GFM_Ultrasonic_Cutter_IH_Survey.pdf

DEPARTMENT OF THE AIR FORCE

75TH AEROSPACE MEDICINE SQUADRON (AFMC)

HILL AIR FORCE BASE, UTAH

5 March 2012

MEMORANDUM FOR 533 CMMXS/ MXDPA

FROM: 75 AMDS/SGPB

SUBJECT: Industrial Hygiene Assessment, Advanced Composites/LADS Shop, Building 238, PEGs: 238Q1 and 238Q5

1. Attached is the 75 AMDS Bioenvironmental Engineering (BE) Industrial Hygiene

Assessment for your shop. This assessment was done on 9 February 2012 by Chris Hoefelmeier and SrA Chris Heil. An opening conference was conducted with Chad Mather and Merrill

Butler. AFGE was contacted 7 February 2012. This assessment was accomplished in accordance with AFI 48-145, Occupational and Environmental Health Program.

2. Your shop is not in compliance with Air Force and Federal regulations:

a. The B-2 Downdraft Paint Booth, PM #9465, ventilation system did not meet the 100 fpm flow rate criteria (ACGIH ventilation recommendations, see Attachment 5); therefore, needs maintenance. This booth cannot be used until repaired.

b. ESOHCAMP tier 1 checklists for occupational health related items were provided to this shop in February 2011. These checklists have been reviewed in the past year, however, it was not clear when the quarterly reviews were conducted; therefore, a more centralized documentation and tracking system is needed. Due to these tracking issues, it was not clear if checklist findings were being tracked and fixed by the supervisors.

3. Your workplace has been identified as a Category 1 shop, which is defined as a high risk workplace. Your shop will be surveyed annually. In accordance with AFI 91-202, The US Air

Force Mishap Prevention Program, 5 August 2011, supervisors must brief all personnel of the findings and recommendations in this report and post it in the work area for a minimum of ten days. This report must be kept on file for two years. Make this report available to new personnel as a part of their initial workplace safety briefing. When you have changes in personnel, it is your responsibility to inform Kathleen Biegenwald by fax at 777-1050 or e-mail at Kathleen.Biegenwald@hill.af.mil.

4. Thank you for your help in conducting this assessment. Please contact Chris Hoefelmeier or

SrA Chris Heil at 777-4551 or e-mail at chris.hoefelmeier@hill.af.mil or christopher.heil@hill.af.mil if your work conditions change or if you have any questions regarding occupational health matters. OSHA Standard 29 CFR 1910.1020, Access to Employee

Exposure and Medical Records, requires that employees receive an annual briefing on the availability of medical and exposure records. A signed copy of this report and all other mailto:Kathleen.Turner@hill.af.mil mailto:chris.hoefelmeier@hill.af.mil mailto:christopher.heil@hill.af.mil applicable industrial hygiene data is maintained in our office, Building 249, and is available for your review. Medical records for civilians are located in the Occupational Health Clinic, Building 249. Military medical records are located in the main clinic, Building 570.

3/7/2012

X

CARY FISHER, GS-13, DAF

Industrial Hygiene Supervisor

Attachments:

1. Response to Recommendations

2. Industrial Hygiene Assessment

3. Certified PPE Listing

4. Hazardous Noise Assessment Data

5. Ventilation Survey Results

6. Fetal Protection Information

7. Specific OSHA Standard Training Information (Chromium VI)

8. Regulated Area Sign

9. Eyewash Stations

10. Air Sampling Results Information cc:

75 ABW/SEG - Ron James

75 AMDS/SGPM - Jolene Garner

OO-ALC/AFGE – William Boyd

309 MXW/CL

309 MXW/SE – Kerry Miller/Tim Helms

533 CMMXS/CL

309 CMXG/CL - Rick Buhl

309 CMXG/ENV- Guy Whalen

309 CMXG/EN – Allan Cooley

309 CMXG/OB – Shayla Gilbert

9 February 2012

Attachment 1

RESPONSE TO FINDINGS AND RECOMMENDATIONS

Recommended actions for 533 CMMXS/ MXDPA, Advanced Composites/LADS Shop, Building 238, PEGs: 238Q1 and 238Q5

RETURN THIS SHEET TO 75 AMDS/SGPB NLT 6 April 2012

FINDINGS AND RECOMMENDATIONS ACTION TAKEN

The B-2 Downdraft Paint Booth, PM #9465, ventilation system did not meet the 100 fpm flow rate criteria (ACGIH ventilation recommendations, see Attachment 5); therefore, needs maintenance.

