Document DGdqmv05dNbVQL1ngdO72XXDo
ESIS. Inc.
a CIGNA company
Liberty Federal Tower
201 Second Street, Suite 530
Macon. GA 31213
(012) 743-8080
-
October 30, 1986
Dr. E. Edvard Wang, Manager Corporate Environmental Control J-M Manufacturing Company, Inc. 1051 Sperry Road. Stockton, CA 95206
CIGNA
PLAINTIFFS
I EXHIBIT JMMC-33
RE: ESIS Contract t 51-180
Dear Dr. Wang:
On September 16 and 17, 1986, I made a visit to the Denison plant to conduct
an Environmental Health Survey. As a result of that visit, I am submitting
the attached recommendation which should receive your immediate attention and
consideration.
'
You will also find the results of the Environmental Health Report attached. These results are an indication of the environmental health conditions that existed on the days of my visit.
I wish to thank you and your staff for the cooperation that was extended during the course of this visit.
If you have any questions regarding this report and recommendation, please do not hesitate to call me at (713) 933-1826.
Sincerely,
Aileen Teng, CIH Senior Environmental Health Specialist CIGNA Loss Control Services, Inc.
cc: Charles Stelchek, Plant Manager, J-M Mfg., Denison, TX John T. Armstrong, J-M Mfg., Denison, TX Daniel Weetmen, Alexander & Alexander of NY
NOV. 1 O 1988
D 002260
SC-JMM-3250
.. RECOMMENDATIONS
a Cigna compary
NAME:
J-M Manufacturing
LOCATION:
Denison, TX
CIGNA
EH 86-1
As can be seen from the sample results presented in Table I. the PPL $2 inspector was exposed to an asbestos level in excess of the OSHA permissible exposure limit. The willow operator's exposure level exceeded the OSHA action level.
Routine monitoring of asbestos exposure levels and a medical surveil lance program have already been implemented per the requirements of the 1972 asbestos standard. Several revisions were incorporated into the 1986 asbestos standards. It is recommended that the addi tional provisions, for notification of monitoring and medical examina tion results, work practices, preventive clothing, hygiene facili ties, warning signs, compliance program, respiratory protection, medical surveillance, record keeping and employee training in the 1986 standard be adhered to. A comparison of the two standards is presented in Appendix II for your reference.
OMA98o Ptd.lnU.S.A.
002261
ENVIRONMENTAL HEALTH REPORT
PREPARED FOR: J-M Manufacturing Company, Inc.
Denison, Texas
DATE OF SURVEY: September 16 & 17, 1986
CONDUCTED BY: Aileen Teng, CIH Sr. Environmental Health Specialist CIGNA Loss Control Services, Inc. ACCOMPANIED BY: John T. Armstrong J-M Manufacturing Co., Inc.
D 002262
1
INTRODUCTION
Or September 16 &-17, 1986, an Environmental Health Survey was conducted at your plant in Denison, Texas, to evaluate employee exposures to noise, vinyl chloride monomer, respirable dust, total dust, asbestos, organic solvents, and carbon monoxide. The survey was conducted at the request of J-M Manufacturing Company, Inc., as an on-going monitoring program.
The standards and guidelines, methods, results, and discussion pertinent to this report follow.
STANDARDS AND GUIDELINES
The recommendations made in this report are based on current OSHA standards and/or accepted state-of-the-art industrial hygiene practices to give reason able protection to the health and well-being of your employees.
The standards pertinent to this report are found in the Appendix Section.
METHODS Air sampling and analyses were conducted using the following.
Air Contaminant
Vacuum Source
Flow Rate Liters/Min.
Collection Medium
Asbestos
Gilian HFS113UT Pumps, DuPont 2500 Sampling PUmps
1.5
Open-faced 25mm AA filters. Cassettes with 50mm extension cowl
Vinyl Chlo ride Monomer
Gilian HFS113UT Pumps
0.05
2CT** in series
Respirable Dust
Gilian HFS113UT Pumps
. 1.7
Pre-weighed PVC filters on mini cyclones
Total Dust
Gilian HFS113UT Pumps
1.5
Pre-weighed PVC filters
Tetrahydrofuran. Ethyl Acetate
DuPont P-4000 Sampling Pumps
0.2
CT
Methyl Ethyl Ketone, Methylene Chloride
Gilian HFS113UT Pumps
0.05
2CT in series
Analytical ' Method PCM*, NIOSH P&CAM #239
NIOSH P&CAM #127 *** NIOSH P&CAM #106
Gravimetric
NIOSH P&CAM #127 GC
NIOSH P&CAM #127 GC
D 002263
-2
Carbon Monoxide
Gilian HFS1I30T Pump
0.0035
Detector Tubes Direct Reading
* PCM * Phase Contrast Microscopy ** CT * Activated Charcoal Tubes *** GC " Gas Chromatography
Unless otherwise stated, samples were taken in the workers' breathing zones to obtain samples indicative of actual employees exposure. Pumps were calibrated prior to and after the sampling period.
All analyses were conducted by Environmental Health Laboratory in Macon, GA, which is accredited by the American Industrial Hygiene Association.
Noise
Sound level measurements were taken throughout the plant at the various opera tions in the hearing zones of the employees. General Radio Sound Level Meter, Type 1933, was used for the survey; this meter was acoustically calibrated with General Radio 1562 Sound Level Calibrator before and after use.
Quest Model M-7B noise dosimeter was used to measure cumulative exposure to noise. The noise dosimeter measures and accumulates noise and produces a con tinuous reading of the allowable exposure to which the wearer has been subject ed. The microphone of the dosimeter was clipped on the employee's shirt col lar near the ear, thereby receiving and accumulating approximately the same dosage as the ear.
RESULTS
Asbestos
The results of asbestos sampling are presented in Table I. The concentrations are presented in number of fibers (longer than 5 microns) per cubic centime ter, by job description. Also included are sample time, sample volume, and OSHA standard.
Respirable Total Dust
The results of respirable dust sampling are listed in Table II. The concentra tions are presented in milligrams per cubic meter (mg/M^), by job description and location, along with the applicable OSHA standard.
Vinyl Chloride
The results of vinyl chloride monomer sampling are presented in Table III. The concentrations are presented in parts per million (ppm), by job descrip tion and location, along with the applicable OSHA standard.
D 002264
3
Organic Solvents
The results of organic solvents air sampling are listed in Table IV. The con centrations are presented in parts per million (ppm), by job description and location, along with applicable OSHA standards.
When tvo or more hazardous substances are present, their combined effect, ra-- ther than that of either individually, should be given primary consideration. The health effects must be considered additive unless there is evidence to the contrary; thus, exposures are added relative to their designated OSHA stan dards. When adding these exposures, a value "Em" (equivalent exposure for the mixture) is determined by the OSHA formula. Exposure is considered excessive when the value "Em" exceeds unity (1.00).
Em = TWA]_ + TWA2 + TWA} ....+ TWA^
PELi PEL2 PEL3
PELq
Where: TWA is the Time-Weighted Average concentration of a particular substance and PEL is the corresponding permissible limit for the substance.
Total Dust
The results of total dust sampling are presented in Table V. The concentra tions are reported in milligrams per cubic meter (mg/M^).
Carbon Monoxide
The results of carbon monoxide sampling are presented in Table VI. The concen tration is reported in parts per million (ppm).
Noise
The results of noise level measurements and Time-Weighted Average (TWA) expo sure are listed in Table VII.
D 002265
Account: J-M Manufacturing Location: Denison, TX .
TABLE I AIR SAMPLING DATA - ASBESTOS
Job Description (J-M No.)
