Document 6w9mvdZxVEX0qq2XxKEbvORNd

gg SAFETY & FIRE PROTECTION DIVISION OCCUPATIONAL HEALTH SURVEY REPORT BEAUMONT WORKS ELASTOMER CHEMICALS DEPARTMENT BEAUMONT, TEXAS ' V" -.jv - REPORT NO. 9055-H July 12, 1979 EMPLOYEE RELATIONS DEPARTMENT E. I. DU PONT DEiMNOOEnMwwOiUaRS & COMPANY WILMINGTON, DELAWARE 19898 DUP 0502319 DU 001963 SUMMARY Overall rating is good. Organization is excellent. Improved audit program is recommended. Chemical catalog is fair; plans are excellent and include a new four-page format. Physical examination program scope exceeds corporate recommendations and should be reexamined. Respirator program is excellent. Use of eve wash stations needs attention. Pull shift personnel chemical exposure samples are needed in Hydan. Some other areas need additional samples for some carcinogens. : Annual testing of ventilation exhaust systems is generally needed. Noise control program is good; reevaluation of 12-hour shift exposures is needed. . Improved recordkeeping is needed for radiation exposure control. Film dosimeter use is urged. DUP 0502320 DU 001964 GENERAL The second occupational health survey of the Beaumont Works was conducted by the undersigned engineer June 17-29, 1979. Escorts during the visit included area supervision and the Environmental Health Coordinators. ' The purpose of the survey was to evaluate occupational health programs and practices and provide suggestions for improvement, if needed. Practices, procedures and facilities for identifying, evaluating, and controlling environmental factors that may cause illness, impaired health, and significant discomfort to employees were addressed. The Beaumont Works was rated good on a scale of excellent, good, fair and poor, with the first three being degrees of satisfactory performance. This report summarizes the observations and recommendations presented to the Manager and staff at the conclusion of the survey. Details and many of the specific recommendations developed during the survey are not included since these were discussed in field notes provided for the Site. We would appreciate being advised within the next few months con cerning the actions taken on recommendations in this report and your response to any of the field_naS--wlth_which you disagree. SAFETY AND FIRE PROTECTION DIVISION ' !.. _. . il Health Engineer j. xi. vwwuya.xwiia. ..ealth Consultant RCC/dla DUP 0502321 DU 001965 naiafeii >A.*Maija-r.r Buiaiiillii sw, ORGANIZATION AND ADMINISTRATION Organization The organization for occupational health is excellent. An Environ mental Health group has been formed and Environmental Health Coordinators serve for each tenant Department, as well as an overall program coordinator for the Site. An Environmental Health Sub committee of the Central Safety and Health Committee is active and addresses occupational health topics in depth. Occupational health.program auditing in each area needs strengthen ing to eliminate program weaknesses reflected in survey field notes. Audits should occasionally include the Departmental Environmental Health Coordinators to further expand the expertise of tnc audit Communications The communications program is good. Management issues timely information on hazardous chemicals to supervision for informing and training affected employees. A good flow of occupational health information to the Site from Departmental sources is reported and employees were found generally knowledgeable. The 1979 safety program contains several occupational health related topics to expand employee awareness. The availability of video tape equipment provides an excellent vehicle for furthering the education of personnel. Its expanded use for occupational health subjects is recommended. ~1""' " " ' --- Improvements in documenting information to employees who handle ojtrcnogena is urged. Althoug_h___t_h_e___s_c_o_p__e__o__l1__l_ir_?_o__m__a_'_tl_o_n__~ _ carcinogens is we1l1l documented., little documentation exists to show which employees were informed and when (except for the Acrylonitrile Area where documentation required by the OSHA Standard is complete). It is recommended that documentation of discussions ,1th employees who hy carcinogen show tne scope of the presentaSloflg, the'"empiovees mrormefl and ! Chemical Catalog The employee chemical information system is rated fair} however, plans for improvement are excellent. Information on about 200 chemical hazard summary sheets is recognized as inadequate and will be expanded and transferred to a new four-page format (a modified version of that currently in Engineering Standard S 11 T). -1- DUP 0502322 DU 001966 Distribution of the new format will be made to all user areas. Hazardous trade name chemicals and toxic laboratory chemicals, not now summarized, will be included. These efforts are endorsed