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Interoffice Aleiiior;iii<Uim TO (Name and Location) H. P. Heathman FROM (Name and Location) C. W. Whaley e.9 CCLAMCS6 CV*UTv DATE August 27, 1985 REFERENCE NO. CWW-608-85 cc: E. L. Tejml J. N. Gann C. R. Pennington K. L. Rozanc E. D. Luke W. G. Cornman R. E. Allen A. B. Savage J. C. Nash M. R. Stenzel Dal 1 as SUBJECT: Employee Notification of p-Benzoquinone Monitoring Results Attached is an interpretive statement for an industrial hygiene monitor ing survey for p-Benzoquinone in the Vinyl Acetate Unit. Please communi cate. this information through line supervision to affected employees. Pam available to assist in the communication if needed. The statement wtll be posted on appropriate plant bulletin boards per plant policy. GEN. 55 Rev. 3 (S/84) DO IT RIGHT THE FIRST TIME 005071 Interpretive Statement p-Benzoquinone Monitoring Survey - Bay City Plant An industrial hygiene monitoring survey for p-Benzoquinone (PBQ) has been completed in the Vinyl Acetate Unit. The data (Table I) shows that potential employee exposure can exceed the American Conference of Govern mental Industrial Hygienist (ACGIH) Short Term Exposure Limit (STEL) during PBQ mixing operations. PBQ vapor is irritating to the eyes. Single or repeated exposure to markedly irritating concentrations can cause corneal edema, ulceration, and scarring. Chronic exposure may result in loss of visual acuity. Contact with the solid or vapor may cause severe damage and discoloration to the skin as well as irritation to the upper respiratory tract. The Occupational Safety and Health Administration (OSHA) has established an 8 hour time-weighted-average (TWA) Permissible Exposure Limit (PEL) of 0.1 part per million (PPM) for PBQ. The ACGIH recommends an 8 hour TWA Threshold Limit Value (TLV) of 0.1 PPM and a STEL of 0.3 PPM. The TLV and PEL are the concentrations to which nearly all workers can be exposed for an 8 hours per day, 40 hours per week for a working life-time without adverse health effects. The STEL is the concentration to which workers can be exposed continuously for short period of time without suffering from irritation, chronic or irreversible tissue damage, or narcosis of sufficient degree to increase the likelihood of accidental injury, impair self rescue or materially reduce work efficiency, provided the daily TLV-TWA is not exceeded. Monitoring data shows that exposure to PBQ during mixing operations could pose a health hazard to employees. Though average short term exposure is only 0.09 PPM compared to the ACGIH STEL of 0.3 PPM, individual sample con centrations exceed the STEL a significant amount of time as indicated by the data range (<.01 to .95 PPM) and 90% tolerance level (1.93 PPM). PBQ mixing is done infrequently and the operation is of short duration. Employees are required to wear fullface air supplied respirators and gloves to prevent exposure when mixing PBQ. The survey reinforces the importance of wearing proper protective equipment when handling this material. 005072 para-Benzoquinon&, M o n ito rin g Data S h o rt Term Exposure L im it (STEL) <On _O_)i i cQJn c s: crno a. CL. CO o -M O tn o a> v* c o l-- 4-> (O V-- > *<aa Ec O<D -4-3> CD 00 <n a- i- o_ +J Q. <d o S Q s_ <D a> xi CE "O 3 f-J Z co CO o 005073 Interoffice Aleiiioniiidnin TO (Njm and Location) W. G. Cornman CEIANESC - .-AoT OATE August 27, 1985 REFERENCE NO. CWW-609-85 cc: E. L. Tejml J. N. Gann C. R. Pennington E. D. Luke K. L. Rozanc H. P. Heathman R. E. Allen B. A. Logue A. B. Savage M. R. Stenzel - Dallas SUBJECT: Employee Notification of Calcium Hydroxide Monitoring Results Attached is an interpretive statement for an industrial hygiene monitoring survey for calcium hydroxide (lime) in the Utilities Unit-Water Treatment Area. Please communicate this information through line supervision to affected employees. I am available to assist in the communication if needed. The statement will be posted on appropriate plant bulletin boards per plant policy. CWW/bl C. W. Whaley GEN. 55 Rev. 3 (5/84) 005074 DO IT RIGHT THE FIRST TIME Interpretive Statement Calcium Hydroxide (Lime) Monitoring Survey - Bay City Plant An industrial hygiene monitoring