13' Control Op. (D-2WE)
Employee Name
Charles Moore
Date Sampled
9/16/86
Air Cone. (fibers/cc)
Federal Standard
(fibers/cc)
<0.013
0.2 .
TWA (1) (fibers/cc)
Sample Time (min)
<0.013
258
Sample Vol. (liters)
387
Comments
It
13' Utility Op. (D-8WE)
Cecil Bill
9/16/86
0.040
0.2
0.040
338 507
13' Tender (D-1WE)
Arthur Dawson
9/16/86
0.040
0.2
0.040
351 526
13' Head Curer (D-3WE)
Ray Terrell
9/16/86
0.085
0.2
0.085
335 502.5
13' Curer (D-3WE)
Vernon Hall
9/16/86
0.039
0.2
0.039
339 508
Willow Operator (D-7WE)
Johnny Crain
9/16/86
0.15 0.079
0.2
0.122
202 303 128 192
The TWA exposun level exceeded the OSHA action level of 0.1 fibers/cc.
Steam Tank Op.
Jimmy Lang
9/17/86
0.018
0.2
0.018
303 454.5
D 002266
Account: J-M Manufacturing Location: Denison, TX
TABLE I AIR SAMPLING DATA - ASBESTOS
Job Description (J-M No.)
Service Man & Salvage Grinder Operator (D-8WE)
Employee Name
Phillip French
Date Sampled
9/16/86
Air Cone. (fibers/cc)
Federal Standard (fibers/cc)
<0.011 0,013
0.2
TWA U) (fibers/cc)
Sample Time (min)
0.012
30 312
Sample Vol. (liters)
45 468
Comments ll
In-Process & Coupling Testing Area Inspector (D-13S)
Henry Coldiron
9/16/86
<0.012
0.2-
<0.012
288 432
Large Coupling Cut Off Op. (D-15F)
Bobby Brown
9/16/86
PVC Fitting Assembly Molder (D-11F)
James Blount
9/17/86
Slash Saw & MOA Operator (D-lF & D-6F)
Gary Templeton
9/16/86
<0.048 0.051 0.077
<0.0082
0.2 0.2
0.031 <0.019
0.2
0.047
72 108 130 195
93 140
<0.0082 419 628
0.015
175 262 176 264
UPL 02 Op. (D-4F)
Bill Roger
9/16/86
0.045 0.038
0.2
0.042
176 264 171 256
Processing 16" Class 100 pipes
D 002267
V/1
Account: J-M Manufacturing Location: Denison, TX
TABLE I AIR SAMPLING DATA - ASBESTOS
Job Description (J-M No.)
UPL #2 Inspector (D-lls)
Employee Name
Date Sampled
Darvin Holder
9/17/86
Air Cone. (fibers/cc)
Federal Standard (fibers/cc)
0.15 0.52
0.2
TWA (1) (fibers/cc)
Sample Time (min)
0.33
181 165
Sample Vol. (liters)
272 248
Comments
a) The TWA expo sure level ex ceeded OSHA'a permissible ex posure limit. b) Processing 16" Class 100 pipes.
UPL t 2 Hydrotester
D.F. Dill
9/16/86
0.027 <0.021
0.2
0.014
172 258 167 250
Processing 16" Class 100 pipes
UPL #2 Unit Loader
(D-5F)
Raymond Hesse
9/16/86
<0.010
0.2
<0.010
330 495
Processing 16" Class 100 pipes
UCL n Op. (D-16F)
Larry Henderson
9/16/86
0.082
0.2
0.082
335 502
Processing 16" Class 100 pipes
UPL #2 Helper
Glen Weger
9/17/86
<0.0089
0.2
<0.0089
385
577.7
Processing 16"
Class 100 pipes
Finishing Area Platform Driver & Cleaning of Bag House (D-30F)
Jerry Bruce
9/17/86 '
0.033 0.063*
0.2
0.052
175 262.5 293 439.5
Account: J-M Manufacturing Location: Denison, TX
TABLE I AIR SAMPLING DATA - ASBESTOS
Job Description (J-M No.)
Sweeper Op. & Salvage Truck Operator (D-6S & D-10S)
Employee Name
Date Sampled
Arils Chambers
9/17/86
Air Cone. (fibers/cc)
Federal Standard (fibers/cc)
<0.010
, 0.2
TWA
(1) (fibers/cc)
Sample Time (min)
<0.010
342
Sample Vol. (liters)
513
Comments
Finishing Area Mechanic (D-26S)
George Kerley
Finishing Area Electrician (D-15S)
Troy McGehee
9/17/86 9/17/86
<0.0094*
0.2
<0.011
0.2
<0.0094 365 548
<0.011
311 466
Finishing Area Foreman
Bobby Reynolds
9/17/86
0.015
0.2
0.015
346 519
Finishing Area Forklift Driver
Jack Hamsard
9/17/86
0.0092
0.2
0.0092 391 586
* These samples were heavily laden with particulate matter; some fibers could have been obscured during the count; therefore, results may be low.
(1) TWA = The Time-Weighted Average concentration for a normal 8-hour workday.
the actual exposure time to the air contaminant.
'
This determination is based on
D 002269
VJ
I
Accounti J-H Manufacturing Location: Denison, TX
TABLE II AIR SAMPLING DATA - RESPIRABLE DUST
Job Description (J-M No.)
UPL #1 Operator
Employee Name
Bill Roger
Date Sampled
9/16/86
UPL #2 Helper
Glen Weger
9/16/86
Air Cone. (mg/M3)
0.11
Federal Standard
(mg/M3)
5
0.049
5
TWA (1) (mg/M3)
0.113
Sample Time (min)
223
Sample Vol. (liters)
Comments
379 '`Processing 8" Class 150 pipe:
0.049
215 365
Processing 16" Class 100 pipe1
UPL 02 Inspector
Darvin Holder
9/17/86
0.088
5
0.088
293 498
Processing 16" ClaBS 100 pipe)
UPL 02 Hydrotester
D.F. Dill
9/17/86
0.18
5
0.18
171 291
Processing 16" Class 100 pipe'
MOA Operator
Gary Templeton
9/17/86
0.056
5
0.056
365 620.5
13' Head Curer
Ray Terrell
9/16/86
0.058
5
0.058
232 394
13' Utility Operator
Cecil Bell
9/16/86
0.25
5
0.25
226 384
Boiler, Ball Mill & Dryer Op. (D-55)
Don Beturnbell
9/17/86
0.28
5
0.28
251 426.7
D 002270
CO
Account: J-M Manufacturing Location: Denison, TX
TABLE II AIR SAMPLING DATA - RESPIRABLE DUST
(1) T.W.A. a The Time-Weighted Average concentration for a normal 12-hour workday. This determination is based on the actual exposure time to the air contaminant.
ii
D 002271
Account: J-M Manufacturing Location: Deniaon, TX
TABLE III AIR SAMPLING DATA - VINYL CHLORIDE
Job Description (J-M No.)
Employee Name
Injection Molding Glen
Mixer Operator
Reynolds
Date Sampled
9/16/86
Air Cone. (ppm)
<0.048
Federal Standard (ppm) (1)
0.7
TWA (2) (ppm)
<0.048
Sample Time (min)
168
Sample Vol. (liters)
8.4
Comments 1,
Injection Molding #1 & #2 Operator (V-21P)
Ralph Raper
9/16/86
<0.038
0.7
<0.038
207 10.35
PVC Pipes Mixer Operator (V-1P)
Charles Caldwell
9/17/86
<0.038
0.7
<0.038
207 10.35
Extruder #5 Operator (V-20P)
James Rhoads
9/16/86
<0.035
0.7
<0.035
230 11.5
Permalock, Sonoco #3
Raymond Crites
9/17/86
<0.036
0.7
<0.036
223 11.15
(1) The OSHA 8-hour TWA PEL for vinyl chloride is 1 ppm. The PEL for a 12-hour workday is calculated to be 0.7 ppm (1 ppm x 8/12 0.7 ppm).
