Attachment_04i_2015_IHS_of_93552 _93562_and_93567_Shops.pdf

2015 PERIODIC INDUSTRIAL HYGIENE SURVEY

OF

93552, 93562 and 93567

AIRCRAFT MACHINIST SHOPS

INDUSTRIAL HYGIENE DEPARTMENT

NAVAL HEALTH CLINIC

CHERRY POINT, NC 28533-0023

Enclosure (6)

Table of Contents

EXECUTIVE SUMMARY

EVALUATION SUMMARY

SHOP 93552 MANUFACTURING MACHINE SHOP

SHOP 93562 MACHINE REPAIR AND LINE SHOP

SHOP 93567 MACHINE REPAIR POWER PLANT

IH EXPOSURE ASSESSMENT STUDY OF EXPOSURE TO MINERAL OIL, MIST…………..……73

LIST OF METAL SPRAYS FROM SHOP 93202

FLAMMABLE DUSTS ……………………………………………………..….……………..Appendix A

METAL WORKING FLUIDS………………………………………..……..…………………Appendix B

BERYLLIUM COMPLIANCE GUIDE FOR FRCE (2014 REVISED) ……………...............Appendix C

GLOSSARY OF TERMS...........................................................................................................Appendix D

CUSTOMER SATIFACTION FORM........................................................................................Appendix E

EXECUTIVE SUMMARY

A periodic industrial hygiene survey of Fleet Readiness Center-East 6.0J Industrial Integrated Product Team (IPT), Common Processes/Manufacturing Aircraft Machinists (Shops 93552/62/67) was conducted by Mr. Daniel R.

Gilleski, Industrial Hygienist, in July 2015, with additional monitoring conducted in August/September 2015 timeframe. Industrial Hygiene Technician support was provided by Leslie Cabilin and Aquiles Faustino. The purpose of the survey was to evaluate any changes to work processes or work practices that have occurred since our previous annual periodic IH surveys.

Responsibilities of the Industrial Machine Manufacture and Repair Branch include the following:

Performs machine operations, conventional and numerical control, to manufacture and/or modify miscellaneous aircraft, engines, and related components.

Performs CNC programming functions to support manufacturing operations.

Performs manufacture and repair of sheet metal.

Areas of particular concern or Command interest are as follows:

Medical Surveillance: DODINST 6055.5 requires a registry of personnel occupationally exposed to hazardous chemicals, physical or biological agents to be developed for each workplace surveyed. This registry is used to ensure that each employee potentially exposed to a health hazard is enrolled in the appropriate medical surveillance program, and is examined by an occupational health physician, audiologist, or other health care provider to detect any insidious or acute ill effects. FRC East Division Secretary compiles a registry and contacts FRC-East Safety

Division at 464-7514 or 464-7045 for appointment scheduling, cancelation or changes to appointments for the required medical surveillance physicals. As staffing and requirement changes occur, FRC-East Safety department must be made aware of any changes to the registry and appointments scheduled as necessary.

Hazard Communication/Materials Program: Personnel receive initial training to inform them of job-related potential hazards and necessary protective measures. Hazard specific training is conducted on a weekly basis from the FRC East Internal Television network (ITN). All hazardous materials are drawn from storage and distribution areas throughout the FRC East. The Hazardous Material Distribution Support Center (HDSC) maintains Authorized

Use Lists (AULs) for hazardous materials used by the shops. Safety Data Sheets (SDS) are available to the employees through the Hazardous Material Management System (HMMS). Employees interviewed seemed knowledgeable about the hazards associated with their duties. Hazardous materials containers were appropriately labeled.

Managers should ensure that personnel receive hazard specific training about the chemicals to which they are exposed. Under the HAZCOM standard, 29 CFR 1910.1200, “chemical” means any element, chemical compound or mixture of elements and/or compounds. Therefore, metal alloys (mixtures of elements) are considered to be chemicals. Personnel should be aware of the hazardous metals present, in a part to be machined, that are available for exposure. Additional training should be provided whenever process changes, employee transfers, new hazards, etc. occur.

Hearing Conservation Program: The Hearing Conservation Program is in good order. The majority of all tools and equipment that produce sound levels of 85 dB(A) were labeled.

Interim Navy Medicine Hearing Conservation Program Guidance (dated 24April 2014) identifies 85 decibels (dBA) as the interim Bureau of Medicine and Surgery (BUMED) OEL. Noise hazardous equipment and operations are identified in this survey including applicable Hearing Protection Device (HPD) requirements. Hearing protective devices are required to be used by all personnel whenever they work or enter an area or utilize tools/equipment where Sound Pressure Levels (SPLs), regardless of duration, are greater than 85 dB(A). Operations with SPLs exceeding 96 dBA, regardless of duration, require double hearing protection. Shop personnel were observed wearing appropriate hearing protection during the survey.

Based on noise data collected, the majority of Machines do not produce sound pressure levels in excess of 85 dBA and Machinists are not routinely expected to exceed the 8-hr TWA of 85 dBA for Machining Operations. However, there are work tasks that may be performed by some Machinists, including pneumatic and hand tool operation, cutting metal with band saws and abrasive circular saws, and pedestal machining equipment usage that may expose workers performing those tasks to sound pressure levels above 85 & 96 dBA depending on the material machined and the duration of exposure. Although noise exposures are not routinely expected to exceed the 8-hr TWA of 85 dBA for all work operations performed by Aircraft Machinists, all Aircraft Machinists are currently enrolled in the hearing conservation program and receive annual audiograms. Audiometric hearing tests are required for employees working in areas where the noise exposure 8-hour time weighted average is expected above 85 dB(A) (NOEL). We recommend Machinists that routinely work with noise hazardous tools and equipment to continue to be enrolled in the Hearing Conservation Program and noise medical surveillance program.