as a significant improvement over current chemical hazard summaries. A chemical purchase approval system for introducing new chemicals OB' onto the Site Is active but can be improved. It is recommended /Tfthat formal approval by.the Environmental Health Coordinator be (Ujireauired before an area orders a new chemical for us-e. Medical The medical program is excellent. Medical surveillance has been implemented where required by OSHA standards. A board-certified radiologist interprets all X-rays associated with routine physical examinations, as well as those reviewed as part of the asbestos standard. However, the scone'of the periodic ^*Tr1nnf1~nn go beyond recommendations In the Physician's Guidelines or that required by government regulations. For example, blood chemistry work includes an SMA-21; only an SMA-12 is recommended. EKG's are given annually beginning at age 40, instead of annually beginning at age 50. (Other examples were addressed in the field notes.) It is recommended that the advisability of continuing thJ% expanded scope of routine physical examinations be discussea with tfie ~"c corporate Medical Director. "_ L<jaxa^tVPer3onnel Environmental Records System (PERsT) During 1979 the Conpany plans to issue guidance to each department regarding a computer-based program to relate employee work assign ments to chemical eicposures in the work place. The Site should remain alert to the^iceue-efi the. egeggamand implement its provlslonsjbased on uepartmental_and-Cflfflpany guidance; ' Contractor Operations Contractor handling is generally good. Employees are knowledgeable concerning protecting both Du Pont employees and contractors when contractors work on the Site. The survey indicated that -Additional & attention is needed to insure proper use of hearing protection devices by contractors in pu Pont-generated high nol3e areas, particularly m the" Powerhouse. ' PROTECTIVE EQUIPMENT Respirators The respirator program is excellent; an almost complete overhaul has - 2- DUP 0502323 DU 001967 ..iueitaiKBa; JljJiilt iaaais .:.: msmtacaBta. r,, 1 been accomplished since the 1977 occupational health survey. The program, which includes quantitative fit testing, represents a large expenditure of funds and manpower .A Addltionalefforts are-) ('V\ fneeaed., - to remove unapproved" respirators and canisters J i \frora area storage cabinets and Stores/"``feeo. fefersonnel responsible /^ffor' coMUnitV use respirators" in t'heghops" should become more----------- ( W Axand.liar witn storage, handling and cleaning policies. Eyewash Stations The eyewash station program is fair with improvements needed as follows: ^2 Continuous flow?atations. tested daily, should not be approved for"use unless both water streams Have equal, strong flow and the streams converge. Retraining ...of employees, tnnludlng supervision, la recommended regarding the minimum acceptable flush time after chemicals are splashed into the eyes! Most employees questioned wereunsure, even where proper instructions were posted in the immediate area. Bottle eve flush stations should be maintained full of flush solution'J Many were noted which needed refilling. ~ Gloves The glove use program is satisfactory. However, except for the Acrylonitrile Area, gloves have not been selected based on per meation data. Plana to review glove selection and base it-on available permeation data are endorsed. Additional efforts are needed to remove ,g.abe^tos gloves, no longer approved for use: from~Tocations 3uch as the Powerhouse and hot suit storage cabinets EXPOSURE HAZARDS - IDENTIFICATION. EVALUATION AND CONTROL Chemical Exposures The chemical exposure monitoring program is excellent. Approved analytical methods are used and a manifold system is being developed to further verify the accuracy of sampling and analytical techniques. The Site embraces the sampling strategies and techniques of Engi neering Standard 3 11 T, S 12 T and S 13 T. Where appropriate, DUP 0502324 DU 001968 i the LOGAN method of statistical analysis of data is used. Elght'-hour. TWA personnel samples are recommended to more accurately quantify personnel exposures to kdN, acrolein, and methyl mercaptan in the HVQan... Area. Only detector tube arid fixed area, mnwitnring has been previously done. T- --. process areas should review their resample frequency for airborne chemicals, particularly for carcinogens.to insure S 12 T guidelines are met. More' frequent sampling for hydrazine in the Methanol Area and EDB in the tel. Area is needed. '---- Field notes addressed several other possible process exposures which " should be investigated. The U3e of silver solder containing cadmium should be eliminated, if possible, in favor or cadmium-rree silver solder, to protect: against highly toxic airborne fumes. Where it cannot be