Z288.pdf

DEPARTMENT OF THE AIR FORCE

75TH AEROSPACE MEDICINE SQUADRON (AFMC)

HILL AIR FORCE BASE, UTAH

28 June 2012

MEMORANDUM FOR 532 CMMXS/MXDPDAF

FROM: 75 AMDS/SGPB

SUBJECT: Industrial Hygiene Assessment, Heat Treat and Foundry Shop, Building 507, PEG: Z288

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

Assessment for your shop. This assessment was done on 4 June 2012 by A1C Akina Jones. An opening conference was conducted with Richard Poulsen. AFGE was contacted 1 June 2012.

This assessment was accomplished in accordance with AFI 48-145, Occupational and

Environmental Health Program.

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

a. Engineering and administrative controls of noise hazards must be considered. BE must have documentation that all processes involving hazardous noise-producing equipment cannot be completed in a way that does not create a hazard to personnel. Work with BE and your engineering function to review engineering and/or administrative controls for noise hazards or to document that alternative methods of controls are not practical.

b. Your HAZCOM program is not in compliance. When questioned about HAZCOM, workers could not explain the hazard of the material they were using. Workers need to be able to show that they know the hazard communication information.

c. You need to create a workplace specific lesson plan IAW AFI 90-821 and HAFBI 48-106.

Please see attachment 6 for HAZCOM Lesson Plan Template.

d. IAW AFI 91-203, Air Force Consolidated Occupational Safety Instruction, the eyewash stations must be tested weekly. Your shop inspects the stations monthly however you do not test them weekly.

e. Personnel utilize a large tilting furnace, two small floor hoods and a pouring station hood.

A baseline ventilation assessment needs to be conducted on these systems. BE will contact you to schedule a day and to complete this assessment.

f. Current noise dosimetry documentation does not accurately reflect the shop’s 8-hr time weighted average (TWA). BE will contact you to schedule a day to complete accurate noise dosimetry.

g. Air sampling for lead has not been accomplished for several years. Please contact BE at least 1 day prior to performing foundry operations so that we can perform air sampling.

3. Your workplace has been identified as a Category 2 shop, which is defined as a medium risk workplace. Your shop will be surveyed every two years. 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 A1C Jones at

777-4551 or e-mail at akina.jones@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 applicable industrial hygiene data are 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.

6/28/2012

X

CARY FISHER, GS-13, DAF

Industrial Hygiene Supervisor

Attachments:

1. Response to Recommendations

2. Industrial Hygiene Assessment

3. Health Hazard Controls and PPE Certification

4. Hazardous Noise Assessment Data

5. Fetal Protection Information

6. Specific OSHA Lead Standard Training Information cc:

75 ABW/SEG - Ron James

75 AMDS/SGPM - Jolene Garner

309 CMXG/QPDB – Victor Rodriguez

309 CMXG/CL - Rick Buhl

309 CMXG/ENV- Guy Whalen

309 CMXG/EN – Allan Cooley

309 CMXG/OB – Shayla Gilbert

532 CMMXS/CL – Breck Baker

309 MXW/CL – Mr Raiff/Jan Drain

309 MXW/SE – Kerry Miller/Tim Helms mailto:Kathleen.Turner@hill.af.mil mailto:akina.jones@hill.af.mil

4 June 2012

Attachment 1

RESPONSE TO FINDINGS AND RECOMMENDATIONS

Recommended actions for 532 CMMXS, Heat Treat Shop, PEG: Z288

RETURN THIS SHEET TO 75 AMDS/SGPB NLT 30 July 2012

FINDINGS AND RECOMMENDATIONS ACTION TAKEN

Engineering and administrative controls of noise hazards must be considered. BE must have documentation that all processes involving hazardous noise-producing equipment cannot be completed in a way that does not create a hazard to personnel.

Work with BE and your engineering function to review engineering and/or administrative controls for noise hazards or to document that alternative methods of controls are not practical.

Your HAZCOM program is not in compliance. When questioned about HAZCOM, workers could not explain the hazard of the material they were using.

You need to create a workplace specific lesson plan IAW AFI

90-821 and HAFBI 48-106. Please see attachment 6 for

HAZCOM Lesson Plan Template.

IAW AFOSH Standard 91-501, Air Force Consolidated Safety

Standard, the eyewash stations must be tested weekly. Your shop inspects the stations monthly however you do not test them weekly.

ADDITIONAL HEALTH HAZARD EVALUATIONS:

The following operations still need evaluation. Please call us ASAP prior to these operations so we may schedule an evaluation.

