Air quality study redacted 2_Redacted.pdf

Industrial Hygiene Survey

U .S. Department of Justice Unicor - Coleman Wood Factory

FCC Coleman 846 NE 54TH Terrace Coleman, FL. 33521

Survey Date: February 28, 2024

Report Date: April 3, 2024

Kimberly C. Owens Chief of Project Management - Office Furniture Group FCC Coleman 846 NE 54th Terrace Coleman, FL 33521

Dear Ms. Owens, An industrial hygiene survey was conducted on February 28, 2024, by Jeff Hutchins - Cardinal Compliance Consultants (CCC) at FCC Coleman Wood Factory, Coleman, FL. The purpose of the survey was to assess industrial hygiene conditions as they apply to airborne respirable wood dust and respirable crystalline silica (RCS) concentrations during the fabrication of wood office furniture components.

To accomplish this, ten personal breathing zone (PBZ) air samples were collected according to the methods described in Attachment A.

Please keep in mind that this evaluation was not all-encompassing of the site's occupational safety and health conditions, but rather a representative review of those conditions evident or explained during the visit. Comments and recommendations are confined solely to occupational health issues of the tasks and operations evaluated. Various aspects of your operation’s occupational hygiene programs and personal protective equipment use were reviewed. In assessing the need for improved occupational health controls at the site, do not rely solely on the information contained in this report as the only alternatives available since conditions change and there are numerous methods of achieving control of workplace exposures.

Results Summary

• All ten (10) PBZ samples were below the OSHA Permissible Exposure Limit (PEL) of 50 µg/m3 for

RCS.

• All ten (10) PBZ samples were below the OSHA Permissible Exposure Limit (PEL) of 5 mg/m3 and the American Conference of Governmental Industrial Hygienists Threshold Limit Value (ACGIH- TLV) of 1 mg/m3 for respirable wood dust.

Air sampling results are summarized in Table 1.

Additionally, local exhaust ventilation (LEV) measurements were taken on woodworking machines with accessible LEV entries. These results are summarized in Table 2.

Several opportunities to improve health and safety conditions at the facility are detailed in the Observations & Recommendations section of this report.

OSHA requires affected workers to have access to workplace sampling results. The employer shall individually notify each affected employee in writing of the results of that assessment or post the results in an appropriate location accessible to all affected employees. Attachment B contains posting tables you can use to communicate the sampling results to affected workers.

The results and recommendations contained in this report represent conditions on the date of the survey.

The long-term application of these results and recommendations must be made with caution and diligence, as changes in production techniques, processing volume, maintenance and service activities, environmental conditions, facility layout, and work practice variables can have an impact on exposures, and additional control requirements may be necessary.

Cardinal Compliance Consultants (CCC) is providing this report to inform the client of actions that may be necessary to improve its operations and reduce potential exposure to workplace contaminants. In providing this information, CCC expressly disclaims any responsibility for the client’s facility, its employees, or its industrial hygiene, safety, or work practices. Significant changes in the process, work practices, or production volumes could potentially alter the generation of workplace contaminants and will require evaluation by a qualified industrial hygiene professional. It remains the client’s responsibility and obligation to take the actions necessary to protect its employees from occupational hazards.

Thank you for the opportunity to visit your facility and do not hesitate to contact us if you have any questions or need additional occupational health and safety services.

Report Prepared by: Report Reviewed by:

Unicor – Coleman Wood Factory Industrial Hygiene Report April 3, 2024

Introduction

The sampling period was approximately 6 hours for most workers. Since workers did not leave the factory area for lunch, the air samplers continued to run during this time. Workers and supervisors described the day as a “typical” production day.

Observations & Recommendations

• Several workers were noted wearing filtering facepiece respirators (“dust masks”). Since the air sampling results are below occupational exposure levels (OELs) for both respirable wood dust and RCS, continued use of dust masks can be permitted but the Voluntary Use provisions (Appendix D) of the OSHA Respiratory Protection standard must be followed. The OSHA “Small Entity Compliance Guide for the Respiratory Protection Standard” provides additional information for administering a voluntary use respirator program.

• Use a vacuum for cleaning facilities and personnel. Prohibit dry sweeping and the use of compressed air to avoid creating airborne, inhalable dust by re-entraining settled dust into the factory atmosphere.

• The LEV measurements show airflow frequently below industry recommendations as found in the American Conference of Governmental Industrial Hygienists’ Industrial Ventilation – A Manual of Recommended Practice. The type of woodworking machines used at your factory should have an exhaust flow rate of 350 – 550 cubic feet per minute (cfm), and duct transport velocities should be at least 3500 feet per minute (fpm). The following improvements can increase the efficiency of the existing LEV system:

1. Equip the LEV ducts with “flanged” or “tapered or conical” hoods. A flange is a surface, at and parallel to the hood face which provides a barrier to unwanted airflow from behind the hood. In practice, flanged or tapered hoods can increase capture velocity by approximately 25%. For most applications, the flange width should be equal to the square root of the hood area (√A).