eliminated. ventilation or respiratory protection should be provided. Where gasoline-powered industrial trucks are used in close quarters the carbon monoxide buildup should be checked periodically. ..... Only small quantities of asbestos are handled by Site employees; major removal work is handled by contractors. Involved Du Pont employees are included in implementation of the asbestos standard which the Site is following. The use of local ventilation to control potential employee exposures at chemical handling stations is good. Additional exhausted sampling boxes are planned for the Acrylonitrile Area and about $500M will be spent by the Elastomers Laboratory to upgrade the air supply system as well as hood exhaust efficiency for handling carcinogens. However,.other improvements in the program are recommended: >oda. such as those in the Elastomers Laboratory. should be posted to show the date and results of the exhaust efficiency tedC. Exhaust systems Installed to control chemical exposures to personnel, such as the welding fume exhausters m the Shoos and sample station enclosures in process areas'; * should h&Vfe their collection -efficiencies verified at least annually to insure an acceptable level of protection ror personnel.- ' " -------- -4- DUP 0502325 DU 001969  The accuracy of air velocity measuring devices should 6e verified annually, e.g.. by using thebechnique described to escort personnel. Field notes addressed several specific examples where improved ventilation controls are recommended. Spill Control Procedures ite-wide fume release/spill control procedures are good. However, sarv vehicular and pedestrian traffic was noted immediately following the hexane release in the Nordel Area on June 28. 197q. In addition, the incorrect incident location signal was sounded. Eliminating recurrence of these problems would strengthen indolent control and further nrofcect personnel from exposur~es7 ~~------- Housekeeping and Facility Maintenance Housekeeping, and facility maintenance, as it might affect the ;ional health of employees, is satisfactory. However, mal attention is needed to keep lunchroom areas across the Lean and sanitary, particularly freezer compartments of i-t.QPs J /Equipment.-*; not related to food eonsuantlonx.sueh as tBI'V trgaicers and containers, shouldnotbe aiiowea Investing Noise The noise exposure control program is good. Annual noise surveys are conducted and semiannual updates are prepared of noise abatement plans. Hearing protection is required for all personnel entering a workplace noise level of 90 dBA and above, regardless of work time. Some program improvements are needed, however: Hearing protection requirements and boundary identification are based on a noise level of 90 dBA, even where twelvehour shift employees are involved, such as in the Nordel Area. It is recommended that twelve-hour ghf ftr ynnk locations be reassessseed using 9*7 dfeA as the criteria for administrative contro boundary identification. e survey program to spot deteriorating exposure conditions. -5- DUP 0502326 DU 001970 Mnigy nrvp-hahi o tools, and stationary shop equipment should be Identified (by labeling or posting) to remind use1*8 oT the need for hearing protectiorwor uag-oi'^a^ilnljstratlve controls. ~ \r- - - " Both yellow and white floor stripes are used to denote the boundary of some high noise areas, it is recommended that a eonaistenr. cm nr finds be uaed throughout tha Si fro to avoid possible employee conrusion. !' Radiation The radiation exposure control program is good. A trained Radia tion Protection Officer is available and basic program requirements are receiving attention. The following improvements are recommended: - roJl ccKv* The use of direct-reading pocket-dosimeters as the . primary means or recording exposure should, be phased out HTTgrcT uf firm Badge dosimetry. TE5" direct-reading ' "dosimeters could be used, if desired,"as a supplement to film badge dosimetry. Improved accuracy and legally strengthened recordkeeping would be realized by using a film dosimeter service. rokAv'aAwv* Other^recordkeeping should be Improved, such as recording racfiation surveys where du ir'ont employees might be affected by contractor fadiatlbh device use. Documentation, with the exposure records, is needed to explain why some dosimetry results are missing. Use of a "Hi-Plus" intensifying screen with routine.chest y~rav3 :lnsteaH ofthe "Par speed11 screen now usea should be considered as new screens are_.purchased_or...old screens are replaced. (.This^wouTd.reduce radiation exposure to personnel during chest examinations by 50 percent.) Formal short-term training of the nurses in X-ray techniques land'Teaulpmerit' is recommenaed since no previous formal training has been received. `' A contractor cheeks microwave ovens for stray