Document 6B3Y7KboJ9gDL4mBqzXBMBa49

Monsanto ..... ...... - J . J. Murph^Dcpt. of Medicine & Environmental Health G2WB (4-8836) *-. April 30, 1982 DMEH/MCIC Industrial Hygiene Program Evaluation Texas City, 3/10-12/82 TO G. L. Tromblee - 1890 D. N. Campbell - 1890 J. E. Fox - 1890 J. T. Garrett - G2WB J. A. Glass - 1890 J. L. Henshaw - G2WB P. M. Jeannot - G2WB D. E. Kaldenberg - 1890 H. M. Keating - G4WA C. M. McCullough - 1890 W. B. Papageorge - G4WA S. D. Paul - G2WB H. 0. Reid - 1890 J. H. Spraul, M.D. - G2WF B. G. Ward - G2WB Attached are the results and recommendations of the DMEH/MCIC Industrial Hygiene Program Evaluation Team which visited your plant in mid-March. The evaluation was conducted with Messrs. John Fox and Dan Campbell by Paul Jeannot, Harry Keating, Jim Murphy and Steve Paul. It's purpose was to review the Texas City Plant Industrial Hygiene Program using the 14 elements outlined in DMEH's Bulletin #80-2, "Industrial Hygiene Program Evaluation Guide". These 14 elements comprise the framework for the development of quality sustaining industrial hygiene programs - the goal of all such hygiene programs within Monsanto. In reviewing the Texas City Plant's industrial hygiene program, an effort was made to identify both strengths and weaknesses. The strengths will be communicated to other MCI locations in order to promote excellent efforts and ideas and prevent unnecessary developmental duplication. Recommendations to improve the weak nesses identified should help strengthen your industrial hygiene program. We appreciated the opportunity to review and discuss our pre liminary comments with Mike McCullough, Henry Reid, Arnold Glass, and John Fox at the completion of our visit. We also thank you for the hospitality and cooperation shown us by Arnold, John, Dan and your plant organization. If you have any questions or comments regarding this report, please contact Harry Keating or myself. O JJM:sml James J. Murphy l.M 10W IRCV 2/7S1 MAP 005269 LAM001096 DMEH/MCIC INDUSTRIAL HYGIENE -PROGRAM EVALUATION OF THE TEXAS CITY PLANT Conducted: Report Issued: Evaluation Team: March 10-12, 1982 April 30, 1982 P. M. Jeannot - DMEH-I.H. Chemistry H. M. Keating - MCIC-Environmental Operations J. J. Murphy - DMEH i.H. staff S. D. Paul - DMEH-I.H. Staff 005270 LAM001097 icaos v_jl 0^/30/82 Page 1 in riuyidiil LVdiUdliUll INTRODUCTION The Texas City plant industrial hygiene program was evaluated against 14 major program elements which have been outlined by DMEH (see attachment) as comprising a quality sustaining indus trial hygiene program. This evaluation is part of a company wide effort coordinated by MCI-Environmental Operations and DMEH to uniformly review the status of each MCI location's program. The evaluation team spent one-half day reviewing and discussing the written elements of the program (i.e., the standard operating procedures, training presentations, plant policies relating to worker health, etc.) with John Fox and Dan Campbell. A day was spent visiting operating units to evaluate actual practice in the field, and in clarifying previously discussed questions about the program. A summary of the evaluation team's comments was reviewed with Mike McCullough, Henry Reid, Arnold Glass, and John Fox. Overall, the team felt that a good job was done by the Texas City Industrial Hygiene group in completing the program evaluation document. The comments and recommendations of the DMEH/MCIC Industrial Hygiene Program Evaluation Team are organized accord ing to the 14 program elements and are as follows: I. General Information 1. This section contains basic information about the plant (major products, guest operations, number of employees, union representation, etc.). It was satisfactorily completed. II. Organization and Staffing 1. The current staffing level of three professionals and 5 technicians appears ample to meet the needs of the Industrial Hygiene function. It is important that the skills of the hygiene professionals and technicians be maintained and improved through continued (annual where appropriate) professional training (e.g., AIHA sponsored courses on respiratory protection, radi ation protection, noise/hearing conservation, etc.). Continued technical training and annual participation at the national AIHA1 conference for the ABIH2 certified professional is critical toward maintaining a certified hygienist at the plant. 1AIHA - American Industrial Hygiene Association 2ABIH - American Board of Industrial Hygiene MAP 005271 LAM001098 Texas City IH Program Evaluation 04/30/82 Page 2 2. Placing the hygiene lab within the industrial hygiene organization is evaluated favorably. Close coordination and maximum utilization of people and lab resources is a significant positive result of this organizational arrangement. 