ESOHCAMP tier 1 checklists for occupational health related items were provided to this shop in

February 2011. These checklists have been reviewed in the past year; however, it was not clear when the quarterly reviews were conducted;

therefore, a more centralized documentation and tracking system is needed. Due to these tracking issues, it was not clear if checklist findings were being tracked and fixed by the supervisors.

9 February 2012

Attachment 2

Industrial Hygiene Assessment

1. Use of Engineering Controls: OSHA requires hazards be abated with the use of engineering and administrative controls where feasible. Personal protective equipment, such as respirators, is considered an interim solution. Air sampling (see attachment 11) has shown that your engineering and administrative controls are not controlling worker exposures below allowable exposure levels in your large sanding booth, even though that ventilation system is properly performing as designed. An abatement package that includes the use of Clayton vacuum sanders is being submitted to OSHA. Engineering needs to review other processes in these shops where workers are required to wear PPE to determine if additional administrative or engineering controls are available or feasible.

2. Personal Protective Equipment (PPE): Attachment 3 lists the tasks that were evaluated for health hazards, PPE use and effectiveness and the limitations of existing PPE during our survey. This serves as the PPE certification required by AFOSH Std 91-501. If there are changes to any of the activities discussed during this survey, (including but not limited to changes in frequency, exposure time, application method, chemicals, or process re-design) the supervisor must notify our office so we can re-evaluate the potential health risks and PPE requirements.

3. Occupational Safety and Health Administration (OSHA) Expanded Standard Chemicals: The following OSHA expanded standard chemicals are used in this shop. Listed below are the specific chemicals and references to attachments regarding training, change rooms, laundry requirements, personal hygiene and break room areas.

a. Hexavalent Chrome (Chrome VI) (29 CFR 1910.1026): Hexavalent chrome is considered a suspect carcinogen. Personnel in this shop work with materials containing hexavalent chrome. Some of these materials are strontium chromate (yellow or green primer paints) or alodine conversion coatings. We have air sampled these processes. We have determined that your workers come under the requirements of this standard, based on the results of sampling or potential for exposure.

b. Methylenedianiline (29 CFR 1910.1050): Personnel assigned to PEG 238Q1 prepare patches from

Methylenedianiline (MDA) impregnated carbon fiber material sheets. MDA is absorbed through the intact skin and lung tissue. Long term moderate exposure through skin contact or by inhalation may lead to liver damage. Several animal studies suggest that MDA may also be associated with bladder cancer.

The patches are cut by hand from the sheets and sized to fit areas of the B-2 parts being repaired. This activity only creates a potential MDA skin absorption hazard since the MDA is a solid coating on the carbon fibers. When working with or handling the pre-impregnated carbon fiber sheets the appropriate protective coveralls and polyethylene gloves must be worn.

4. ESOHCAMP Tier 1 Checklists (AFI 90-803): In accordance with AFI 90-803, we provided you with your quarterly ESOHCAMP tier 1 checklists for occupational health items in February 2011. These checklists have been reviewed in the past year; however, it was not clear when the quarterly reviews were conducted; therefore, a more centralized documentation and tracking system is needed. Due to these tracking issues, it was not clear if checklist findings were being tracked and fixed by the supervisors.

5. Respiratory Protection Program (RPP)(AFOSH Std 48-137):

a. Respiratory protection must be worn during specific activities listed in attachment 3. Respirators are authorized only during those activities. A shop specific respirator operating instruction and shop specific worker training will be provided NLT 10 Mar. Supervisors are required to provide the respirator training to any employees not trained on this date. This training is required to be documented on the workers’ AF

Form 55/equivalent.

b. Supervisors of shops using respirators are required to attend Course 1767, Respiratory Protection

Training for Supervisors. Supervisors have attended this training. This course is taught monthly by BE;

contact your training monitor for specific training dates.

c. Respirators used under this program must be certified by the National Institute for Occupational

Safety and Health (NIOSH). Certification numbers are prefixed with the letters TC (Test Certification) followed by numerical sequence. BE must approve any additional respirators used prior to purchase;

workers may require re-fit testing. Call us whenever you are considering a new respirator or alternate cartridges.

d. Workers wearing respirators must be fit tested on an annual basis. Your employees will be contacted by Occupational Medicine Services to schedule their annual fit test. New workers must be fit tested prior to wearing a respirator; that fit test can be scheduled by calling Courtney Thornsbury, 775-

2719. Workers who do not pass their fit test may not perform tasks requiring respiratory protection.

e. The Air Force does not require workers who wish to use disposable respirators for comfort purposes to be fit tested. The use of disposable respirators does need to be approved by BE; supervisors must train workers on the limitations of these respirators and the training must be documented on the AF

Form 55/equivalent. Workers in this shop use disposable respirators during cutting of composites with power saws.