(2) T.W.A. = The Time-Weighted Average concentration for a normal 8-hour and 12-hour workday. This determination is based on the actual exposure time to the air contaminant.
\ D 002272
o
Account:: J-M Manufacturing Location: Denison, TX
TABLE IV AIR SAMPLING - ORGANIC SOLVENTS
Job Description (J-M No.)
Employee Name
PVC Moulding &
Fred
Assembly Operator Kerley
Air Contaminant
Tetrahydrofuran
Ethyl Acetate
Air Cone. (ppm)
5.8 3.4
<0.55 <0.36
Federal Standard
(ppm) 200
400
TWA (1) (ppm) 4.35
<0.36
Sample Time (min)
95 145
Sample Vol. (liters)
19 29
95 19 145 29
Em 0.02
Extruder #6 & it7 Operator
Roy Shives
Methylene Chloride
MEK
<0.90 3.0 3.0
11 8.4 9.7
333*
1.7
133**
9.9
66 3.3 44 2.2 45 2.3
66 3.3 44 2.2 45 2.3
(1) T.W.A. - The Time-Weighted Average concentration for an 8-hour or 12-hour workday. ' This determination is based on the actual exposure time to the air contaminant.
* The OSHA PEL for methylene chloride is 500 ppm, 8-hour time-weighted average. The PEL for an average 12-hour workday is calculated to be 333 ppm (500 ppm x 8/12 = 333 ppm).
** The OSHA PEL for MEK is 200 ppm, 8-hour time-weighted average. The PEL for an average 12-hour workday is calculated to be 133 ppm (200 ppm x 8/12 133 ppm).
i ]
I
D 002273
Account: J-M Manufacturing Location: Deniaon, TX
table V AIR SAMPLING DATA - TOTAL DUST
Job Description (J-M No.)
PVC Pipes Mixer Operator
Employee Name
Charles Coldwell
Date Sampled
9/16/86
Air Cone. (mg/M3)
1.6
Federal Standard (mg/M3)
15
TWA (1) (mg/M3)
1.6
Sample Time (min)
248
Sample Vol. (liters)
372
Comments 1.
Injection Mold ing Mixer Op.
Glen Reynolds
---------------------f
9/17/86
1.6 15
___ _______ ,,___
-- ,
,
.................
1.6 . , --i i ... .1
200
(1) T.W.A. a The Time-Weighted Average concentration for an 8-hour or 12-hour workday. Thia determination is based on the actual exposure time to the air contaminant.
300
D 002274
M
Account: JrM Manufacturing Location: Denison, TX
TABLE VI AIR SAMPLING DATA - CARBON MONOXIDE
Job Description (J-M No.)
Employee Name
Fork Lift Driver Finishing Area
Jack Hamsard
Date Sampled
9/17/86
Air Cone. (ppm)
<10
Federal Standard
(ppm)
50
TWA (1) (ppm)
<10
Sample Time (min)
295
Sample Vol. (liters)
103
Comments (<
(1) T.W.A, ** The Time-Weighted Average concentration for an 8-hour or 12-hour workday. This determination is based on the actual exposure time to the air contaminant.
D 002275
Account: J-M Manufacturing Location: Denison, TX
Job Description
Employee Name
TRANSITE DIVISION
Willow Operator (N-7WE)
Johnny Crain
TABLE VII
RESULTS OF NOISE MEASUREMENTS
SLM dBA(1)
Dosimeter Test
Time (2)
Dosimeter Reading (3)
82-84
316 min.
36,222
13' Utility Operator
Cecil Bell
- 338 min.
70.132
13' Control Op. (N-4WE)
Charles Moore
86-91
308 min.
69.392
13' Tender
Arthur Dawson
- 305 min.
59.182
13' Curer
Vernon Hall
84-90
338 inin.
71.902
Serviceman & Salvage Grinder Operator (N-8WE)
Phillip French
' 350 min.
53.352
UPL 02 Unit Loader
UPL #2 Inspector
Raymond Hesse Darvin Holder
89-94 90-98
225 min. 239 min.
50.902
.................................................
87.732
Full Shift Dose
82.532 149.392 162.212 139.702 153.162 109.752
162.882 264.292
Date: 9/16 & 17/86
Equivalent TWA dBA <1 86
90
91
89 90 88
91
94 D 002276
Account: J-M Manufacturing Location: Denison, TX
Job Description
Employee Name
UPL #2 Operator (N-4F)
Bill Roger
TABLE VII
RESULTS OF NOISE MEASUREMENTS
SLM dBA(l)
Dosimeter Test
Time (2)
Dosimeter .Reading
(3)
90-107
226 min.
118.902
Slash Saw & MOA Operator (N-6F)
Gary Templeton
88-95 MOA Machine 231 min.
100-104 Slash Saw
PVC Moulding 6 Assembly Worker (N-17F)
Fred Kerley
82-96
189 min.
65.422 42.922
In Process & Coupling Testing Area Inspector
Henry Coldiron
83-92
277 min.
31.552
PVC Moulding & Assembly - Saw Operator
Jack Bartley
95-105 Cutting 83-87 Background
372 min.
161.012
Large Coupling Cut Off Operator (N-13F)
Bobby Brown
90-94 Cutting 86-89 Background
245 min.
55.702
Full Shift Dose
378.802 203.912 109.002 82.012
207.752
163.692
Date: 9/16 & 17/86
Equivalent TWA dBA
---9--7-- -
f,
92 '
91
86
95
91
D 002277
Account: J-M Manufacturing Location: PeniBon, TX
Job Description
Extruder 03 (N-3P)
Employee Name
TABLE VII
,
RESULTS OF NOISE MEASUREMENTS
SLM dBA(1)
88-90
Dosimeter Test
Time (2)
Dosimeter Reading (3)
Extruder 03
James Rhoads
88-90
194 min.
42.30%
Extruder 06 Operator
PVC Powder Hopper
87-89 92-94
Grinder Operator David Houston
- 364 min.
106.51%
Mixer Operator (N-1IM)
Charles Coldwell 88-96
209 min.
70.95%
Truck Driver
Sylvester Shives
-
125 min.
89.83%
MAINTENANCE DEPT. Carpenter
Tommy Clipper
80-83
159 min.
13.10%
SHIPPING DEPT. Load Driver
Marc Ayres
- 124 min.
20.30%
Full Shift Dose
156.99%
210.68% 244.42% 517.42% 39.55% 78.58%
Date: 9/16 A 17/86 Equivalent
TWA dBA ii
90
93 94 99
83
88 D 002278
Account:: J-M Manufacturing Location: Denison, TX
Job Descript ion
Employee Name
Finishing Area Forklift Driver
Jack Hamsard
TABLE VII
RESULTS OF NOISE MEASUREMENTS
SLM ' dBA(l)
Dosimeter Test
Time (2)
Dosimeter Reading (3)
- 81 min.
19.76%
Finishing Area Platform Driver (N-20F)
Jerry Bruce
Finishing Area Mechanic
George Kerley
Finishing Area Electrician
Troy McGehee
- 172 min. - 274 min. - 228 min.
35.86% 39.01% 24.15%
UCL #1 Operator (N-15F)
Larry Henderson
92-98 UCL#1 in operation
86-90 background
241 min.
