Industrial Hygiene Program Development, Andersen Air Force Base, Guam February 22 - March

Transcription

1 Industrial Hygiene Program Development, Andersen Air Force Base, Guam February 22 - March Consultative Letter # AFIOH-DO-BR-CL Prepared by: Detachment 3, AFIOH/CD Kadena AB, Okinawa, Japan Distribution Statement: Approved for public release; distribution unlimited

2 DEPARTMENT OF THE AIR FORCE DETACHMENT 3, AIR FORCE INSTITUTE FOR OPERATIONAL HEALTH (AFIOH) (AFMC) APO AP April 2005 MEMORANDUM FOR 36 MDOS/SGOAB Attention: Maj Lewis FROM: Detachment 3, AFIOH/CD Unit 5213 APO AP SUBJECT: Consultative Letter, IOH-DO-BR-CL , Industrial Hygiene Program Development, Andersen Air Force Base, Guam 1. Scope: At the request of your office, Detachment 3, of the Air Force Institute for Operational Health (AFIOH) reviewed base-wide implementation of Air Force and Occupational Safety & Health Administration (OSHA) requirements for industrial hygiene workplace surveillance. All existing work areas were evaluated for program compliance and new processes were identified. From this, a comprehensive industrial hygiene management plan was developed that will be helpful in evaluating program compliance and assisting with program maintenance at bases throughout the Air Force. 2. Background: Recent industrial hygiene surveillance activities conducted by Andersen AFB Bioenvironmental Engineering Services (BES) identified the need for specialized assistance in creating a comprehensive program management structure. The complex nature of this project, and the additional requirement for training in this arena, led to a request for assistance from Detachment 3, AFIOH. The project was prioritized and funded using the Detachment 3, AFIOH fiscal year 2005 operating budget. 3. Personnel Contacted: Major Kerry Lewis, Aerospace Medicine Flight Commander 1Lt Bruce Auville, Bioenvironmental Engineering Element Chief TSgt Michael Miranda, NCOIC, Industrial Hygiene Program 4. Process Description: Based upon funding and the Andersen AFB BES schedule, the project was scheduled for February 22 through March 4, A variety of references were consulted to develop the project scope and prepare Detachment 3 personnel for fieldwork. Two weeks prior to team arrival, the Andersen AFB master industrial hygiene shop listing was forwarded to Detachment 3. Included in the listing was a summary of workplaces with potential exposures to OSHA expanded standards chemicals. Due to changes in shop tasks, composition, chemical

3 listings, and location, it became evident that all of the shop industrial hygiene casefiles required review, so a spreadsheet was developed to assist with this process. During the site visit, 51 industrial hygiene casefiles were examined for all information related to industrial hygiene program operation. Special attention was afforded to the procurement, usage, and disposition of expanded standards chemicals. Documents reviewed in the Bioenvironmental Engineering Shop included master workplace summaries (AF Form 2775), baseline and annual industrial hygiene survey letters, chemical listings (AF Form 2761 or equivalent), documentation of sampling events (letters, results, data sheets, AF Form 2758 Industrial Hygiene Data Form, memos), respiratory protection documentation, waste disposal information, and Command Core process assessment forms. If complete information was not available in the casefile, the base Hazardous Material Pharmacy and/or individual work areas were contacted. Using the gathered resources, a framework for industrial hygiene program oversight was developed. This included a operating instruction governing industrial hygiene program management an multiple attachments detailing critical program aspects. Included in these is a revised master shop listing, a special surveillance listing, a summary of OSHA requirements for common expanded standards chemicals, a listing of known or suspected carcinogens, a listing of carcinogens without exposure limits, a listing of specifically regulated chemicals, and a listing of substance specific regulated area requirements. 5. Findings & Observations: It became clear during this project that a comprehensive industrial hygiene program management guide was a necessary tool for the Andersen BEE element. To create this document, a number of regulatory sources (OSHA standards, Air Force requirements and compliance interpretations) were merged into a cohesive program. It was also evident that the plan needed to detail chemical exposure evaluation. Due to the large number of OSHA expanded standards rules and AF regulated area requirements; workers were having difficulty conducting chemical process identification and evaluation. This was being complicated by squadron reorganizations, shop relocations, Hazardous Materials Pharmacy policy, and a variable industrial hygiene surveillance schedule. The management plan developed during this effort seeks to provide a clear path for the BEE to follow and overarching guidance for program implementation. Although the plan is tailored for Andersen AFB, it is the author s hope that the concepts included can be applied at BEE shops throughout the AF. 6. If you have any questions concerning this survey, please contact me at DSN or e- mail me at [email protected]. I appreciate the opportunity to provide assistance on this project and would like to extend my gratitude to all of the professionals in your shop for their cooperation and support. 1 Industrial Hygiene Program Management Plan GREGORY A. FRICK, Maj, USAF, BSC, CIH Chief, Occupational Health Division

4 BY ORDER OF THE COMMANDER, 36 MDOS/SGOAB INSTRUCTION April 2005 Workplace Evaluation Occupational Health Program COMPLIANCE WITH THIS INSTRUCTION IS MANDATORY OPR: DET 3/ AFIOH (Maj Frick) Certified by: 36 MDOS/SGOAB (Maj Lewis) Pages: 42 This instruction implements Air Force Instruction (AFI) 48-8, AFI and portions of Occupational Safety and Health Administration (OSHA) Standards 29 CFR 1910 and 29 CFR It prescribes policy and procedures for industrial hygiene surveillance and recognition, evaluation, and control of chemical exposures in workplaces located throughout Andersen AFB and associated properties 1. SCOPE The basic strategy of the AF occupational health program is to provide a medical component required to build a better Air Force. This is accomplished through collaboration and integration. The goals of this program are to: Structure ESOH support to minimize interference with and maximize support of operations; Prioritize work based on risk, the opportunity to improve performance and/or reduce costs, and legal requirements; Provide ESOH technical expertise to workplace supervisors to support risk management and improvements in productivity. Provide input to commanders and supervisors on the priority of hazard management based on the level of risk; and to Coordinate and work with other installation ESOH professionals to achieve the most effective operations for the AF. The purpose of the activity surveillance process is to enhance overall mission effectiveness by protecting human resources in the workplace, reducing costs, and improving performance. Additionally, this process provides a framework to shift surveillance efforts to those activities posing the highest risk. Ultimately, the goal is to advance from simple quantification of exposures and use of expedient controls that result in long-term monitoring, occupational physical exams, or extensive use of personal protective equipment to application of risk based engineering principles to solve problems and effect lasting solutions. Hazardous materials are a critical component in many Air Force processes. Work areas utilize these products to fabricate, protect, repair, and maintain facilities, equipment, and war materiel. In many cases, the hazardous nature of the materials can be minimized through substitution, process change, or reduced usage. However, there remain many tasks that require the usage of 1

5 significantly hazardous items. Proper management of these materials is necessary to protect the health and welfare of Air Force members. On the federal level, OSHA regulates these materials and their usage with a variety of substance-specific regulations. Many of these are complex and can be misinterpreted. Couple this with the current AF standards that address these materials and confusion can arise. To ensure proper implementation of all relevant standards, this operating instruction will outline the plans and programs for hazardous material evaluation and control at Andersen AFB. 2. REFERENCES 2.1 AFI , Aerospace Medical Operations. 2.2 AFI , Occupational Health Program. 2.3 AFI , Hazard Communication. 2.4 AFI , Air Force Occupational and Environmental, Safety, Fire Prevention and Health (AFOSH) Program. 2.5 AFOSH Std. 48-8, Controlling Exposures to Hazardous Materials. 2.6 AFOSH Std , Respiratory Protection Program. 2.7 AFOSH Std , Chemical Safety. 2.8 AFOSH Std , Industrial Ventilation. 2.9 OSHA Std. 29 CFR , including Tables Z-1, Z-2, and Z OSHA Std. 29 CFR , General Industry Standard for Asbestos OSHA Std. 29 CFR , Vinyl Chloride OSHA Std. 29 CFR , Inorganic Arsenic OSHA Std. 29 CFR , General Industry Standard for Lead OSHA Std. 29 CFR , Cadmium OSHA Std. 29 CFR , Benzene OSHA Std. 29 CFR , Acrilonitrile OSHA Std. 29 CFR , Ethylene Oxide OSHA Std. 29 CFR , Formaldehyde. 2

6 2.19 OSHA Std. 29 CFR , Methylene Chloride OSHA Std. 29 CFR , Construction Standard for Lead OSHA Std. 29 CFR , Construction Standard for Asbestos. 3. BIOENVIRONMENTAL ENGINEERING RESPONSIBILITIES 3.1 The Bioenvironmental Engineering Element Commander will directly or through designation of authority: Manage the installation occupational health surveillance program Oversee exposure monitoring and ensure all employees are informed of results Determine whether regulated areas are required and establish appropriate boundaries Investigate mishaps and suspected overexposures involving hazardous materials Assign Risk Assessment Codes (RAC) in situations where hazardous material exposures can not be adequately controlled through engineering methods Evaluate changes to the installation mission which may affect hazardous material usage Communicate program status and significant issues to Wing, Group, and Squadron level officials Review the Squadron Commander s summary document and authorize its findings. 3.2 The Bioenvironmental Engineering Element Deputy Commander will: Oversee industrial hygiene program routine and special surveillance Prioritize surveillance requirements and determine surveillance frequency Ensure all employees monitored through the surveillance program receive sample results in a timely manner Train all technicians to properly evaluate hazardous material risk and perform necessary employee monitoring Review all risk assessments, sampling events and employee correspondence for completeness and accuracy Interpret new regulatory guidance to determine applicability of standards. 3

7 3.2.7 Prepare the Squadron Commander s summary document and provide squadron outbrief. 3.3 The Industrial Hygiene Program Coordinator will: Manage the day-to-day operations of the industrial hygiene program Track all routine and special surveillance using appropriate computer systems Schedule all special surveillance using the Command Core System (CCS) Suspense Management Module, ensure special surveillance is completed on time, and report status of special surveillance completion during monthly element management meetings Ensure BE technicians have necessary training to complete special surveillance projects assigned Review all documentation of special surveillance, including Command Core entries and AF Form 2754 entries, for consistency Review all sampling results that exceed the action level with the Deputy Element Commander Coordinate with the element equipment program manager to ensure equipment is calibrated Coordinate new equipment requirements with the equipment custodian and the element cost center manager. 3.4 BE Technicians will: Perform routine industrial hygiene surveillance in accordance with the shop survey schedule and ensure all documentation and reports are completed in a timely manner Perform special surveillance when assigned by the Industrial Hygiene Program Coordinator and document the survey in Command Core and on the AF Form 2754 in the appropriate casefile Review all risk assessments during industrial hygiene surveys and identify necessary air sampling requirements Notify the Industrial Hygiene Program Coordinator if they have not received training or are unsure of the proper procedures to accomplish special surveillance. 4. WORK AREA RESPONSIBILITIES 4

8 Although the Bioenvironmental Engineering function has the primary responsibility to identify, quantify, and control potential hazards, it falls to the individual workplace supervisor to ensure all AF employees are properly protected on the job. As such, there are many specific requirements that supervisors must follow to ensure this occurs. For military and government service supervisors, these responsibilities include: Establish and control access to regulated areas. Institute engineering controls and work practices to maintain employee exposures below the OEL. Supply adequate and appropriate Personal Protective Equipment (PPE) to employees. Provide training to employees so they can recognize the potential hazards of their materials and can take specific measures to avoid hazardous exposures. Notify Ground Safety, BE and Public Health (PH) of mishaps and suspected overexposures involving hazardous materials. Ensure employees comply with work practices established to reduce exposures. Ensure work practices used to control hazards are written and available. In some circumstances, contractor personnel will work in AF facilities where there is a potential for chemical exposure. In these situations, it is important to remember that it is the responsibility of the AF to inform the contractor of any hazard associated with the workplace but it is the contractor s responsibility to comply with the hazards. Therefore, if the hazard exists due to AF operations (i.e. contractors must work in a contaminated room), then the contractor will be told what they need to do to comply with the rules associated with the facility. However, if the contractor is going to create the hazard (i.e. contractors are spraying paint in a paint booth), then it is the contractors responsibility to follow all appropriate rules and regulations. 5. INDUSTRIAL HYGIENE ROUTINE SURVEILLANCE Proper evaluation of industrial work areas requires a combination of training, experience, and diligence. It is imperative that workers performing routine industrial hygiene surveillance are provided with the tools necessary to succeed. 5.1 Master Listing: The basis of the IH program is a comprehensive master shop listing that accurately reflects the level of attention each work area requires. To develop this listing, each workplace, contract operation requiring support, and host tenant support sites is categorized as to its risk. This risk assessment is based on federal, state, and host nation requirements, local priorities, and guidelines present in AFI , table 2.1, Workplace Categorization and Surveillance Frequency. The current listing with explanations for shop category can be found at attachment Changes to Shop Categorization: Over time, shops change processes, materials, and missions. In some instances, sufficient task characterization allows for a reduction in surveillance frequency. Category change should only be accomplished after careful consideration of all factors involved in initial category assignment. 5