6. Noise (AFOSH Std 48-20):

a. The equipment listed in attachment 4 produces hazardous noise and must have the appropriate label (AF Visual Aid 48-102 through 48-105). The equipment is labeled. The entrance to or the borders of a hazardous noise area must be labeled with AF Visual Aid 48-101, Caution – Hazardous Noise – May

Cause Hearing Loss – Hearing Protection Required When Equipment is in Operation. Hearing protection is required only when the source is producing noise. The hazardous noise areas were labeled.

b. Evaluation of worker exposure: The Air Force noise exposure limit is 85 dBA as an 8-hour time-weighted average. We determined that your workers exceed the exposure limit. A summary of our monitoring is provided in attachment 4. The requirement for annual hearing tests is based on measured worker exposure and periodic review of the information by Occupational Medicine and Audiology.

c. Controls: Hearing loss is preventable. Engineering controls are the most preferred method in reducing exposure, but often the only practical way to control exposures is the use of hearing protection.

When worn correctly, the hearing protection you are currently using (E.A.R. Classic, Howard Leight

MAX1/MAX30, or Peltor H10A earmuffs) is adequate to reduce noise exposure. If you change to a different brand of hearing protection not listed in attachment 3, contact us to determine if it is adequate.

New equipment must meet hazardous noise standards in AFOSH Std 48-20, Occupational Noise and

Hearing Conservation Program.

d. Regulations: OSHA requires that supervisors and workers have access to the regulations governing the Hearing Conservation Program and hazardous noise exposure, 29 CFR 1910.95, Occupational Noise Exposure. The regulation is available on the internet at the US Government Printing

Office, http://www.gpo.gov/fdsys/search/home.action.

7. Confined Space Program (AFOSH Std 91-25): Your confined space program has been evaluated.

The following are confined spaces in your shop. The MEPs must be reviewed annually. The confined spaces managed/entered by this shop are classified as follows:

ID #

ENTRY PERMIT

REQUIRED (Y or N)

LOCATION DESCRIPTION

Current within 12 months (Y or N)

No Master

Entry

Permit required

Y Bldg 238 Chemical Treatment Tanks

(2 sources)

NA

No Master

Entry

Permit required

Y Bldg 238 Rinse Tanks (5 sources)

NA

CMXG003 Y Bldg 238 B-2 Mid Elevon Y

CMXG003 Y Bldg 238 B-2 Inboard Elevon Y

CMXG002 Y Bldg 225 C-130 Fuel Cell Y

a. Shop personnel break the plane at the top of the chemical treatment tanks, but do not completely enter the tanks for maintenance. This shop does manage confined spaces that they may enter.

b. The base Confined Space Program Team (CSPT) has determined that Master Entry Plans (MEPs) are required for the Mid/Inboard Elevons and the C-130 fuel cell entry. In place of MEPs, non-routine permits are issued for each entry into the chemical treatment and rinse tanks. Each permit must list tasks performed in the space, the hazards of the space, hazard control measures, and emergency actions.

Prior to entry, submit permits to the CSPT for approval. Permits will document the preparations, as specified in the entry plan, taken to guarantee safe permit-required confined space entries.

8. Radiation:

a. Ionizing Radiation Sources: This shop has sources of ionizing radiation. Although these sources do not present a hazard when properly handled, annual radiation awareness training of personnel is required. This training must include proper handling of sources/equipment. Training must be documented on the workers’ AF Form 55/equivalent.

http://www.gpo.gov/fdsys/search/home.action

RADIOACTIVE

MATERIALS or

IONIZING RADIATION

DEVICES

QUANTITY

SOURCE OR DEVICE

USE

CONTROLS

Sr-90 (S/N 42347) <0.185 µC Fisher Scope Secured area in an equipment locker

b. Lasers: This shop has sources of non-ionizing radiation in the form of lasers. The laser is a Class

4. The supervisor is responsible for conducting initial and annual laser safety training for all employees working on or around Class 3b and 4 Lasers, in PEG 238Q5 only. Training must be documented on the workers’ AF Form 55/equivalent.

3b or 4 LASERS CLASS POWER USE OF SOURCE CONTROLS

DC Slab Laser

Class II

ONLY with all interlocks in place

8 kW Paint Decoating

Class II with all Interlocks in place using the remote operating station

Class IV without all the

Interlocks in place

9. Ergonomic Hazards: Personnel have an increased risk of acquiring an ergonomic related illness or injury when using vibrating tools or performing carbon fiber repair activities. To reduce the potential of acquiring an ergonomic related illness, personnel are encouraged to vary body positions during maintenance operations and take frequent rest periods or breaks to allow the affected area time to recover.

