SAFETY SOLUTIONS:In-Plant Air Monitoring & Analysis

Every business owner should be aware that there are stringent OSHA standards limiting Air Contaminants: hazardous substances that are found in the workplace and represent a danger to the health and welfare of workers.

OSHA regulations that require employers to control employee exposure to air contaminants are covered in Subpart Z. The first section, 1910.1000, lists the permissible exposure limits for over 500 air contaminants and the priority of control methods to be used. Each of the remaining sections deals at length with one specific substance. The substances regulated, however, represent only a small percentage of those identified as health hazards. Employers must keep track of all chemicals in the workplace and look for any information on health affects that could be caused by any of the substances in use.

OSHA has a standardized form, the Material Safety Data Sheet, which is useful as a fact sheet on the properties and potential hazards of a chemical. Employers can assess the risks of using any chemical by compiling the information called for on this form. It covers chemical composition and specific information on health hazards, reactions that may allow the formation of hazardous by-products, correct protective equipment and procedures for handling spills, leaks and emergencies.

OSHA regulations for air contaminants require that employers identify the foreign substance present, obtain accurate, reliable measurements that actually reflect employee exposures, design and install engineering systems that can control emissions, monitor contaminant concentrations and choose effective respiratory protection.

OSHA’s air contaminants standard sets Permissible Exposure Limits (PELs) and provides other information such as ceiling values and eight-hour-time-weighted averages. The standard (1910.1000) also contains three tables, Z-1, Z-2 and Z-3 that provide air contaminant limits.

Compliance Measures

To achieve compliance within safe limits, you must first develop feasible administrative and engineering controls. Then, if necessary, use protective equipment or other protective measures to keep the exposure of employees within prescribed limits. Any such equipment or technical measures must be approved for each specific use by a competent industrial hygienist or other technically qualified person. Any respirators used much comply with 1910.134.

Are carcinogens present in your workplace? OSHA has identified the following 13 substances as carcinogens, some that may be used in the plastic industry, and set regulatory standards regarding their manufacture, use and storage: 4-Nitrobiphenyl, alpha-Naphthylamine, methyl chloromethyl ether, 3,3’-Dichlorobenzidine (and its salts), bis-Chloromethyl Ether, beta-Naphthylamine, Benzidine, 4-Aminodiphenyl, Ethyleneimine, beta-Propiolactone, 2-Acetylaminofluorent, 4-Dimethylaminoazo-benzene or N-Nitrosodimethylamine.

Commonly in use in our industry are Trichloroethylene, methyl ethelketone (MEEK) and tetrahydroferon, which are not considered carcinogens, and methylene chloride, which OSHA calls a potential workplace carcinogen. There are specific recommendations for handling these materials, including the use of protective clothing and eyewear, working in vented areas and with respirators when necessary, proper storage of open materials, such as fire-resistant cabinetry, monitoring expiration dates and proper disposal of old and unneeded materials. You can obtain specific information on the safe use and exposure to these substances from the OSHA web site: www.osha.gov.

There are very stringent regulations and requirements for areas containing carcinogens and recommendations for exposure to non-carcinogenic substances. Regulation areas must be established for all workplaces within the scope of these standards, and controls must be set up as required. Employees must wash their hands, forearms, face and neck upon each exit from the regulated area, close to the point of exit and before other activities. (Note: This wash-up requirement does not apply to methyl chloromethyl ether, bis-chloromethyl ether, Ethyleneimine and beta-Propiolactone.)

Personal protective equipment requirements can be found on the OSHA web site, in particular the requirement for respirators. Please check further under 1910.134 if you have specific questions.

In the event of a leak or spill, any maintenance and decontamination activities that may expose the employee to a carcinogen should be handled as follows: Authorized employees entering the area must wear clean, impervious garments including gloves, boots and continuous-air supplied hood as required by 1910.134; be decontaminated before removing the protective garments and hood and are also required to shower upon removing them.

In emergencies, these and any other appropriate measures must be taken immediately;:

• Evacuate the potentially affected area; eliminate the hazardous conditions and decontaminate the potentially affected area before resuming normal operations.
• Institute, within 24 hours, special medical surveillance by a physician for employees present in the affected area, and include any medical surveillance and treatment in the incident report required.
• Require any employee who has contact with the carcinogen to shower as soon as possible, unless physical injuries prevent it.
• Deluge showers and eyewash fountains with running potable water near, within sight of, and on the same level with, places where direct exposure to the carcinogen would be most likely because of equipment failure or poor work practices.
• Storage or consumption of food, and storage or use of beverage containers, cosmetics or smoking materials, tobacco products or chewing products are prohibited in regulated areas.

Contamination Control

Except for outdoor systems, regulated areas must have negative pressures in relation to non-regulated areas. Local exhaust ventilation may be used for this purpose and an equal volume of clean makeup air must replace air removed.

Movement of any equipment, material, etc., to or from a regulated area must not cause contamination in non-regulated areas or the external environment.

Establish and implement decontamination procedures to remove the carcinogen from surfaces of materials, equipment and the decontamination facility.

Dry sweeping and dry mopping are prohibited. (Note: they are permitted for regulated areas that involve methyl chloromethyl ether, bis-chloromethyl ether, Ethyleneimine and beta-Propiolactone.)

Remember all regulated work areas must be posted with signs that read:

Cancer-Suspect Agent – Authorized Personnel Only. At entrances to regulated areas where maintenance or decontamination operations are being carried out, post signs that are worded: Cancer-Suspect Agent; Exposed in this area impervious suit including gloves, boots and air-supplied hood – required at all times. Authorized Personnel Only.

Prior planning for a possible contamination from a car-cinogen may just save a life, yours or one of your employees. No one likes to think this could happen in their facility, but it could, it does and will continue to do so, please take heed and be prepared.

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