3. The plant has shown continued commitment of resources to maintain its extensive employee health protection program. The team fully supports this significant and necessary commitment. 4. The respiratory protection and personnel protective equipment responsibilities lie with the safety function rather than the industrial hygiene function. These responsibilities, overall, appear well handled. Since the result sought from each of these programs is the prevention of over-exposure via inhalation or dermal routes, they are often made the responsiblity of the industrial hygiene function. Such a change may at some time be appropriate. Ill. Employee Education and Training 1. New employees receive a general introduction to indus trial hygiene as part of their "new employee" training. Hourly employees receive training on industrial hygiene related topics as scheduled by their supervision. Departmental supervision receives IH training on an "as requested" basis. The plant also sponsors an "hourly safety committee" which allows approximately 25 employees from all parts of the plant to participate more intensely in the plant safety effort, including IH training. Membership is rotated every 6 months and has involved a large number of plant employees over the years. It appears that a significant effort is being put forth by the plant in the training area. The team supports this emphasis on training and recommends that every depart ment annually use one or two of its monthly safety meetings to discuss pertinent industrial hygiene/ employee health topics.2 2. It is recognized that the responsibility for training lies with department supervision. The plant teaches that good safety and industrial hygiene practices are the responsibility of each individual employee. However, the team shares a concern about "Who trains the trainer?" If IH training for department supervi sion and/or trainers is on an "as requested basis" then weaknesses may exist in quality of the training given to employees. It is our recommendation that the industrial hygiene professionals become more actively MAP 005272 LAM001099 Texas City IH Program Evaluation 04/30/82 Page 3 involved in reviewing and evaluating the programs presented on industrial hygiene, particularly for appropriateness of topics and the accuracy of the contents. The hygiene group will recognize the weak nesses which exist in departmental training programs and what direct/indirect assistance from this group is necessary to help any department upgrade its program. 3. Posting of chemicals encountered in a specific department, their specific hazards, and the proper protective equipment for handling these materials was evident throughout the plant. Additional information of this nature is part of every departmental operating manual and is part of the training an employee receives upon assignment into a department. Posting departmental chemical hazards is an excellent way to provide high visibility for this important information. IV. Contract Employees 1. The effort to deal with the problems of contractor safety and health is quite evident. Both written and visual training material has been developed to explain safety and operating rules to contractors. These training efforts also address in a general way health and safety concerns associated with contractors working within the plant. The team strongly supports continued emphasis in this important area. 2. The plant booklet "Contractors Guide to Accident Pre vention" does not discuss related industrial hygiene concerns. We recommend that a section or a series of statements on industrial hygiene be added during the next update of this pamphlet. If the pamphlet "Plant Chemical Safety Manual" was also designed for distri bution to contractors, then basic information addressing respirator use, hearing protection, tagging of breathing air cylinders, etc. could alternatively be covered here. V. Industrial Hyqiene/Occupational Medicine Interface 1. The plant now has a resident physician. The plant also utilizes the services of a medical clinic and the community hospital. An in-depth evaluation of the medical surveillance program would require participa tion by DMEH medical staff and was not planned as a part of this evaluation. MAP 005273 LAM001100 04/30/82 Page 4 VI. Exposure Assessments 1. Baseline exposure assessments consist of the original base data survey and the initial monitoring assessments made at the plant. The base data survey was conducted by John Fox and Steve Roberts in November, 1975. Initial baseline monitoring assessments were conducted by the plant industrial hygiene group and were completed in 1979. A thorough job was done of gathering this information and these historical documents are essen tially complete. 