76.25%
PVC,DIVISION
Extruder #1 Operator
PVC Powder Hopper
86-90 90-92
Full Shift Dose
175.64% 150.11%
68.34% 50.84%
227.80%
Date: 9/16 & 17/86 Equivalent
TWA dBA 91 90 87 85 93
0 0022^
Account: J-M Manufacturing Location: Denison, TX
Job Description
Employee Name
INJECTION MOLDING DEPT.
Injection Mold ing 01 & 02 Op.
Ralph Raper
TABLE VII
RESULTS OF NOISE MEASUREMENTS
SLM dBA(l)
Dosimeter Test
Time (2)
Dosimeter Reading (3)
85-89
212 min.
34.37%
Full Shift Dose
116.73%
Date: 9/16 & 17/86
Equivalent TWA dBA
1. 88
Injection Mold ing Mixer Op.
Glen Reynolds
84-95
178 min.
39.92%
107.65%
91
PERMALOCK
Permalock 03 Sonoco Operator
Raymond Crites
83-88
223 min.
21.59%
69.71%
87
(1) SLM dBA : General Radio Sound Level Meter reading in dBA (using the "A" weighted scale, slow response).
(2) Test Time: Duration of dosimetry test in minutes. (3) Dosimeter Reading: Noise dose as the percentage of the daily allowable dose.
D 002280
19
DISCUSSION
The J-M Manufacturing Company, Denison plant, manufactures three different types of pipes: transite; FVC; and permatran. The permatran plant was not in operation during the days of the survey. The transite plant is operated by one 3-day, 12-hour shift. The PVC plant operates around the clock.
Asbestos
OSHA has promulgated a new asbestos standard (1910.1001) on June 20, 1986 to lower the permissible exposure limit to 0.2 fibers/cc as an 8-hour timeweighted average. An action level, which will trigger requirements for periodic monitoring, medical surveillance, and employee training, is set at 0.1 fibers/cc.
As can be seen from the sample results presented in Table I, The UPL #2 in spector was exposed to an asbestos level in excess of the OSHA permissible exposure limit. The willow operator's exposure level exceeded the OSHA action level.
Routine monitoring of asbestos exposure levels and a medical surveillance pro gram have already been implemented per the requirements of the 197 2 asbestos standard. Several revisions were incorporated into the 1986 asbestos stan dards. It is recommended that the additional provisions for notification of monitoring and medical examination results, work practices, preventive cloth ing, hygiene facilities, warning signs, compliance program, respiratory protec tion, medical surveillance, record keeping, and employee training in the 1986 standard be adhered to. A comparison of the two standards is presented in Appendix II for your reference.
Vinyl Chloride, Respirable Dust, Total Dust, Organic Solvents, and Carbon Monoxide
As can be seen from, the sample results presented in Tables II, III, IV, V, and VI, the exposure levels to vinyl chloride, respirable dust, total dust, organ ic solvents, and carbon monoxide were all within OSHA permissible exposure limits. OSHA permissible exposure limits are levels to which nearly all work ers may be repeatedly exposed without adverse effects.
All the respirable dust samples listed on Table II had an insufficient dust deposit for a free silica analysis. Therefore, the OSHA silica permissible exposure limit is not applicable in this case. The exposure limit for respira ble total dust is used to evaluate the exposure levels.
Though the exposure level to methylene chloride is well within the recommended exposure limit, the management at the Denison plant has expressed interest in the health effects of methylene chloride. The toxicological data on methylene chloride can be found in the Appendix III.
Noise
The results of noise measurements (Table VII) indicate that noise levels ex ceeded the OSHA permissible exposure limit in many areas. A comprehensive hearing conservation program has been implemented by the management. To as--
D 002281
20
sure the protection for the worker's hearing, the hearing conservation program
should be continued.
-
CONCLUSION
Implementation of the above mentioned recommendations should assist you in providing a more healthful working environment and reduce the potential for occupational disease.
D 002282
APPENDIX I
STANDASPS AND GUIDELINES
A complete listing of the appropriate health standards can be found in the following Appendix. Included in this table are the following:
1. Occupational Safety and Health Standards, Subpart Z, CFR Title 29, Section 1910.1000. These standards represent the legal exposure limits as set by the Department of Labor.
2. The American Conference of Governmental Industrial Hygienists (ACGIH)
Threshold Limit Values (TLV's) refer to exposure limits as set by this
organization. These limits, many of which were adopted by the Department
of Labor, are the work of professional personnel in governmental agencies
and educational institutions engaged in occupational safety and health
programs. These TLV's should be used as guides in the control of health
hazards and should not be used as fine lines between safe and dangerous
concentrations.
3. The National Institute of Occupational Safety and Health (NIOSH) has pro posed changes in certain standards based on new evidence in regard to hu man health. These proposed limits are awaiting review, but should be kept in mind as applicable standards for the near future.
D 002283
APPENDIX I
STANDARDS AND GUIDELINES FOR AIR CONTAMINANTS
SUBSTANCE
Asbestos Tetrahydrofuran
UNITS
fibers/cc ppm
Occupational Safet y and Health Administra tion 29 CFR 1910.
8-hr1 0.2 200
Cei 1 ing3 -
Peak4 .-
-
American Conference of Governmental
Industrial Hygienists (ACGIll)
National Institute for Occupational Safety and Health (NIOSH) Proposed
8-hr1
Stel2 Ceiling3
10-hr1
Ceiling3
2-
- 0.1
200 250
-
-
-
Ethyl Acetate ppm
A00
Methyl Ethyl
ppm
200
-
Ketone
-
A00 - - 200 300 - 200
-
Methylene ppm 500 1000 2000 100 - - 75 500 Chloride
Vinyl Chloride ppm
Carbon Monoxide
ppm
15 50 -
-- -
5" 50 A00
- Minimum detectable level
- 35
1 200
Respirable Total Dust
mg/M3
5
-
-
5-
--
-
Total Dust
mg/M3
15
-
-
10 - - -
-
1 8-hr or 10-hr - The time weighted average for an 8- or 10-hour work shift in a AO-hour workweek.
STEL - ACGIH'a standard maximum concentration to which workers can be exposed for a period up to 15 minutes.
(Short Term Exposure Limit)
~*------
Ceiling (OSHA) - The concentration that should not be exceeded even instantaneously, except when the standard has a peak value (A).
^ ?esk -- Acceptable instantaneous peak exposure above ceiling concentration (A).
D 002284
APPENDIX I
1910.95 Occupational Noise Exposure
a) Protection against the effect of noise exposure shall be provided when sound levels exceed those shown in Table G-16 when measured on the A scale of a standard sound level meter at slow response.
TABLE G-l
Permissible Noise Exposures
Sound Level (dBA)
Duration Hours/Day
90 8 92 6 95 4
97 3 100 2 102 1.5 105 1.0 110 0.5 115 0.25 or less
b) When workers are being exposed to excessive noise levels based on Table I, feasible administrative and/or engineering controls shall be utilized. If such controls fail to reduce noise exposure to within these limits, personal protective equipment shall be provided and its use strictly enforced.
c) When noise exposures exceed the action level (85 dBA equivalent) the employer shall administer a continuing effective hearing conservation program. This program should be made available to employees whose eight hour time weighted average (TWA) exposure equals or exceeds 85 (dBA) and such a program should consist of the following:
1. Perform noise monitoring to determine which employees may be exposed to noise equaling or exceeding 85 dBA eight hour TWA.
2. Provide baseline and annual audiometric testing of all exposed employees. Baseline test must be completed by March 1, 1984.
