Document jBLvvEMQjGDwXxBKED4z7kROp

IFGobdrich INTER-ORGANIZATION CORRESPONDENCE Status Report on Industrial Hygiene Survey ~ August 1982 A. Previous Survey Items 1) Formal reply to survey 2) Eyewash fountain, Process 3rd floor replacement 3) Physical examinations for worker respirator useage. 4) Respirator program 5) Dust filters 6) Ammonia tanks 7) PVC bagger noise 8) Increase personal monitoring time for VCM. B. 1982 Recommendations 1) Written respirator procedure. 2) SPCC procedure to address protective clothing. 3) Written procedure for VCM monitoring. 4) Noise: a) Signs at 100% hearing protection areas (above 85 dBA) b) Signs at Dryer locations. c) Dosimeter data supplied to nurse to compare audiometry results. d) Calibrate audio dosimeters annually. 5) > 80 ft/min. on laboratory fume hood. Comments By Nov. 28/82 as requested. Quotes obtained; GPO being circulated for approval. Doctor now complies, all plant workers able to wear respir ators. Completed project. Completed Completed Completed Completed Completed Completed Completed. When issued, SPCC will include this requirement. Will be written. To be completed soon. Monitor ing still in progress. As above. Completed. Data will be made available for the nurse & doctor as required. Completed. Unit has returned from supplier. Engineering project in progress to achieve this ventilation rate. BFG45116 2- - B. 1982 Recommendations - Continued 6) Use of respirators and hearing protection be reported monthly. 7) 4 G.C. probes in Geon South have missing end filters* 8) Balston filters in G.C. lines in Geon North not tight. 9) Lead stabilizer in lab: Monitoring and blood lead not required. Comments Completed Completed Completed Completed. In addition, assessment completed for the work place. /cs CjJ. Carl B. Reid 25894002 BFG45117 *\-cd TO J. J. Dunn T. S. Bialke SUBJECT Industrial Hygiene FIELD POINT OR DEPT. & BLDG. NO. Niagara Falls^.Canada cFiIcEiLrD> dP/O-mINmTt aOoR rDsEroPTT. &o, aBiLnD/G;. NO. Akron - D/0020, 5-H Survey; August 10-13, 1982 DATE YOUR LETTER DATE THIS LETTER 9-20-82 An industrial hygiene survey was conducted at the Niagara Falls chemical plant during the period August 10-13, 1982. Most items from the previous survey have been satisfactorily completed; however, no formal reply to the 1980 survey was issued, an eye wash fountain valve had not been changed over, and routine exami nations for respirator users had not been implemented. Items that need attention as a result of this survey include pro cedures for respirator usage and vinyl chloride monitoring develop ment; the noise program needs refinement, and laboratory hoods need to be.updated. The plant has identified and posted most areas with excessive noise as being "noise hazardous". I found the wearing of hearing protection by plant personnel to be good. As in the past, I want to thank C. Reid for his help in making my survey productive. v cc: H.W.Dietz/E.B.Katzenmeyer,Jr. C.Reid/J.Nagy H.Waltemate/E.Martinelli P.J.Weaver/D.A.Brooks W. C.Becker R. E.Healey !' S. Bialk G-495S-E 1 I/30LITHO IN 'J S A. BFG45118 Niagara Falls IH Survey; 1982 Findings Recommendations 1. Exp.date Re spansi- Completion bility - Items from Previous Survey 1. No formal reply to 1980 IH survey. 1. A formal reply to an IH survey is to be issued within 60 days of the receipt of the survey report and quarterly thereafter until actions addressing each recommendation have been satisfactorily completed. 2. Eyewash fountain, 3rd floor poly building, Geon south is still of the spring-loaded type. 2. Replace spring loaded valve on referenced eyewash fountain with a type that will remain r^P2 open until manually closed, thus permitting ^ employee operating fountain to use both hands to keep eyes open when flushing out eye con taminants . ^ 3. Physical examinations for respirator wearing approval not being done. 3. BFG policy requires that all employees working on jobs that require wearing of res pirators be approve to wear them. All pro visions of BFG OHP 1.17 "Use of Respirators" are to be implemented for employees working on jobs at Niagara Falls that require them to wear respirators. B F G 4 5 119 4. Respirator program: a. improve storage conditions b. assure cleanliness and serviceability c. replace 3M8500 with 3M8710. d. require'PVC bagger to wear respirator until exhaust ventilation is improved. 