2. The most recent status report on routine exposure moni toring was issued in November of 1980. The industrial hygiene group indicated that more recent summaries have been delayed largely due to efforts being directed at conversion of industrial hygiene and work history data from an interim format into a format programmed for and acceptable to the final MEHI system. The team recommends that a report on the results of current monitoring be issued on a semi-annual frequency. It is understood that the hygiene group will use the MEHI "Industrial Hygiene Status Report" output service to provide a compilation and summary of sampling data gathered over the monitoring period and add written comments as appropriate. 3. The hygiene group currently reports monitoring results back to departmental supervision. On personnel monitor ing results above the recommended exposure guideline, follow-up to determine the cause is conducted in conjunction with supervision. On exposure results below recommended guidelines, the option of communicat ing the results is left to supervision. The team recommends that all monitoring results on employees who wear pumps, badges, etc. be communicated to them whether or not they are above the recommended limits. The plant appears to be in compliance with the specific written reporting requirements of the OSHA acrylonitrile standard applicable to monitoring. VII. Monitoring Data Integrity (P. M. Jeannot) Basically this section covers the "nuts and bolts" of the sampling and analyses program. Comments are directed such that we may be assured that the data generated within the program are of the highest quality, and proper documentation exists for the same. MAP 005274 tAMOOllOl Texas City IH Program Evaluation 04/30/82 Page 5 1. Outstanding positive elements of the monitoring (sampl ing and analyses) program include: a. Most documentation is now in place for planned AIHA accreditation by 1983. Included are: a) calibration logs for sampling and analytical equipment, b) maintenance log for sampling and analytical equipment, and c) recent completion of a GLP manual. b. Initial efforts on control charts for major chemicals, e.g., AN, Styrene, Benzene, is an important step in documenting laboratory analyti cal control. This area is strongly emphasized by AIHA laboratory accreditation site visitors. c. Monitoring emphasis is in the proper direction as evidenced by the fact that about 85% of the samples taken in the program are personnel samples. d. Sampling and analytical equipment are sufficient to do the job presently at hand with the exception that new noise dosimetry equipment will be neces sary to comply with the new noise standard. I was particularly impressed with the credentials, both educational and experience, of the personnel within the Texas City I.H. program. The monitoring program, in general, reflects those skills. 2. Specific recommendations within the Texas City program are: a. A routine frequency be established for field vali dation of all I.H. monitoring methods where validation is possible. Continue and expand field validation efforts on passive monitors particularly because a transition is in process from the previously used pump and tube methods. It should be documented that data obtained using either passive devices or pump and tube methods give comparable results. b. Personnel samples should be taken for welding fumes utilizing I.C.A.P. (Inductively Coupled Argon Plasma) or A.A. (Atomic Absorption) for specific metals after filter collection, rather than surveys using a T.S.I. (Thermo-Systems, Inc.) survey instrument. MAP 005275 LAM001102 Texas City IH Program Evaluation 04/30/82 Page 6 VIII. Action/Compliance Planning 1. Action/compliance plans apparently exist as part of the routine effort of each department to engineer improvements/corrective projects. Once having the need for corrective action, the IH group relies on depart ment supervision to satisfy the need. No master list of IH projects and the status of corrective action is maintained by the IH group. Without the latter it is difficult to assess performance vs. indicated need. However, we made no observations which would suggest that this practice is not being used success fully at Texas City. 2. The team recommends that an in-depth review be made to ensure compliance with each requirement of the Acryl onitrile standard (OSHA 29CFR1910.1045). Specific concerns are: updating on a 6 month basis the written compliance plan as recommended by Corporate legal (P. S. Park); frequency of quantitative fitting of respirators; and, documentation of annual training of AN exposed workers. 