10. Ventilation: Your industrial ventilation systems were evaluated during this survey using the criteria of the American Conference of Government Industrial Hygienists Industrial Ventilation Manual, see attachment 5. Even though the large sanding booth ventilation system meets ACGIH ventilation requirements; this booth is not adequate in controlling airborne levels of hexavalent chrome under the

OSHA Permissible Exposure Limit (PEL) as mandated in 29 CFR 1910.1026. Additionally, the B-2

Downdraft Paint Booth ventilation did not meet the 100 fpm criteria.

11. Emergency Eyewash: IAW AFOSH Standard 91-501, Air Force Consolidated Safety Standard, the eyewash stations/locations can be found in attachment 10. These eyewashes are readily accessible.

These stations are tested weekly and inspected on a monthly basis. These stations are fully operational and adequate.

12. Hazard Communication (HAZCOM) Program (AFI 90-821/HAFBI 48-106): Your HAZCOM

Program is available in an electronic format. We questioned one worker about hazard communication.

Workers questioned knew how to access this information. Workers could explain the hazard of the material they were using. They could explain what PPE was required for the task they were doing.

Supervisors did have a workplace specific lesson plan. Your lesson plan was reviewed; based on the results of the review and worker answers to questions, your program is in compliance with BE and Public

Health (PH) requirements. Contact BE if you need assistance with your program or training issues.

13. Fetal Protection Program: Attachment 7 lists chemicals used in this shop that may be hazardous to a developing fetus or affect the male or female reproductive system. Supervisors should ensure that pregnant women have their workplace reviewed by Public Health, 777-1170.

14. Work Practice Controls: No smoking, eating, or drinking is allowed in industrial work areas.

Ensure your workers practice good personal hygiene by washing their hands with soap and water immediately after handling chemicals. This reduces the risk of workers accidentally ingesting toxic/hazardous substances. Personnel are maintaining good routine maintenance, sanitation, and housekeeping practices. These are essential to ensuring a safe and healthy environment.

15. Self-Help Projects: These projects need to be coordinated through the electronic 332 work request system so they can be reviewed by BE, Safety, Fire Department and Environmental Management prior to starting work. Some work areas have asbestos-containing materials, such as floor tile, and lead containing materials, such as paint or ceramic tile. There are potential health hazards and environmental requirements that must be considered when these materials are disturbed.

16. Future Changes: If workload, operations, equipment, tasks, or chemicals used change significantly, we will need to re-evaluate the health hazards in your workplace. Notify us of any changes as soon as possible so we may evaluate them.

Attachment 3

Certified Personal Protective Equipment Listing

HAZARD CONTROLS

PERSONAL PROTECTIVE EQUIPMENT (PPE) CERTIFICATION

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

Adhesive/Sealant/

Resin Mixing and

Application All

Methods

Inhalation

(Heat resistant coating, Sealants, Epoxy Primers, Adhesives, Polyurethane paints, AC-130 PART A)

Hood/Booth Ensure hoods/filters are maintained according to manufacturer specifications

Contact

(Heat resistant coating, Sealants, Epoxy Primers, Adhesives, Polyurethane paints, AC-130 PART A)

Safety glasses Does not protect from chemical splash hazard.

Replace when excessively scratched.

Nitrile gloves

One time use only. Replace if torn, cut, punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No single glove material protects against all chemical exposures.

Tyvek coveralls

Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

Hexavalent Chrome training

Noise

(HEPA Vacuums and Paint Booth)

E.A.R. Classic plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

Hearing Conservation

Program

Hand wipe cleaning composite parts-

HVPS cleaners and non HVPS cleaners

Contact/Inhalation

(HVPS)

Solvents

Cleaners

Alcohols

(NON-HVPS)

Solvents

Cleaners

Alcohols

Diethylenetriamine

Technical

Adhesion Promoter

Lacquer Thinner punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No single glove material protects against all chemical exposures.

Tyvek coveralls Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear

Hood/Booth

Ensure hoods/filters are maintained according to manufacturer specifications

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

Half or full-face Air

Purifying Respirators w/ multi-gas/P100 cartridges

Cannot be used in oxygen deficient atmospheres. Must be cartridge specific.

Cartridges for the half-face air-purifying respirators or the full-face air-purifying respirators will be changed out at the end of each shift during periods of regular daily use.

Half-face respirator protection factor 10, full-face protection factor 50

Chemical Goggles Does not protect face from chemical splash hazard. Replace when excessively scratched.

Sanding Composite

Surfaces

Inhalation

(Strontium

Chromate in primer dust, other coating materials)

Full-face Air Purifying

Respirators w/ multi-gas/P100 cartridges

Cannot be used in oxygen deficient atmospheres. Must be cartridge specific.