DATE

CONTACTED

DATE OF

ACTIVITY

Personnel utilize a large tilting furnace, two small floor hoods and a pouring station hood. A baseline ventilation assessment needs to be conducted on these systems. BE will contact you to schedule a day and to complete this assessment.

Current noise dosimetry documentation does not accurately reflect the shop’s

8-hr time weighted average (TWA). BE will contact you to schedule a day to complete accurate noise dosimetry.

Air sampling for lead has not been accomplished for several years. Please contact BE at least 1 day prior to performing foundry operations so that we can perform air sampling.

4 June 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. Your shop has no chemical exposures above permissible exposure limits and the current controls in place are adequate. There are noise hazards in this shop. Engineering and administrative controls of noise hazards must be considered. BE must have documentation that all processes involving hazardous noise producing equipment cannot be completed in a way that does not create a hazard to personnel. Work with BE and your engineering function to review engineering and/or administrative controls for noise hazards or to document that alternative methods of controls are not practical.

2. Personal Protective Equipment (PPE)(AFI 91-203): 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 AFI 91-203. 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 redesign) the supervisor must notify our office so we can reevaluate the potential health risks and PPE requirements.

3. Occupational Safety and Health Administration (OSHA) Expanded Standard

Chemicals: The following OSHA expanded standard chemical is used in this shop. Air sampling and/or calculations indicate that there is no risk for worker exposures over the

Occupational and Environmental Exposure Limit (OEEL).

Lead (29 CFR 1910.1025): Personnel are potentially exposed to inhalation, ingestion and contact hazards from lead when performing casting operations. Lead is considered a suspected carcinogen. Lead becomes a hazard when operating temperatures exceed 800F. Your casting operations do not reach temperatures high enough to create an inhalation hazard. Wet wipe the area and wash hands after any of these operations to minimize potential ingestion hazards. See attachment 6 for OSHA training requirements.

4. ESOHCAMP Tier 1 Checklists (AFI 90-803): n accordance with AFI 90-803, we provided you ESOHCAMP tier 1 checklists for occupational health items associated to your shop. These checklist need to be completed quarterly.

5. 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 eight-hour, time-weighted average. Current noise dosimetry documentation does not accurately reflect the shop’s 8-hr time weighted average (TWA). BE will contact you to schedule a day to complete accurate noise dosimetry. 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 (Moldex Spark

Plug foam ear plugs) are 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.

6. Ventilation: Personnel utilize a large tilting furnace, two small floor hoods and a pouring station hood. A baseline ventilation assessment needs to be conducted on these systems. BE will contact you to schedule a day and to complete this assessment.

7. Ergonomic Hazards: Personnel have an increased risk of acquiring an ergonomic-related illness or injury when building casting molds, heat treating components, and adding sodium silicate to sand. 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.

8. Emergency Eyewash: IAW AFI 91-203, Air Force Consolidated Occupational Safety

Instruction, the eyewash stations located left of front entrance, right of the back entrance, bay door entrance, foundry area and welders area are readily accessible. The stations are not tested weekly as required. They are inspected on a monthly basis. The stations are fully operational and adequate.

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

HAZCOM Program is available as electronic access. We questioned one worker about hazard communication. The worker did know how to access this information. The worker could not explain the hazard of the material they were using. They could explain what PPE was required for the task they were doing. Supervisors did not have a workplace specific lesson plan, therefore lesson plans was not reviewed; based on the results of the review and http://www.gpo.gov/fdsys/search/home.action worker answers to questions, you are not in compliance with BE and Public Health (PH) requirements. Contact BE if you need assistance with your program or training issues

10. Thermal Injury: Shop personnel are potentially exposed to thermal (extreme heat) injury while performing casting operations, heat treat components and air quench operations. Personnel are periodically briefed on the hazards, prevention, symptoms, and signs of heat and cold stress related illnesses. Additionally, personnel are given opportunities to take breaks as needed to avoid thermal stress while performing assigned duties. For specific guidance on heat stress, refer to AFPAM 48-151, Thermal Injury. Wind chill temperatures and heat stress levels are posted on the Hill Air Force Base SharePoint site, https://cs.eis.afmc.af.mil/sites/Hill/default.aspx.

11. Fetal Protection Program: Attachment 5 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.

12. 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.

13. 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 like 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.

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

https://cs.eis.afmc.af.mil/sites/Hill/default.aspx

Attachment 3

HEALTH HAZARD CONTROLS AND PPE CERTIFICATION

ACTIVITY HAZARDS

CONTROLS

PPE, Engineering, Admin

CONTROL LIMITATIONS

and PPE CHANGE OUT

FREQUENCY

Building Casting

Molds

Inhalation

(Sand)

Pouring Station Hood

Hood should be positioned above the pouring station when performing process

Contact

(Sand) Safety Glasses

Does not protect from chemical splash hazards. Replace when excessively scratched.