Engineering Controls: The majority of machines in the various Machine Shops use wet methods during machining operations, particularly when machining aircraft parts that may be coated with metals such as nickel and chromium

(such as INCONEL and metal sprayed metal parts). HOCUT 795-B water soluble coolant is used as a coolant in the machines and is used to keep metal parts wet during machining operations. In addition, most new equipment (e.g.

grinders, etc.) are equipped with enclosures, and other exposure control equipment: exhaust ventilation, mist collectors, and splash guards. Also some equipment (e.g. Shop 93552 E90 CNC lathe, & shop 93567 Campbell

Vertical Grinder, Hauser Jig Grinder), are not equipped with full enclosures; however, they all use HOCUT-795B coolant and use wet methods to help keep the machine part wet in order to help reduce inhalation exposures.

Respiratory Protection: Most Machining work areas are equipped with engineering controls as discussed above, which reduces the need for respiratory protection. However, the use of respiratory protection is recommended in

Shop 93552 for machining 2 nd stage diffuser housing, even though no over exposures to air contaminants are anticipated. The use of a half-face respirator with P100 (HEPA) particulate filters is recommended.

Respiratory protection is currently required in Shop 93562 when machining parts (hand sanding/blending) with paint, primer, potting or plate present, although Machinists indicated that they try to prevent machining on suspect areas with these materials present. A half-face air purifying respirator equipped with P100 particulate filters is recommended.

Personal Protective Equipment (PPE): Adequate PPE is readily available to all personnel. In addition to engineering controls, Machinists also use personal protective equipment to help reduce exposures and safety hazards. Safety equipment observed used include: insert ear plugs and muffs (during noise hazardous activities), safety glasses/safety glasses with side shields, face shields are readily available in shop areas, steel toe shoes, and disposable nitrile gloves used when skin contact is possible with metal working fluids, and work (leather/Zorbit) gloves. Workers were observed to change out nitrile gloves after hand contact with metal working fluids as necessary. Workers also followed good hygiene practices such as washing hands after machining work and before breaks. During the walkthrough, the PPE in use was clean, in a usable condition and properly stored. It was observed that some face shields present in shop areas get dirty easy and it is recommended for shops to keep a stock of PPE cleaning wipes in the work area in order to use as needed to keep their PPE as clean as possible. Contact the

FRCE Safety Office for assistance selecting and obtaining PPE cleaning wipes as needed.

Eyewash Equipment: Pressurized plumbed eyewash stations are provided throughout the shops. For the most part, emergency eyewash equipment in shop areas were observed to clear from obstructions, and appeared to be in good material condition. Continue to ensure plumbed eyewash stations are activated weekly for three minutes to verify proper operation and to flush the line of rust and other contaminants. Ensure required weekly eyewash inspections are routinely documented.

Ergonomic: Employees are provided training to identify hazards for musculoskeletal injury and safe work practices. Some items are heavy and/or awkward to lift and move. Lifting aids are readily available and utilized.

Team lifting is practiced for items that weigh more than 50 lbs. No work-related injuries or ergonomic issues were reported during the walkthrough.

Mats were provided for cushion when standing at machines for extended periods. Most stations provided a chair for use while the parts were being processed. A few were ergonomically designed chairs, although most chairs observed were not. Many were cloth making it difficult to clean. As chairs are replaced they should be replaced with ergonomic chairs made with impermeable materials.

It is recommended that all personnel receive ergonomic training including specific guidance indentified in

OPNAVINST 5100.23G, Ch. 23. Contact the Training Coordinator for assistance with this training.

Design Review: Industrial hygienists are required to actively participate in all facility planning, design, construction, and acceptance projects including both special and military construction projects to ensure appropriate hazard control techniques are applied. Please ensure all special projects, engineering designs, and purchasing contracts involving potential health hazards such as toxic materials, radiation, noise, or other health hazards are sent to the Industrial Hygiene Department for review.

Changes In Workplace Processes: This report reflects conditions and operations at this activity during the survey period. Please notify Industrial Hygiene when significant changes occur in work center operations, chemical use, work processes, SOP revisions, or construction that may adversely affect worker health so review of documentation and evaluation may be conducted.

Customer Satisfaction/Complaint Form: A customer satisfaction/complaint form is found in Appendix F of this report. The first half of the form is a general satisfaction questionnaire and allows for suggestions of improving the services this department provides. The second half of the form provides an avenue for a specific complaint to be filed. Please complete this form as deemed necessary and return to the Naval Health Clinic Industrial Hygiene

Department Head.

This report reflects conditions at 6.0J Industrial Integrated Product Team (IPT), Common Processes/Manufacturing

Aircraft Machinists (Shops 93552/62/67) during the survey period. Periodic industrial hygiene surveys are required for most work places by DOD INST 6055.5. In addition, changes in procedures, processes, or workload that may significantly alter personnel exposures may require more frequent evaluations. Significant changes are defined as workplace modifications that require a change in recommended medical surveillance enrollment, personal protective equipment, or exposure control measures (ventilation, etc). Supervisory personnel should be encouraged to notify the FRC-East Safety Office when significant changes occur.

EVALUATION SUMMARY

PERIODIC INDUSTRIAL HYGIENE SURVEY

FRCE Shops 93552/62/67

New or Significantly Modified Work Center Operations/Processes?

No significant changes in operations/processes were identified. *

The following changes were identified:

Machining bench work from Shop 93562 Machine Repair and Line Shop was moved to Shop 93567 at building 4173 at the time of the IH walk-through. This work center is being reassigned to shop 93567. Some machining equipment from Shop 93562 was being moved to

Shop 93567 at FRCE Bldg. 133. Supervisory personnel indicated that in the future the Line Machinist Shop at Shop 93562 will be its own

Shop, and will be coded 93562. Also, the Machine Repair Shop from 93562 will be merged together with shop 93567. At the time of the

IH walk-through, contractors work adjacent to Shop 93567 was in progress to allow movement and installation of machines from shop

93562 to FRCE bldg. 137 to 133, 93567 Power Plant Shop.