2. Minimize the use of flexible ductwork:

• Flex duct adds severe pressure losses that reduce airflow and velocities.

• Even straight sections of flexible duct have almost twice the losses of similarly sized metal duct and should be avoided except where necessary (i.e., ONLY when mobility is required).

Flex duct is often misused on “fixed” LEV hoods for installation convenience.

• In general, the use of flexible ductwork should be minimized whenever possible, especially where the formation of severe bends is not restricted (e.g., do not use flex ducts to make 30°, 45°, or 90° angles). Typically, bends in flexible ductwork produce extremely large static

Unicor – Coleman Wood Factory Industrial Hygiene Report April 3, 2024 pressure losses that cannot be easily predicted.

• Where required, minimize the length to no longer than is necessary to perform the required flexibility of the connection (< two feet).

• If flex duct is necessary, use types with a smooth interior bore.

3. Assure duct transitions follow the guidelines below. Branch entries should be 30° - 45° and entry into main ducts at the point of primary duct diameter changes should be avoided.

Similarly, smooth, gradual directional changes should be employed and the use of 90° elbows should be prohibited.

4. Some measured duct velocities were less than 10% of the recommended 3500 fpm (see Table 2). The inside of the ductwork system should be inspected to ensure airflow is not obstructed or blocked.

5. Remove LEV from obsolete equipment and close blast gates on temporarily unused equipment to direct available airflow to operating equipment. Also remove “dead end” branches where equipment has been removed.

6. Have a qualified industrial ventilation professional balance the LEV system. There have been obvious modifications to the original LEV design. Re-balancing the system will ensure that the capture velocities are appropriate for the type of machinery / dust generation and duct velocities are sufficient to prevent dust settling in the ductwork.

Attachment B

Employee Exposure Assessment Notification Letters and Posting Table

To:

Re: Industrial Hygiene Sampling Results

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

Pallet saw 343

Wood dust [R] 0.10 mg/m3 5 mg/m3 1 mg/m3

RCS <7.2 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from clothing and work surfaces.

Employee Signature (optional) Date

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

CNC #2 367

Wood dust [R] 0.069 mg/m3 5 mg/m3 1 mg/m3

RCS <6.9 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

CNC #3 229*

Wood dust [R] 0.11 mg/m3 5 mg/m3 1 mg/m3

RCS <11 µg/m3 50 µg/m3 25 µg/m3

*sampling time reduced due to worker leaving factory for medical call-out

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

Saw #2 358

Wood dust [R] 0.11 mg/m3 5 mg/m3 1 mg/m3

RCS <6.8 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

CNC #1 354

Wood dust [R] 0.13 mg/m3 5 mg/m3 1 mg/m3

RCS <7.0 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

Top master 328

Wood dust [R] <0.076 mg/m3 5 mg/m3 1 mg/m3

RCS <7.6 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

Vertical saw 352

Wood dust [R] 0.28 mg/m3 5 mg/m3 1 mg/m3

RCS <7.1 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used Filtering facepiece µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

CNC #4 349

Wood dust [R] 0.087 mg/m3 5 mg/m3 1 mg/m3

RCS <7.2 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

CNC #2 343

Wood dust [R] <0.071 mg/m3 5 mg/m3 1 mg/m3

RCS <7.1 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used None observed µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Air sampling was recently conducted during your work activities on March 7, 2024. The following table summarizes the job activities/tasks performed, exposures measured and respective sampling results.

Job Description Sampling Time (minutes)

Contaminant of Concern Result OSHA PEL ACGIH TLV

CNC #2 349

Wood dust [R] 0.073 mg/m3 5 mg/m3 1 mg/m3

RCS <7.3 µg/m3 50 µg/m3 25 µg/m3

Respiratory Protection used Filtering facepiece µg/m3 = microgram per cubic meter of air mg/m3 = milligram per cubic meter of air RCS = respirable crystalline silica Wood dust [R] = wood dust, respirable fraction OSHA PEL = Occupational Safety & Health Administration Permissible Exposure Limit ACGIH TLV = American Conference of Governmental Industrial Hygienists’ Threshold Limit Value

< = less than the analytical laboratory’s reporting limit of 5.0 µg RCS / 50 µg respirable dust

Discussion – Your air sampling results were below the applicable OSHA Permissible Exposure Limit (PEL) and American Conference of Governmental Industrial Hygienists’ Threshold Limit Value (ACGIH-TLV).

Recommendations:

• Always make sure the local exhaust ventilation is operating and position the duct opening as close as possible to the point of dust generation.

• Do not use compressed air to clean your clothing or work areas. Use a vacuum to clean dust from

Attachment C

Laboratory Analytical Results