Cartridges for the half-face air-purifying respirators or the full-face air-purifying respirators will be changed out at the end of each shift during periods of regular daily use.

Full-face protection factor 50

3M Supplied Air Hood

Air pump inlet filter must be in an area that is free of contaminants.

Recommend locating the entire breathing unit in an area free of contaminants.

Hose lengths between 50 - 300 feet; longer than

300 ft is prohibited.

Hood protection factor 1000

Sanding booth vent Must meet ACGIH recommendations

Hexavalent Chrome training

Ventilated pneumatic tools or hand-held vacuum hoses

Ensure proper alignment of sandpaper (holes).

Holding a vacuum hose and pneumatic tool can cause major fatigue.

Contact

(paint dusts, carbon fiber)

Replace gloves if they become sticky, torn or show signs of breakthrough.

Tyvek coveralls w/ booties Provides protection against splashing, not impervious to chemical or vapor penetration.

Discard after rips, tears, or holes appear.

Noise

(sanding room ventilation, HEPA

Vacuums)

E.A.R. Classic plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

Application of

Top Coats & Primer

Paints

Polyurethane paints

Sealants

Supplied-air hoods

Air pump inlet filter must be in an area that is free of contaminants.

Recommend locating the entire breathing unit in an area free of contaminants.

Hose lengths between 50 - 300 feet; longer than

300 ft is prohibited.

Hood protection factor 1000

Full-face Air Purifying

Respirators w/ multi-gas/P100 cartridges

Change out cartridges after 8 hours use or when you detect paint solvent odors inside the respirator

Full-face protection factor 50

Cross-Draft Booth Must meet ACGIH recommendations

Contact

Sealants, Primers, alcohols

Adhesives, Polyurethane paints

Acetone Solvents

Chemical goggles

Does not protect face from chemical splash hazard. Replace when excessively scratched.

Nitrile rubber Replace gloves if they become sticky, torn or penetration. Discard after rips, tears, or holes appear.

Hexavalent Chrome training

Noise

(HEPA Vacuums, F-

22 Cross-Draft

Booth)

E.A.R. Classic plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

Chemical Preparation of Metal and

Composite Surfaces

Phosphoric acid and sulfuric acid

Butyl rubber gloves Replace gloves if they become sticky, torn or penetration. Discard after rips, tears, or holes appear.

Chemical Splash Goggles Replace if excessively scratched.

Hood/Booth Must meet ACGIH recommendations

Cleaning Paint Guns

Contact

Sealants, Paint Thinner

Chemical Splash Goggles Replace when excessively scratched.

Nitrile rubber gloves punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

Tyvek coverall Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

Hood/Booth Must meet ACGIH recommendations

Cutting of Composite

Structures for Repair

Noise

(Die Grinder, HEPA

Vacuums)

E.A.R. Classic plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

Howard Leight

MAX1/MAX30 plugs

One time use only. Must be inserted properly for noise attenuation to occur. NRR 26

(Chromium/

Carbon fibers/

Fiberglass)

Exhaust Ventilation

Use saw ventilation to remove dust from composite materials during cutting operations.

Do not use compressed air to clean.

Full-face Air Purifying

Respirators w/ multi-gas/P100 cartridges

Cannot be used in oxygen deficient atmospheres. Must be cartridge specific.

Cartridges for the half-face air-purifying respirators or the full-face air-purifying respirators will be changed out at the end of each shift during periods of regular daily use.

Full-face protection factor 50

Hexavalent Chrome training

Hood/Booth Must meet ACGIH recommendations

Contact Sealants, paints

Safety glasses

Does not protect from chemical splash hazard.

Replace when excessively scratched.

Nitrile gloves One time use only. Replace if torn, cut, punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No

Tyvek Coveralls Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

Core Milling of

Composite and Foam

Structures

Noise

(Air File, Champher

Saw, Downdraft

Table, HEPA

Vacuums, Milling

Unit, Vertical Mills)

E.A.R. Classic plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

Howard Leight

MAX1/MAX30 plugs

One time use only. Must be inserted properly for noise attenuation to occur. NRR 26

Assemble/

Disassemble

Noise

(Die Grinder, Drill

E.A.R. Classic plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

Composite

Components

Motor, Drills, HEPA Vacuums)

Howard Leight

MAX1/MAX30 plugs

One time use only. Must be inserted properly for noise attenuation to occur. NRR 26

Peltor H10A ear muffs Replace if foam becomes worn or cracked.