*For purposes of this survey, “significant changes” are defined as workplace modifications that require a change in recommended medical surveillance enrollment, personal protective equipment, or exposure control measures (ventilation, etc).

Program Findings and Recommendations

1. Medical Surveillance Program Status:

No Medical Surveillance is Recommended.

Medical Surveillance is Recommended.

No Change in Medical Surveillance Recommendations.

Medical Surveillance Recommendations have changed as follows: Metal Working Fluids Medical Surveillance Program # 162 is recommended for Shops 93552/62/67 Machinists with health sensitivities to metal working fluids used and is recommended for all new hire

Machinists. Per the National Institute for Occupational Safety and Health: “Medical monitoring is needed for early identification of workers who develop symptoms of MWF-related conditions such as asthma, other respiratory conditions, and dermatitis. If identified early, affected workers can control their exposures and minimize their risks of acute or chronic effects. All exposed workers should be included in an occupational medical monitoring program. However, priority should be given to those at highest risk. Medical monitoring should be conducted regardless of exposure concentration in work areas where one or more workers have recently developed asthma, or other serious conditions apparently related to MWF exposure.”

2. Hazardous Material Control and Management (HMC&M) Program:

AUL Y N N/A Accurate Y N

MSDS Files Y N N/A Accurate Y N HMMS is available.

HAZMAT Training Required? Y N (Note: IH does not track training completion).

Other (lead, asbestos, etc): See Below. Y N

Comments:

Shop personnel potentially exposed to harmful physical, biological, chemical agents and noted reproductive hazards and carcinogens are required to receive hazard training in accordance with OPNAVINST 5100.23G and 29 CFR 1910.1200.

All employees must receive training on hazards associated with the materials utilized with processes before conducting the process.

Shop 93567 requires Asbestos training for the supervisor and those employees involved in asbestos liner remover.

Shops 93567, 93562 and 93552 require Beryllium training for the supervisor and those employees involved in work requiring the machining of Beryllium.

Shop 93562 requires training (Hexavalent Chromium) for the supervisor and employees that may blending/ sanding/buffing/grinding on aircraft lines when incidental contact may occur with aviation surfaces containing paint/primer/potting.

See specific information in Shop Area Hazard Assessments for each shop.

3. Management of Reproductive Hazards:

Reproductive Hazards Present? Y N

Any changes from previous survey? Y N

Comments:

Reproductive hazards identified by the Navy and Marine Corps Public Health Center (NMCPHC) have been identified in these shops and are noted in each shop assessment. It is recommended that wherever possible the work center reduce, minimize, and/or eliminate the reproductive hazards and personnel exposure.

See specific information in Shop Area Hazard Assessments for each shop.

FRCE Shops 93552/62/67

4. Noise and Hearing Conservation Program (HCP):

Are personnel recommended for the HCP? Y N (Note: IH does not track

Are personnel receiving audiograms? Y N N/A training completion)

Is hearing protection readily available? Y N N/A

Is hearing protection used? Y N N/A Not Available for Observation

Comments: All workers in Shop 93567, 93562 & 93552 are included in the Hearing Conservation Program and Noise Medical Surveillance Program.

Personnel were observed using hearing protection when required and the hearing protectors were found to be in adequate stock and maintained in good material condition.

Saws, pneumatic hand tools, pedestal equipment, and compressed air are the primary sources of noise exposure, above the Navy

Occupational Exposure Limit (NOEL), in these shops. Hand tools are labeled with noise hazard labels.

Anyone operating any saw, pedestal equipment, pneumatic hand tool, using compressed air or within 10 feet of anyone performing these activities must wear appropriate hearing protection.

5. Respiratory Protection:

Are respirators used to control workplace exposures? Y N

Are they effective? Y N N/A

Is the Respiratory Protection Program satisfactory? Y N N/A

Comments:

Respirators are used in shop 93552 while machining diffuser housings for humanitarian purposes. A Half-face air purifying respirator equipped with P100 filters are recommended to be used.

Although Machinists indicated that they try to prevent machining on suspect areas with these materials present, respiratory protection is currently required in Shop 93562 when machining parts with visible paint, primer, potting or plate present for health protection measures. A half-face respirator with P100 particulate filters is recommended for all processes requiring respiratory protection.

All Machinists that use respirators for respiratory protection must be included in the respirator medical surveillance program (716) and receive annual training and fit testing on their respirator.

6. Ventilation:

Are ventilation systems used to control workplace exposures? Y N

Are the systems effective and operating properly? Y N N/A A few do not meet requirements

Comments:

Fans shall not be used to control dust. This blows the dust into adjacent areas and does not remove any contaminants.

Fans also disrupt air flow of local exhaust ventilation (LEV) and shall not be utilized in areas where ventilation is used.

The use of ventilated evacuated tools with HEPA filtration is recommended during sanding/grinding activities.

Ventilation systems evaluations are provided in the Individual Shop Area Hazard Assessment.

7. Ergonomics:

Ergonomic risk factors were identified pertaining to shop work office/computer work

Available equipment/furniture incorporates good ergonomic design? Y N N/A (not all)

Ergonomic training recommended? Y N (Note: IH does not track training completion)

Comments and/or Recommendations:

Though a few ergonomically designed chairs were observed, Personnel are at risk of developing Work Related Musculoskeletal Disorders

(WMSDs) as they must assume awkward positions, bend, stretch, lift, use pneumatic hand tools, hand saws and stand for long periods of time.

It is recommended that all personnel receive ergonomic training including specific guidance identified in OPNAVINST 5100.23G, Ch. 23.

Hoists are available throughout the shops for lifting of most heavy parts. Team lifting is practiced in areas where hoists are not available.

Mats are available to reduce fatigue from standing for long periods in front of machines where standing is necessary. Mats are not available in front of all machines and should be provided where standing for extended periods is required.

