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OSHA Really Doesn’t Like These Chemicals

We get a lot of inquiries for indoor air quality (IAQ) testing, often referred to industrial hygiene monitoring. IAQ is performed for a variety of reasons; either an enforcement action, an employee complaint, the promulgation of a new rule, or a responsible employer doing their due diligence.

Our IAQ experience travels and provides us the opportunity to see new industrial settings and processes. We’ve conducted monitoring in welding shops, label manufacturers, sign makers, refrigerator manufacturers, and even a secondary aluminum foundry. One of the more interesting settings we’ve been in is a firearms store with an indoor shooting range. There’s a long history of outdoorsman in my family, but this place was a little bit different. The first thing you’d notice when you walk through the door is that every employee was armed with a holstered pistol. Most employees were ex-police or ex-military, so they were quite comfortable.

The owner of the shooting range had a concern for his employee’s exposure of lead. He asked us to do the monitoring on the day that the bullet trap at the end of the shooting range was to be emptied. I’ve come to learn that there are several excellent designs for bullet traps, but this one was not one of them. At the back of the range, the floor and ceiling started sloping towards each other at shallow angles until they finally converged. The lead bullets (steel bullets were not allowed at this range due to the damage they would do to the bullet trap) ricocheted off floor and ceiling until the shattered remains of the bullet reached the back of the trap, whereby the lead fell by gravity into one of many five gallon pails lined up across the back of the trap.

The procedure for emptying the pails was to manually empty each pail into a 55-gallon drum. When full, the drum would be sent off-site for recycling/disposal. The employee was equipped with a hooded Tyvek-type suit, booties, gloves and a full-face respirator (APF = 50) and was quite careful during this procedure. Still, there was a cloud of lead that could be seen above the drum each time a pail was emptied (we watched through the door from outside). The procedure took less than fifteen minutes. Results of the monitoring showed that the employee was not overexposed to lead when considering the full-face respirator. We also monitored several other employees but none of those samples had a detectable amount of lead.

Although monitoring showed that the employee was not overexposed, OSHA takes a dim view of lead in general. Lead is one of the materials for which OSHA has promulgated a specific standard. Chemicals and elements with their own OSHA standard include:

  • Acrylonitrile;

  • Arsenic;

  • Asbestos;

  • Benzene;

  • Beryllium;

  • 1,3-Butadiene;

  • Cadmium;

  • Crystalline Silica;

  • Ethylene Oxide;

  • Formaldehyde;

  • Hexavalent Chromium;

  • Lead;

  • Methylene Chloride;

  • Methylenedianiline (MDA);

  • Vinyl chloride; and

  • Thirteen different carcinogenic compounds.

Each rule is a unique, but they do have quite a bit of overlap in terms of requirements. For example, the lead standard has requirements for biological monitoring (blood testing), repeated exposure monitoring, medical removal, hygiene facilities and training.

These standards have extremely low exposure limits (lead has a TWA of 50 µg/m3) and also have an “action level” — which is a level of exposure, while not over the limit, is close enough whereby many program elements are still applicable (usually 50% of the TWA).

The message here is to check to see whether any of these materials are being used at your facility. It’s recommended to determine the employee exposure as required by the standard and create a compliance program. Don’t’ wait for an inspection as it’s much easier to do this without the scrutiny and tight deadlines of an OSHA inspector.

CFR has been conducting indoor air testing for over 20 years. Please contact CFR to learn how we can assist in your industrial hygiene monitoring requirements.

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