NRR 30

Ergonomics

(Physical Stress)

Work/Rest Cycle

Inhalation/Contact

(dusts)

Hood/Booth Must meet ACGIH recommendations

Tyvek Coveralls Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

Nitrile gloves One time use only. Replace if torn, cut, punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No single glove material protects against all

Applying Lubricants

Lubricant oil, Lubricant grease chemlease 41

WD-40,

Sealants, Nitrile gloves One time use only. Replace if torn, cut, punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No single glove material protects against all chemical exposures.

Tyvek coveralls Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

Hood/Booth Must meet ACGIH recommendations

Starch Media

Blasting Composite

Parts

Hexavalent Chrome

NIOSH-approved Supplied-air abrasive blasting hood

Air pump inlet filter must be in an area that is free of contaminants.

Recommend locating the entire breathing unit in an area free of contaminants.

Hose lengths between 50 - 300 feet; longer than

300 ft is prohibited.

Protection factor 1000

Nitrile gloves One time use only. Replace if torn, cut, punctured or otherwise damaged. Thicker gloves provide better abrasion resistance and chemical resistance, but reduced dexterity. No single glove material protects against all chemical exposures.

Tyvek coveralls Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

Hexavalent Chrome training

Booth/Hood Must meet ACGIH recommendations

Noise

(HEPA Vacuums, Sanding Booths)

E.A.R ear plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

Repair composite materials containing

MDA

Methylene Dianiline

(MDA)/

Isocyanates

Potential contact, ingestion, and skin hazards while using pre-impregnated carbon fiber material lay-up procedure.

Respiratory system

& skin Sensitization

MDA room with dilution ventilation

Rubber latex QSM-00062 or nitrile/butyl rubber or neoprene rubber gloves

Replace when cracks, tears, or stickiness occur

(signs of degradation). Latex/Nitrile gloves are one time use only. Replace when rips or blistering occur.

safety glasses or goggles Does not protect from chemical splash hazard.

Replace when excessively scratched.

Tyvek suits Not impervious to chemical or vapor penetration. Discard after rips, tears, or holes appear.

HEPA vacuum cleaners

Petco vented sanders

MDA training

Noise

(Drills, HEPA

Vacuums)

E.A.R ear plugs One time use only. Must be inserted properly for noise attenuation to occur. NRR 22

ACTIVITY HAZARDS CONTROLS

LIMITATIONS and PPE CHANGE OUT

FREQUENCY

(238Q5 ONLY)

Laser Stripping of

Radome

Radiation (ionizing and non-ionizing)

Self-contained LASER shielding, remote controls, interlocks, signs, warning lights, and laser training.

Working in PEG

Calibration Gases

Natural Dilution

Attachment 4

Noise Producing Equipment and Areas

Equipment Measured dB(A)

85 dB(A)

Line Approved hearing protection

Noise

Reduction dB(A)

Electric Vacuum 93 4 ft

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Drill Motor 85 N/A

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Die Grinder

(small disk) 93 3 ft

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Milling Unit 87 2 ft

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Spray Painting

Ventilation booth 87 Entire booth

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Air File 88 3 ft

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Downdraft table 94 Entire shop

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Champher saw 94 Operator’s position

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Vacuum cleaner 94 Operator’s position

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Vertical mill- 5 axes 85 Entire shop

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Vertical mill

(PM9813)

Without load.

Wear hearing protection when cutting

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Drills 88 3 ft

Howard Leight MAX earplugs

E.A.R Classic earplugs

Peltor H10A earmuffs

Noise Exposure Monitoring

Person Monitored Date Duties Average dB(A)

(8-hr)

Bill Pettigrew 2001/09/18 Depainting (scuff sanding) 89.50

Bill Pettigrew 2001/09/19 Damage removal/scarfing, core repair 84.00

Massey, Dallis N. 1997/03/13 Background noise from structural repair/grinding 79.07