radiation leakage each six^moptjis. Basel Qh ^ leakage tests ^nffirens should be done quarterly^ Tjie^ contractor snouia calibrate his test metei* at Teast annually and provide the Site with a report of calibration. DUP 0S02327 -6 DU 001971 itti--wHWia 'K ..aaiMgi.L Miimgi li,J jii-i M i1;sjB-aigfeitiS;lMMIIMl':|l^aBaWlB.iji8~: Heat Stress The heat stress evaluation program, based on subjective analysis, is generally satisfactory. The Site has several recognized hotT work areas, such as in the Ammonia Area, Methanol Area, and Nordel but heat stress symptoms have infrequently been experienced \ by workers. However, plans are endorsed to study hot work areas to 1 determine if informally established work/rest cycles are appropriate. S Where air conditioned break `areas are provided to relieve employee heat discomfort, such as in Nordel, the cooling system.should be maintained in good reliable working order.'' Several employee complaints were received concerning operation of this system. An ESD consultant recently measured potential heat stress in the waste acid stripper building; his recommendations are forthcoming. Previous Reports A review of the 1977 Occupational Health Survey Report No. 701^-H, revealed the following-recommendations which-have not vet been. adequately implemented: n\ Documentation of discussions with employees concerning ^ non-OSHA carcinogens. (Acrylonitrile discussions are adequately documented; other discussions are not.) Improved recordkeeping of radiation surveys. Heat stress analysis in the hotter work areas such as Ammonia, Methanol and Nordel. 'y Annual exhaust efficiency testing for exposure control systems such as welding exhausters. Updating the chemical hazard information system. v'"# Identification of noisy, portable tools. Response to other recommendations is adequate. ####### DUP 0502328 DU 001972 OCCUPATIONAL HEALTH SURVEY ADVANCE INFORMATION_____ In preparation of an occupational health survey, the following information is requested: An organization chart. Please indicate persons with responsibility for occupational health. Plow diagrams for each site process. (Sample included.) If the site uses more than 20 processes, send diagrams for the 20 highest volume processes. Complete list of raw materials, catalysts, intermediates (normal and abnormal), by-products, waste materials, fin ished materials and emissions associated with each process. Written procedures which have been developed on occupational health, e.g., respiratory protection, hearing conservation, airborne contaminant monitoring, spills, protective equipment. e Date of last OSHA or other governmental industrial hygiene survey. e Information on calibration/verification of procedures for determining concentrations of airborne contaminants. Please complete enclosed questionnaire and return. Summaries of air monitoring prepared for management review during the last year. The requested information will improve the effectiveness of the site's occupational health survey and should be completed and returned to the Safety and Fire Protection Division prior to the survey as Indicated on the cover letter. DUP 0502329 DU 001973 OCCUPATIONAL HEALTH SURVEY SUGGESTED' SCHEDULE EVENT ESTIMATED TIME (hours) (1) Introductory Meeting with Plant Manager 1/2 (2) Familiarization Tour of Plant 1-2 (3) Discussion of Site-Wide Programs With Appropriate Personnel ' A - Organization O.H. Personnel/Duties/Location in Organization 1/2 O.H. Commlttees/Duties/Programs/ Accomplishments S - Plant Process/Chemieals Used and Produced/Exposure Potential 1-11/2 C - Review Communications to Employees Concerning Hazardous Materials D - Chemical Catalog (Material Safety Data Sheets) , S - Chemical Purchase Approval Plan 1/2 1 1/4 F - Respiratory Protection Program C - Use of Gloves, Chem Suits 1-11/2 1/4 H - Chemical Monitoring Program/ DocumentatIon. 2 I - Periodic Checking of Hoods and Exhaust Ventilation 1/4 J - Noise Monitoring and Abatement Program K - RadirCtion Program, Microwaves/Lasers 1 1 L - Heat/Cold Stresses 1/2 DUP 0502330 DU 001974 Occupational Health Survey - Suggested Schedule~ Page 2 (4) Evaluation of Individual Production Areas A - Discussion of responsibilities for occupational health in area, processes, programs for monitoring and controlling airborne toxicants, noise and radiation. Review monitoring data. 3 - Walkthrough Survey of Area (laboratories. stores and maintenance shops Included) 1-2 (each area) Varies depending on size (5) Continue Discussion of Site-wide Programs A - Discuss Occupational Health Activities 1-2 B - Discuss Chemical Spill Control Program (as it affects employees) C - Review Contractor Protection Program 1/2 - 1 1/2 D - O.H. Audits on Site 1/2 (6) Pinal Review Meeting with Plant Manager and Staff 1 NOTE: . It is usually advisable to begin the evaluation of individual production areas on the second, day and have this activity distributed throughout the week.