Noise

(Large and Small

Pneumatic

Tampers)

Moldex Spark Plugs

(NRR 26 dB)

Plugs must be inserted correctly to provide optimum protection. One-time use only.

Hearing Conservation

Program

Workers receive Annual

Audiograms

Ergonomic Stress

(Energy

Expenditure)

Ergonomic training proper lifting techniques, varying positions and frequent breaks

Personnel receive training on proper ergonomic techniques

Casting Operations

Thermal Stress

(Radiant Heat)

Heat Resistant Gloves Not impervious to chemicals.

Replace if ripped or torn

Welders Jacket Not impervious to chemicals.

Replace if ripped or torn

Face Shield

Only provides face protection; no eye protection from flying debris/chemical splash. Goggles or safety glasses required for eye protection. Replace if excessively scratched.

Noise

(Small Floor

Furnaces-

Running) time use only.

Hearing Conservation

Program

Workers receive Annual

Audiograms

Inhalation

(Lead)

Large Tilting Furnace Hood System provides optimum protection when doors are closed

OSHA Lead Training Annual Training

Heat Treat

Components

Ergonomic Stress

(Dynamic

Posture)

Ergonomic training proper lifting techniques, varying positions and frequent breaks

Personnel receive training on proper ergonomic techniques

CONTROLS

PPE, Engineering, Admin

CONTROL LIMITATIONS

and PPE CHANGE OUT

FREQUENCY

Heat Treat

Components cont’

Thermal Stress

(Radiant Heat)

Thermal Stress

(Radiant Heat)

Aluminized Carbon Kevlar

Coat

Not impervious to chemicals.

Replace if ripped or torn.

Face Shield

Only provides face protection; no eye protection from flying debris/chemical splash. Goggles or safety glasses required for eye protection. Replace if excessively scratched.

Heat Resistant Gloves Not impervious to chemicals.

Replace if ripped or torn

Cleaning/Solvent

Inhalation

(Presolve, Isopropyl

Alcohol)

Natural Dilution

Because of the small amounts of product used, natural dilution ventilation is adequate to control the inhalation hazard during maintenance.

Contact

(Presolve, Isopropyl

Alcohol)

Disposable Nitrile Rubber

Gloves

One-time use only. Abrasiveness may wear gloves sooner. Replace immediately if torn. Do not use more than 8 hours, breakthrough may occur.

Safety Glasses

Does not protect from chemical splash hazards. Replace when excessively scratched.

Preventative

Equipment

Maintenance

Contact

(lubricating oils) immediately if torn. Do not use more than 8 hours, breakthrough may occur.

Apply Surface

Coatings

Contact

(No Carb Green)

Note: Does not contain known chemical hazards.

However immediately if torn. Do not use more than 8 hours, breakthrough may occur.

CONTROLS

PPE, Engineering, Admin

CONTROL LIMITATIONS

and PPE CHANGE OUT

FREQUENCY

prolonged exposures may cause skin irritation.

Safety Glasses

Does not protect from chemical splash hazards. Replace when excessively scratched.

Canvas Apron Not impervious to chemicals.

Replace if ripped or torn

Air Quench

Thermal Stress

(radiant heat) Heat Resistant Gloves

Not impervious to chemicals.

Replace if ripped or torn

Noise

(Air Quench

Stand) time use only.

Hearing Conservation

Program

Workers receive Annual

Audiograms

Adding Sodium

Silicate to Sand

Ergonomic

(Energy

Expenditure-

Heavy Lifting)

Ergonomic Training, Proper

Lifting Techniques

Personnel receive training on proper ergonomic techniques

Contact

( Sodium Silicate) Safety Glasses

Does not protect from chemical splash hazards. Replace when excessively scratched.

Noise

(Small Floor

Furnaces-

Running) time use only.

Hearing Conservation

Program

Workers receive Annual

Audiograms

Working In PEG Noise

Moldex Spark Plugs

(NRR 26 dB)

Plugs must be inserted correctly to provide optimum protection. One-time use only.

Hearing Conservation

Program

Workers receive Annual

Audiograms

Parts Washer in

Foundry Area

Inhalation

(Super Agitene) Natural Dilution

Because of the tank that contains the solution has a lid, natural dilution ventilation is adequate to control the inhalation hazard during maintenance.

Contact

(Super Agitene)

Neoprene Rubber Gloves Caution use for 1-4 hours only.

Not recommended for longer use.

Canvas Apron Not impervious to chemicals.