Massey, Dallis N. 1997/03/14 Sanding operations 95.95

Whitten, Michael 2002/09/12 Sander 93.40

Brown, David R. 2002/09/12 Jitter bug sander, high speed pneumatic grinder 79.30

David Brown 2011/12/14 Sanding A10 Flight Control and Flaps 90.4

Michael Whitten 2011/12/14 Sanding A10 Flight Controls and Flaps 86.4

Attachment 5

Ventilation Survey Results

Type Vent Bldg/

Rm AQ # PM # Activity

Measured

Flow Rate

Required

Flow Rate

Adequate to Use

Sanding Booth Bldg

N/A 10138 Sanding 150 fpm 100 fpm Yes

Sanding Booth Bldg

N/A 10160 Sanding 165 fpm 100 fpm Yes

Sanding Booth Bldg

38850 11177

Sanding

Composites

159.7 fpm 100 fpm Yes

Grinding Booth Bldg

N/A 10137

Sand/Cut/Grind A-

10 Inlet Rings 128 fpm 100 fpm Yes

Phosline Paint

Booth

Bldg

34244 8339

Painting

A-10 parts 123 fpm 100 fpm Yes

Alkaline Cleaner

Tank

Bldg

34249 8347 Neutralizing >300 cfm 75 cfm/ft

Yes

Weak Phosphoric

Acid Tank

Bldg

34254 8342 Degreasing >300 cfm 75 cfm/ft

Yes

Sulfuric Acid Tank Bldg

34251 8345 Degreasing >300 cfm 75 cfm/ft

Yes

Crossdraft Table Bldg

N/A 11557 Mixing resin 356 fpm 250 fpm Yes

Crossdraft Table Bldg

N/A 11558 Mixing resin 400 fpm 250 fpm Yes

Media blasting Bldg

38854 11399

Wheat Starch blasting 109 fpm 100 fpm Yes

B-2

Downdraft Paint

Booth

Bldg

34532 9465

Application carbon fiber component coatings & sealers

88.6 fpm 100-125 fpm No

B-2

Mixing Booth

Bldg

N/A 10904 Mixing Paint >50 AC/hr 6 AC/hr Yes

F-22

Crossdraft

Paint Booth

Bldg

38771 11179

Application carbon fiber component coatings & sealers

101 fpm 100-125 fpm Yes

Attachment 6

Female Reproductive Hazards

HAZARDOUS

CONSTITUENT

& EXPOSURE

ROUTES

ACTIVITY WHERE

CHEMICAL IS USED

POTENTIAL HAZARD

Acetone

Inhalation, Ingestion, Contact

HAND WIPE SOLVENT B2

PARTS - NON HVPS

ADHESIVE

APPLICATION/BRUSH

APPLYING COATINGS TO B2

PARTS

APPLYING LUBRICANTS

B-2 PARTS - HVPS SOLVENT

USE

USE PAINT GUN CLEANER

39006

USE PAINTBOOTH 38771 FOR

PAINT/PRIMER

- Not a known reproductive hazard, but may have adverse effects on female fertility and pregnancy

- Earlier than normal menstrual period at levels slightly above the OEEL

- Freely crosses the placenta

2-Butoxyethanol

USE SPRAY BOOTH 34532 FOR

- Does not appear to be selectively fetotoxic, embryotoxic, or teratogenic in animals at doses which are not toxic to the mother

Cadmium

Ingestion

- Unconfirmed reproductive hazard; does not affect female fertility at a gross level

- Cadmium levels in breast milk may be elevated if mother or father smokes

& EXPOSURE

ROUTES

ACTIVITY WHERE

CHEMICAL IS USED

POTENTIAL HAZARD

Carbon monoxide

(CO)

Inhalation, Contact

(liquid)

WORKING IN PEG 238Q1 – is byproduct of LASER paint removal

- Known to have neurological effects on the fetus; doesn’t have a “no effect” level

- Chronic occupational exposures to low levels of

CO would be of comparable risk to the fetus as smoking in the mother

- If a pregnant women smokes and ALSO is exposed to CO on the job; she may be at increased risk for having a child with neurological problems

Ethanol

- Ethanol ingestion by pregnant women is known to cause fetal alcohol syndrome (low birth weight, low IQ, slow growth, facial abnormalities, nervous system defects, other malformations)

- Not clear if exposures which are solely occupational (below the OEEL) are sufficient to be a reproductive risk

Ethylene glycol

WORKING IN PEG 238Q1 - Mixed reproductive hazard results in animals

- Teratogenic effects in animals were generally produced at very high levels

- No human reproductive studies available, so the reproductive hazard in humans is unknown

Ethyl acetate

HVPS SOLVENT USE

- Metabolized to ethyl alcohol in the body, so it would have the effects of ethyl alcohol

- Ethanol ingestion by pregnant women is known to cause fetal alcohol syndrome (low birth weight, low IQ, slow growth, facial abnormalities, nervous system defects, other malformations)

- Not clear if occupational exposures (below the

OEEL) are sufficient to be a reproductive risk

& EXPOSURE

ROUTES

ACTIVITY WHERE

CHEMICAL IS USED

POTENTIAL HAZARD

Methyl ethyl ketone/

USE SPRAY BOOTH 34532 FOR

- Not sufficient evidence to regard it as an occupational reproductive hazard, but should be considered a possible hazard until more is learned

Methyl

Methacrylate

-Animal studies show low fetal birth weight

- No human reproductive studies available, so the reproductive hazard in humans is unknown

Toluene

- High levels of exposure (or abuse) during pregnancy may cause spontaneous abortion, or abnormalities or growth retardation in the child