3. Make hearing protection available to employees whose noise exposures equal or exceed 85 dBA eight hour TWA.
4. Make hearing protection mandatory for:
a) Employees whose 8 hour TWA exposure exceeds 90 dBA.
b) Employees whose 8 hour TWA exposure equals or exceeds 85 dBA and who show a "significant threshold shift" or deteriorating hearing acuity, on their lastest audiogram.
5. Provide initial and annual training of exposed employees including the
use and proper fitting of hearing protection.
D 002285
APPENDIX || Comparison of 1972 and 1986 OSIIA Asbestos Standards
The following points are highlights of the differences between the old (1972) and new (1986) OSIIA Asbestos Standards:
Effective Dates -
NEW - GENERAL INDUSTRY July 21, 1986
h:l -
8-hr. TWA
- 0.2 fiber/cc. Fibers are defined as longer than 5 microns with a length to width ratio of >3:1. Applies to chrysotile, amosite, crocidolite, tremolite, anthophylllte,. actinolite and altered or chemically treated forms of the above. Requirements pertaining to non-fibrous forms have been stayed until 4/87.
NEW - CONSTRUCTION
July 21, 1986 (All sections must be complied with 1/21/87)_____________
- Same
OLD.
July 7, 1972
i. ; 2 fiber/cc. Fibers are defined as longer than 5 microns (no other dimensions are specified). (PEL lowered from 5 fibers/cc to 2 fibers/cc effective 7/1/76.)
Ceiling
- None. With the low TWA, the ceiling Is effectively 6.4 fibers/cc.
- Same
10 fibers/cc
Action Level
- 0.1 fiber/cc - triggers monitoring. medical, and employee information and training requirements
- Same
None.
-ur.* ci'.
asbestos at any
level triggers med
ical monitoring.
0.1 fiber/cc was
used as the enforce
ment level.
Occupations
- Separate standards for Construction and General Industry. Occupational exposures are interpreted co include office workers and workers in the vicinity of abatement situations.
- See ATTACHMENT LI for list of occu pations.
Applies to all asbestos-relaced occupations. Does not specifically men tion office workers
0 02286
Comparison of 1972 and 1986 OSliA Asbestos Standards
NEW - GENERAL INDUSTRY
NEW - CONSTRUCTION
OLD
Page 2
Monitoring' - Frequency ** *Initial monitoring for employees at or above the action level required by
' 10/20/86.
- Repeat monitoring frequently enough to "reasonably" represent exposure, at least once every 6 months, unless doc umentation shows levels consistently below action level.
- Whenever there is a change in work circumstances.
Type
- Personnel only, in breathing zone, full shift.
- Initial monitoring
- Effectively similar to new
at the initiation of each job. - Daily monitoring
staml/ir.l; however, im re quirements for sampling after work changea are
representative of each employee In the
stipulated.
regulated area. (Ex cept where employees
' i. .
are wearing supplied
air respirators -
positive pressure
mode)
- Monitoring may be
discontinued if data
shows statistically
validated levels be
low the action level.
- Same
- Personnel and area samples required in breathing zone - full shift not specified; however, inter pretation most often required fulL shift.
Media
- 25mm mixed cellulose ester (MCE) filter cassettes with 50mm extension cowl, open-faced.
- Same
37mm, 0.8 micron pore MCE filter cassettes, open-faced.
Flow rate - 0.5 to 2.5 liters per minute
- Same
None specified, usually
interpreted as 2.0 Liters
per min.
-
Air Volume
- A sufficient air volume to yield between 100 and 1300 fibers/mmon the filter.
- Same
.acquirements for monitoring are detailed in the 0SMA Standard Mandatary Appendix A.
None specified. D 002287
Comparison of 1972 and 1986
Monitoring - (continued)
Shipping
NEW - GENERAL INDUSTRY
- Use packing material with low electrostatic charge, e.g. no polystyrene.
Calibration - Before and after sampling.
Blanks Analysis
- 10% blanks, at least 2 (reject blank if >7 fibers/100 fields).
- Phase Contrast Microscopy (PCM), approximately 400 x, Walton-Beckett graticule, Phase Shift test slide, acetone/triacetin mounting procedure, 10% duplicate counts. Count using rules sllilar to N10SH 7400 A rules, effective QA program including round robins and microscopist training.
Employee Notification - Written notification of monitoring re sults required within 15 days after receipt of monitoring results.
- Written notification of medical exam results within 30 days after receipt.
Asbestos Standards
Page 3
NEW - CONSTRUCTION Same
OLD . - None specified. ,
Same Same
Same
` It
- Not specified.
- Not specified.
- 400 - 450 x Phase Contrast Microscopy
- Notification re quired - no time limit specified for monitoring results.
- Notification of asbestos related activities to other employers in the facility.
- Notification required within 5 days If employee exposure is higher titan the PEL. Employees must have access to monitoring records.
0 002288
Comparison of 1972 and 1986 0SI1A Asbestos Standards
NEW - GENERAL INDUSTRY
Engineering Controls
- Engineering Control Specifications re quired by July 20, 1988.
- Local exhaust ventilation with 11EPA-- filtered exhaust systems (and other con trols) designed and maintained to lower fiber levels to below 0.2 fibers/cc*
- All hand operated power tools which would, release asbestos fibers pro vided with local exhaust ventilation.
- No usage of compressed air (except in conjunction with appropriate ventilation system).
- HEPA-filtered vacuuming - Wet removal of asbestos materials - No spraying of asbestos materials - Waste shall be sealed in impermeable
bags and disposed of.
Page 4
NEW - CONSTRUCTION
OLD
- ADD: Negative
- Local exhaus-t ventil
pressure enclosures
ation systems designed
to be established
and maintained to lower
where feasible.
fiber levels as much as
- "Competent person"
practical
to supervise setup, - All hand operated power
entry, exit, enclo
tools which would re
sure integrity, use
lease asbestos fibers
of protective gear,
provided with local
monitoring, train
exhaust ventillation
ing, work practices, - Wet removal of asbestos
hygiene, decontam
materials
ination, proper
functioning of engi
neering controls,
- Use of wetting agents
or encapsulants
during handling,
mixing, removal, cut
ting, application,
and cleanup.
- Prompt disposal of
waste.
- Use of high-speed
abrasive disk saws
prohibited.
*Exception - For the following operations, engineering controls to 0.5 fiber/cc are allowed if 0.2 is not feasible: coupling cutoff in primary asbestos cement pipe manufacturing, sanding in primary and secondary asbestos cement sheet manufacturing, grinding primary and secondary friction product manufacturing, carding ami spinning in dry textile processes, and grinding and sanding in primary plastics manufacturing. Respiratory protect toil must be used to supplent other controls.
v D 002289
Work Practices
Comparison of 1972 and 1986 OSUA Asbestos Standards
NEW - CENERAL INDUSTRY
- Requirements (effective 7/20/88) include no eating or drinking in area, adequate housekeeping to prevent accumulations of asbestos dust, cleanup of spills, washing prior to eating or smoking, showering after work, cleaning of clothing and equipment before entering clean areas.
Page 5
NEW - CONSTRUCTION
OLD
ADD: Decontamination area entry and exit procedures speci fied - Enter: through clean room, remove street clothes and don protective gear, pass through equipment room. Exit: .remove gross contamination in work area, remove protec tive clothing in equipment room and place in bags - do not remove respirators in equipment room shower, change Into street clothes in clean room.
Adequate housekeeping prevent accumulations <>i asbestos dust required.
Protective Clothing
- Full-body coveralls, gloves, head cover ings, foot covering required for all em ployees exposed to levels above the PEL. Face shields and vented goggles required where appropriate.