9 5.3 Routine Surveillance Scheduling: Once a master listing has been completed, a master surveillance schedule is developed based on the workplace categorization, available resources and surveillance frequency requirements in AFI , table 2.1. It is a good idea to complete all work areas in a squadron within the same time frame. This allows for comparisons across the squadron and eases reporting to the squadron commander. In most cases, class II shops should take about two weeks to complete whereas class I shops could take up to a month. It is expected that a properly trained technician could be working multiple routine surveys at any given time. 5.4 Routine Surveillance Activity Assessments: Activity assessments are conducted according to the master schedule using 29 CFR 1960 Subpart D, Inspection and Abatement, as a guide for performing the assessment. Typically, this consists of a workplace visit to identify potential health risks posed by workplace activities, determine the level of additional monitoring required to characterize those risks, validate the adequacy of controls, and determine compliance with health related programs, standards and laws. The workplace assessment acts as a screening tool to prioritize follow-on execution of well defined special evaluations of activities. 5.5 Documentation: All routine surveillance will be documented in Command Core and the corresponding shop AF Form 2755 will be updated. It is critical that all entries on the AF Form 2755 are verified each time it is updated, with special attention provided to air sample results and expanded standards chemicals. Documentation, including all communication with the shop, should be completed in the manner demonstrated in the example casefile. 5.6 Commander s Summary: Upon completion of all annual routine surveillance for each squadron, a summary document will be prepared, briefed, and provided to the commander. The goal of this document is to communicate items of significance at a level where intervention is necessary. It is expected that this document and briefing will not detail all of the individual findings in every work area. Instead, it will address squadron-wide trends, significant deficiencies, and areas of outstanding performance. This document should be completed within thirty days of the final survey in the squadron. 5.7 Program Assessment: Periodically, the Industrial Hygiene Program Manager will assess adherence to the routine surveillance plan, adjust as needed, and report the results to the Element Commander through the Element Deputy. 6. INDUSTRIAL HYGIENE SPECIAL SURVEILLANCE During routine surveillance, it may become apparent that additional BE investment is needed to better characterize risks posed by activities, improve hazard controls, or improve compliance with specific regulatory requirements. Special surveillance evaluations are identified to fill these needs. The special surveillance process entails the planning and execution of special evaluations to provide information required to improve understanding and characterization of the hazards and the effectiveness of hazard controls. Special evaluation requirements generally are identified by routine workplace assessments but may also be identified by other sources such as illness or injury reports. 6

10 6.1 Prioritization: Special surveillance is prioritized using guidance in AFI , table 2.2. This table equally weights BES knowledge of the true risk of the hazard and the degree to which BES feels the process is controlled. A high priority is equivalent to low hazard knowledge and low confidence in process control. 6.2 Scheduling: Special surveillance is assigned by the Industrial Hygiene program coordinator. Projects should be completed in priority order with regard to special circumstances that may exist (equipment availability, seasonality, etc.). Periodically, the list should be reviewed and the schedules adjusted as required. 6.3 Documentation: All special surveillance will be documented in Command Core and the corresponding shop AF Form 2755 will be updated. It is critical that all entries on the AF Form 2755 are verified each time it is updated, with special attention provided to air sample results and expanded standards chemicals. Documentation, including all communication with the shop, should be completed in the manner demonstrated in the example casefile. 7. HAZARDOUS MATERIAL EXPOSURE IDENTIFICATION When identifying chemical hazards, it is critical to utilize a systematic approach. An examination of the applicable regulations provides insight into a standardized method that will enable all potential chemical exposures to be thoroughly investigated. Each chemical hazard at a workplace should be evaluated in this manner to ensure uniformity and completeness. This approach, coupled with proper process and task risk assessments will result in compliance with all regulatory requirements and protection of AF workers. Additionally, proper application of the method will create standard negative risk assessments that will ease workload and assist with data entry into the Command Core System. For each hazardous material to be evaluated, a series of questions are asked. Based upon the answers to these questions, the product is evaluated utilizing the appropriate regulatory requirements. These questions have been formulated in order of importance. Therefore, if a question is answered yes, no further questions are necessary. 7.1 Does the hazardous product contain one of the six common chemicals having substance-specific requirements?: As stated above, the power of this method is in its systematic approach to chemical evaluation. The first question that must be asked is whether the work area is utilizing chemicals covered by OSHA or AF substance-specific standards. There are many substance-specific standards in the 29 CFR XX and 29 CFR XX series of federal regulations, as well as in the attachments to AFOSH STD 48-8, but there are six chemicals found at most AF locations that have the most stringent regulations and present the greatest potential hazards. These chemicals are outlined below and summary guidance is presented in attachment Asbestos (29 CFR & 29 CFR ; AFOSH STD 48-8, 9): Two separate regulations cover AF operations that may potentially exposure workers to asbestos. The 29 CFR 1910 regulation covers non-construction activities. At most AF bases, the primary source of non-construction asbestos exposures 7

11 are brake repair/removal operations. Typically these occur in the transportation squadron and in the flightline Wheel & Tire shops. The 29 CFR 1926 regulation addresses construction activities such as asbestos repair and removal. Most of these duties are accomplished by workers in Civil Engineering. However, some bases may have janitorial workers or school employees who have the ability to do some asbestos repair work Cadmium (29 CFR ; AFOSH STD 48-8, 6): Almost exclusively, cadmium exposures are associated with corrosion control and refurbishment activities. Cadmium is a component in many structural metals. When paint is removed from these surfaces utilizing aggressive sanding techniques, airborne cadmium is often a result. Common AF shops with cadmium exposures include Corrosion Control, Allied Trades, Refurbishment, AGE, Missile Maintenance, and Weapons Benzene (29 CFR ; AFOSH STD 48-8, 3): Benzene is a byproduct found in most hydrocarbon-based fuels. It is present in JP-4 and JP-8 jet fuel, in addition to many grades of gasoline and diesel vehicle fuels. Although these fuels are present throughout the AF, most of the requirements under the benzene regulations are exempted. The primary reason for this is the amount of benzene present in these fuels does not meet the minimum regulatory requirements. It is important to note, however, that benzene exposures are still covered under standard exposure regulations and monitoring is necessary if the risk assessment indicates as such Lead (29 CFR & 29 CFR ; AFOSH STD 48-8, 7): Although lead products have been aggressively removed from the AF inventory over the past twenty years, many work areas still have significant potential exposures to this hazardous material. In fact, lead and asbestos are probably the most prevalent exposure hazards at the majority of AF bases. Lead is found in a variety of solder and welding materials, as well as many corrosion-preventative coatings. Additionally, some structural materials still contain lead which can become airborne during sanding operations. Based upon this, all of the work areas with potential cadmium exposures will typically also be evaluated for lead exposures Formaldehyde (29 CFR ; AFOSH STD 48-8, 6): In most cases, formaldehyde has been removed from the AF inventory. However, formaldehyde (as formalin) is still used in a variety of medical and veterinary procedures. Additionally, there are some chemicals that contain small amounts of formaldehyde as a byproduct of their production. These items include adhesives and sealants found in many flightline shops. Typically, the percentage of formaldehyde in these products is small and a negative exposure assessment is easily written Methylene Chloride (29 CFR ): The primary usage of methylene chloride is as a paint thinning solvent. Prior to its inclusion on the EPA 17 hazardous material listing, it was a common paint removal agent utilized whenever aggressive means were inappropriate. Usage has dropped significantly in the past ten years, but some paints and thinners still contain this product. 7.2 Does the chemical product contain one of the other chemicals with substance-specific requirements?: In addition to the six common chemicals outlined above, there are other 8

12 specifically-regulated chemicals detailed below that may be found on AF installations. If one of these chemicals is present or can be produced, the cited regulatory reference must be consulted for additional assessment guidance ,2-dibromo-3-chloropropane (29 CFR ; AFOSH STD 48-8, 6): A pesticide component that was outlawed in the United States in The most likely exposure source for AF personnel is as an environmental contaminant Acrylonitirile (29 CFR ; AFOSH STD 48-8, 6): A chemical component used to manufacture nitrile rubber and plastic beverage bottles. It could be released when some plastic and rubber components are cut/fabricated or heated to decomposition. The most likely exposure source for AF personnel is in work areas that cut, melt, or burn plastics Methylenedianiline (29 CFR & 29 CFR ; AFOSH STD 48-8, 6): This chemical is most commonly found in two-stage epoxies as the hardening agent. It is also a component in some rubber materials. It could be released upon heating to decomposition of rubber. The most likely exposure source for AF personnel is in work areas utilizing two-part epoxies Vinyl Chloride (29 CFR & 29 CFR ; AFOSH STD 48-8, 6): Vinyl chloride is primarily a raw material utilized in creating resins. In fact, under normal conditions, it is a gas. The most likely exposure source for AF personnel is during the breakdown of resin-based materials through cutting, grinding, or burning. This is most critical in shops where workers fabricate resin-based materials such as aircraft panels ,3-Butadiene (29 CFR ; AFOSH STD 48-8, 6): Like vinyl chloride, 1,3-Butadiene is a gas at room temperature. It is utilized in the production of tires and other synthetic rubber products. It is also in some latex paints. There are no likely exposure sources for AF personnel Inorganic Arsenic (29 CFR ; AFOSH STD 48-8, 6): OSHA considers "Inorganic Arsenic" to mean copper acetoarsenite & all inorganic compounds containing arsenic except ARSINE. In most cases, the chemical will have arsenic, arsenate or arsenite as part of the name. Inorganic arsenic is a component in many metallic compounds (welding materials and solder). It is also in some pesticides. The most likely exposure source for AF personnel is in pest management duties Ethylene Oxide (29 CFR ; AFOSH STD 48-8, 4): The most common usage for this chemical is as a equipment sterilizing agent in medical facilities. However, due to its hazardous nature, most AF facilities have replaced it or utilize closed systems Hydrazine (AFOSH STD 48-8, 8): Although this is not specifically regulated by OSHA, the AF has several requirements for the use of hydrazine. This chemical is found in missile, aircraft, and spacecraft applications where it functions as a monopropellant or as a 9