3. It is also recommended that a plant-wide compliance plan be developed outlining additional actions (training, dosimetry, engineering controls, etc.) necessary to meet the hearing conservation amendment to the noise standard. Compliance with this recent amendment will require a concerted effort by medical, hygiene, engi neering and production groups. IX. Information Reporting 1. The plant position that the mortality study had top priority over other activities involving health data collection has been recognized and supported. However, when data processing and support personnel become available, other priority needs exist as follows: a. Correcting data already in the MEHI system. b. Maintaining the MEHI system "evergreen" with current monitoring (Industrial Hygiene) and Work History (Personnel) data. Currently hygiene monitoring data and work history records are being stored in hard copy form. MAP 005276 LAM001103 Texas city in rrogram evaluation 04/30/82 Page 7 X.Noise and Hearing Conservation 1. Recently, Industrial Hygiene re-assumed responsibility for conducting plant noise surveyd in addition to continuing personnel monitoring. The fully supports this more active role. 2. After a plant-wide noise survey is conducted and dosi metry work is completed, an action plan should be developed to ensure compliance with the new OSHA hearing conservation amendment (see Section VIII, item 3). DMEH has recently published Industrial Hygiene Bulletin #82-1, "Hearing Conservation Program Guide", which outlines major elements of an effective, comprehensive program. 3. The team recommends that the practice of posting areas above 95 dBA with time limits (e.g., 95 dBA - Hearing protection required after 4 hours) should be reconsid ered vs. the alternative of requiring hearing protection wherever the noise levels exceed 90 dBA. We support the latter approach as providing more effective protection. XI. Respiratory Protection 1. Historically, the Texas City plant has been a leader in the area of respiratory protection. It has had for a number of years, a qualitative fit/facial hair res pirator policy which now is being implemented through out Monsanto. It has also been a forerunner in the development of dedicated breathing air systems which is another concept being implemented throughout the corporation. 2. The plant has plans to update/revise its respirator program to reflect recent advances in program concepts, including quantitative fit. These concepts have expanded into 11 key program elements outlined in ANSI Z88.2 1980 "Standard Respiratory Protection Practices" and explained in DMEH Industrial Hygiene Bulletin #81-2 "Monsanto Respirator Program Guide". The team supports review of such an important plant program. 3. It is our understanding that in the past year the responsibility for respiratory protection was re assigned to Mark Riddle. Advanced training for Mark would be appropriate. We suggest the AIHA sponsored training course attached (Appendix A). MAP 005277 LAM001104 Texas City IH Program Evaluation 04/30/82 Page 8 4. By plant policy, medical evaluations of potential respirator users are being made to determine their ability to wear this equipment. Records of these evaluations are being made on an "exception" basis (i.e., only restricted individuals are being recorded). For compliance with the documentation provision of OSHA 1910.134, and the AN standard, OSHA 1910.1045 all eval uations, both approvals and restrictions, should be noted in the individuals medical file. A medical approval form for respirator use is attached (Appendix B). 5. A careful review of the quantitative fitting schedule for 1982 is necessary to ensure that twice-yearly respirator fitting of employees exposed to AN will be accomplished per the requirement in the AN standard. XII.Personal Protective Equipment 1. Departmental personal protective equipment procedures were reviewed for selected departments during the field walk-thru. The information found in the depart ment operating procedures manual appeared to be adequate to meet the needs of those departments. No failures by employees to wear proper protective equipment were noted. XIII. Radiation Protection 1. The plant has several sources of both ionizing and non ionizing radiation. The plant has had for several years a well written radiation protection program which is currently being revised/updated. We recognize the high quality of the program and support the effort to update it. XIV. Hygiene Facilities and Practices 1. The plant provides special "clean and dirty" lockers for both