedures addressing exposure controls, PPE requirements, and employee training. Consider using LegalZoom employment agreements to ensure safety expectations are clearly communicated in your worker agreements.

Take Action Today

If your business handles MDA, don’t wait for an OSHA inspection. Review your current practices, assess your compliance gaps, and implement the necessary controls and documentation systems now. Proactive compliance protects your workers and shields your business from costly penalties.