8. Other Applicable Programs:

Lead Control

Asbestos Control

Carcinogens

Other

Comments:

Stressors identified as known or suspected carcinogens by the Occupational Safety and Health Administration (OSHA), the National

Toxicology Program (NTP), the International Agency for Research on Cancer (IARC), and the American Conference of Governmental Industrial

Hygienists (ACGIH) are noted throughout this report. Stressors identified as known or suspected reproductive hazards by Navy and Marine Corps

Public Health Center are noted throughout this report. Asbestos is present in one process at Shop 93567:: Asbestos Liner Removal using Jig Borers using wet methods. This process is rarely performed.

Consultative or Special Surveys/Findings Since the Previous Survey: (check if none)

FRCE Shops 93552/62/67

Changes to Specific Workplace Evaluations and Monitoring Plan

1. Workplace Assessments:

No significant change to workplace assessment information was identified.

The following significant workplace assessment changes were identified:

Comments: None

2. Exposure Assessment:

New exposure data were obtained since the prior evaluation and are summarized at the end of each shop survey.

No change in any exposure assessment was identified as part of the survey or from sampling data.

The following changes in exposure assessments were identified:

Comments:

See specific results at the end of each Shop Area Hazard Assessment.

3. Findings and Recommendations:

There were no significant findings identified during this survey that require corrective action.

The following significant findings were identified:

Findings/Comments:

29 CFR 1910.141 requires work areas be kept clean to the extent that the nature of the work allows and sweepings be removed in such a manner as to avoid creating a menace to health and as often as necessary to maintain the place of employment in a safe and sanitary condition.

Do not use compressed air for removing dust from work surfaces or clothing. Continue to use industrial explosion proof HEPA vacuums to help clean dry debris and dust from work surfaces.

In most areas employees do not machine cadmium plated aircraft components. The SOP requires that all cadmium surface finishes be chemically stripped from work pieces before they are machined. In the event that abrasive removal is required in one of the shops, Naval

Health Clinic Cherry Point (NHC-CP) IH Department must be contacted prior to the job to evaluate the work process and to perform exposure monitoring.

Employees shall inspect parts for the presence of primer/paint/potting prior to sanding/blending/grinding and parts are rerouted to chemical strip/blasting to have this material removed prior to machining the part.

4. Exposure Monitoring Plan. Required Exposure Monitoring requests are located in the report.

Exposure monitoring needs were identified.

No exposure monitoring needs were identified.

There are no changes to the previous Exposure Monitoring Plan.

Comments: During the 2015 IH survey, an air sample study was conducted in order to evaluate Aviation Machinists inhalation exposure to metal working fluids, specifically, Mineral Oil, Mist, an ingredient of HOCUT 795-B coolant. HOCUT 795-B is used as a machine coolant and is used to help keep the work piece wet during Machining work operations in the FRCE Machine Shops 93552, 93562, and 93567. Mineral Oil is listed as a hazardous ingredient, 30-60% by weight, in the product Safety Data Sheet (SDS) and health effects of exposure listed include respiratory, eye, and skin irritation. The product SDS advises to avoid breathing product mists, and explains that mists may cause irritation of the upper respiratory tract.

During Machine Shop usage, HOCUT 795-B water soluble coolant is diluted in water at a ratio of less than 10% HOCUT 795-B to 90% or greater

Water. All air sample results were below regulatory and recommended occupational exposure limits: the Navy OEL and OSHA Permissible Exposure

Limit, and NIOSH Recommend Exposure Limit (REL) occupational exposure limits. Sample results are provided in each individual shop report and at the end of this survey report. All results were below the analytical laboratory detection limit except for one air sample, sample #15-0537. For that sample, grinding was conducted using an older Campbell Vertical Grinder that has no enclosure, but does have an exhaust ventilation/mist collector system that was used. Even though there was a detectable concentration, the sample result was well below all the noted occupational exposure limits.

-New air sample data for Machining Beryllium stock is included. All samples were below the analytical limit of detection for beryllium.

-Additional personal breathing zone air samples for specific stressors, area samples, and noise samples are presented in each individual shop hazard assessment report.

SHOP AREA HAZARD ASSESSMENT DATE: 1, 2, 8, 9 JULY, & 20 AUGUST 2015

RECORDED BY: Daniel R. Gilleski

INSTALLATION: FRC-East

BUILDING NUMBER: 137

SHOP NAME: 93552 Manufacturing Machine

Shop

SUPERVISOR: Mark Gillikin

PHONE: 464-8282/7912

TOTAL PERSONNEL: 19 MALE 19 FEMALE 0

SHOP OPERATIONS: Personnel use shop machine tools and hand tools to manufacture and repair a variety of aircraft components.

OPERATIONS AND ASSOCIATED

HEALTH HAZARDS

WORKERS-

DURATION/

FREQUENCY OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

1. Administrative work:

Ergonomic hazards;

5 Programmers and 1

Engineer, Variable/

Intermittent during 8 hour shift

Ergonomic Training Ergonomics Hazards – No reported issues, however, potential exists for ergonomic injuries to occur. Ensure all personnel receive training on prevention of ergonomic injury (Reference

OPNAVINST 5100.23G, Ch. 23)

2. Machining Operations (Dry): Manual hand

Machining various metal aircraft parts- (e.g. manual use of scotch brite pads & emory tape, in the shop.

Inhalation and Skin Exposures Hazards:

Metal and synthetic dusts and chips created from machining parts:

Aluminum is primary metal machined 90% of time, Stainless Steel and other alloy metals are used less often, approximately 10% of the time.

(Note: alloys may contain – C, Mn, Cr, Mo, Ni, Fe, P, S, Si, Al, Cu, Zn, Ti, Zr, O, N, H, B, Co, W, V), Nickel, Iron, Teflon, epoxy, nylon, Bakelight, Delrin

Any 1 of 19 workers-

Intermittent duration per shift/ estimate:

30 minutes per person/ per shift

General ventilation, PPE: Safety glasses with side shields, safety shoes, appropriate protective gloves, insert ear plugs: 3M

UltraFit, NRR = 25 dBA and/or muffs

(when using compressed air and when material being machined causes higher noise levels);

Inhalation Exposure: ACCEPTABLE

- based on existing controls and short task duration of dry machining work tasks.