13 component in the fuel mixture. AF personnel working at Space Command bases or at locations where F-16s are present will need to evaluate the processes associated with this chemical Composite Materials (AFOSH STD 48-8, 10): Many aircraft and spacecraft in the AF inventory have composite material components. These typically consist of a reinforcing fiber and a resin in a polymer matrix. The fibers in these composites have been found to cause significant lung problems with inhalation. For this reason, there are specific monitoring requirements for these materials when they are fabricated, repaired, or removed. There is a table in the AFOSH STD outlining the aircraft type and composite location for most items in the AF inventory Chromates (AFOSH STD 48-8, 12): Chromium VI (chromate) is combined with a variety of metals (commonly, lead, zinc and strontium) and added to paint as a corrosion inhibitor. Workers in any AF shop that applies primers or removes paint from metal surfaces will likely have some exposure to chromates. It is likely that this chemical will be specifically regulated by OSHA within the next two years Isocyanates (AFOSH STD 48-8, 13): A variety of isocyanate products are commonly found in polyurethane painting and spray-foam insulation applications. Specific requirements for monitoring of these products are clearly provided in the AFOSH Standard. 7.3 Does the hazardous product contain a known or suspected carcinogen?: Many of the most hazardous substances encountered in routine AF operations are covered by the substancespecific standards. However, there are some chemical carcinogens that do not have substancespecific standards that can be found in AF work areas. This is important since OSHA and AF regulations place a high degree of emphasis on proper assessment of the hazard potential presented by these products. A listing of these chemical carcinogens is presented in attachment 4. Guidance on proper assessment of these chemicals can be found in AFOSH STD 48-8, 6 and 29 CFR Does the hazardous product contain one of the OSHA-designated carcinogens without an Occupational Exposure Limit (OEL)?: In addition to all of the chemicals identified so far, OSHA maintains a listing of carcinogens for which no OEL has been established. Each of these chemicals has a substance-specific standard outlined in 29 CFR through 29 CFR Additionally, the AF addresses these chemicals in AFOSH STD 48-8, 5. A listing of these chemicals can be found in attachment 5 to this document. It is important to note that these standards do not apply to laboratory usage of these chemicals. This is critical in that their presence in AF operations would typically be limited to laboratory settings. There are no standard AF exposures to these chemicals. 7.5 If the hazardous product has an OEL, is it used in such a manner as to create a potential for the Action Level to be exceeded?: When evaluating chemicals that are not specifically regulated under OSHA or AF rules, it is important to utilize sound judgment. Limited time and resources mean that critical decisions must be made when determining where the Bioenvironmental Engineering Element will spend its time. As a general rule of thumb, if the exposure limit is greater than 100 ppm and the product is only being used for short periods of 10

14 time (< 15 minutes) in a well ventilated area, the hazard potential is low. In most cases, this equates to a negative exposure assessment. When the product has a lower exposure limit, is used for longer periods of time, or the work is completed in a confined area, professional judgment and chemical calculations should determine the exposure assessment. In some instances, screening air samples can be used as part of the decision process If the hazardous product does not have on OEL, is there any information indicating that the product presents an inhalation hazard? When a product is not a carcinogen and no occupational exposure limit has been established, the common assumption is there is no inhalation hazard. In fact, there may not be enough information available to set an exposure limit. An example of this is diesel exhaust. Due to the large number of components, regulatory bodies have found it difficult to set an appropriate exposure limit that is representative of the true hazard. In these cases, the best practice is to limit the exposure to as low as reasonably achievable. If the process can be sampled, a statistically significant number of samples should be accomplished (see discussion below). Using these samples as a baseline, all successive samples can be compared to determine if exposures are changing. This could indicate a change in process or a failure of controls. 7.7 If the hazardous product does not present an inhalation hazard, is it used in such a manner as to create a contact hazard?: In some instances, skin or eye contact with the hazardous product can result in negative health effects. Often, this is true even when the hazardous material is not a concern via the inhalation route of exposure. If the material is a contact hazard, controlling the exposure is required. This is most commonly done through the use of barriers or personal protective equipment. However, product substitution should never be ruled out as a viable option. Any exposure assessment for these chemicals should clearly outline the potential route of exposure. 8. HAZARDOUS MATERIAL EXPOSURE ASSESSMENT 8.1 Sampling Strategies and Statistical Significance: After identifying the hazard, the next step is to develop an evaluation strategy. This strategy should fully characterize the risk associated with use of the material. There are many issues to consider when formulating a sampling strategy, but at a minimum the following items will be addressed: Choosing who to sample: The risk assessment conducted under section 5 above should help to determine the appropriate personnel to sample. In some cases, certain individuals must be sampled due to regulatory requirements. These regulations may also drive the number of samples that must be taken. Other factors to consider include - Worker closest to point of contaminant generation - Willing worker; workers that want to be sampled are usually more cooperative and more likely to provide you with complete documentation of tasks they accomplish - Areas of concern; talk to the supervisor and the workers to find out what they feel is the most hazardous part of the process/activity, they usually can identify the areas they feel most uncomfortable about 11

15 - Equipment limitations; understand your equipment and know what it is capable of before sampling. There may be occasions where you don t have enough pumps to sample everything - Worker schedule; find out if anyone has other appointments during the day that will take them away from the work area and reduce their potential exposure Sampling statistics: Prior to air sampling a process, it is critical to determine the number of samples to take. When this number is not specified by regulation, the tendency is to collect one sample and call it good. There are several problems with this, but the most critical is the potential for that single sample to have significant error problems resulting in an improper conclusion (i.e. stating that a person is not exposed to the chemical when they are or vice versa). Most statistical sources recommend a minimum of three samples of the same process before any conclusions are drawn. In some AF documents, four samples are recommended for statistical significance. Of course, these numbers can be impacted by the degree of hazard and how close the initial sample is to the exposure limit. For chemicals with minimal hazards, one sample may be adequate to negatively document an exposure. Likewise, if a sample result is less than 1% of the exposure limit, the likelihood that the person was actually overexposed is remote. As a rule of thumb, most processes should be sampled three times Confidence Limits: If OSHA conducts an inspection and performs air sampling of a process, they must calculate the sample results and include confidence limits. A confidence limit takes into account the errors inherent in scientific processes. When air sampling, this includes laboratory instrumentation errors, chemical dilution errors, timing errors, and pump flow rate errors. It is important to note that these are not accidents or human errors. They are errors inherent in the instrumentation being used for the sampling. Confidence limits merely sum up these errors and provide a more accurate understanding of the sample result. Therefore, if OSHA samples and the result is 100 ppm, the confidence limit may be ppm. This is interpreted to mean OSHA believes that the true value of the sample is actually between ppm. The reason this is important is that OSHA must show that the lower confidence value (75 ppm in the example) is above the exposure limit to prove that there is an overexposure. Basically, this gives the entity being inspected the benefit of the doubt. For the standard BEE shop, confidence limits are not that important. The National Institute of Occupational Safety & Health (NIOSH) requires that air sampling methods have maximum confidence limits of +/- 25%. Therefore, if a sample result is outside of +/- 25% of the OEL, applying confidence limits will not have any affect (i.e. it won t change a positive result to negative or vice versa). Of course, if the AL triggers some requirements, then +/- 25% must be applied to it. The easiest way to deal with confidence limits is to go with the following rule of thumb: If the sample result is less than 10% of the OEL or over the OEL, there is no need to calculate confidence limits. If the sample result is between 10% of the OEL and the OEL, then an upper confidence limit is necessary Common sampling questions: Occasionally, questions arise during air sampling events. It is critical that the all events are conducted in the same manner to ensure 12

16 uniformity of analysis. Therefore, shop guidance has been developed on the proper method to handle these issues What do I do if the shift lasts longer than eight hours? If the worker being sampled continues to be exposed to the chemical of concern, then sampling of that worker should continue. A great example of this is the coal plant at Eielson. Workers in this plant have a ten hour shift. During the entire time, they have potential exposure to coal dust. Therefore, they must be sampled for the entire duration of the shift. On the other hand, if the chemical exposure stops, there is no need to continue sampling. For instance, an Allied Trades worker may work a ten hour shift, but if they only spend the first three hours painting a vehicle, there is no need to monitor the other seven hours. When extended shift sampling is accomplished, analysis of the results should be accomplished using the Brief & Scala method as outlined in Patty s Industrial Hygiene books What do I do when the worker goes to lunch? Stop the sample. Workers should not be sampled while they are eating lunch, even if it is in a lunch room adjacent to the work area Do I really need to take bulk and/or swipe samples? It depends. In some instances, a bulk sample is required as part of the analysis process (i.e. take a fuel sample when sampling for JP-8 and benzene). If a bulk sample is not required by the lab method, the question that needs to be answered is What information will be gained by having a bulk result? For processes like sanding, bulk samples can help explain metal sources. Swipe samples are always a good idea when air sampling a process that leaves residue (i.e. sanding, welding, painting). They can be used to demonstrate contaminant movement as well as level of clean-up (before and after swipes). If a swipe sample helps to answer possible questions, take one Do I really need to contact the lab before I sample? It is recommended that sample method and detection limits be verified with the analytical laboratory before any sample. There is nothing worse than sending a sample to the lab and then finding out it was done incorrectly. 8.2 Evaluation of OSHA Substance-Specific Chemicals: In many cases (such as for the OSHA substance-specific standards), the strategy is laid out in regulatory documents. All of the work areas on Andersen AFB were reviewed for usage of these materials and a chart was created to aid with management and compliance (see attachment 6). For each work area, the chart details the chemicals of concern, the processes where these chemicals are used, and the current level of regulatory compliance. The chart is colorcoded to indicate areas of significant concern. 8.3 Exposures above the OEL and AL: As was discussed above, there are many hazardous chemicals that can negatively impact worker s health other than those specifically regulated by OSHA. It is often necessary to conduct air sampling for these chemicals to characterize the degree of hazard. When the air sample results are above an 13

17 occupational exposure level or action level, proper controls must be implemented to reduce the exposure. 9. REGULATED AREAS Occasionally, a work area will utilize hazardous materials in a manner that could potentially expose workers or members of the public who are unaware of the hazard. When this occurs, OSHA rules in 29 CFR 1910 and 29 CFR 1926 establish regulated areas to protect these individuals. These rules have been mirrored, and in some cases expanded upon, in AF regulations. However, the simple purpose of a regulated area is as a zone of protection around hazardous operations. According to AFOSH Standard 48-8, a regulated area is defined as an area under the work area supervisor s control where entry and exit are restricted and controlled to prevent exposure to hazardous materials. The supervisor is required to ensure all personnel entering a regulated area have the proper training, protective equipment, and authorization to be there. Although the supervisor as the responsibility for enforcing the regulated area, it is the Bioenvrionmental Engineer s job to determine when a regulated area is necessary. The Bioenvironmental Engineer s source for determining the necessity of a regulated area is AFOSH Standard Under paragraph 4.3 in this standard, it outlines the circumstances under which a regulated area shall be established. The general guideline is that the BEE defines in writing a regulated area where needed to prevent exposure to a hazardous material. The standard goes on to list five situations that would drive the need for a regulated area. There has been some controversy around the need for a regulated area in some of these situations and in a draft update to AFOSH Standard 48-8, two of the situations have been removed. Each situation is discussed below. 9.1 Federal Requirement: The first type of regulated area is one that is required by federal law (29 CFR 1910 or 29 CFR 1926). This situation is self-explanatory and military bases have no choice about compliance. There are two general categories of federal regulations with regard to regulated areas. The first category is for specifically regulated chemicals, much like those discussed above. The second category is for carcinogens without Occupational Exposure Limits. By combining these two categories, a complete listing of the current chemicals regulated under OSHA that can have regulated area requirements can be created (attachment 7). Each of these chemicals currently found on Andersen AFB is analyzed below Asbestos: There are two separate regulations based upon the method of exposure If the exposure is from a standard work area, then the 29 CFR 1910 asbestos regulations apply. A good example of this would be asbestos brake pad operations in a Transportation Maintenance shop. In this case, a regulated area means an area established by the employer to demarcate areas where airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limits If the exposure is from a construction work are, then the 29 CFR 1926 asbestos regulations apply. This would include all asbestos removal and repair operations, including clean-up. In this case, a regulated area means an area established by the employer to demarcate 14

18 areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos, exceed or there is a reasonable possibility they may exceed the permissible exposure limit Andersen AFB Asbestos Regulated Areas: None Cadmium: A regulated area means an area demarcated by the employer where an employee s exposure to airborne concentrations of cadmium exceeds, or can reasonably be expected to exceed the permissible exposure limit Andersen AFB Cadmium Regulated Areas: Currently, the Structural Maintenance shop sanding area is a regulated area. A sample collected in 2002 was above the action level. Although, a regulated area is only required if the sample exceeds the OEL, the BES decided to designate the area as regulated. A change in the process resulted in a sample collected in August 2004 being well below the AL. A second sample is necessary to confirm this Benzene: A regulated area means any area where airborne concentrations of benzene exceed or can reasonably be expected to exceed, the permissible exposure limits, either the 8-hour time weighted average exposure of 1 ppm or the short term exposure limit of 5 ppm for 15 minutes Andersen AFB Benzene Regulated Areas: None Formaldehyde: A regulated area shall be established where the concentration of airborne formaldehyde exceeds either the TWA or the STEL Andersen AFB Formaldehyde Regulated Areas: None Methylene Chloride: A regulated area means an area, demarcated by the employer, where an employee s exposure to airborne concentrations of methylene chloride exceeds or can reasonably be expected to exceed either the 8-hour TWA PEL or the STEL Andersen AFB Methylene Chloride Regulated Areas: None. 9.2 Carcinogens: According to the AFOSH Standard, a regulated area shall also be established where exposures to known or suspect human carcinogens exceed the Occupational Exposure Limit. Although this is not a federal requirement, there is general agreement that the hazard of these situations is significant enough that control of the area around the task is necessary. The 15