- Contaminated clothing must not be taken out of work area except for cleaning; must be stored in labeled, closed con tainers; clean clothing and equipment must be provided at least weekly;
laundering must be done so as not to release fibers, cleaners must be In formed of appropriate cleaning methods for asbestos - no blowing or shaking of clothing.
Same except instead '
of requirement for
weekly provision of
clean clothing,
standard specifies
that the "competent
person" will Inspect
clothing periodically
for leaks and tears
and immediately repair
or replace clothing
when damaged.
Similar to NEW. No requirements for clothing replacement, prevention of shaking, or removal from work area.
D 002290
Facilities
Comparison oi iy/2 and 19tit> OSIIA Asbestos Standards
Page 6
NEW - CENERAL INDUSTRY
NEW - CONSTRUCTION
OLD
- Limited access, demarcated, regulated areas; showers, change rooms, separate lockers for street and work clothes, and positive pressure lunchrpom are required if exposure is above PEL. (Regulated areas are to be established by 11/17/86; showers and lunchrooms by 1/16/87.)
- Limited access, de marcated, regulated areas.
- Clean change rooms (except for small,
- Change rooms and separate lockers are required if exposure is above PEL.*
short duration jobs
where IIEPA vacuuming
of clothing is
allowed), separate storage facilities
h
for street and work
clothes, lunch area
<action level, de
contamination area
adjacent and con
nected to regulated
area, decontamina
tion area to con
sist of equipment
room, shower, and
clean room in series.
Warnings
- Warning signs of specific wording are required at all regulated areas and approaches; labels are required on all waste materials, MSDSs required of manufacturers and importers if asbestos >0.1% and not coated.
- Same
- Warning signs of specific size and wording required at all approaches if levels > PEL. Specific labels are required on all waste materials.
Compliance Program >
- A written program to reduce employee exposure by means of engineering and work practice controls is required if levels exceed the PEL.
- Program must be written by 7/20/87 and updated regularly.
- Employee rotation shall not be used as a means of compliance with the PEL.
- Compliance program not specified,
- Written program not required.
- Employee rotation prohibited.
D 002291
Respiratory Protection
.
Comparison of 1972 and 1986 OSIIA Asbestos Standards
NEW - GENERAL INDUSTRY
NEW - CONSTRUCTION
OLD
Page 7
- (Effective by 11/17/86 depending on
- Same
employee exposure)
Respirators shall not be used to comply
with PEL. They are required while
engineering controls are being imple
mented and can be used during maintenance
activities, and in emergencies. Appro
priate respirators are listed in ATTACH
MENT I.
- The employer will provide respirators
at no cost to.the employee.
- *Respirators must be properly fit tested
using specified quantitative or quali
tative face fit tests at the time of
Initial fitting and at least every six
months thereafter.
- Employees using filter respirators must
be allowed to change filter elements when
ever an increase in breathing resistance
is detected.
- Employees wearing respirators must be
allowed to wash their faces whenever
necessary to prevent skin icritation.
- If a physician determines that an em
ployee cannot function normally while
wearing a respirator, then that employee
shall not be assigned to a task re- .
quirlng respirators.
- Similar to NEW except for the following:
- Specific face fit tests are not required
- Maintenance activities are not included as allowable respirator usages.
Fit testing requirements are detailed in 0S11A Standard Mandatory Appendix C.
D 002292
Medlcal Surveillance
Comparison of 1972 and 1986 0S1IA Asbestos Standards
NEW - GENERAL INDUSTRY
NEW - CONSTRUCTION
OLD
Page 8
- For employees exposed to levels at or above the action level, medical mon itoring must be instituted by 11/17/86
- *The program must include preplacement exams; termination of employment exam within 30 days of termination; annual exams; provision of standard, descrip tion of employees' duties and exposure details to physicians; a written opinion from the physician.
- A standardized questionnaire must be used for documenting the medical program.
Required if em
ployees exposed
'
to action level for
30 or more days per
year. Exam must be
provided within 10
working days fol
lowing 30th day of
exposure. Not re
quired if exam pro
vided previously
within 1 year before
assignment. Termin
ation exams not
specified.
Similar to the new standard except that a standardized ques tionnaire Is not re quired.
i.
Recordkeeping
- The employer will maintain accurate records of all exposure measurements and applicable details (for 30 years), data for exempted operations, medical monitoring data (for 30 years), training records (for 1 year after termination of employment)
- Records will be available for examination by affected employees or designated OSltA representatives
- Same
Exposure measurements and applicable details must be maintained for 3 years, medical records for 20 years Records will be avail able for examination by affected employees, their physicians, and OSHA representatives.
*Detalled exam requirements'are Included in the 0SHA Standard. Mandatory Appendix E outlines Interpretations of Chest Roentgenograms. The Medical Questionnaire is contained in 0SUA Standard Mandatory Appendix D
D 002293
Training
Comparison of 1972 and 198$ OSIIA Asbestos Standards
Page 9
NEW - CENERAL INDUSTRY
NEW - CONSTRUCTION
OLO
- The employer must institute a training program for all employees who are ex posed to levela at or exceeding the action level. Training must be prior to work assignment, and at least annually thereafter. Training must be provided by 10/20/86 and should include health effects, relationship between smoking and asbestos engineering controls and work practices, respirators, medical monitoring program, and a review of standard.
- Same except training not necessary if provided previously within 1 year before work assignment.
- Training not required, .
0 002294
Comparison of 1972 and 1986 OSHA Asbestos Standards
ATTACHMENT I
New Standard: ' ao X PEL 2 fibera/cc) <50 x PEL (<10 flbers/cc <100 x PEL (<20 flbers/cc)
<1000 x PEL (<200 flbers/cc) >1000 x PEL (>200 flbers/cc) or unknown
Old Standard: <10 x PEL (<20 flbers/cc) <100 x PEL (<200 flbers/cc) >100 x PEL (>200 flbers/cc)
Respiratory Protection
.
Half mask air-purifying respirator with high efficiency filters Full face piece alr-purifylng respirator with high efficiency filters
''
Any powered air-purifying respirator with high efficiency filters or any supplied-alr respirator operated in continuous flow mode.
Full facepiece supplied-air respirator operated in pressure- demand mode.
Full facepiece supplied air respirator operated in pressure demand mode equipped with an auxiliary positive pressure self-contained breathing apparatus.
Reusable or single use air purifying respirator. Full facepiece powered air purifying respirator or powered air purifying respirator. Type C continuous flow or pressure demand supplied-air respirator.
0 002295
Comparison of 1972 and 1986 OSHA Asbestos Standards
ATTACHMENT LI
Occupations/Processes Covered by Construction Standard
1. Demolition or salvage of structures where asbestos, tremolite, anthophyllite, or acfinolite is present.
2. Removal or encapsulation of materials containing asbestos, tremolite, anthophyllite, or actinolite.
3. Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that
contain asbestos, tremolite, anthophyllite, or actinolite.
'
4. Installation of products containing asbestos, tremolite, anthophyllite, or actinolite.
5. Asbestos, tremolite, anthophyllite, and actinolite spill/eroergency cleanup; and
6. Transportation, disposal, storage, or containment of asbestos, tremolite, anthophyllite, or actinolite or products containing asbestos, tremolite, anthophyllite, or actinolite on the site or location at which construction activ ities are performed.
NOTE: Exceptions for small-scale, short duration operations Include pipe repair, valve replacement, installing elec trical conduits, installing or removing drywall, roofing, and other general building maintenance or renovation.