3. Machining Operations (Dry): Machining various aircraft parts with pneumatic hand tools such as pneumatic hand tools including: impact wrenches, air ratchets, and grinders (discussed below).

Inhalation Hazards: Metal and synthetic dusts and chips created from machining parts: Aluminum is primary metal machined 90% of time, Stainless Steel and other alloy metals are used 10% of the time.

Noise Hazards pneumatic hand tools, compressed air and vacuum; Sound pressure level averaged 85-87 dBA

(91peak), when worker used a pneumatic grinder to buff aluminum (I.H. log #15-0496).

Any 1 of 19 workers-

Intermittent duration per shift/ estimate:

30 minutes- 1 hour intermittent per person/ per shift

Engineering controls: General ventilation, Explosion proof

HEPA vacuums

PPE: Safety glasses, safety shoes, leather gloves, insert ear plugs: 3M UltraFit, NRR = 25 dBA, muffs

Inhalation Exposure: ACCEPTABLE -based on current work practices, Noise Exposure: UNACCEPTABLE during use of pneumatic tools; however, 8-hr Time Weighted Average (TWA) noise exposure is not routinely expected to exceed the OEL of 85 dBA.

The use of hearing protection is required.

The use of double hearing protection

(muffs and insert plugs) is required when using air ratchets and impact wrench.

WORKERS-

DURATION/

FREQUENCY OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

4. Machining 2nd Stage Diffuser Housing: Diffuser is machined dry using a handheld pneumatic tool with a

3M Scotch Brite Roloc Surface Conditioning Disk

TSM.

Nuisance Dust

-Dust created from scotch brite disk contains Aluminum

Oxide mineral, talc, lubricant, nylon fiber, cured resin and additive.

- Dust associated with remaining coatings on part when worked (paint, primer etc.) which may contain:

potassium ferricyanide, hydrochloric acid, acetic acid, chromic acid, strontium chromate, sodium fluorosilicate, sodium fluroborate, zirconium potassium fluoride, EPON 1001 resin, quartz, polyamide resin, triethylene tetramine amino ethyl piperazine nonyl-phenol, aluminum, nickel, miscellaneous organics

(including – toluene, xylene, methyl isobutyl ketone, ethylene glycol mono butyl ether, di ethylene glycol mono butyl ether acetate, etc) titanium dioxide, barium chromate, isocyanates (HDI), barium sulfate, carbon black, copper, and antimony trioxide

1-3 workers – 2 man-hours/week;

Less than 1 minute duration of time that part is sanded.

Controls: wet methods and HEPA vacuums during process and for clean-up.

PPE: Safety glasses, safety shoes, leather gloves, insert ear plugs: 3M UltraFit, NRR = 25 dBA, half face air purifying respirator equipped with P100 particulate filters

Inhalation Exposure: UNCERTAIN:

however, overexposures are not expected based on short task duration.

2nd Stage Diffuser Housing (and any other parts conditioned with Scotch Brite Disks) must be conditioned in a ventilated area or the operator must wear a respirator with

P100 filters - employees performing this work must be entered into the respirator user program, enroll in medical surveillance (#716) and receive annual training and fit testing.

5. Machining Operations (Wet): Machining various aircraft parts on shop machines with no enclosures, (e.g.

Weilier Lathe, E90 CNC lathe):

Inhalation and Skin Exposures Hazards:

Machining fluids:

Hocut 795-B (179309): Mineral Oil (30-60%) and glycerin (1-10%), by weight.

machining parts: Aluminum is primary metal machined 90% of time, stainless steel and other alloy metals are used less often, approximately 10% of the time.

Alloys machined may contain – C, Mn, Cr, Mo, Ni, Fe, P, S, Si, Al, Cu, Zn, Ti, Zr, O, N, H, B, Co, W, V, Nickel, Aluminum, Iron, & may machine Teflon, epoxy, nylon, Bakelight, Delrin.

Noise Hazards compressed air and vacuum, certain materials and shapes result in higher noise levels than typical materials being machined. Sound pressure levels have been measured to be below 85 dBA.

Carcinogens and suspected carcinogens: chromium, nickel

11 workers-

6-8 hours day per person

Engineering: wet machining methods using Hocut coolant; splash guards gloves, ear plugs, based on existing controls and air sample results. Current air sample results are presented at the end of this report section.

Noise Exposure: ACCEPTABLE based on noise data. Hearing protection is required when using compressed air and if noise levels are expected to be elevated from the norm due to shape or composition of material being machined.

TWA is not expected to exceed the

Occupational Exposure Limit (OEL).

6. Machining Operations (Wet): Machining various aircraft parts (enclosed machines with/without mist collectors, (e.g. VMC 4020 CNC Mill)):

Machining fluids: Hocut 795-B (179309): Mineral Oil

(30-60%) and glycerin (1-10%), by weight.

15 workers-

10 man-hrs/ day

Engineering controls:

enclosures, mist collectors, exhaust ventilation system;

wet methods, splash guards;

based on existing controls. Current air sample results are presented at the end of this report section.

WORKERS-

DURATION/

FREQUENCY OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Metal and synthetic dusts and chips created from machining parts: Aluminum is primary metal machined 90% of time, Stainless Steel and other alloy metals are used less often, approximately 10% of the time. Alloys machined may contain – C, Mn, Cr, Mo, Ni, Fe, P, S, Si, Al, Cu, Zn, Ti, Zr, O, N, H, B, Co, W, V), Nickel, Aluminum, Iron, and may machine Teflon, epoxy, nylon, Bakelight, Delrin.