Replace if ripped or torn

CONTROLS

PPE, Engineering, Admin

CONTROL LIMITATIONS

and PPE CHANGE OUT

FREQUENCY

Safety Glasses

Does not protect from chemical splash hazards. Replace when excessively scratched.

Attachment 4

Noise Producing Equipment and Areas

EQUIPMENT or

AREA

Measured dBA

Distance from equipment hearing protection must be worn

(85 dBA Line)

Approved hearing protection

Small Floor Furnace

(Qty-2) 106 dB(A)

Entire room is a hazardous noise area Moldex Spark Plugs Large Tamper 103 dB(A)

Small Tamper 106 dB(A)

Water Jet 87 dB(A)

Air Quench Stand 105 dB(A) Heat Treat Shop Area

(All noise PPE has been evaluated using a “NRR-7dBA” conservative calculation. The actual

NRR reported in this letter will not reflect manufacturer rating.)

Noise Exposure Monitoring

Person Monitored Date Duties Average dBA

(8 hr)

Stewart, Tom 1995/05/16 General foundry operations 70

Stewart, Tom 1995/05/17 General foundry operations 79

Sigmon, Gary 1995/05/16 General heat treat operations 76

Sigmon, Gary 1995/05/17 General heat treat operations 73

Attachment 5

Female Reproductive Hazards

Male Reproductive Hazards

HAZARDOUS

CONSTITUENT &

EXPOSURE ROUTES

ACTIVITY WHERE

CHEMICAL IS USED POTENTIAL HAZARD

2-Butoxyethanol

Inhalation, Ingestion, Contact

Working in PEG -Testicular effects

Ethanol

Inhalation, Ingestion, Working in PEG - 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.

Lead

-Affects production of sperm

HAZARDOUS

CONSTITUENT &

EXPOSURE ROUTES

ACTIVITY WHERE

CHEMICAL IS USED

POTENTIAL HAZARD

2-Butoxyethanol

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

Ethanol

Working in PEG - 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.

Lead

- Known to cause an increase in miscarriages, stillbirths, and delayed mental development.

- It is believed reproductive effects are not associated with blood lead levels less than 30 mcg/mL, although there is some evidence levels may still cause some effects.

- Can enter breast milk.

Attachment 6

Training Requirements – 29 CFR 1910.1025, Lead General Industry

Who Must Be Trained: Shop personnel who have any potential exposure to airborne lead

Frequency: All personnel with potential exposure: At initial assignment

If exposures are above the Action Level: Annually

References: 29 CFR 1910.1025(l), Lead (General Industry Standard)

Required Content for All Personnel:

1. Appendix A of 29 CFR 1910.1025, Substance Data Sheet for Occupational Exposure to

Lead http://www.osha.gov/dts/sltc/index.html Look up lead, industry in the index at this link and follow the other documents as needed.

2. Appendix B of 29 CFR 1910.1025, Employee Standard Summary

3. Additional Content if Lead Exposures exceed the Action Level (AL):

4. Review 29 CFR 1910.1025, Lead

5. Operations which might result in exposure to greater than the Action Level

6. Respiratory protection

7. Medical surveillance

8. Medical removal protection

9. Engineering and work practice controls

10. Compliance Plan (only required if exposures exceed the Occupational Exposure Limit -

OEL)

11. Prohibition of chelating agents without physicians direction

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

Health Hazard Summary:

Lead is commonly added to industrial paints because of its characteristic to resist corrosion. Industries with particularly high potential exposures include: construction work involving welding, cutting, brazing, blasting, etc., on lead paint surfaces; radiator repair shops; and firing ranges. Oral ingestion may represent a major route of exposure in contaminated workplaces. Most exposures occur with inorganic lead. Organic

(tetraethyl and tetramethyl) lead, which was added to gasoline up until the late 1970s, is http://www.osha.gov/dts/sltc/index.html not commonly encountered. Organic forms may be absorbed through the skin, while inorganic forms cannot.

The effects of lead are the same whether it enters the body through breathing or swallowing. The main target for lead toxicity is the nervous system, both in adults and in children. Long-term exposure of adults to lead at work has resulted in decreased performance in some tests that measure functions of the nervous system. Lead exposure may also cause weakness in fingers, wrists, or ankles. Some studies in humans have suggested that lead exposure may increase blood pressure, but the evidence is inconclusive. Lead exposure may also cause anemia, a low number of blood cells. The connection between the occurrence of some of these effects (e.g., increased blood pressure, altered function of the nervous system) and low levels of exposure to lead is not certain. At high levels of exposure, lead can severely damage the brain and kidneys in adults or children. In pregnant women, high levels of exposure to lead may cause miscarriage. High-level exposure in men can damage the organs responsible for sperm production.