19 most appropriate source for carcinogen listings is the United States Department of Health & Human Services. By federal regulation, this body issues a peer-reviewed, biennial report that contains a list of all substances that are known or appear likely to cause cancer. The most recent report available was issued in 2002 and entitled Tenth Report on Carcinogens. As discussed earlier, a listing of the chemicals on this report is located at attachment 4. Although these listings are extensive with well over 200 substances included, the application is limited since there are few commonly found at most typical AF locations. When these chemicals are found on an AF base, they are typically utilized in such small amounts that exceeding an exposure limit is not a concern. However, there are a few compounds that warrant discussion based upon their probable presence at AF installations Hexavalent Chromium: AF Operations: This compound is found in a variety of primers used in aircraft and vehicle painting. It is typically complexed with strontium, zinc, or lead. Exposures occur during sanding operation on materials painted with these primers as well as during the application of the primers themselves Andersen AFB Hexavalent Chromium Regulated Areas: The only shop with hexavalent chromium exposure above the OEL is Structural Maintenance. The process is the same as for the cadmium exposure and is detailed above Crystalline Silica: AF Operations: Silica in its crystalline form is most often found in coal and sand. The most likely exposure source for AF workers is during sanding of roads in inclimate weather. At some Northern tier bases, heat is supplied through coal plants and AF workers may be exposed if they work in these areas Andersen AFB Crystalline Silica Regulated Areas: None Nickel: AF Operations: Nickel is present in a variety of metal compounds. AF workers may be exposed during welding and brazing operations in a variety of different work areas. Nickel is also in some aircraft wheels and workers maintaining them may be exposed Andersen AFB Nickel Regulated Areas: None Wood Dust: AF Operations: Wood dust is created during a number of construction activities on AF bases. Many Civil Engineering shops have woodworking equipment that is used intermittently. Most bases have a Wood Hobby Shop that is staffed by AF employees. In reality, however, the exposures in these work areas are minimal due to the limited amount of wood work accomplished and the availability of local exhaust ventilation systems. 16

20 Andersen AFB Wood Dust Regulated Areas: None. 9.3 Personal Protective Equipment: The third regulated area situation is in areas where personal protective equipment is required to avoid skin or eye contact hazards. There is a lot of disagreement about this issue and in the draft rewrite of the AFOSH Standard, it has been removed. It is impractical to attempt to define regulated areas based on this broadly stated requirement, especially for activities not confined to a specific location. There already exist OSHA regulations that require supervisors to ensure workers are trained and have the proper protective equipment prior to performing a job; it is unnecessary to add regulated area requirements into this mix. A more appropriate way to address this is to consider the personal protective requirement of any attendant/bystander who is on-looking the activity being performed. If an attendant/bystander in the area requires PPE to avoid skin or eye contact hazards while simply observing the activity then a regulated area should be designated. Due to the fluid nature of most jobs, this will have to be handled on a case-by-case basis. Currently, there are no regulated areas that meet these requirements on Andersen AFB. 9.4 Respiratory Protection: The fourth regulated area situation is in areas where respiratory protection must be worn to prevent exposure. There is also a lot of disagreement about this statement and it has been removed from the draft rewrite of the AFOSH Standard as well. The key to examining this statement is the word must. If all workers entering an area must put on a respirator before they proceed, then the area is regulated. Two good examples of this are paint booths and asbestos containments. The intent is not to require a regulated area around everyone wearing a respirator, only to ensure that all workers entering an area where respirators are required put them on prior to entry. There are no processes at Andersen AFB that qualify as a regulated area under this requirement. 9.5 Other Areas: The final regulated area situation is in any other area where a hazardous exposure could occur if access is not controlled. This is a catch all statement that is meant to provide the BEE with latitude in controlling areas where a risk assessment may determine that hazardous exposures could occur outside of those already covered by the other areas. At present, there are no situations that qualify in this regard at Andersen AFB. 10. SUMMARY This document provides program definition for industrial hygiene surveillance and analysis of hazardous material exposures at Andersen AFB. It thoroughly analyzes current operations and exposures and outlines proper evaluation techniques for future situations. It also serves as the defining methodology for interpretation of current AF regulatory requirements. KERRY L. LEWIS, Maj, USAF, BSC Aerospace Medicine Flight Commander 17

21 7 s 1. Master Shop Listing 2. Special Surveillance Listing 3. Summary of OSHA Requirements -- Six Common AF Chemicals 4. Known or Suspected Carcinogens 5. Carcinogens without an OEL 6. Specifically Regulated Chemicals 7. Substance Specific Regulated Area Requirements 18

22 WIC SHOP CATEGORY JUSTIFICATION 002C FUELS BULK STORAGE 2 Although there is benzene in the fuels, it is exempted due to small percentage -- shop processes reasonably well defined and minimal potential exposure. 002D FUEL DISTRIBUTION 2 Although there is benzene in the fuels, it is exempted due to small percentage -- shop processes reasonably well defined and minimal potential exposure. 002E FUELS LABORATORY 2 Although there is benzene in the fuels, it is exempted due to small percentage -- shop processes reasonably well defined and minimal potential exposure. 002F CRYOGENICS 2 Shop has minimal potential exposure to hazardous materials. 008B DENTAL CLINIC 2 Shop processes are well defined and there is minimal exposure potential. 008C MEDICAL CLINIC XRAY 2 Shop processes are well defined and there is minimal exposure potential. 008D MEDICAL LABORATORY 2 Shop processes are well defined and there is minimal exposure potential. 008F VET CLINIC 1 Shop processes are not well defined -- anesthetic gas baseline does not exist -- formaldehyde usage with no sampling accomplished. May be able to move to CAT 2 in the future. 008H BIOMEDICAL MAINT 2 Shop processes are well defined and there is minimal exposure potential. 009B AUTO HOBBY SHOP 2 Shop needs significant work, but experience indicates that this shop typically falls into category two. I visited the shop and tasks are not peformed frequently enough or at a high enough pace to justify a higher category. 009C BOWLING ALLEY MAINT 2 Shop processes are well defined and there is minimal exposure potential. 009H WOOD HOBBY SHOP 2 Shop processes are well defined and there is minimal exposure potential. 009K GOLF COURSE MAINT 1 Several processes need additional investigation and pesticide usage needs to be locked down. I visited shop and determined that pesticide usage is enough to warrant category one status. 009L GRAPHICS 3 Administrative shop. 009M EOD 2 Shop processes are well defined and there is minimal exposure potential. 009N COMMISSARY 3 Administrative shop. 010C ENTOMOLOGY 1 Several processes need additional investigation and pesticide usage needs to be locked down. I visited shop and determined that pesticide usage is enough to warrant category one status. 010D ELECTRICAL CONTROL SYS. 2 Shop has minimal potential exposure to hazardous materials. 010G FIRE DEPARTMENT 1 Shop needs to be visited regularly -- respirator usage, hazmat exposure, confined area entry, breathing air checks 010K LIQUID FUELS 1 Shop processes are not well defined -- benzene and lead exposures are not properly characterized -- shop has respirators and confined space entries. May be able to move to CAT 2 in the future. 010N UTILITIES MAINT 2 Shop processes are well defined and there is minimal exposure potential. 010O POWER PRODUCTION 2 Shop processes are well defined and there is minimal exposure potential. 010V POWER PRODUCTION 2 Shop processes are well defined and there is minimal exposure potential. 010X ZONE 1 1 Shop processes are not well defined -- there are several tasks in this workplace that may create special surveillance requirements and medical exams other than audiograms -- potential asbestos exposure, welding, and painting processes have not been reviewed. This shop needs equivalent of baseline survey. 010Y ZONE 2 2 Shop processes are well defined and there is minimal exposure potential. 010Z HORIZONTAL SHOP 2 Shop processes are well defined and there is minimal exposure potential. This shop and Grounds Maintenance share a casefile and are surveyed at the same time. 19

23 WIC SHOP CATEGORY JUSTIFICATION 010Z- 2 GROUNDS MAINTENANCE 2 Shop processes are well defined and there is minimal exposure potential. This shop and Horizontal Shop share a casefile and are surveyed at the same time. 011B COMBAT ARMS 2 Shop processes are well defined and there is minimal exposure potential. 015E ELECTRO ENVT 2 Shop has minimal potential exposure to hazardous materials. 015F STRUCT/CORROSION CON. 1 Several samples necessary to properly quantify exposures in this shop. 015O AIRCRAFT SERVICES 2 Shop has minimal potential exposure to hazardous materials. 015P METAL TECHNOLOGY 1 Shop performs many types of welding -- no samples have ever been taken -- shop used chromium welding rods -- records for this shop are minimal 015S SORTIE SUPPORT 2 Shop has minimal potential exposure to hazardous materials. 016B MET NAV MAINT 2 By nature, COMM shops are very low hazard and processes are routine. 016H BASE RADIO MAINT 2 By nature, COMM shops are very low hazard and processes are routine. 016J RADAR MAINT 2 By nature, COMM shops are very low hazard and processes are routine. 016N CABLE MAINT 2 By nature, COMM shops are very low hazard and processes are routine. 016P SATCOM WIDEBAND 2 By nature, COMM shops are very low hazard and processes are routine. 018D HVAC 3 Shop works with electronic repairs of HVAC systems -- some minor soldering, but most tasks are admin in nature -- CAT 3 is appropriate. 018H VERTICAL SHOP 1 Multiple follow up items in this shop have neve been addressed -- without proper analysis of these tasks, shop must be category one. In time, should be able to move this shop to CAT A AIR NATIONAL GUARD 3 No routine tasks. 021A AGE 1 Several samples necessary to properly quantify exposures in this shop. 021B PMEL 3 Shop is contractor only. 021C NDI 1 Significant hazards from x-ray and non-routine medical exams -- shop needs to be CAT 1 so that it is visited every year. 021D CONVENTIONAL MAINT 1 Multiple follow up items in this shop have neve been addressed -- without proper analysis of these tasks, shop must be category one. In time, should be able to move this shop to CAT F ARMAMENT 2 Shop has minimal potential exposure to hazardous materials. 021H STORAGE & HANDLING 2 Shop has minimal potential exposure to hazardous materials. 021K MUNITIONS INSPECTIONS 2 Shop has minimal potential exposure to hazardous materials. 021 L FUEL CELL REPAIR 3 Shop is only stood up during contingency operations -- no routine tasks. 021N MUNITIONS SUPT EQ MAINT 1 Multiple follow up items in this shop have neve been addressed -- without proper analysis of these tasks, shop must be category one. In time, should be able to move this shop to CAT O MISSILE MXT 1 Tasks in this shop led BEE to reclassify as CAT 1 in January P BOMB RENOVATION PLANT 3 Shop is only stood up during contingency operations -- no routine tasks. CONTINGENCY RESPONSE Administrative shop. 022A GRP 3 MOBILITY RESPONSE Administrative shop. 022B SQUADRON 3 SECURITY FORCES Administrative shop. 022C SQUADRON 3 909A ELEMENTARY SCHOOL 3 Administrative shop. 20

24 WIC SHOP CATEGORY JUSTIFICATION 910A MIDDLE SCHOOL 3 Administrative shop. 911A DUPLICATE 3 Administrative shop. 912A TELEPHONE SYSTEMS 3 Administrative shop. 913A RADIO BRANCH 3 Administrative shop. 914A FACILITY MANAGEMENT 3 Administrative shop. 915A HOUSING MAINTENANCE 3 Administrative shop. 916A MOBILITY 3 Administrative shop. 917A TRANSIENT MAINTENANCE 3 Administrative shop. 918A WILDLIFE SERVICES 3 Administrative shop. 21