PPE: safety glasses, gloves, insert ear plugs, Administrative:

safety procedures

7. Machining Beryllium-Copper Alloys (wet)

(typically machined on 2 lathes):

Inhalation, skin exposures hazards: Metalworking fluids (primarily Hocut 795-B (179309): Mineral Oil

(30-60%) and glycerin (1-10%), by weight.

Alloys C172 & C173: Copper/ Beryllium Alloys:

(Beryllium < 2.0%, Lead 0.2 – 0.6%) and

Alloy C174 Copper/ Beryllium Alloys:

(Beryllium 1.50 - 1.55%, & Cobalt 0.35 – 0.36 %)

Alloy C175 Copper/ Beryllium Alloy:

(Beryllium 0.4 – 0.7%, & Cobalt 2.4 – 2.7 %)

Note: Toxic metals including Be are in very low composition of Cu/Be alloys used. No dust is generated when machining wet or handling machining shavings/chips of Beryllium Copper alloy after machining wet. Work precautions must continue to prevent potential dermal exposure when handling Be/Ce shavings and chips, and Be/Cu stock material.

Carcinogens and suspected carcinogens: Beryllium, Cobalt, Nickel and Lead

1-2 workers-

Variable frequency and duration based on aircraft line demands; estimated

12 man-hours per week

Note: at the time of the IH walk-through the shop was manufacturing H-53 bushings from C172

& C173 Cu/Be alloy.

Engineering: wet machining methods using Hocut coolant, mist collectors and splash guard used on lathe without enclosure, PPE: Safety splash goggles, safety shoes, Tyvek coveralls, earplugs, nitrile gloves, leather gloves, Administrative/

Safety procedures:

SOPs, signage and decontamination procedures

Inhalation: ACCEPTABLE based on existing controls and work practices, current air sample results, warning signage, wet methods and, SOPs.

Skin exposure: Per current safety policy, gloves must be worn when handling

Beryllium (Be) stock and during cleanup.

Be is a sensitizer. Continue to wear impermeable gloves (usually nitrile rubber) when working with solvents and leather gloves when handling pieces with sharp edges.

Current air sample results are presented at the end of this report section.

8. Stock Prep/Metal Cutting – Cutting a variety of metals to usable size of varying shapes and sizes using a variety of saws (e.g. band saws, vertical band saw, abrasive circular saw, etc).

Inhalation and Skin Exposures hazards:

Metal Dusts, synthetic dusts (fiberglass and composite)

Noise hazards: Metal cutting, hand tools and machines in surrounding area that exceed the NOEL of 85dB(A) and nickel

1-2 workers;

Intermittent, 1-4 hours per shift/

30 seconds- 0.5 hour per cut/

Engineering:

machine guards, the vertical band saw uses a coolant that floods the metal being cut, which minimizes metal dust generation.

PPE: Safety glasses, Face shields, safety shoes, leather gloves, insert ear plugs and ear muffs, Administrative:

SOPs based on type of cutting and minimal occurrence.

Noise Exposure: UNACCEPTABLE:

based on noise data presented below in the sound level survey. Must use hearing protection and enrollment in the Hearing

Conservation Program is required for

Machinists that work with the saws to cut metal. Double Hearing Protection required with abrasive circular saw use.

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9. Water Knife Operation – This stock prep with skill saw process is now conducted with Shop 93553 water knife in the adjacent shop area. Skill saw is no longer used for stock prep. Shop saws above are used as needed.

Metal Dusts, synthetic dusts (fiberglass and composite)

Noise hazards: Metal cutting, hand tools and machines in surrounding area that exceed the NOEL of 85dB(A)

1 worker

1- 2 man-hour per week/ intermittent

Safety glasses, safety shoes, leather gloves, ear plugs and ear muffs and face shield, machine guards based on type of cutting and minimal occurrence.

Hearing Protection must be used as required.

10. Dry sanding and grinding Operations: Sanding and grinding various aircraft parts, deburr parts and shape tools with machines, pedestal equipment

(grinders, buffers, sanders and belt sanders).

Aluminum is primary metal machined 90% of time, Stainless Steel and other alloy metals are used less often, approximately 10% of the time.

Alloys may contain – C, Mn, Cr, Mo, Ni, Fe, P, S, Si, Al, Cu, Zn, Ti, Zr, O, N, H, B, Co, W, V), Nickel, Aluminum, Iron; and Teflon, nylon, Bakelight, Delrin, Norton Bear-Tex Convolute wheels (carbon black, calcium stearate, polyurethane resin, talc, nylon, silicon carbide, phenol formaldehyde polymer)

Noise hazards: Pedestal equipment (wheels and belts) exceed the NOEL of 85dB(A)

Carcinogens and suspected carcinogens: chromium and nickel

Any 1 of 11 workers

– ≤0.5 man-hours per day intermittent, typically ‹30 seconds per event

Engineering:

Machine guards, HEPA vacuums for dust clean-up.

PPE: Safety glasses, face shields, safety shoes, leather gloves, insert ear plugs and muffs.

Administrative:

safety procedures based on current work practices, short duration, previous exposure monitoring results.

NOTE: This process does not include sanding of paint, primer, plating, potting, adhesive or carbon epoxy coatings.

during use pedestal equipment

(grinders, buffers, sanders and belt sanders); Must wear hearing protection with pedestal equipment and where posted.

11. Spray/Wipe Cleaning Machinery:

Inhalation and Skin exposures: Daily end of shift cleaning is performed for work area and machinery

(≈5-15 minutes) Once a month all employees are involved in a shop clean-up where all surfaces are cleaned. This process last ≈4 hours and every surface below 6’ is cleaned.

Inhalation and Skin exposures:

FRCE approved chemical cleaner ingredients- some may be skin and respiratory irritants, Isopropanol, Carcinogens and suspected carcinogens: none

Reproductive hazards: glycol ether

11 workers –

5-10 minutes / shift / worker

Safety glasses with side shields, nitrile gloves, safety shoes

Inhalation: ACCEPTABLE: based on minimal occurrence and general ventilation.