survey for calcium hydroxide has been com pleted in the Utilities Unit-Water Treatment Area. The monitoring data (Table I) shows that personal exposure is well below the recotrenended American Conference of Governmental Industrial Hygienist (ACGIH) Threshold Limit Value (TLV). Results indicate that calcium hydroxide exposure does not pose a health risk to employees. Calcium hydroxide is an alkaline material and therefore is irritating to the skin and respiratory system. It can cause dermatitis, irritation of the eyes, and mucous membranes. The Occupational Safety and Health Administration (OSHA) has not established a Permissible Exposure Level (PEL) for calcium hydroxide. The ACGIH has assigned an 8 hour time-weighed-average (TWA) TLV of 5 milligrams (Mg) per cubic meter (m3) of air. The level was set to prevent irritation. The TLV is the concentration to which nearly all workers can be exposed for 8 hours per day, 40 hours per week for a working lifetime without adverse health effect. No short term exposure level has been established. Calcium hydroxide mixing is intermittent and of short duration. Employee exposure over an entire work day is Well below the ACGIH TLV of 5 Mg/M^ and therefore the mixing operation should pose no health hazard to employees. Short term personnel and area samples taken during the mixing operation show levels which may be irritating to some employees. Should irritation occur, the employee should wear a disposable dust mask, goggles, and gloves during the mixing operation. 005075 Calcium Hydroxide (Lim e) M o n ito rin g Data < 4i-n> CD t3-- Er-- O ^ t-- CD CD CO Eu I--CD CO c CcOn rc--d 5- CD S- Cl =c r- cd E CO 3cd <> v<)a +J CD i- CL 3O= CEO oo oo aijoo cnS c<C ^C75 a: si 4o-> c-- O O 1-- c o -t-> co > cd Q O vj-- 1i3- -M cO CD *o oE cco <d +j CD CO co oo aS -- \ S- CT +<ju sI: Eo C<o cd <d cd s: o <+- o </) s- CJ a) r-- JO CL 3 <a z oo LO 4oJ cn 00 O f-- O ^}- in oo CO c 3h--: <0 oo :s <c oo s~ o H </> 4-> r(--1) SSoZ- rOa. OO (/> 4o-> 1-- O 1-- +o-> cn CcCMOn CO 'S' I-- CvJ r-- CM OO CM CO c o +J <T3 *or4to tn JO <T3 O r-- ro o s_ +o-> <SaCaD. o S- 4C-D> 03 CO C E c 3 ca O or- C1O 4-> CO 4-> CD = ar-. CD .-- +-> E O S- t- 4J S_ o r-- CO *-> V) S- o o DhU So 4r> <o taj o. (O o 0S)c< i- 4o-> -o <o 3i: C0 c <o 4- Eo ooc -Or- Ca? r* -4t---> 4-> oS- --r- (<OU 4-> c -M Z3 S_ l-- Co_> S4<-D> T3 CO C E 3 CO O 1O co +J cc CD C 1- CD 1-- t+--J +EJ OU <-- CO +-> T- CD = n4-> iS-_ oo CO CSD_ <C s- 4C-D> T3 3CO cCo oEO tCC--OD +CCDj OC r" *+r->- +EJ OS_ -- CO -M T ID C 4J $- O 33 1-- C_J s<D <D J3 rO-J z=5 roo r~- r-~ oo oo c*-. o o 005076 SHE Department CELANESE CHEMICAL CO., INC. Employee Communique Industrial Hygiene (Interpretive Statement) Policy No. 5 07/25/85 Page 1 of 1 PURPOSE The purpose of this Guideline/Policy is to provide for a uniform employee communique for the reporting of industrial hygiene monitoring data (interpretive statement). SCOPE This Guideline/Policy outlines the basic components necessary for a good employee communique relating to monitoring data and for its distribution. PROCEDURE It will be the responsibility of the facility Industrial Hygienist function to summarize, evaluate, interpret and disseminate all industrial hygiene monitoring survey results. A.written employee communique should be prepared by the facility TH function and if practical verbally communicated to the employee. A bulletin board posting is also necessary. The employee communique should include the basic components as listed below. Listing and explanation of appropriate exposure limits (PEL, TWA, etc) Summary of effects of exposure Data, including time of survey, place, etc. Interpretation of data Plan of action, if necessary J fan /7) ljaJ. 005077 S1 2nterofficc Alciimraiidui.. TO {Name and Location) L. E. Hackfeld FROM (Name and Location) C. W. Whaley " 11$.D GEN 55 (REV.6// OATE January 14, 1980 REFERENCE NO. CWW-129-80 SUBJECT: Cyclohexane Monitoring Data - Interpretative Statement Attached is an interpretative statement on a cyclohexane monitoring survey conducted at the BCP. Survey results are to be communicated to BCP employees through supervision and posting. Individual results were communicated to employees