- Low levels of exposure may cause menstrual disturbances

- Not clear if occupational exposures below the

OEEL present significant risks for the unborn

VM&P naphtha

238Q1 - USE PAINTBOOTH

38771 FOR PAINT/PRIMER

- Some studies show it may produce menstrual disturbance, abnormal pregnancy, or birth defects

- Considered an unconfirmed human reproductive hazard

& EXPOSURE

ROUTES

ACTIVITY WHERE

CHEMICAL IS USED

Xylene

USE PAINT GUN CLEANER

39006

- Not a teratogen in laboratory animals

- High levels of exposure may be linked to birth defects and possibly menstrual disturbances

- Occupational (low level) exposure to xylene is unlikely to cause harm to human reproduction

Male Reproductive Hazards

CONSTITUENT &

EXPOSURE

ROUTES

ACTIVITY WHERE

CHEMICAL IS USED

2-Butoxyethanol

Inhalation, Ingestion, USE SPRAY BOOTH 34532

FOR PAINT/PRIMER

-Testicular effects

Ethanol

Inhalation, Ingestion,

- Can affect male fertility and produce reduced birth weight in newborns through paternal exposure

- Not clear if exposures which are solely occupational (below the OEEL) are sufficient to be a reproductive risk

Manganese dioxide

Ingestion

APPLICATION/BRUSH

-Linked with impotence at high exposure levels

Causes alteration of testes in some animal studies

Attachment 7

Training Requirements – 29 CFR 1910.1026, Chrome VI

Who Must Be Trained: Personnel who have any potential exposure to Chrome VI

Frequency: At initial assignment and annually

References: 29 CFR 1910.1026(l)(1), Chrome VI

Required Content:

1. Health Hazards of Chrome VI

2. Operations which could result in exposure to Chrome VI

3. Quantity and location (products) of Chrome VI

4. Engineering and work practice controls

5. Protective measures including prohibition of smoking in the workplace, personal hygiene, emergency procedures, and Personal Protective Equipment (PPE)

6. Respiratory protection and PPE

7. Medical surveillance program

8. Contents of the OSHA Standard and Appendices

9. Employees right of access to medical and exposure records

10. Where regulated areas are established: rules and procedures for working in regulated areas

EFFECTS OF SHORT-TERM EXPOSURE:

The substance is corrosive to the eyes, the skin and the respiratory tract. Corrosive on ingestion.

EFFECTS OF LONG-TERM OR REPEATED EXPOSURE:

Repeated or prolonged contact may cause skin sensitization. Repeated or prolonged inhalation exposure may cause asthma. The substance may have effects on the respiratory tract and kidneys, resulting in nasal septum perforation or kidney impairment. This substance is carcinogenic to humans. May cause heritable genetic damage to human germ cells. Animal tests show that this substance possibly causes toxicity to human reproduction or development.

Attachment 8

Regulated Area Sign

DANGER

REGULATED AREA

CHROME VI SUSPECT CANCER

HAZARD

PERSONAL PROTECTIVE

EQUIPMENT REQUIRED

AUTHORIZED PERSONNEL ONLY

Attachment 9

Eyewash Station Locations

Permanent Portable

1 F-22 Paint Booth 1 CMM Room/Milling Machine Rm

1 Breezeway 2 Core Milling Room

2 F-16/A-10 Production Area 1 B-2 Paint Shop

1 Wheat Starch Area 1 F-16/A-10 Production Area

1 Radome Production Area 1 Hazardous Material Area

1 B-2 Production Area 1 De-bulk Room

1 West Entrance to Secure Area

1 West side of B-2 Clean Room

1 South side of B-2 Clean Room

1 Autoclave Area

1 NDI Film Area

1 Entrance to MDA Area

1 MDA Area

2 Phos Line

2 Upstairs Clean Room Eyewash station plumbed through sink

Attachment 10

Air Sampling Results

Hexavalent Chrome

This sampling was performed on 14 December 2011, in the Advanced Composites Shop, while two people sanded A-10 flight controls and A-10 flaps in the large sanding booth.

EMPLOYEE SAMPLE # ANALYTE TIME

SAMPLED

8 HR TWA OEL

David Brown 000060N1

000060N2

Hexavalent

Chrome 412 Min total 0.0062666 mg/m

0.005 mg/m

Michael Whitten 000060N5

000060NJ

Hexavalent

Chrome 350 Min total 0.012022 mg/m

0.005 mg/m

Key to Abbreviations:

PEL = 8 Hr Occupational Exposure Limit (set by OSHA Standards)

TWA = Time Weighted Average (based on time sampled) mg/m3 = milligrams per cubic meter of air