Skin exposure: Continue to wear nitrile gloves when working with solvents.

12. Dip Corrosion Preventive Compound (CPC) note: workers primarily apply by dip coating from a

1 gallon metal canister containing CPC and dip and apply using an application brush

Inhalation and Skin exposures :

Aerosol CPC (180910): 1,1,1,2-Tetrafluoroethane, Naphtha Solvent, Medium aliphatic, Barium Oxidate, Barium Sulfonate, Liquid CPC (So Sure - 172917): Petroleum Sulfonate and Stoddard Solvents

Any 1 of 19 workers

≤ 0.5 man hours per day/ intermittent

General or local ventilation, Safety glasses with side shields, rubber

(nitrile) gloves, safety shoes, Inhalation: ACCEPTABLE based on minimal occurrence and good general ventilation and the CPC does not contain

Chromium

Skin exposure: Continue to wear gloves when working with solvents

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13. Brush Application of Layout Fluids, Dyes, &

Removers

Inhalation and Skin exposures:

Steel Blue Layout Fluid (158988): Butyl ester acetic acid, n-butyl alcohol, n-propyl acetate, nitrocellulose, isopropyl alcohol, ethanol

≤0.15 man hours per month/ intermittent

General ventilation, Safety glasses with side shields, nitrile gloves, safety shoes, good general or local exhaust ventilation.

Inhalation: ACCEPTABLE based on minimal occurrence and good general ventilation

Skin exposure: Continue to wear gloves when working with solvents

14. Foil packet Epoxy Primer (used in place of

Sempen) :

Inhalation and Skin Exposure:

182470 Ethylbenzene, 1-Butanol, Acetone, Methyl n-

Amyl Ketone, Amidoamino Polymer, Polyamidoamine, Amorphous Precipitated Silica, Titanium Dioxide and

Strontium Chromate/182471 ethylbenzene, xylene, acetone, methyl isobutyl ketone, methyl n-amyl ketone, epoxy polymer

Carcinogens and suspected carcinogens: Strontium

Chromate

Reproductive hazards: xylene

Not routinely used;

Any 1 of 19 workers

≤0.15 man hours per week/

General ventilation, Safety glasses with side shields, butyl rubber gloves, safety shoes

Inhalation: ACCEPTABLE based on minimal occurrence and good general ventilation, brush/stick application

Skin Exposure: brush application method and small quantities applied.

Continue to wear gloves during application process

15. Faro Platinum Laser Scan Arm V2 Inspection

Laser:

Inspection tool used to scan part which reflects laser back to the reader to be transmitted to computer for a 3-

D image.

Laser Hazards: Class 2 exposures

Carcinogens and suspected carcinogens: none

Reproductive hazards: none

Any 1 of 6 workers;

Rarely used/

0.5 hour per year

Laser safety training, safety glasses with side shields, safety shoes

Laser Exposure :

The Class II laser measuring system is open. Overexposures are not expected because of the level of the laser, although over-exposures can occur if an individual stares into the laser. Hazard specific safety training must be provided for all operators. No medical surveillance is required.

16. Glove Box Blasting: Deburring and final finish on parts manufactured in this shop. This is typically stock metal with no coatings. No aircraft parts are blasted.

Inhalation and Skin Exposures Hazards.

Hazards: glass blasting media, dust from items being blasted (Aluminum and stainless steel stock (Cr, Ni, Nb, Mo, Ti, Fe, C, O))

Noise Hazards: blasting

< 30 minutes per day.

Engineering-enclosed-ventilated system; Safety glasses, ear plugs, safety shoes, nitrile gloves;

Inhalation Exposure: ACCEPTABLE –

Based on enclosed system, SOP and training. Overexposures are not anticipated. Respiratory protection is not required. System is to remain closed until the area clears after blasting.

Skin Exposure: Continue to use nitrile gloves to reduce potential spread of infection from the use of shared PPE (i.e.

glove box gloves)

Noise Exposure: UNACCEPTABLE based on noise data. Must wear hearing protection for this process and where posted.

17. Compressed Air Etching (Viberpeen/Engraver):

Etch information onto parts and stock

Noise Hazards: Compressed air use, operation of pneumatic engraver

Ergonomic Hazards: Vibration

< 1 man hours/week

Safety glasses with side shields, safety shoes, ear plugs/ ear muffs

Noise Exposure: UNACCEPTABLE based on noise data. Must use hearing protection and enrollment in the Hearing

Conservation Program is required.

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GENERAL COMMENTS/& RECOMMENDATIONS:

SHOP NOISE EXPOSURES: A noise survey of the 93552 Machine Shop was performed in 2014 and 2015 and the results are provided below in the noise survey table. In addition, personal noise dosimetry was performed in this shop earlier in 2015 (February), and in years past. Both current noise exposure results and historical noise dosimetry results are also presented below.

Based on statistical analysis of noise dosimeter data collected in shop 93552, shop personnel are not routinely expected to exceed the 8-hr TWA of 85 decibels (dBA). However, there are work tasks that may be performed by some workers, including cutting metal with band saws and the use of the shop abrasive circular saw and belt sander, and using other shop’s noise hazardous equipment which may expose workers performing those tasks to noise levels above 85 dBA. Other noise hazardous shop equipment include: pedestal grinders/buffers, use of pneumatic hand tools (ratchets/impact wrench), the use of hand held pneumatic grinders used to buff/grind metal such as aluminum, and the use of pneumatic air (air gun) attachment on

CNC Mills, especially when spraying down within enclosed mills, and compressed air etching using the pneumatic viberpeen/engraver, and operation of the shop forklift. Those identified noise hazardous equipment are generally operated for short periods of time per person (less than 30 minutes duration), and when performed with other Machining work tasks, do not routinely cause Machinists to be overexposed to noise for their 8-hr or 10-hr work shift based on collected noise dosimeter data. However, overexposures to noise may occur. During the IH walk-through on multiple days, workers were observed using hearing protection devices (insert ear plugs), when engaged in noise hazardous work tasks.