5. Install dust filters on LPA VCM area monitoring lines. 4. completed 5. Completed? however see Item 8 under current findings. 6. Secure ammonia tank in H2~ treatment building. 6. Completed. Niagara Falls IH Survey; 1982 Findings Recommendations Exp.Date Completion 2. Responsi- bility - Items from Previous Survey (con't) 7. Muffle PVC bagger/packer #1 exhaust. 7. Completed. 8. Increase VCM monitoring times. 8. Completed, Items from this Survey (Current Findings) 1. No written procedure for wearing, cleaning, disin fecting of respirators or training of users. 1. A written program must be prepared and kept on file incorporating existing elements of the respirator program to comply with BFG policy and the Ontario Ministry of Health VCM regulations. The written program must establish annual training and fit testing of respirator users. Attachment II is a copy of the Akron chemical plant's respiratory pro tection program as an example of a good pro gram.2 3 0 - 2. Emergency spill and clean up procedures do not address personal protective clothing and equipment requirements. 3. No written procedure for VCM monitoring. BJ -n O Ur E00S68SZ 2. All emergency spill and clean-up procedures must contain requirements for the wearing of protective equipment. Such procedures must contain requirements for the wearing of respirators, eye and face pro tection, boots, gloves, aprons, etc. Each requirement must specify the type of pro tection necessary to protect against the particular hazard that may be encountered. < 3. To comply with the Ontario Ministry of ^ Health VCM standard, the plant must prepare a written procedure establishing VCM sampling and analysis requirements. Existing sampling procedures are kept "in the head" of the environmental technicians, thus making it very difficult to evaluate procedures when technician responsible is absent. Having no written pro cedure may also result in loss of program con tinuity as technical personnel come and go. / 9^ Y Niagara Falls IH Survey? 1982 Findings Recommendations Exp.Date Responsi- Completion bility 4. Noise a. Signs for noise hazardous areas have time allowed to be in area limits posted on them. a. BFG OHP 5.05 "Noise" requires that hearing protection be worn in areas where noise levels exceed 85 dBA. b. Dryer bldg, noise levels b. Post all of the dryer building as 85-93 dBA at #2 bagger, noise hazardous and require hearing operator's desk and 3rd floor, protection to be worn while working in this area. if- ,y c. Noise dosimeter data not made available to nurse to compare audiometric exams when counseling employees. c. To facilitate employee counseling re on/off the job noise exposures, the plant nurse should be supplied with noise dosimeter data by employee and job class. r d. Last factory calibration of noise dosimeters was done in 1980. d. To guarantee accurate and precise noise dosimeter readings, the plant's noise dosimeters must be returned to the factory each year for calibration. 5. Laboratory hoods operation "O" to 30 fpm across 6" wide face. ta s`n Ui --i tO fcflOS68SZ 5. Upgrade the referenced lab hood ventilation rate to provide for 80 fpm across the face opened to normal operating position. Attach. I is a sketch of a hood modification plan by Ray Marshke of the Brecksville R&D Center. The modification increases the airflow of a typical hood from 28 to 80 fpm across the open face. This simply reduces the area of the hood face and consists of providing for a lock that keeps the horizontal sash hood from being opened above a- certain point with out unlocking it, A vertical safety shield which is on a rail that can be slid from side to side is also installed. The vertical shield is narrow enough for the lab worker to reach' around. Also, an airfoil is attached to the front creating a laminar airflow pattern across the lab hood bench top. An alarm system is f 3 Niagara Falls IH Survey; 1982 Findings 5. Laboratory hoods (conTt) 6. Use of respirators and hearing protection not reported when monitoring * data results are listed in monthly environmental report. 