through supervision as they were com pleted. Please post the statement and attachments on appropriate bulletin boards. CWW/cmr Attachments cc: E. L. Tejml D. H. Miller K. A. Dunn W. F. Soward H. P. Heathman L. E. Moore D. F. Ripple C. J. Schaefer A. Kemp N. V. Smith W. J. Seeliger D. G. Bremer C. D. Barrett, Dallas L. R. Birkner, NYO File: 71-2 (U^aJllU C. W. Whaley _______ ^ W. T. McNair, CCCTC Central Files, CCCTC (2) UNITERMS: Cyclohexane Propanol Warehouse/Traffic CHOX OSHA 005078 Cyclohexane Monitoring Survey - Interpretative Statement An Industrial Hygiene Monitoring survey for cyclohexane has been completed at the Bay City Plant. Several 8-hour time-weighedaverage (TWA) samples (see Attachment #1) were obtained on Operations personnel in the Warehouse/Traffic area and the CHOX unit. In addition short term exposure samples were obtained on Warehouse/Traffic Operators during cyclohexane barge unloading and tank strapping jobs. Two area samples were collected near T-110 OH oil sample point in the Propanol unit (see Attachment #2). The Occupational Safety and Health Administration (OSHA) has set the permissible exposure level to cyclohexane at 1,050 mg/M^ based on an 8-hour TWA. The American Conference of Governmental Industrial Hygienist (ACGIH) likewise recommends an 8-hour TWA limit of 1,050 mg/Mbut further recommends a short term exposure limit (STEL) of 1,300 mg/W Both 8-hour TWA and STEL monitoring data for cyclohexane is well below the Federal Safety Standard of 1,050 mg/M^. Celanese believes that the results of this survey do not indicate a health hazard. 005079 CWW-129-80 Attachment #1 Cyclohexane Monitoring Data - Personnel Samples Operator Unit or Area Classification CHOX A-Outside B B B B Average (X) Warehouse/ Traffic B Monitoring _ Results -- mg/M3 <1.0 2.0 <1.0 1.0 2.0 <1.4 147 A 60 A 256 A 20 A 10 B3 Comments Strapped cyclohexane storage tank V-646 (5 min sample) Gauged cyclohexane barge (13 min sample) Strapped cyclohexane storage tank V-646 (4 min sample) Cyclohexane barge and strapped storage tank V-646 (438 minute sample) Cyclohexane barge (159 min sample) Cyclohexane barge (452 min sample) 005080 CWW-129-80 Attachment #2 Cyclohexane Monitoring Data - Area Samples Area Sample Location Monitoring Results - mg /M3 T-110 OH, Oil Sample Point <.l T-110 OH, Oil Sample Point <.l Average (X) <.l Comment 380 min sample 369 min sample 005081 CWW-129-80 ' lifitcroffice AVeinoniiidiiiii TO (Name and Location) Mr. L. E. Hackfeld FROM (Name and Location) C. W. Whaley r/g. O GEN 55 (REV.6/7* DATE December 27, 1979 i. REFERENCE NO. CWW-123-79 SUBJECT: Nylon Salt Monitoring - Interpretative Statement Attached is an interpretative statement for Nylon Salt monitoring performed on Arthur Brothers, Inc. employees during the past year. This information will be communicated to employees through supervision and posting. Individual sample results were communicated through supervision as they were completed. Please post the statement and attachments on appropriate bulletin boards. CWW:gmt Attachments cc: E. L. Tejml K. A. Dunn W. F. Soward D. H. Hiller C. J. Schaefer H. P. Heathman R. J. Kane D. G. Bremer T. Conway - Arthur Brothers C. D. Barrett - Dallas L. R. Birkner - NYO W. T. McNair - CCCTC Central Files, (2), CCCTC r-zr. C. W. Whaley Uniterms Nylon Salt OSHA 005082 CWW-123-79 Nylon Salt Monitoring - Interpretative Statement Page 2 During the past year, numerous 8 hour time-weighted-average (TWA) area and personnel nylon salt dust samples were obtained on Arthur Brothers Inc. (ABI) personnel who work in the Nylon Salt Unit. Sampling was centered around the nylon salt bagging and sealedbin unloading jobs. The data (see attachments I and II) shows that exposure to nylon salt dust can exceed the total nuisance dust standard. There is no established permissible exposure limit (PEL) for nylon salt dust. The OSHA nuisance or inert dust standard of 15 mg/m^ (total dust) or 5 mg/nr (respirable dust) was used to determine compliance. Respir able dust is the fraction that reaches the terminal airways of the lungs and is therefore of greatest "hygienic significance. There was one known case of overexposure to total dust during the year at the