* The first half hour of each day should be set aside for reviewing field notes with the escort. * On surveys exceeding one week duration evaluation of individual production areas may begin on the third day. DUP 0502331 DU 001975 OCCUPATIONAL HEALTH AUDIT Items to be Evaluated 1. Occupational health policy, organization, committees, objectives, programs and accomplishments. 2. Plant processes; hazards, and engineering control programs, equipment and maintenance. 3. Noise, radiation and ventilation monitoring programs, procedures, equipment and records. 4. Air contaminant monitoring programs, priorities, sampling procedures, equipment and records..' 5. Employee work history records. 6. Program for communicating information on hazardous materials to employees. ' ' 7. Employee training in work practices; programs and effectiveness. 3. Personal protective equipment; suitability for associated hazards, fitting, training and maintenance. . 9. Emergency spills; recognition, equipment, procedures, training, and drills. 10. Incidents; recognition, reports, operating control limits, and elimination. .... 11. Signs, labels, storage areas, containers, etc., for occupational health controls. 12. Medical practices; examinations, biological monitoring, data evaluation, involvement in industrial hygiene activities. 13. Analytical capabilities regarding radiation, chemicals, noises; records, procedures and verification. 14. Contract operations and non-Du Pont employee exposures and communications. DUP 0502332 DU 001976 SAMPLE PROCESS FLOW DIAGRAM 2,4-D* ACID PROCESS * 2,4-dichlorophenoxyacetic acid DUP 0502333 DU 001977 1 Mo Eh < a fOa E2i Ed M 2 0 6* 0 22 P O< 0f<ri O 0 W22 M 2 S fa P i Pa Cd 2t 2o ;o ^ iO2-i 6a< aa c2d a c-* aa--< a&o 0aw3d,i PJi co fa < ao aaa fd o oaa OT ot a OT <0 >> bp 0) O 3 OSh ^4 CO OJ O *H cu b C > Si P 3 u <u u o o >>ao O J3 r-t c cd b P OT o PCb a) co a> <o *h ua 3 CO W U C1 Sx W 0) (U <H ja >i X U Cfl P b O fa >fa fH ri 4* rH *H O <D JJ O C 1> > c a id p r-4 at id 3 O OT P bi OT C4 *H 0> H *H 0) C-* <D T3 bapa c cd aj c w o OT SO S 3 m <u myna 3 > p t> as p o a n a) & >>p b a o a a Si s a s till o i) P 3 MH # >>o>c) d iud s<<o b pp oa a c fa a ot O a <0 O O <9 OT oa ha a a -p rj O u p o fa cohtaoo pa) s iond<a p p p ot d d pDaufnlWcSi iCdOT 033 ot ot a ot o b P P SP C id a as as ot id fi ot a p ot np pc m a p r-t a cd p 3 bcoo id ot >- o>t M p a ti id ot _j P 4) E o a b, o >> p 3p P P P O. Id M P P Id OT Si ID as O C SO O P O <M as Si c a Qi p 3P cd E P OT "3 o P'P <9 >a c >* Q. OT P P cd S 4) cd c asa S C C 60 O P * cd O c OT o P OT OT P C OT OT p p p 3 4 p p a as cd o IdicsEati fa b o as p a c p 3_ ot ot ca hw aSotdpp o>s iaC ; p o ot o a as b >>1 OT \ C ot aOT! 3O* OT O ot a Mb & a <U <a a w Du M as 03 ** >a 0 N. H SU 2a d o Op Ms &i o so CO o Mi a /a Cu cc < a u -4 c M c o 5* s Ocn 0>! Q U 0> ChO ttl o oc!, pX Pcdi O OT fr* a 3 CO -J M**l n c\ o a o a. ss DU 001978 a;; ^saiJsars as ^jg;; ,,..^^iiiiEjMMiiaiig?!w'as^^H: INSTRUCTIONS: a. Toxic Substance - list chemical name. b. Source of Method - list by number from following table: 1. OSKA or NIOSH 2. ASTM, APHA Intersociety or similar group 3. Standard departmental method 4. Vendor's procedure 5. From technical literature 6. Developed elsewhere in Du Pont 7. Developed on site 8. Other . c. Method Documented - indicate yes or no if procedure is written in official format as a site, departmental or governmental method. d. Description of Method - e.g. carbon tube/GC, Miran, stain tube. Badges, etc. e. Calibration/Verification - list calibration standard by number from the following table: If more than one method has been used list each. Both Sampling and Analytical Method Calibrated Using: 1. Known concentration of toxicant in air prepared using dynamic system, e.g., environmental manifold, permea tion tube, air bubbled through liquid of known vapor pressure, slow injection of gas or liquid intb air stream, etc. 2. Known concentration of toxicant in air using static system of preparation, e.g., gas mixture prepared by. measuring volume, pressure or weight, etc. 3. Cross check with another method - please specify. 4. Cross check with another laboratory - please specify. 5. Calibration or calibration standard mixture supplied by vendor. , 6. Other - please specify. ^ DUP 0502335 OVER DU 001979 Sampling Not Calibrated but Analytical Method Calibrated Using: 7. Gas or vapor mixture prepared as in e. 2 above. 8. Cross cheok of spiked collection tube or scrubber solution with another laboratory please specify. 9_ Cross check with another method - please specify. 10. Other - please specify. 11. Analytical method not calibrated. DUP 0502336 DU 001980