25 PRIORITY (Hazard/ Controls) 1 (Low/ Medium) 2 (Low/ Medium) 3 (Low/ Medium) 4 (Low/ Medium) 5 (Low/ Medium) 6 Admin WIC SHOP Issue Activity/Comments 015F Structural Maint Cadmium/Lead Personnel use pneumatic sanders to prep equipment for painting. A cadmium sample collected in 2002 indicated exposures above the AL, but none of the supporting documentation is available for verification. In any case, BES established a regulated area based upon this and completed a follow-up sample in August This sample was well below the AL for both lead and cadmium. This is adequate for a negative exposure assessment for lead. In order to meet OSHA requirements, the cadmium process every six months until two consecutive samples show results below the AL. Therefore, to meet OSHA regulations, sampling should have been completed in February This must be done immediately. At the same time, proper sampling for chromates should be performed since there are no correct samples in the casefile at this time. 008F Vet Clinic Isoflurane Isoflurane is used as an anesthetic during veterinary surgeries. This chemical does not have an exposure limit, so IAW AFOSH STD 48-8 a baseline level must be established. This was attempted in June 2004, but levels were high in comparison to other bases with similar set-ups. Therefore, maintenance personnel were called in to fix the system. This took place in Sept/Oct No further samples have been collected. This will be a significant issue if sampling is not at least attempted between now and the HSI. Highly suggest you complete this sampling. 015P Metal Technology Shop Visit This is another favorite casefile of the HSI. Currently, there is a significant lack of proper process assessment in this shop. Although one of the primary tasks in this shop is welding, it has never been air sampled (although it has been recommended over and over). This shop uses chromium metal welding rods which can present a significant inhalation hazard. Additionally, there is welding ventilation system which is not on the BES ventilation program. Recommend a shop visit to identify critical processes followed by appropriate air sampling. 021O Missile Maint. Shop Survey Shop has not been visited in a long time and BES recently moved it to Category 1. Additionally, when the surveillance frequency was changed, a promise was made that a shop survey would be performed in March Recommend that shop survey is accomplished as promised. 021N Munitions Supt Eq. Equipment Refurbishment Shop survey in August 2003 indicated that shop refurbishes munitions support equipment. There are several recommendations that this process be sampled as it involves sanding, blasting and painting. A recent entry on the AF Form 2754 states that sanding is no longer accomplished. The true process needs to be clarified and sampling accomplished for lead and cadmium if necessary. 010K Liquid Fuels Benzene The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Additionally, tasks involving fuel are specifically exempted under the OSHA standard. This file has a mistake with regard to benzene sampling wherein a JP- 8 sample result was applied to the benzene standard, thus showing an exceedance of the OEL. Several follow-up actions were taken over a two and a half year period due to this. A memo for record needs to be generated and placed in the casefile that explains this issue and clears it up. 7 (Low/ 009K Golf Course Maint. Pesticides -- Arsenic Shop uses several pesticides to control insects and weed growth on the golf course. None of the exposures have ever been evaluated with air sampling, even though some products have exposure limits below 1.0 mg/m 3. These processes need to be fully identified in the casefile and air sampled. 22

26 PRIORITY (Hazard/ Controls) 8 (Low/ 9 (Low/ 10 (Low/ 11 (Low/ 12 (Low/ 13 (Low/ 14 (Low/ 15 (Low/ 16 (Low/ Medium) WIC SHOP Issue Activity/Comments 010C Entomology Pesticides Shop uses several pesticides to control insects and weed growth throughout the base. None of the exposures have been properly evaluated with air sampling. These processes need to be fully identified in the casefile and air sampled. 015F Structural Maint Priming Sampling during priming operations has not been properly sampled. Samples need to be collected for hexavalent chromium during the next available operation. 018H Vertical Formaldehyde Present in paints used by shop. Air sampling has been recommended, but never accomplished. Recommend that painting operation with formaldehyde-containing paint be sampled. 021A AGE Lead/ Methylene Chloride Lead and methylene chloride are present in a solid film lubricant used by the shop. This has never been evaluated. Typical usage of these products is minimal, so a negative exposure assessment would normally be adequate. However, the lead standard does not allow for a negative exposure assessment without at least one air sample. Therefore, if the shop is going to continue to use this product, air sampling is necessary. 021C NDI Lead Lead is present in some of the oils used by this shop. Air sampling has never been accomplished while using this product. Verify that these oils are still used. If so, at least one air sample is necessary for a negative exposure assessment. 021D Conventional Maint. Lead Shop has marking stencil ink containing lead. This process has not been fully evaluated or sample. Recommend that a process assessment be completed and air sampling for lead by accomplished. 021F Armament Lead Lead is present in a sealing compound. The process involving this product has not been fully evaluated and no air sampling has been completed. Recommend that the use of this product be fully explored and air sampling be conducted. 010K Liquid Fuels Benzene - Fuel Filters The fuel filter change-out process is one of the highest potential exposure sources for fuel-related tasks. You recommended sampling in February 2003, but it has never been accomplished. I would recommend that this be done as soon as practical. 010X Zone 1 Welding Welding operations are not well characterized and the most recent air sampling was done in Welding is an OSHA regulated task and usually a high interest item on the HSI. Recommend that a review of this process be accomplished and welding sampling be completed if necessary. 23

27 PRIORITY (Hazard/ Controls) 17 Admin 18 Admin 19 (Medium/ 20 (Medium/ 21 (Medium/ 22 (Low/ Medium) 23 (Low/ 24 (Medium/ 25 (Medium/ WIC SHOP Issue Activity/Comments 008F Vet Clinic Ventilation The Veterinary Clinic has two surgery rooms that require semi-annual ventilation surveys. The last survey was done in June Complete this survey soon. 021C NDI Benzene/ Methylene Chloride 021F Armament Methylene Chloride 021K Munitions Inspections Methylene Chloride 009B Auto Hobby Shop Methylene Chloride Benzene and methylene chloride are present in some of the oils used by this shop. An exposure assessment has never been completed for these items. Verify that these oils are still used. If so, complete a negative exposure assessment using the extremely small percentages of the chemicals in the oils, the limited amount of oil used, and the infrequency of the process. Methylene chloride is present in solid film lubricant used by this shop. The usage of this product has never been evaluated. Based upon experience, this item is typically used in small amounts and infrequently. Recommend that a negative exposure assessment be developed if the product is still in use. Methylene chloride is present in liquid rubber adhesive used by this shop. The usage of this product has never been evaluated. Based upon experience, this item is typically used in small amounts and infrequently. Recommend that a negative exposure assessment be developed if the product is still in use. Methylene chloride is present in the Universal Cement (Balkamp ) used for tire repair. This product is only used by shop personnel. The top has a brush in the cap that is used to spread the cement on the tire. Recommend that a negative exposure assessment be completed for this based upon limited usage, limited amount, and plenty of natural dilution ventilation. 018H Vertical Chromium Present in paints used by shop. Air sampling has been recommended, but never accomplished. Recommend that painting operation with chrome-based paint be sampled. 018H Vertical Welding Shop does large scale outdoor welding projects. Air sampling has been recommended, but never accomplished. Welding is high interest HSI item. Recommend that welding air sampling be completed. 021N Munitions Supt Eq. Lead/Cadmium Lead and cadmium has been sampled while workers grind parts using a bench grinder. Both samples were well below the AL. No further samples are necessary for lead, but a second sample for cadmium must be collected if this process is still occurring. Verify that this process is still active and schedule cadmium sampling if necessary. 002C Fuels Bulk Storage Benzene The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Additionally, tasks involving fuel are specifically exempted under the OSHA standard. This does not mean the benzene sampling should not be accomplished or is not necessary, it just means that the expanded standard does not apply. This will hold true regardless of whether a sample comes back above the OEL. Remove this shop from the list once a document stating the above is present in the casefile in some form. 24

28 PRIORITY (Hazard/ Controls) 26 (Medium/ 27 (Medium/ 28 (Medium/ 29 (Medium/ 30 (Medium/ 31 (Medium/ WIC SHOP Issue Activity/Comments 002D Fuel Distribution Benzene The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Additionally, tasks involving fuel are specifically exempted under the OSHA standard. This does not mean the benzene sampling should not be accomplished or is not necessary, it just means that the expanded standard does not apply. This will hold true regardless of whether a sample comes back above the OEL. Remove this shop from the list once a document stating the above is present in the casefile in some form. 002E Fuels Laboratory Benzene The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Additionally, tasks involving fuel are specifically exempted under the OSHA standard. This does not mean the benzene sampling should not be accomplished or is not necessary, it just means that the expanded standard does not apply. This will hold true regardless of whether a sample comes back above the OEL. Remove this shop from the list once a document stating the above is present in the casefile in some form. 008B Dental Clinic Formaldehyde Shop utilizes pre-packaged preservation solution containing formaldehyde. Minimal amounts are used and the most recent AF Form 2755 states that it isn't a significant hazard. I would recommend a more formal process evaluation since this is an expanded standard chemical and of high interest. 008D Medical Laboratory Formaldehyde Formalin (10% formaldehyde) is used in three different sample procedures that pass through the lab. In all three cases, the formalin is already present in a container, the sample is added, and then the container is sealed. The sealed container may sit in the laboratory for a few days before it is shipped out to another facility for analysis. The three tests are fecal OVA, tissue sample, and PAP. In every case, the sample is added to the container by either the patient or a provider -- the lab never actually deals with containers that are opened. This information is adequate to prepare a negative exposure document for formaldehyde usage in the laboratory. 008F Vet Clinic Formaldehyde Formalin (10% formaldehyde) is used as a specimen preservative for biopsies performed during animal surgeries. There is a hazard assessment stating that the risk of exposure is low due to the short duration the sample container is opened and the limited number of samples collected. No air sampling has been accomplished. Suggest that a formal negative exposure document be prepared for formaldehyde. 009B Auto Hobby Shop Asbestos There are two sources for potential asbestos exposure -- the first is when the shop manager does brake pad changes on Services Squadron fleet vehicles and there is a potential for those pads to have asbestos in them. Currently, he takes no special precautions. The second involves disposal -- all brake pads, whether from Services vehicles or from customers cars are collected in a bin and occasionally the shop manager double bags them up and arranges for disposal through CEV. Due to infrequency of these tasks and limited potential for contact with friable asbestos, you can create a negative exposure assessment for both of these tasks. 32 Admin 010O Power Pro Equipment Refurbishment Shop survey in November 2004 indicated that shop performs refurbishment tasks on generators. There are several recommendations that this process be sampled as it involves sanding and painting. This process needs to be verified to determine if it is much like what is happening with the AGE shop and their equipment. Recommend that this task be carefully evaluated and a common approach be developed for any shop performing this type of work. 25