D 002296
APPENDIX III D 002297
21:8766
riEi nnuicE pile
-- an open-transfer of the liquid: -- leakage front process equipment:
(\ Toxicology Data. I. Aimnal Studies:
-- maintenance or repair-work done on process equip*
Experiments have been conducted to determine the
ment or transfer systems containing methylene chloride; carcinogenicity of methylene chloride. Some of these
-- a failure of temperature controls and/or of exhaust . studies and the investigator's conclusions aie summa
ventilation systems or when these controls arc inad rized below.
equate, ineffective or improperly applied.
The I9H4 publication by llutck. el al. ( t) icpoiis the
IV. Health Effects.
findings of a Dow Chemical Company I'M!) stud) of
A. Routes of Exposure.
.
chronic inhalation in rats and hamsters. Inhalation expo
Methylene chloride can affect the body if it is inhaled sures of 0. 5UO, f51)0. or .1500 parts of methylene
or if it comes in contact with the eyes or skin. It can also chloride per million parts of air (ppm) lor ft Itouts per
affect the body if it is swallowed (45).
day, 5 days a week for 2 years were used. Ihirck's results
B. Metabolic Pathways/Pharniacokinctics.
showed an increase in belling iminus in (cmnic rats at alt
Analysis of the capability of various tissues to metabo doses ami in male rats at the highest (loses. Itmek also
lize methylene chloride indicates the liver as the primary reported a significant increase in salivary gland sat co
site, with some metabolic action in the lung and kidney. mas at tlic high dose only in rats. Hamsters .showed mi
Data from both in vitro and in vivo studies indicate that tumors, even at the highest dose levels.
methylene chloride is metabolized via two pathways.
In 1982 Dow Chemical Company performed a second
The P-450 mixed function oxidase pathway is located in inhalation study to explore the toxicity of methylene
the microsomal fraction of the cell and yields carbon chloride at concentrations below those that cause saluta
monoxide as an end product. The glutathione-dependent tion of the metabolic processes (U. 50. 200. and 51)0
enzyme pathway found in the cytosolic fraction of the ppm). No compound-related increased incidence of any
eel! yields carbon dioxide as an end product with formal other tumor type was observed by Dow researchers.
dehyde and formic acid as metabolic intermediates. Both
The NTP (19) inhalation bioassav of methylene chlo
pathways generate metabolically active intermediates: ride was conducted on F.144/N rats ami HftC.H-1 mice.
formyl chloride, formaldehyde or S-chloromcthyl glu-
Moth sexes were exposed at concentrations of tt. 100(1.
talhionc, which arc theoretically capable of irreversibly
2000 ami 4000 ppm for rats and 0.-7.000. amt 4000 ppm
binding to cellular macromolcculcs such as DNA (11).
for mice. 6 hours/dny, 5 days/week. Tor 102 weeks. In
In vivo data suggest that during exposure to low
both male ami female rats there was an increased inci
concentrations of methylene chloride the two pathways
dence of benign niaimnary gland neoplasms, primarily
appear to be utilized equally. At high concentrations
fibroadenomas. According to tlic N i P study tlieie was a
experimental animals exhale more carbon dioxide than significant increase in hepatocellular neoplastic nodules
carbon monoxide. This suggests the cytosolic pathway and hepatocellular carcinomas (combined) by the (tend
producing carbon dioxide may metabolize significantly
test only in the female rats. NTP also noted a significant
more methylene chloride than the microsomal pathway
increase in mesotheliomas in male rats. In addition tlieie
yielding carbon monoxide (9).
was a statistically significant imnense of mononuclear
At present there arc no data to prove that humans
cell leukemias in female rats by age adjustment. A
utilize the cytosolic pathway. Some investigators have
marginally significant increase was noted in adiena!
speculated that this pathway is functional in humans
pheuehromocytomas and interstitial cell tumois in male
based on uptake data (9). Human utilization of the
rats and pituitary gland adenomas and carcinomas com
microsomal pathway has been confirmed by monitoring
bined in male ami female rats by the 11cm) test only.
the carboxyhcmogiobin (carbon monoxide attached to
In the NTP mouse study, there was a highly signifi
the usual oxygen site on the hemoglobin molecule) level
cant increase in aiveolar/broncliioiar adenoma and/or
following exposure (54).
carcinoma in both sexes. The incidence of hepatocellular
The carbon monoxide generated as an end product of adenoma ami hepatocellular caicinoma combined was
methylene chloride metabolism impairs the ability of the
increased in the high-dose groups (or bulb sexes ami in
blood to transport oxygen to the tissues. Hemoglobin has
the lower dose female gioup. NTP icpoited a dose-
a strong affinity for carbon monoxide, approximately
related increase in tlic number of mice bearing multiple
210 times greater than for oxygen. This results in carbon
lung and liver tumors. While (lie omirol mice bad no
monoxide being readily attached to hemoglobin and
more than one lung tumor per mouse. 41) percent of all
slowly dissociated. Once the carboxyhcmogiobin is dose animals had multiple lung Illinois. Likewise. 2
formed the hemoglobin is unavailable to transport oxy percent of Ibe conliots wen* lonml to have nmlfiplc
gen and the release of oxygen from oxygenated hemoglo liepatocellular I moors and 40 peiccut of the c.\| vised
bin is affected.
animals exhibited multiple liver tumors.
Occupational Safety & Health Ropottor
0 0022" 2*1
osha standard directives
21 0/67
The NTP concluded that "there was some evidence of carcinogenicity of methylene chloride for male F344/N rats as shown by increased incidence of benign nco. plasms of the tnarnmary gland. There was dear evidence of carcinogenicity -of dichioromethanc for female F344/N rats as shown by increased incidence of benign neoplasms of the mammary gland. There was clear evidence of carcinogenicity of methylene chloride for male and female D6C3FI mice, as shown by increased - incidences of alvcolar/bronchiolar neoplasms and of he patocellular neoplasms."
2. Epidemiological Studies: Fricdlandcr, et al. (13) and the follow-up study by Hcarnc and Fricdlandcr (17) performed mortality analy ses of male Uasttnan-Kodak employees exposed to low levels of methylene chloride for up to 30 years. Propor tionate and cohort mortality studies were used to assess whether adverse health efTccts could be shown to occur as a result of exposure to methylene chloride. The proportionate mortality study was used to exam ine 334 deaths of methylene chloride exposal workers during 1956 to 1976. The control group consisted of Eastman Kodak workers who had not been exposed to methylene chloride. Eastman Kodak reported 71 neo
plasms found while 73 were expected based on other Eastman Kodak employee mortality ratios. No single neoplasm site was over-represented.
In the Hcarnc cohort mortality study (17), 751 methy
lene chloride exposed workers were compared to two control groups: Eastman Kodak employees not exposed
to methylene chloride and New York Stale males. The exposed group had a slightly elevated but not statistical
ly significant rate of death from circulatory and respira tory diseases, a slightly higher but not statistically sig nificant incidence of brain or nervous tissue cancers, and a significant excess of hypertensive heart disease com pared to other Eastman Kodak employees.
Another facet of the cohort mortality study centered on 252 males with 20 year or more of exposure. Fricd landcr reported that this group did not demonstrate a statistically significant increase in neoplasms or in circu
latory diseases when compared to the control groups. The study by Ott, et al. (47) reported the results of a
health evaluation of employees of a liber production plant where a solvent mixture of methylene chloride, acetone and methanol was used. The control population was chosen from a plant where only acetone was used. The investigation focused primarily on health clfccts occurring to the cardiovascular system associated with
the increased carboxyhcmoglobin levels resulting from metabolized methylene chloride. The Ott, et al. study reported no statistically significant differences between observed and expected deaths.