nylon salt bagging machine. The overexposure occurred because the ABI Operator was not wearing a dust mask, which is required during bagging and sealedbin unloading. Dust masks are required because the existing dust collection systems are not totally effective in removing dust. Since the overexposure more emphasis has been placed on the importance of wearing dust masks and correcting violations. Gelanese believes that the results do not indicate a health, hazard. Average potential respirable dust exposure of 0.7 mg/m^ is well below the Federal Standard of 5.0 mg/rn^. In addition dust masks and protective clothing are required to minimize employee exposure. We are attempting however, to reduce total dust exposure through engineering controls. Process and Engineering are currently reviewing possible soltuions to the dusting problem at the bagging machine; C. W. Whaley 005083 Attachment I Nylon Salt Monitoring - Personnel Samples Date Job Description 11/3/78 Nylon Salt Bagger 11/6/78 Nylon Salt Bagger 11/10/78 Nylon Salt Bagger 6/12/79 Sealedbin Unloading 8/20/79 Nylon Salt Bagger 8/22/79 Nylon Salt Bagger 8/24/79 Nylon Salt Bagger 8/28/79 Nylon Salt Bagger 8/29/79 Nylon Salt Bagger 10/1/79 Nylon Salt Bagger 10/3/79 Nylon Salt Bagger 10/8/79 Nylon Salt Bagger 10/11/79 Nylon Salt Bagger 10/15/79 Nylon Salt Bagger 11/1/79 Nylon Scllt Bagger 11/2/79 Nylon Salt Bagger 11/6/79 Nylon Salt Bagger 11/13/79 Nylon Salt Bagger 11/16/79 Nylon Salt Bagger 12/7/79 Nylon Salt Bagger 12/13/79 Nylon Salt Bagger Average 00 Range o Actual Exposure-mg/mJ Total Dust Respirable Dust 0.2 0.8 0.2 23.9 0.1 3.2 2.3 23.9 -------- -1.1 0.1 to 3.2 Potential Exposure-mg/m^ Total Dust Respirable Dus 40.0 2.3 2.6 1.5 9.7 4.5 35.2 13.7 1.5 to 40.0 0.3 0.1 0.8 0.5 0.5 <0.1 <0.1 0.3 <0.1 to 0.8 005084 Attachment II Nylon Salt Monitoring - Area Samples Date Area Sample Location Total Dust - mg/nT* 8/29/79 Weigh Scales @ N.S. Bagging 14.3 10/11/79 Weigh Scales @ N.S. Bagging 5.5 11/2/79 Weigh Scales @ N.S. Bagging 45.2 11/5/79 Weigh Scales @ N.S. Bagging 4.4 11/15/79 Weigh Scales Q N.S. Bagging 6.8 12/6/79 Weigh Scales @ N.S. Bagging 2.3 12/10/79 Weigh Scales 6 N.S. Bagging 0.7 Average 00 Range 11.3 0.7 to 45.2 005085 Interoffice AleinoraiidiiL. TO (Name and Location) As Listed* FROM (Name and Location) C. W. Whaley tr^.u gen 55 (REV.6/: OATE September 17, 1979 REFERENCE NO. CWW-103-79 *W. G. Comman C. J. Schaefer D. G. Bremer SUBJECT: Hydrogen Sulfide Monitoring Survey - Interpretative Statement An industrial hygiene monitoring survey for hydrogen sulfide exposure has been conducted in the Partial Oxidation (POX) Unit. Four 8-hour tine-weighted-average personal samples were obtained on the outside B-cperator. Results follow: 1. <0.1 ppm (actually none detected) 2. <0.1 ppm 3. <0.1 ppm 4. <0.1 ppm The Occupational Safety and Health Administration (OSHA) has established a ceiling concentration of 20 ppm for personal exposure to hydrogen sulfide and a peak exposure of 50 ppm for ten minutes. This means an employee's exposure shall not exceed at anytime during an 8-hour shift the 20 ppm concentration limit except for a ten-nminute period where a peak concentration of 50 ppm is allowable. The tenminute peak exposure is allowed once per 8-hour shift provided no other measurable exposure occurs. The American Conference of Governmental Industrial Hygienist (ACG3H) has reccttnended an 8-hour TWA threshold limit value (TLV) of 10 ppm for hydrogen sulfide and short-term exposure limit (15 minutes) of 15 ppm. Celanese believes that the monitoring results do not indicate a health hazard from hydrogen sulfide exposure. All monitoring results are veil below the 8-hour TWA TLV recommended by the AGGIH. Barring a significant process leak, employees should not be exposed to hydrogen sulfide concentrations approaching the ceiling limit of 20 ppm established by OSHA. CWW/cmr cc: E. L. Tejml D. H. Miller W. F. Soward K. A. Dunn L. E. Moore C. D. Barrett, 005086 Interoffice illciiiontiiduir TO (Name and Location) AS LISTED* PROM (Name and Location) M. R. STENZEL CW WHALEY-BAY CITY G ILLE-BISHOP RM GUEDIN-CCCTC KF BAILEY - CLEAR LAKE JD WILSON-PAMPA CEN 55 (REV.6 DATE 6/4/79 REFERENCE NO. MRS-85-79 