29 PRIORITY (Hazard/ Controls) 33 (Medium/ 34 Admin 35 (High/ 36 Admin 37 Admin 38 Admin 39 Admin 40 Admin 41 Admin 42 (High/ WIC SHOP Issue Activity/Comments 018H Vertical Asbestos Roofing cement used by shop contains asbestos. This product is of limited hazard since the asbestos is bound in a adhesive matrix that is applied wet. However, since it is an expanded standard chemical, an evaluation is necessary. Recommend that a negative exposure assessment be created using wet application justification. 021D Conventional Maint. Munitions Refurbishment Shop survey in May 2003 indicated that shop refurbishes munitions. There are several recommendations that this process be sampled as it involves sanding and painting. This process needs to be verified to determine if it is much like what is happening with the AGE shop and their equipment. Recommend that this task be carefully evaluated and a common approach be developed for any shop performing this type of work. 021N Munitions Supt Eq. Asbestos According to the most recent AF Form 2755, asbestos is present in brake pads on the bomb carriers and munitions trailers. The pads are removed using the wet method. Air sampling has not been accomplished. As long as the wet method is used, a negative exposure assessment can be generated for this task. Recommend that the process be verified and a negative exposure assessment be generated. 009B Auto Hobby Shop Ventilation The shop has two systems that are customer use only -- a paint booth and a sanding booth. Although, these are customer use only, there is a tacit understanding that they are operating properly. Customers using these systems are going to expect they will be protected when using them -- otherwise they wouldn't be allowed to use them. Therefore, although this is not an occupational exposure, many BEE shops survey these systems from a public relations standpoint. Recommend that BES consider this situation and document a decision. 010C Entomology Ventilation Shop has two pesticide storage areas that should be checked annually -- last survey was done in Recommend ventilation surveys be accomplished. 008B Dental Clinic Methylene Chloride Methylene chloride was present in Zap-It -- an adhesive used by the dental clinic that was removed from their inventory in Remove from your records. 010K Liquid Fuels Lead There is no information in the casefile with regard to the potential source of this exposure. The shop is unaware of any processes that involve a potential exposure to lead. Recommend that you remove from your records. 010O Power Pro Benzene A review of the casefile revealed that the potential benzene exposure was associated with filling generators with unleaded fuel. This is a specifically exempted task and does not apply under the benzene standard. Recommend that you document this and remove it from your records. 010V Det 5 Power Pro Benzene A review of the casefile revealed that there is no benzene exposure in this shop. Remove from your records. 011B Combat Arms Lead Potential lead exposure from weapons firing. Most recent sampling took place in August 2000 with exposures at roughly 20% of the OEL. A conversation with the shop seems to indicate that operation temp has increased since then, but weapons have not changed. The single sample is adequate to satisfy the lead standard, but I would watch this carefully and consider another sample since almost five years have passed since the last one. 26

30 PRIORITY (Hazard/ Controls) 43 Admin 44 Admin 45 Admin WIC SHOP Issue Activity/Comments 018H Vertical Benzene According to the casefile, benzene exposure is possible because workers occasionally weld on lines containing JP-8 fuel and they could be exposed to fuel vapors. I think I would be worried a lot more about the explosion from the welding torch lighting the vapors. Before this type of welding can be accomplished, the line has to be completely empty and allowed to ventilate. The fire department would never issue a permit without it. Recommend that this be removed from the casefile. 021A AGE Cadmium/Lead The AGE shop performs the same tasks in the same location as Structural Maintenance so the evaluations above apply. Recommend that the casefile clearly reflect this. 021 L Fuel Cell Repair Benzene Shop is only active when personnel deploy -- remove from list. 46 Admin 021N Munitions Supt Eq. Methylene Chloride Product which contained methylene chloride has been removed from shop -- remove from list. 47 Admin 48 Admin 021P Bomb Renovation Cadmium/Lead Shop is wartime only -- remove from list. 021B PMEL Lead Shop is contract -- no lead issue -- remove from listing. 27

31 As of Mar 05 Asbestos (29 CFR ) Cadmium (29 CFR ) Benzene (29 CFR ) Lead (29 CFR ) Methylene Chloride (29 CFR ) Formaldehyde (29 CFR ) Exposure Assessment 8 Hr TWA 30 minute Excursion 8 Hr TWA 8 Hr TWA 15 minute STEL 8 Hr TWA 8 Hr TWA 15 minute STEL 8 Hr TWA 15 minute STEL Limit (EL) (See note at pg 3) OSHA PEL 8 Hr TWA: 0.1 f/cc 30 min EL: 1 f/cc 8 Hr TWA: mg/m 3 8 Hr TWA: 1 ppm STEL: 5 ppm 8 Hr TWA: 0.05 mg/m 3 8 Hr TWA: 25 ppm STEL: 125 ppm 8 Hr TWA: 0.75 ppm STEL: 2 ppm Action Level N/A 8 Hr TWA: mg/m 3 8 Hr TWA: 0.5 ppm 8 Hr TWA: 0.03 mg/m 3 8 Hr TWA: 12.5 ppm 8 Hr TWA: 0.5 ppm AF OEL AF Action Level Initial Monitoring Same 8 Hr TWA: mg/m 3 AL: 0.001mg/m 3 For employees who are, or may reasonably be expected to be exposed to airborne concentrations at or above the TWA or EL TWA: Representative samples for full-shift exposures for each shift and each employee in each job classification in each work area. STEL: Representative samples for 30 minute exposures associated with operations that are most likely to produce exposures above EL for each shift and for each job classification in each work area If documented objective data confirms exposures will not be above PEL initial monitoring is not required. Objective data shall represent the highest exposures likely to occur under reasonably foreseeable conditions. Air samples that reflect the monitored employee's regular, daily 8-hour TWA exposure to cadmium. TWA: Representative samples for full-shift exposures for each shift and each employee in each job classification in each work area. In representative sampling, the employer shall sample the employee(s) expected to have the highest cadmium exposures. If documented objective data confirms exposures will not be above PEL initial monitoring is not required. Objective data shall represent the highest exposures likely to occur under reasonably foreseeable conditions. If initial monitoring is preformed and the results are below the AL, a confirmatory sample is required at least seven days later (d)(3)(ii) 8 Hr TWA: 0.5 ppm AL: ppm STEL: 2.5 ppm Air samples that are representative of each employee's average exposure to airborne benzene. TWA: Representative 8- hour TWA employee exposures representing the full shift exposure for each job classification in each work area. STEL: Samples during operations where there is reason to believe exposures are high. The use objective data, such as measurements from brief period measuring devices, can be used to determine where STEL monitoring is needed. Initial monitoring must be conducted within 30 days of the introduction of benzene into the workplace. 28 Same Same ACGIH sets a ceiling limit at 0.3 ppm Full shift personal samples shall be representative of the monitored employee's regular, daily exposure to lead. Representative sample should be of the employee(s) who are exposed to the greatest concentrations of lead. Monitoring for the initial determination may be limited to a representative sample of the exposed employees who the employer reasonably believes are exposed to the greatest airborne concentrations of lead in the workplace. When initial samples are positive (above the AL), at least one sample for each shift for each job classification is required. Where a determination is made that no employee is exposed to airborne concentrations of lead at or above the action level, the employer shall make a written record of such determination. Air samples that are representative of each employee's exposure. TWA: Air samples for at least one employee in each job classification in a work area during every work shift, and the employee sampled is expected to have the highest MC exposure. STEL: The employer has taken one or more samples that indicate the highest likely 15-minute exposures during such operations for at least one employee in each job classification in the work area during every work shift. If documented objective data confirms exposures will not be above PELs initial monitoring is not required. Objective data shall represent the highest exposures likely to occur under reasonably foreseeable conditions Initial monitoring is not required if employees are exposed on fewer than 30 days per year and there is sufficient data, through the use of DRI, to determine exposures and what control measures are necessary. For employees who are, or may reasonably be expected to be exposed to airborne concentrations at or above the TWA/STEL. There must be sufficient exposures within each job classification for each workshift to correctly characterize and not underestimate the exposure of any employee within each exposure group. If documented objective data confirms exposures will not be above PEL initial monitoring is not required. Objective data shall represent the highest exposures likely to occur under reasonably foreseeable conditions)

32 Monitoring Frequency Asbestos (29 CFR ) If AL (or reasonably expected to be) at least every 6 months Cadmium (29 CFR ) If AL at least every 6 months Benzene (29 CFR ) If AL but PEL-TWA at least annually If > PEL-TWA at least every 6 months Monitoring for the STEL shall be repeated as necessary to evaluate exposures of employees subject to short term exposures. Lead (29 CFR ) If AL but PEL-TWA at least every 6 months If PEL-TWA at least quarterly Methylene Chloride (29 CFR ) If < AL but PEL-STEL: monitor STEL quarterly If AL and < PEL-TWA and PEL-STEL: monitor TWA every 6 months If AL and PEL-TWA and > PEL-STEL: monitor TWA every 6 months and STEL quarterly Formaldehyde (29 CFR ) If >AL at least every 6 months If >PEL-STEL monitor at least annually under worst conditions Termination of Monitoring after Positive Result Employee Notification (any monitoring) AF Notification Requirements Additional Notification Requirements if results >PEL Written Program Specific PPE Requirements if >PEL Sampling statistically indicates exposures < PEL-TWA/Excursion Limit 15 working days after receipt of any results: notify each affected employee individually in writing or post in accessible location 2 consecutive samples (at least 7 days apart) below the AL 15 working days after receipt of any results: notify each affected employee individually in writing and post in accessible location 2 consecutive samples (at least 7 days apart) below the AL/PEL-STEL 15 working days after receipt of any results: notify each employee individually in writing or post in accessible location 2 consecutive samples (at least 7 days apart) below the AL 5 working days after receipt of any results: notify each employee in writing of the results that represent that employee's exposure. If > PEL-TWA and PEL-STEL: monitor TWA quarterly 2 consecutive samples (at least 7 days apart) below the AL/PEL-STEL 15 working days after the receipt of any results: notify each affected employee individually in writing, or post in accessible location 2 consecutive samples (at least 7 days apart) below the AL/PEL-STEL 15 days after receipt of any results: notify each affected employee by distributing copies of the results to the employees or by posting the results in accessible location. 15 calendar days 15 calendar days 15 calendar days 5 working days 15 calendar days 15 calendar days Corrective action being taken to reduce exposure below the TWA/EL Include in the written notice a statement that the PEL has been exceeded and corrective action being taken to reduce exposure below the PEL. Corrective action being taken to reduce exposure below the PEL or refer to a document available to employees stating the corrective actions to be taken. Include in the written notice a statement that the PEL has been exceeded and corrective action being taken to reduce exposure below the PEL. Include in the written notice the corrective action being taken to reduce exposures below the PEL/STEL and the schedule for completion of this action. Include in the written notice the corrective action being taken to reduce exposure below the PEL. Where the PEL is exceeded, the employer shall establish and implement a written compliance program to reduce employee exposure to or below the PEL by means of engineering and work practice controls. To the extent that engineering and work practice controls cannot reduce exposures to or below the PEL, the employer shall include in the written compliance program the use of appropriate respiratory protection to achieve compliance with the PEL. At a minimum, RPP, coveralls, gloves, head covering, faceshields At a minimum, RPP, coveralls, gloves, head covering, faceshields None At a minimum, RPP, coveralls, gloves, head covering, faceshields None None 29

33 Additional Info All Chemicals: - Job rotation cannot be used to reduce employee exposures. - Regulated area must be established when exposure levels are > PEL. Appropriate warning signs must be posted. - The employer shall institute engineering controls and work practices to reduce and maintain employee exposure to or below the TWA/EL/STEL except to the extent that such controls are not feasible. Wherever the feasible engineering controls and work practices that can be instituted are not sufficient to reduce employee exposure to or below the PEL, the employer shall use them to reduce employee exposure to the lowest levels achievable by these controls and shall supplement them by the use of respiratory protection. Cadmium: - The requirement to implement engineering and work practice controls to achieve the PEL does not apply where the employer demonstrates the following: the employee is only intermittently exposed; and the employee is not exposed above the PEL on 30 or more days per year. - Written compliance programs shall include at least the following: A description of each operation in which cadmium is emitted; description of the specific means that will be employed to achieve compliance; report of the technology considered in meeting the PEL; air monitoring data that document the sources of cadmium emissions; detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.; work practice program; written plan for emergency situations; other relevant information. - Written compliance programs shall be reviewed and updated at least annually, or more often if necessary, to reflect significant changes in the employer's compliance status. Benzene: - Does not apply to the storage, transportation, distribution, dispensing, sale or use of gasoline, motor fuels, or other fuels containing benzene subsequent to its final discharge from bulk wholesale storage facilities, except that operations where gasoline or motor fuels are dispensed for more than 4 hours per day in an indoor location; storage, transportation, distribution or sale of benzene or liquid mixtures containing more than 0.1 percent benzene in intact containers while sealed in such a manner as to contain benzene vapors or liquid; containers and pipelines carrying mixtures with less than 0.1 percent benzene; work operations where the only exposure to benzene is from liquid mixtures containing 0.5 percent or less of benzene by volume - The employer shall establish a regulated area wherever the airborne concentration of benzene exceeds or can reasonably be expected to exceed the permissible exposure limits, either the 8-hour time weighted average exposure of 1 ppm or the short-term exposure limit of 5 ppm for 15 minutes. - Where the employer can document that benzene is used in a workplace less than a total of 30 days per year, the employer shall use engineering controls, work practice controls or respiratory protection or any combination of these controls to reduce employee exposure to benzene to or below the PELs, except that employers shall use engineering and work practice controls, if feasible, to reduce exposure to or below 10 ppm as an 8-hour TWA. - When it can be documented that one shift consistently has higher exposures, it is only necessary to determine exposures on that particular shift (for the specific operation) - The written program shall include a schedule for development and implementation of the engineering and work practice controls. These plans shall be reviewed and revised as appropriate based on the most recent exposure monitoring data, to reflect the current status of the program. - Per AFOSHSTD 48-8, Atch 3, JP-4 contains <1% benzene and JP-8 <0.1% benzene. Each fuel sample should include an analysis for the benzene component. Lead: - Where any employee is exposed above the PEL for > than 30 days per year, engineering and work practice controls will be implemented (including admin. controls) to reduce and maintain employee exposure to lead, except to the extent that the employer can demonstrate that such controls are not feasible. - Where any employee is exposed to lead > PEL, but for 30 days or less per year, the employer shall implement engineering controls to reduce exposures to 0.2 mg/m 3, but thereafter may implement any combination of engineering, work practice (including admin. controls), and respiratory controls to reduce and maintain employee exposure to lead to or below 0.05 mg/m 3. - Written plans for these compliance programs shall include at least the following: description of each operation in which lead is emitted; description of the specific means that will be employed to achieve compliance; report of the technology considered in meeting the permissible exposure limit; air monitoring data which documents the source of lead emissions; detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.; work practice program; administrative control schedule; other relevant information. - Written programs must be revised every 6 months to update status of program. 30