male and female employees from the Acrylo nitrile (all employees), maintenance (insulators) and materials handling (pumper/gaugers) departments. Showering is mandatory/encouraged per the specific legal requirements of the applicable standard. These locker facilities were visited and appeared clean and well kept. Individuals in the insulator shop were questioned and demonstrated an excellent knowledge of asbestos handling procedures. ^AP 005278 LAM001105 Texas City IH Program Evaluation 04/30/82 Page 9 2. The plant central lunchroom and the eating facilities located within operating departments appear satisfactory. Wash facilities are located convenient to eating areas and employees are encouraged to and apparently do use these facilities prior to eating. 3. Special procedures concerning issuance of work clothing and laundering of contaminated work clothing apply to insulators (asbestos) and on certain maintenance turn arounds . The plant does not normally provide work clothing but subsidizes purchase of work clothing via "clothing cards" issued 4 times/year. 4. The plant does not provide laundry facilities except locally for asbestos or AN contaminated clothing. The team expressed a concern that those who wear work clothes out of the plant can potentially carry chemicals, cata lysts, and other agents into cars, homes, etc., where others including infants could contact them. An alter native would consist of daily issue of standardized, laundered work clothing to be left at the plant, and end of shift showering for some tasks. MAP 005279 LAM001106  H H SECTION I. III. IV. V. VI . VII. VIII. IX. X. XI. XII. XIII. XIV. CONTENTS GENERAL INFORMATION ORGANIZATION AND STAFFING EMPLOYE EDUCATION AND TRAINING CONTRACT EMPLOYES INDUSTRIAL HYGIENE/OCCUPATIONAL MEDICINE INTERFACE EXPOSURE ASSESSMENT MONITORING DATA INTEGRITY ACTION/COMPLIANCE PLANNING INFORMATION REPORTING ( B NOISE AND HEARING CONSERVATION RESPIRATORY PROTECTION PERSONAL PROTECTIVE EQUIPMENT RADIATION PROTECTION HYGIENE FACILITIES AND PRACTICES MAP 005280 LAM001107 V* l t / \f I *1 I/ THE AMERICAN INDUSTRIAL HYGIENE ASSOCIATION 475 Wolf Ledges Parkway Akron, OH 44311 DEPARTMENT FOR PROFESSIONAL CONTINUING EDUCATION INDUSTRIAL RESPIRATORY PROTECTION/ /RROUTE TO SAFETY & HEALTH GROUP * E "o o <C/>L 2 w 2o* c ^Q- w> wo> p .13: k- 2 .i: ~ 3 s a 1/1 4) co (k3A. CO LL _ > ~ O' a O' fl k. Q) C c o `5u *" xi s c ^ o 5 E g o 2 " to w X" .r o" tj a X Q) > II * Oo* cs P 2LU I - i111 D C 3O > >cr JZ EC *D > u 2o O. CO -w*. =</*>o 5 CD .z E c :X TO w >Z mo r> cD -J9; aj -C ?Ot u 10 3 3-- UW 2o ~ Q. 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LAM001109 Establishing and Administering the Respiratory Protection Program Chicago, IL June 23-25, 1282 ; iMfell:), 'JWilJajJ' . lUarV^til' iai A three day course, developed to provide health and safely person nel with the knowledge and skill lo meet the requirements lor estab lishing and maintaining a minimally acceptable respirator program. Benefits you will obtain Irom attending this course: * a working knowledge ol the applicable Occupational Health and Safety Standards * familiarity with all types ol respiratory protective devices and their lunctional characteristics * "hands-on" experience in perlorming qualitative and quantitative HI lesting ol respirators * library of reference materials * comprehensive manual on respiratory protection * belter juslilicalion lor expenditures on an adequate respirator program A prerequistie for this course is the completion ol a six unit home study section. Every attendee is expected to complete it before he or she attends the course. Therefore, prospective registrants should enroll in this course at least sixty days prior to its presentation. Future Dates and Locations Aug. 23-25,1982 Los Angeles, CA To regisler. or lor more information concerning this course, please write or call: John R. Conti. AIHA. 475 Wolf Ledges Parkway. Akron, OH 44311-1087 (216) 762-7294. American INDUSTRIAL HYGIENE ASSOCIATION American Industrial Hygiene Association JOURNAL (43) 4/82 "< - --c.3J Wi)l!-;.\w>TJ:t'. - n* ir.y/ T.m'ya.uwi'is lUirtj itirr:- 11,:- ;li| I-Xl^r-(s'/:l ijjsi iI 'J, ui : 11 Jl I \, r *. CX / & t,V,7i~v .f-;i t.iitii. iV -----. iaL'uUii"-- -'iiiJiC U- '!" : MAP 005283 A 41 LAMOO1110 APPENDIX B RESPIRATOR MEDICAL APPROVAL FORM NAME_____________ ___________________ __________ ____ DATE FACIAL CONTOURS NORMAL ABNORMAL INTRA-NASAL EVALUATION EAR DRUMS (PERFORATION) CARDIOVASCULAR STATUS PULMONARY STATUS BASED ON EVALUATION OF THE ABOVE FACTORS, I CONSIDER THIS INDIVIDUAL: ~ . . . ABLE UNABLE TO WEAR RESPIRATORY PROTECTION IN THE COURSE OF HIS WORK. REMARKS: 1 (SIGNATURE) M.D. MAP 005284 lamooi 111