SUBJECT: INTERPRETATIVE STATEMENTS At the recent company Industrial Hygiene meeting in Chicago, it was ' requested that the company Department of Industrial Hygiene and Toxiology review our position on interpretative statements. Attached, is a copy of the guidelines originally issued in April of 1978. Our position has not changed since this letter. The plant Industrial Hygienist (I.H.) is responsible for writing the interpretative state ment. Normally, the only way our group will get involved is if the Plant I.H. requests our help or if the study has to be coordinated at the company 1 eve!. It is apparent from the Chicago meeting that although each plant has a different procedure for notifying employees of monitoring results, all the procedures are consistent with the attached guidelines. MS/dr Attach. BAY CITY DG BREMER ' LE HACKFELD DH MILLER CJ SCHAEFER " BISHOP C. GARY AR HANCOCK CW HARRISON RW JAMES MP NEFF PM SYKES CCCTC GH FISHER RA GANGEMI JP HAWTHORNE' rc n a mrv fP(Sjx^7/J MARK STENZEL ^ COMPANY INDUSTRIAL HYGIENIST CLEAR LAKE Jj BRUN|ER dFrcTsE> JVTDUtfN JR LAIRD JL WARD DALLAS CD BARRETT RE LARSEN RW SWANBECK GA VOS PAMPA CE LOEFFLER KL LOMBARDOZZI AA MILLER HA THOMAS UU TIIVC TERMINALS . . JE SANBORN^BAYPORT JT SIXEAS-NEWARK CELCO (NARROWS,VA) R TANKERSLEY 005087 aerspilcce A^eE22raEsdGrcaa (Njrh W Locidoa) Messrs. J. A. Bousquet and B. R. Miller - NYO M (M,m <1)4 Loctllon) Ci D. Barrett -Corpus Christi OATE 4/4/78 REFERENCE no. CDB-53-78 Subject: Informing Management and Employees of Monitoring Results I have attached a set of guidelines for informing management and employees of industrial hygiene monitoring results. These guidelines are consistent with Company policy and are actually just a restatement and elaboration of "Industrial Hygiene Administrative Procedures" that have already been distributed to the plants. In the guideline, we have attempted to answer several key questions relating to employee notification. Please review and notify'James concerning your comments. /mg Attachment --__________________ C. D. Barrett, Industrial Hygienist 005088 ferdfftee HecsaaracscSitfsi t^KMilUl Locitlofll DATE *As Listed ___________________________________________________________________________________; M (NJm Locttlonl REFERENCENQ. C. D. Barrett and J. M. Ramey^_______________________________________ *Bay City D. G. Bremer C. W. "Whaley L. E. Hackfeld D. H. Miller C. J. Schaefer CCCTC J. P. Hawthorne E. S. Ramey A. A. Miller R. F.Stubbeman R. M. Guedin Bishop M. P. Neff J. M. Jackson .R. W. Swanbeck C. W. Harrison W. H. Meyer G. D. Boyd # Newark J. Sixeas Clear Lake J. R. Laird R. E. Green J. Bruner D. L. Collison J. W. Dunn Pam pa H. A. Thomas M. R. Stenzel R. W. James P. A. Turek W. H. Tuice Bayport J. E. Sanborn Subject: Informing Employees'of Monitoring Results At the recent Industrial Hygiene Meeting in Houston, there was considerable discussion concerning the best methods for informing employees of monitoring results. Since the meeting,we have discussed this subject on several occasions. As I'm sure we all agree, both management and hourly employees need to be kept well informed of air monitoring results. They need to have the answers to such questions as: Do chemical exposures pose acute or immediate hazards? Do they pose long-term or chronic hazards? What corrective action is required? Are vein compliance with OSHA? All of these questions could be "boiled down" to one overriding concern - Is the job safe, and if not, what should be done to make it safe? Sounds like a simple question - until you try to answer it'.' How do we keep management and hourly employees meaningfully informed of monitoring results? Well, obviously, .there is no one ideal approach. However, the following guideline is consistent-with the-new--organization and conforms to "good industrial hygiene" practicer ."t:.: . . . Guide line for Management/Employee Notification of Monitoring Results It will be the responsibility of the plant Industrial Hygienist to disseminate completed survey results (with conclusions, interpretative statements and corrective action requirements) to the Safety Supervisor and other management personnel (including the Division Industrial Hygienist). Individual sampling results will generally not be reported to Management by the plant Industrial Hygienist until the general sampling study has been completed. 