7. Geon S, four GC probes found with missing filters. 8. Boston filters installed in Geon north G.C.; area monitoring lines not tightly sealed. td O 4^ KJ\ t--* K> to Recommendations Exp.Date Respons Completion bility built into the hood that will respond, both audibly and visually when (1) static pressure drops too low, or (2) when the hood sash is raised above the lock position. The modifi cations include parts which are available from hood manufacturers. Contact Roy Marshke at Brecksville, ext. 5273 for more detailed drawings and parts suppliers. Brecksville has estimated that such a retrofit may be done for about $1,0Q0-$2,000 per hood. No modifi cations to ventilation or A/C systems is necessary. 6. When an employee is monitored for VCM, In dust, noise, etc. a record must be made if the employee wore personal protective equip**' ment. The use of such equipment is also to be noted on the monthly reporting of environ*' mental data. 7. To protect the VCL area G.C., probes have filters installed in the lines to prevent particulates from contaminating system. must the i ^ 8. The G.C, lines are made of teflon which is very inflexible. When the Boston filters were installed, the rigidity of the teflon lines resulted in a poor connection between the Boston in-line filter and sample -lihe. A tighter connection is needed to ensure that no leakage occurs at the filter installation point. Perhaps a more flexible connector such as Tygon or surgical, tubing between the Boston filter and teflon sample line would provide for a gas-tight seal providing no organics diffuse out of the tubing into the sample stream to interfere with the G.C.'s analysis of VCM. V" ^OOSGiSSZ Niagara Falls IH Survey; 1982 Findings 9. Eighty pounds of lead stearate used in laboratory in 1981. Recommendations 9. Due to the small volume and infrequent use of lead, monitoring for lead exposure in the laboratory is not necessary. Also, blood lead exams for lab workers are not necessary. Exp.Date Respons Completion bility , to O to U) 900S68SZ Niagara Falls IH Survey; 1982 6. Discussion: Table I contains results of noise dosimeter monitoring conducted at the plant during this survey. Dosimeter readings were taken with instruments set to the US OSHA standard of 90 dBA exposure for 8 hours, equal to 100%. The Ontario Ministry of Health standard is 85 dBA exposure for 8 hours equal to 100%. Results obtained with my instruments above 50% indicate worker exposures may have exceeded Ontario Ministry of Health standards. The operator helper, Geon south was exposed to noise above 50%. He wore hearing protection. It is difficult to point to any one area or piece of equipment as the cause of the operator's exposure because of the fluid nature of his job and the numerous pieces of equipment in Geon south that are noise producers. Noise dosimeter monitoring is to continue in Geon south and hearing protection must be worn in this area. The outside operator, Glen Way, was overexposed to noise as a result of chipping welds inside the dryer? hearing protection was worn. The Ontario Mininstry of Health has recently passed a bill regulating vinyl chloride. At the time of my visit, the regulation was just be coming available. Please forward a copy of the VCM standard to the Department of Environmental Health in Akron at your earliest convenience. As health standards are promulgated by the Ontario Ministry of Health, please provide this department with copies. TSB 25895007 BFG45124 Employee/SS# S.Kvas 455-04-7266 D.Arseneault 455-12-0238 C.Reidy 455-54-2036 J.Morrison 455-16-5978 R. Jollifte 455-69-5827 G.Way* 455-89-6439 TABLE I. NOISE DOSIMETER MONITORING RESULTS Niagara Falls, Aug. 10-13, 1982 Job/Area Sample Time (min.) H.P. Worn #2 oper., Geon S. 398 yes #1 " "" 397 Oper. helper, Geon S. 397 Foreman, LPA 387 Pigment man, LPA 386 outside oper., Geon S. 385 m II i it i 8-Hr. TW. 90 for 8 hrs 45 34 67.9 10 11 160 *Helped welder chip slag from weld inside dryer. ^Ontario Ministry of Health standard for noise is 85 dBA for 8 hours is equal to 100%. 25895008