34 Methylene Chloride: - Personal breathing zone air samples taken during one work shift may be used to represent employee exposures on other work shifts where the employer can document that the tasks performed and conditions in the workplace are similar across shifts. - If it is reasonably foreseeable that employees' skin may contact solutions containing 0.1 percent or greater MC (for example, through splashes, spills or improper work practices), the employer shall provide conveniently located washing facilities capable of removing the MC, and shall ensure that affected employees use these facilities as needed. - If it is reasonably foreseeable that an employee's eyes may contact solutions containing 0.1 percent or greater MC (for example through splashes, spills or improper work practices), the employer shall provide appropriate eyewash facilities within the immediate work area for emergency use, and shall ensure that affected employees use those facilities when necessary. Formaldehyde: - All contact of the eyes and skin with liquids containing 1 percent or more formaldehyde shall be prevented by the use of chemical protective clothing made of material impervious to formaldehyde and the use of other personal protective equipment, such as goggles and face shields, as appropriate to the operation. - Representative samples for each job classification in each work area shall be taken for each shift unless the employer can document with objective data that exposure levels for a given job classification are equivalent for different work shifts. - Where a face shield is worn, chemical safety goggles are also required if there is a danger of formaldehyde reaching the area of the eye. - Full body protection shall be worn for entry into areas where concentrations exceed 100 ppm and for emergency reentry into areas of unknown concentration. - If employees' skin may become splashed with solutions containing 1 percent or greater formaldehyde, for example, because of equipment failure or improper work practices, the employer shall provide conveniently located quick drench showers and assure that affected employees use these facilities immediately. 31

35 Known Carcinogens 4 Carcinogens Aflatoxins 4-Aminobiphenyl Analgesic Mixtures Containing Phenacetin Arsenic Compounds, Inorganic Asbestos Azathioprine Benzene Benzidine (See Benzidine and Dyes Metabolized to Benzidine) Beryllium and Beryllium Compounds 1,3-Butadiene 1,4-Butanediol Dimethylsulfonate (Myleran ) Cadmium and Cadmium Compounds Chlorambucil 1-(2-Chloroethyl)-3-(4-methylcyclohexyl)-1-nitrosourea (MeCCNU) bis(chloromethyl) Ether and Technical-Grade Chloromethyl Methyl Ether Chromium Hexavalent Compounds Coal Tar Pitches Coal Tars Coke Oven Emissions Cyclophosphamide Cyclosporin A (Ciclosporin) Diethylstilbestrol Dyes Metabolized to Benzidine Erionite Ethylene Oxide Melphalan Methoxsalen with Ultraviolet A Therapy (PUVA) Mineral Oils (Untreated and Mildly Treated) Mustard Gas 2-Naphthylamine Nickel Compounds Radon Silica, Crystalline (Respirable Size) Solar Radiation Soots Strong Inorganic Acid Mists Containing Sulfuric Acid Tamoxifen 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD); Dioxin Thiotepa 231 Thorium Dioxide Vinyl Chloride Wood Dust 32

36 Reasonably Anticipated to be a Human Carcinogen Acetaldehyde 2-Acetylaminofluorene Acrylamide Acrylonitrile Adriamycin (Doxorubicin Hydrochloride) 2-Aminoanthraquinone o-aminoazotoluene 1-Amino-2-methylanthraquinone 2-Amino-3-methylimidazo[4,5-f]quinoline (IQ) Amitrole o-anisidine Hydrochloride Azacitidine (5-Azacytidine, 5-AzaC) Benz[a]anthracene Benzo[b]fluoranthene Benzo[j]fluoranthene Benzo[k]fluoranthene Benzo[a]pyrene Benzotrichloride Bromodichloromethane 2,2-bis-(Bromoethyl)-1,3-propanediol (Technical Grade) Butylated Hydroxyanisole (BHA) Carbon Tetrachloride Ceramic Fibers (Respirable Size) Chloramphenicol Chlorendic Acid Chlorinated Paraffins (C12, 60% Chlorine) 1-(2-Chloroethyl)-3-cyclohexyl-1-nitrosourea bis(chloroethyl) nitrosourea Chloroform 3-Chloro-2-methylpropene 4-Chloro-o-phenylenediamine Chloroprene p-chloro-o-toluidine and p-chloro-o-toluidine Hydrochloride Chlorozotocin C.I. Basic Red 9 Monohydrochloride Cisplatin p-cresidine Cupferron Dacarbazine Danthron (1,8-Dihydroxyanthraquinone) 2,4-Diaminoanisole Sulfate 2,4-Diaminotoluene Dibenz[a,h]acridine Dibenz[a,j]acridine 33

37 Reasonably Anticipated to be a Human Carcinogen (continued) Dibenz[a,h]anthracene 7H-Dibenzo[c,g]carbazole Dibenzo[a,e]pyrene Dibenzo[a,h]pyrene Dibenzo[a,i]pyrene Dibenzo[a,l]pyrene 1,2-Dibromo-3-chloropropane 1,2-Dibromoethane (Ethylene Dibromide) 2,3-Dibromo-1-propanol tris(2,3-dibromopropyl) Phosphate 1,4-Dichlorobenzene 3,3 -Dichlorobenzidine and 3,3 -Dichlorobenzidine Dihydrochloride Dichlorodiphenyltrichloroethane (DDT) 1,2-Dichloroethane (Ethylene Dichloride) Dichloromethane (Methylene Chloride) 1,3-Dichloropropene (Technical Grade) Diepoxybutane Diesel Exhaust Particulates Diethyl Sulfate Diglycidyl Resorcinol Ether 3,3 -Dimethoxybenzidine 4-Dimethylaminoazobenzene 3,3 -Dimethylbenzidine Dimethylcarbamoyl Chloride 1,1-Dimethylhydrazine Dimethyl Sulfate Dimethylvinyl Chloride 1,6-Dinitropyrene 1,8-Dinitropyrene 1,4-Dioxane Disperse Blue 1 Dyes Metabolized to 3,3 -Dimethoxybenzidine Dyes Metabolized to 3,3 -Dimethylbenzidine Epichlorohydrin Ethylene Thiourea di(2-ethylhexyl) Phthalate Ethyl Methanesulfonate Formaldehyde (Gas) Furan Glasswool (Respirable Size) Glycidol Hexachlorobenzene Hexachlorocyclohexane Isomoers Hexachloroethane 34

38 Reasonably Anticipated to be a Human Carcinogen (continued) Hexamethylphosphoramide Hydrazine and Hydrazine Sulfate Hydrazobenzene Indeno[1,2,3-cd]pyrene Iron Dextran Complex Isoprene Kepone (Chlordecone) Lead Acetate Lead Phosphate Lindane and Other Hexachlorocyclohexane Isomers 2-Methylaziridine (Propylenimine) 5-Methylchrysene 4,4 -Methylenebis(2-chloroaniline) 4-4 -Methylenebis(N,N-dimethyl)benzenamine 4,4 -Methylenedianiline and 4,4 -Methylenedianiline Dihydrochloride Methyleugenol Methyl Methanesulfonate N-Methyl-N -nitro-n-nitrosoguanidine Metronidazole Michler s Ketone [4,4 -(Dimethylamino)benzophenone] Mirex Nickel (Metallic) Nitrilotriacetic Acid o-nitroanisole 6-Nitrochrysene Nitrofen (2,4-Dichlorophenyl-p-nitrophenyl ether) Nitrogen Mustard Hydrochloride 2-Nitropropane 1-Nitropyrene 4-Nitropyrene N-Nitrosodi-n-butylamine N-Nitrosodiethanolamine N-Nitrosodiethylamine N-Nitrosodimethylamine N-Nitrosodi-n-propylamine N-Nitroso-N-ethylurea 4-(N-Nitrosomethylamino)-1-(3-pyridyl)-1-butanone N-Nitroso-N-methylurea N-Nitrosomethylvinylamine N-Nitrosomorpholine N-Nitrosonornicotine N-Nitrosopiperidine N-Nitrosopyrrolidine N-Nitrososarcosine 35

39 Reasonably Anticipated to be a Human Carcinogen (continued) Norethisterone Ochratoxin A 4,4 -Oxydianiline Oxymetholone Phenacetin Phenazopyridine Hydrochloride Phenolphthalein Phenoxybenzamine Hydrochloride Phenytoin Polybrominated Biphenyls (PBBs) Polychlorinated Biphenyls (PCBs) Polycyclic Aromatic Hydrocarbons (PAHs) Procarbazine Hydrochloride Progesterone 1,3-Propane Sultone β-propiolactone Propylene Oxide Propylthiouracil Reserpine Safrole Selenium Sulfide Streptozotocin Styrene-7,8-oxide Sulfallate Tetrachloroethylene (Perchloroethylene) Tetrafluoroethylene Tetranitromethane Thioacetamide Thiourea Toluene Diisocyanate o-toluidine and o-toluidine Hydrochloride Toxaphene Trichloroethylene 2,4,6-Trichlorophenol 1,2,3-Trichloropropane Urethane Vinyl Bromide 4-Vinyl-1-cyclohexene Diepoxide Vinyl Fluoride 36

40 5 OSHA-Listed Known Carcinogens with no OEL 4-Nitrobiphenyl 29 CFR Alpha-Naphthylamine 29 CFR Methyl chloromethyl ether 29 CFR ,3 -Dichlorobenzidine 29 CFR Bis-chloromethyl ether 29 CFR Beta-Naphthylamine 29 CFR Benzidine 29 CFR Aminodiphenyl 29 CFR Ethyleneimine 29 CFR Beta-Propiolactone 29 CFR Acetylaminofluorene 29 CFR Dimethylaminoazobenzene 29 CFR N-Nitrosodimethylamine 29 CFR