005089 ' CDBJMR- 2- - Communications of the reported test results to the employee(s) in the work area will be the responsibility of the Safety Supervisor. Communication of test results should be done as soon as possible but no later than five days after the survey results have been reported by the plant Industrial Hygienist. In cases of serious exposures, the employee should be informed of test results immediately and of the corrective action being taken. Information should be communicated to the employee as follows: Copies of all completed Industrial Hygiene Monitoring Forms (or equivalent such as a summary of sampling results - see Attachment A) will be posted in the operating area on the bulletin board for ten days to facilitate employee review. The posted monitoring forms should always be accompanied by a written interpretative statement of the sampling results (i.e., tell the employees what the numbers mean), ..This interpretative statement will be provided by the plant Industrial Hygienist. Oral review of the meaning and significance of personnel monitoring results will be the responsibility of the Safety Supervisor-or his designee.' Oral'review of test results should always precede the posting of test results. Extreme care must be exercised to prevent false "positive"-or false "negative" results from unduly alarming employees due to unrepresentative results, of'transient conditions. Review should address validity of the analysis; whether or not the sample was truly representative: of-the .workplace environment;-the reason for the -- exposure--whether or nqt it is a simple excursion due to equipment failure or is an inherent process design problem; and, most important, to assess the seriousness of the problem and make sure proper corrective action is taken. In reviewing sampling results, the major emphasis should be in interpreting the meaning of the sampling results and not on the "raw" sampling data. Furthermore, employees should not be informed of individual results until the overall sampling study has been completed. The Safety Supervisor may request the plant Industrial Hygienist to assist in communicating information to employees. - -^Questions and Answers on Guideline - -- - -* - --- -- ............- 1. When should individual sampling results be reported to Management and employees BEFORE the survey is completed? Preliminary results should be reported: a) when required-bylaw; -- b) when preliminary results indicate immediate hazard to health (such as high carbon monoxide, nitrogen dioxide, or acid vapors); 005090 CDBJMR- -3- c) when special circumstances arise (i.e., such as when results are needed immediately to make a decision on tank entry or when an employee complaint has triggered the . monitoring and the employee is over alarmed, or when non-routine operations are monitored, etc. 2. Besides the circumstances mentioned above, what is the big danger in reporting preliminary results? In most of our sampling, we're concerned with low levels of chemical exposure that might cause chronic effects after 30 years of exposure. Therefore, a single sample result is almost meaningless. Due to the variability in exposure rconditions in our-plant; many personal^sampies arre .reqprred;to:ar?fcrtrately assess _ employee exposure. Attempting to draw conclusions "based on one test result is 'analogous to the blind man trying-to describe-an-elephant after only1 touching the' ` ~ trunk. What may initially appear to be a serious chronic exposure may,in fact, be due to a non-representative sample. In such cases, premature conclusions and reporting would serve only to confuse the employee, over alarm management, and possibly result'in riee'dles'S-engineering-expenditures- ; 3. Give an example of an "interpretative statement" of sampling results. Assume that a survey was completed of benzene exposure among chemical operators. Twenty 8-hour time-weighted-average personal samples were obtained as follows: 1. 0.8 ppm 2. 2.1 3. 0.1 4/ 0.15 ' 5. 3.60 6. 1.1 7. 2.6 8. 