F.I'A has criticized both <>f these studies stating that
although neither showed excessive risk, both showed
sufficient deficiencies to prevent them from being judged
negative studies. IIPA noted that the Fricdlandcr. et al.
study (13) lacked the statistical power to enable it to
detect a |xtlcnlial carcinogenic ell eel and the Ott. et al.
(47) study, among other deficiencies, lacked a sufficient
latency period for site-specific cancer.
I). Adverse Human Health Fflccts.
Methylene chloride has a narcotic action and acts as a
central nervous system depressant. 'I he symptoms of
exposure may be dizziness, nausea, tingling, numbness
of the extremities, sense of fullness in the head, sense of
heat. sttifHir, dullness, lethargy, and headache. Inhaling
methylene chloride may cause a sensation of drunken
ness with mental contusion and light-hcadcducss. |:xpn-
surc to very high concentrations may lead to staggering,
rapid unconsciousness and death.
.
Skin contact with methylene chloride may cause iiri-
tntion. dryness of the skin or dermatitis. 'I lie problem
may be accentuated if the chemical is confined to the
skin by contaminated gloves, shoes or tight filling eloifl
ing.
Vapor concentrations of methylene chloride above
2.0UU ppm may cause irritation or the eye and rcspiia-
tory tract (4).
Since cx|>snrc to methylene chloride irier<-:i the
carboxyhcmoglobin level in the blood, ambient eaibon
monoxide levels would have an additive died on that
carboxyhcmoglobin level. Under normal conditions
blood contains about 0.5 |<erccnl car boxy Iren mg lofiin
while a onc-pack-a-day smoker will have a carboxy he
moglobin level of approximately 5.9 percent (14). At
high exposure levels (500 PPM ami above), the cnihoxv-
licmoglnbiii level would lie expected to re.adi a maxi
mum between 12 and I 5 percent. 'I his level is below that
considered hazardous for any normally healthy individ
uals but could place additional stress on compromised
individuals, c.g. persons with cardiovascular diseases
(II).
OSliA has initiated a program to evaluate all of the
existing research in order to decide the validity of each.
At the conclusion or this thorough investigation a more
meaningful cxlraiKilalion of lire data from experimental
animal studies to human occupational exposure will be
performed.
Classification.
HPA classified methylene chloride as a I'tobalile Un
man Carcinogen (Group H2). The FI'A Probable Hu
man Carcinogen classification (Group B) is used when
there is sufficient evidence of carcinogenicity in animals
ami evidence of caicirtogriticily Itont epidemiological
studies that rang.es liotn "almost snllicicnl to bind-
9-3-86
D 002299
Published by THE BUREAU OF NATIONAL AfFAIRS. INC.. Wasltfngron. U.C. 2010/
25
21:8768
equate." To reflect this range, the category is divided into higher (Group Bl) and lower (Group B2) degrees of evidence. The Bl category is reserved for those agents for which there is at least limited evidence carcinogen* icity to humans from epidemiological studies, in the absence of adequate data in humans, it is reasonable to regard agents for which there is sufficient evidence of carcinogenicity in animals as probable carcinogens in
humans. Agents for which there is sufficient evidence from animal studies but insufficient evidence from hu man studies are classified as B2 (12).
... V. Permissible Exposure Limit (PEL).
The current OS HA standard for methylene chloride is
500 parts of methylene chloride per million parts of air
(ppm) averaged over an eight-hour work shift, with an
acceptable ceiling level of 1000 ppm and a maximum
peak concentration of 2000 ppm for five minutes in any
two-hour period. The National Institute for Occupation
al Safely-and Health (NIOSH) has recommended that
the permissible exposure limit be reduced to 75 ppm
averaged over a work shift of up to 10 hours per day, 40
hours per week, with a ceiling level of 500 ppm averaged
over a 15-minute period (21). NIOSH further recom
mends that permissible levels of methylene chloride be
reduced where carbon monoxide is present. The NIOSH
Criteria Document for Methylene Chloride should be
consulted for more detailed information (21). In 1986,
the American Conference of Governmental Industrial
Hygienists (ACGIH) published a Notice of Intended
Changes for 1986-87 to lower the Threshold Limit
Value-Time Weighted Average (TLV-TWA) for an
8-hour workday from 100 ppm to 50 ppm and deleted
the Short Term Exposure Limit (STEL) of 500 ppm.
ACGIH further classified methylene chloride in this
notice as A2 (Industrial substance suspect of carcinogen
ic potential for man. Chemical substances or substances
associated with industrial processes, which arc suspect of
inducing cancer, based on either (1) limited epidemiolo
gic evidence, exclusive of clinical reports of single eases,
or (2) demonstration of carcinogenesis in one or more
animal species by appropriate methods) (2).
VI. Monitoring.
Personal and area monitoring, should be conducted
periodically to determine the levels of employee expo
sure. Personal samples measured over an entire work-
shift should be collected at the workers' breathing /ones
to determine their time-weighted average (TWA) expo
sures. Air samples of methylene chloride can be collect
ed by charcoal lubes, the analyte desorbed with carbon
disulfide and analyzed by gas chromatograph equipped
with a flame ionization detector (22,23).
Because methylene chloride is a solvent with a high
vapor pressure, tiicrc is a high probability of its migra
NEmuiwuE FILE
tion once adsorbed on charcoal, l or (his reason, and
since the amount of sample which can be collected is
limited by the quantity each tube will hold before over
loading, OSHA recommends that sampling be done with
_ two charcoal tubes in series, each containing 1(10 mg
front and 50 mg backup sections of ehaieoal at a
maximum How rate of 50 tiil/min ami not to exceed a
sample volume of two liters of air (46).
VII. General Methods of Control.
-
Commonly used methods for controlling occupational
exposure to methylene chloride include piuducl substitu
tion, engineering controls, work practice controls, anti
the use of personal protective clntliiug and equipment.
Appropriate worker education and tiaiuing ptograms ate
also major factors in the control of exposures to methy
lene chloride.
A. Substitution. The best method for controlling cx|hisuic to any ex tremely toxic material is to use a less toxic material wherever possible. Methylene chloride has been de scribed by industry as a very strong and effective solvent for a variety of industrial cotu|niumls. combining several important technical qualities in one solvent (e.g.. it is a flammability suppressant, a vapor pressure depressant, a
viscosity thinner, can be readily atomized, has a high evaporation rate and readily dissolves a wide variety of substances) (10, 15).
Industry has suggested the use of ethyl alcohol as a substitute solvent Tor use in hair sprays, room fresheners, degreasers and oilier household aciosol loimtil.-Kious. Possible alternative solvents for household aerosol spray paint formula lions arc acetone, methyl ethyl ketone or toluene. Care must be exercised in selection of these substitute solvents since they nrc highly llnmmalilc. I or cold cleaning or vn|tor degii-asing. 1.1.2- liichloto1,2,2,-lriHuorocthaiic (fluorocarbon IIJ) or other less toxic halogcnatcd hydrocarbons may be used (10.15).
Triclilorofluoromctlumc (Fluorocarbon 11) has been used as an alternative solvent to methylene chloride for use as a blowing agent in the manufacture of urethane foam products (5).
For many other important industrial processes, there
may not be any viable alternatives to methylene chloride at this lime.
B. Equipment or Process Design. Open equipment which dischaiges methylene chloride to the ambient air should be avoided unless mechanical ventilation or solvent recovery units arc available. Occu pational exposure to methylene chloride can be mini mized by the effective installation, use and pi ope r main tenance of such items as full or p.-ntial process enclosures, including the use of bailies and covers, lor
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