41 6 Specifically Regulated Chemicals SHOP Expanded Standard Task Task Chemical Fuels Bulk Storage Benzene Fuel Operations The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Remove this shop from the list once a document stating the above is present in the casefile in some form. Fuel Distribution Benzene Fuel Operations The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Remove this shop from the list once a document stating the above is present in the casefile in some form. Fuels Laboratory Benzene Fuel Operations The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Remove this shop from the list once a document stating the above is present in the casefile in some form. Dental Clinic Methylene Chloride Adhesive Methylene chloride was present in Zap-It -- an adhesive used by the dental clinic that was removed from their inventory in Remove from your records. Dental Clinic Formaldehyde Sample Preservation Shop utilizes pre-packaged preservation sollution containing formaldehyde. Minimal amounts are used and the most recent AF Form 2755 states that it isn't a significant hazard. I would recommend a more formal process evaluation since this is an expanded standard chemical and of high interest. Medical Laboratory Formaldehyde Sample Preservation Formalin (10% formaldehyde) is used in three different sample procedures that pass through the lab. In all three cases, the formalin is already present in a container, the sample is added, and then the container is sealed. The sealed container may sit in the laboratory for a few days before it is shipped out to another facility for analysis. The three tests are fecal OVA, tissue sample, and PAP. In every case, the sample is added to the container by either the patient or a provider -- the lab never actually deals with containers that are opened. This information is adequate to prepare a negative exposure document for formaldehyde usage in the laboratory. Vet Clinic Formaldehyde Sample Preservation Formalin (10% formaldehyde) is used as a specimen preservative for biopsies performed during animal surgeries. There is a hazard assessment stating that the risk of exposure is low due to the short duration the sample container is opened and the limited number of samples collected. No air sampling has been accomplished. Suggest that a formal negative exposure document be prepared for formaldehyde. Biomedical Maint. Lead Lead Solder Lead is present is solder. Task assessment in casefile states that lead will not become airborne due to low temperature involved in soldering. This is adequate for a negative exposure assessment. Auto Hobby Shop Asbestos Brake Pads There are two sources for potential asbestos exposure -- the first is when the shop manager does brake pad changes on Services Squadron fleet vehicles and there is a potential for those pads to have asbestos in them. Currently, he takes no special precautions. The second involves disposal - - all brake pads, whether from Services vehicles or from customers cars are collected in a bin and occasionally the shop manager double bags them up and arranges for disposal through CEV. Due to infrequency of these tasks and limited potential for contact with friable asbestos, you can create a negative exposure assessment for both of these tasks. 38

42 SHOP Expanded Standard Task Task Chemical Auto Hobby Shop Methylene Chloride Tire Repair Cement Methylene chloride is present in the Universal Cement (Balkamp ) used for tire repair. This product is only used by shop personnel. The top has a brush in the cap that is used to spread the cement on the tire. Recommend that a negative exposure assessment be completed for this based upon limited usage, limited amount, and plenty of natural dilution ventilation. Golf Course Maint. Arsenic Pesticide Application Shop uses several pesticides to control insects and weed growth on the golf course. None of the exposures have ever been evaluated with air sampling, even though some products have exposure limits below 1.0 mg/m 3. These processes need to be fully identified in the casefile and air sampled. Liquid Fuels Benzene Fuel Operations The presence of benzene in JP-8 is at a level specifically exempted by the OSHA standard. Additionally, tasks involving fuel are specfically exempted under the OSHA standard. This file has a mistake with regard to benzene sampling wherein a JP-8 sample result was applied to the benzene standard, thus showing an exceedance of the OEL. Several follow-up actions were taken over a two and a half year period due to this. A memo for record needs to be generated and placed in the casefile that explains this issue and clears it up. Liquid Fuels Lead N/A There is no information in the casefile with regard to the potential source of this exposure. The shop is unaware of any processes that involve a potential exposure to lead. Recommend that you remove from your records. Power Pro Benzene Fuel Operations A review of the casefile revealed that the potential benzene exposure was associated with filling generators with unleaded fuel. This is a specifically exempted task and does not apply under the benzene standard. Recommend that you document this and remove it from your records. Det 5 Power Pro Benzene N/A A review of the casefile revealed that there is no benzene exposure in this shop. Remove from your records. Zone 1 Asbestos Asbestos Tile Removal Asbestos process is adequately characterized -- no action required. Combat Arms Lead Weapons Firing Potential lead exposure from weapons firing. Most recent sampling took place in August 2000 with exposures at roughly 20% of the OEL. A conversation with the shop seems to indicate that operation temp has increased since then, but weapons have not changed. The single sample is adequate to satisfy the lead standard, but I would watch this carefully and consider another sample since almost five years have passed since the last one. Structural Maint Cadmium/Lead Bead Blasting An enclosed bead blasting booth is used to remove rust from parts. It has been out of service since November 2003 and there is no projection on when it will be repaired. Samples for lead and cadmium were collected in August 2002 with both being well below the action level. Samples for strontium chromate were also collected and it has been reported that they were above the OEL. The sampling was not done properly, so these results are suspect. A second cadmium sample is necessary to complete the OSHA requirements, but it can't be collected until the booth is fixed. No action at this time. Structural Maint Cadmium/Lead Sanding Personnel use pneumatic sanders to prep equipment for painting. A cadmium sample collected in 2002 indicated exposures above the AL, but none of the supporting documentation is available for verification. In any case, BES established a regulated area based upon this and completed a follow-up sample in August This sample was well below the AL for both lead and cadmium. This is adequate for a negative exposure assessment for lead. In order to meet OSHA requirements, the cadmium process every six months until two consecutive samples show results below the AL. Therefore, to meet OSHA regulations, sampling should have been completed in February This must be done immediately. At the same time, proper sampling for chromates should be performed since there are no correct samples in the casefile at this time. 39

43 SHOP Expanded Standard Task Task Chemical Sortie Support Lead Lead Solder Process has been adequately assessed and negative exposure documents are present. No further action necessary. Vertical Benzene Fuel Operations According to the casefile, benzene exposure is possible because workers occasionally weld on lines containing JP-8 fuel and they could be exposed to fuel vapors. I think I would be worried a lot more about the explosion from the welding torch lighting the vapors. Before this type of welding can be accomplished, the line has to be completely empty and allowed to ventilate. The fire department would never issue a permit without it. Recommend that this be removed from the casefile. Vertical Asbestos Roofing Cement Roofing cement used by shop contains asbestos. This product is of limited hazard since the asbestos is bound in a adhesive matrix that is applied wet. However, since it is an expanded standard chemical, an evaluation is necessary. Recommend that a negative exposure assessment be created using wet application justification. Vertical Formaldehyde Painting Present in paints used by shop. Air sampling has been recommended, but never accomplished. Recommend that painting operation with formaldehyde-containing paint be sampled. AGE Cadmium/Lead See Structural Maintenance The AGE shop performs the same tasks in the same location as Structural Maintenance so the evaluations above apply. Recommend that the casefile clearly reflect this. AGE Asbetos N/A The task involving asbestos has been removed -- no further action required. AGE Lead/ Methylene Chloride Solid Film Lubricant Lead and methylene chloride are present in a solid film lubricant used by the shop. This has never been evaluated. Typical usage of these products is minimal, so a negative exposure assessment would normally be adequate. However, the lead standard does not allow for a negative exposure assessment without at least one air sample. Therefore, if the shop is going to continue to use this product, air sampling is necessary. PMEL Lead N/A Shop is contract -- no lead issue -- remove from listing. NDI Lead Calibration Oil Lead is present in some of the oils used by this shop. Air sampling has never been accomplished while using this product. Verify that these oils are still used. If so, at least one air sample is necessary for a negative exposure assessment. NDI Benzene/ Methylene Chloride Calibration Oil Benzene and methylene chloride are present in some of the oils used by this shop. An exposure assessment has never been completed for these items. Verify that these oils are still used. If so, complete a negative exposure assessment using the extremely small percentages of the chemicals in the oils, the limited amount of oil used, and the infrequency of the process. Conventional Maint. Lead Stencil Ink Shop has marking stencil ink containing lead. This process has not been fully evaluated or sample. Recommend that a process assessment be completed and air sampling for lead by accomplished. Conventional Maint. Lead/Cadmium Sanding Shop survey in May 2003 indicated that shop refurbishes munitions. There are several recommendations that this process be sampled as it involves sanding and painting. This process needs to be verified to determine if it is much like what is happening with the AGE shop and their equipment. Recommend that this task be carefully evaluated and a common approach be developed for any shop peforming this type of work. 40

44 SHOP Expanded Standard Task Task Chemical Armament Lead Sealing Compound Lead is present in a sealing compound. The process involving this product has not been fully evaluated and no air sampling has been completed. Recommend that the use of this product be fully explored and air sampling be conducted. Armament Methylene Chloride Solid Film Lubricant Methylene chloride is present in solid film lubricant used by this shop. The usage of this product has never been evaluated. Based upon experience, this item is typically used in small amounts and infrequently. Recommend that a negative exposure assessment be developed if the product is still in use. Munitions Inspections Methylene Chloride Liquid Rubber Adhesive Methylene chloride is present in liquid rubber adhesive used by this shop. The usage of this product has never been evaluated. Based upon experience, this item is typically used in small amounts and infrequently. Recommend that a negative exposure assessment be developed if the product is still in use. Fuel Cell Repair Benzene N/A Shop is only active when personnel deploy -- remove from list. Munitions Supt Eq. Asbestos Brake Pads According to the most recent AF Form 2755, asbestos is present in brake pads on the bomb carriers and munitions trailers. The pads are removed using the wet method. Air sampling has not been accomplished. As long as the wet method is used, a negative exposure assessment can be generated for this task. Recommend that the process be verified and a negative exposure assessment be generated. Munitions Supt Eq. Methylene Chloride N/A Product which contained methylene chloride has been removed from shop -- remove from list. Munitions Supt Eq. Lead/Cadmium Bench Grinding Lead and cadmium has been sampled while workers grind parts using a bench grinder. Both samples were well below the AL. No further samples are necessary for lead, but a second sample for cadmium must be collected if this process is still occurring. Verify that this process is still active and schedule cadmium sampling if necessary. Munitions Supt Eq. Lead/Cadmium Sanding Shop survey in August 2003 indicated that shop refurbishes munitions support equipment. There are several recommendations that this process be sampled as it involves sanding, blasting and painting. A recent entry on the AF Form 2754 states that sanding is no longer accomplished. The true process needs to be clarified and sampling accomplished for lead and cadmium if necessary. Missile Maint. Lead/Cadmium Sanding Shop has not been visited in a long time and BES recently moved it to Category 1. Additionally, when the surveillance frequency was changed, a promise was made that a shop survey would be performed in March Recommend that shop survey is accomplished as promised. Bomb Renovation Cadmium/Lead N/A Shop is wartime only -- remove from list. Chemical can be removed from expanded standards inventory. Chemical must remain on inventory, but negative exposure assessment will adequately address OSHA requirements. Chemical must be evaluated soon -- significant potential for exposure. 41

45 7 Substance Specific Regulated Area Requirements 29 CFR 1910 Regulated Area Requirements 8hr TWA- PEL Excursion Limit (30min exposure) Short Term Exposure Limit STEL (15min exposure) Carcinogens 1 4 Nitrobiphenyl YES alpha-naphthylamine YES methyl chloromethyl ether NO 3,2-Dichlorobenzidine (and its salts) YES bis-chloromethyl ether NO beta-naphthylamine YES Benzidine YES 4 Aminodiphenyl YES Ethyleneimine NO beta-propiolactone NO 2 Acetylaminofluorene YES 4 Dimethylaminoazo-benzene YES n-nitrosodimethylamine YES 1017 Vinyl chloride 1 ppm 5 ppm YES 1018 Inorganic arsenic 10 µg/m 3 NO 1027 Cadmium 5 µg/m 3 NO 1028 Benzene 1 ppm 5 ppm NO ,2-dibromo-3-chloropropane 1 ppb YES 1045 Acrylonitrile 2 ppm 10 ppm YES 1047 Ethylene oxide 1 ppm 5 ppm YES 1048 Formaldehyde ppm YES ppm 1050 Methylenedianiline 10 ppb 100 ppb YES ,3-Butadiene 1 ppm 5 ppm NO 1052 Methylene Chloride 25 ppm 125 ppm NO 60 Methylenedianiline 10 ppb 100 ppb YES No Contact Requirement? 1101 Asbestos (Class I, II, and III NO work) fiber/cm 3 fiber/cm Vinyl chloride 5 µg/m 3 NO 2 1 The 13 carcinogens listed are prohibited from use in Open-vessel system Operations. 2 Vinyl chloride is specified in 29 CFR as a contact required regulated area. 42