2.7 9.'3.4 10. 0.5 11. 0.2 12. 6.8 13. 1.-1 ' 14. 0.9 i5. 0. l- 16. 17. 18. '19. 20. 3.1 2.0' 2.1 0.7 0.1 Mean = 1.7 ppm ' ............. "The results do not indicate a health hazard." In other words, exposure to benzene at an average level of 1.7 ppm should not affect your health in any way. The average exposure (i.e. , 1.7'ppm) is well below the existing Federal Safety Standard for benzene of 10. 0 ppm. As you're all aware, overexposure to benzene (probably well above 25 ppm as a daily average) for a period of years may result in a cancer hazard. We are attempting to reduce our benzene exposures to below 1 ppm in order to-incorporate a greater safety margin;- "Sample catching" procedures are being modified to further reduce your exposure. 005091 CDBJMH- -3- (Note: The above statement will have to be modified when the OSHA Benzene Standard is released; furthermore, Mr. G. Rodenhausen has been asked to review.) 4. Does the interpretative statement have to be written? Can it be communicated orally? Unless the Safety Supervisor appoints the Plant Industrial Hygienist 'to personally communicate the results to the employees, it is essential for the statement to be written (by the Plant Industrial Hy'gienist) and sent to the Safety Supervisor. -----. - Although'sometimers'bemecers^sary^fof^the^lairt'* Hygienist to assist in communicating results directly to employees, we strongly agree that in many cases the'-best approach for-informing"the employees'is through line management. 5. Is it always necessary to "post" the samples results and interpretative statement in the work area? Although we prefer that results be posted, the requirement can be waived if you can assure that the information is communicated to all employees. 6. Is it necessary to have the employee sign a statement indicating that he has been informed of sampling results? * Although we may eventually be required to do this, we did not feel that a "sign off" is required at this time. 7. Who is responsible for writing the interpretative statement? What wording should be used? The Plant-Industrial Hygienist is-always -responsible -for'rproviding the interpretative statement..--When necessary;- we-will-assist the Plant -Hygienist in writing the appropriate statement. - -* 8. What if time does not allow us to always provide an interpretative statement and to promptly notify employees of sampling results?................ - In such a case, we have only two options - either place a higher priority on the notification procedure or reduce the number of samples being taken. The American Conference of Governmental Industrial Hygienists and the American Industria-1 Hygiene'Association -have-traditionally -held the opinion that employers would be well advised to terminatemnonitoring programs unless results can be interpreted by trained individuals and then promptly communicated to employees. CDBJMR- -4- 9. Many times our monitoring results indicate extremely low levels of chemical exposures. Should these "negative" results be communicated to management and employees? Certainly! Notification (with interpretative statement) of negative results should be given the same priority as positive results. C. D. Barrett, Industrial Hygienist /mg J. NT. Ramey, Manager, Industrial Hygiene ^nd_To.xicology.______ _ 005093 v_UNUAMJ KANT J-IONJ 'J OKING DATA D1STK1 BUT! ON i-ORM Contaminant: OSHA Permissible Exposui :bevel: Benzene__________ 8-Hour TWA ,10 PPm Ceiling Peak 25 50 Date: 3/10/78 Semple Date the No- Sample Was f~r>11 **c;t Type Sample Area or Personal Name of Employee or Area Pos5t5on of rhe S.-.mol^r 34on i tor ed Concentra tion of Contaminan 165 2/24/78 P Nark Stenzel Laboratory 0.09 ppm 166 M 167 H. A Mounted on the face of the air-conditioner in the control room exit . port. IV A Mounted`near the"air*- ' -'TV' conditioner intake at the SE corner of the roof- 0.82 ppm 0.46 ppm 168 t A Mounted at the break IV 0.69 ppm in the duct system on top of Area Lab. 169 170 ft ft 171 172 It A Mounted on the control IV 0.83 ppm room log desk- . A Mounted at the exhaust IV 0.56 ppm from the electrical room- A Same position as Sample 166. TV 0.29 ppm A Same position as Sample 167. TV 0.09 ppm -- - - - 0050914 -