RECOMMENDATION(s): We recommend that Machinists that may cut metal using shop band saws, abrasive circular saw, and who may use the belt sander on metal, and compressed air etcher (viberpeen/engraver), to be required remain in the Hearing Conservation Program including the Noise

Medical Surveillance Program. Continue to use hearing protection when engaged in noise hazardous work tasks. Continue to use double hearing protection (insert plugs and muffs) when operating the abrasive circular saw and when using the belt sander to sand metal. The use of double hearing protection is required when using pneumatic air gun after machining, even though this work task only takes seconds duration, and when compressed air etching using the viberpeen/engraver, and when using other compressed air hand tools(ratchets/impact wrench) from tool kits. Continue to use single hearing protection when specified in this survey and other FRCE IH and safety surveys, when the noise level has been identified to be above 85 dBA, for any duration of time. Any noise exposure at or above 96 dBA requires the use of double hearing protection- muffs and insert plugs.

The abrasive circular saw needs a noise hazard label/sticker to be attached to the saw, to warn workers that double hearing protection (insert plugs and muffs) is required during operation due to sound pressure levels exceeding 96 dBA during operation. The belt sander also needs a noise hazard label/sticker to be attached. Ensure the viberpeen/engraver has a noise hazard sticker indicating double hearing protection is required during use.

MACHINING BERYLLIUM-COPPER ALLOYS (WET- USING HOCUT 795-B COOLANT): Air samples were collected during the IH survey while Machinists manufactured H-53 bushings using Copper/Beryllium (Cu/Be) Alloy, which contains less than 2.0% Beryllium by composition that is chemically bound to copper metal. The Machinists used an enclosed lathe and a lathe without an enclosure. Results are presented below. This machining process does not produce a dust. Cu/Be alloy metal chips and shavings are created and the waste material is treated as hazardous waste.

There was no concentration of Be detected by the analytical laboratory. Continue to follow FRCE Safety Policy when working with Cu/Be alloys. We recommend the Machinist performing this task, use disposable nitrile gloves after machining when the Machinist cleans up the machine after manufacturing. Continue to follow good personal hygiene practices, such as washing hands and arms after handling and cleaning up shavings, and not drink or eating in the work area when working with Cu/Be alloys. Continue to follow FRCE Beryllium Safety and Health Policy.

METAL WORKING FLUIDS USED AND PERSONAL HYGIENE WORK PRACTICES & SKIN PROTECTION

RECOMMENDATION(s): We recommend using disposable nitrile gloves and safety glasses/goggles anytime that skin and eye exposure may occur such as when draining and refilling machine coolant. Continue to wear impermeable gloves, usually nitrile rubber, when hand contact with coolant and metal working fluids may occur. We also recommend the use of nitrile gloves while clean-up after machining when contact with coolant fluids is possible. Continue to maintain good personal hygiene by cleaning skin that becomes splashed or immersed in coolant or metal working fluid, especially before breaks and meals, with soap, clean water, and clean towels. Workers should change work clothing that becomes soaked with metal working fluids and contaminants during the work shift (reference: OSHA Metalworking Fluids; Safety and Health Best Practices Manual). Continue to follow good work practices in order to minimize inhalation and skin exposures to coolants and metal working fluids. During the survey, it was observed that workers were using good personal hygiene practices, such as frequent hand and arm washing at shop hygiene station, after machining work tasks.

ERGONOMIC HAZARDS: There were no reported issues during the IH walk-through; however, the potential exists for ergonomic injuries to occur.

Ensure all personnel receive training on prevention of ergonomic injury (Reference OPNAVINST 5100.23G, Ch. 23). Identified potential ergonomic hazards include the use of pneumatic hand tools with high hand force (pinching, gripping and hand-arm vibration).

POTENTIAL REPRODUCTIVE HAZARDS IN THIS SHOP: Nickel, found in metal alloys, (e.g. INCONEL), is a potential health hazard(s) and

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has been classified as a known occupational reproductive hazard in NMCPHC-TM-OEM, 6260.01C, April 2010. Noise is also an identified potential female reproductive hazard during pregnancy. Work practices to minimize employee exposures to the identified stressors should be followed to the maximum extent practicable. Individuals with questions concerning reproductive issues are encouraged to consult with Naval Health Clinic Cherry

Point, Occupational Medicine Department physician or private physician.

USE THE FOLLOWING EXPOSURE CODES:

ACCEPTABLE – ONE WHERE THE IH WILL NOT EXPECT THE SEG TO BE EXPOSED ABOVE THE SELECTED OEL.

UNCERTAIN – ADDITIONAL DATA NEED TO BE COLLECTED TO CLARIFY THE EXPOSURE ASSESSMENT. THE IH

SHOULD MAKE AN INTERIM EXPOSURE ASSESSMENT BASED ON OBSERVATION OF THE PROCESS AND/OR

PROFESSIONAL JUDGMENT.

UNACCEPTABLE – ONE WHERE THE IH WILL EXPECT THE SEG TO BE EXPOSED ABOVE THE SELECTED OEL.

SKIN – THE MATERIAL POSES A SKIN ABSORPTION HAZARD

REPRODUCTIVE HAZARD – THE MATERIAL IS A NAVY-RECOGNIZED REPRODUCTIVE HAZARD

CARCINOGEN – THE MATERIAL CONTAINS > 0.1% OF AN OSHA, ACGIH, IARC, OR NTP-RECOGNIZED CARCINOGEN

MEDICAL SURVEILLANCE TABLE

WORK

OPERATION/TASK

RECOMMENDED MEDICAL

SURVEILLANCE PROGRAM

MEDICAL PROGRAM

NUMBER

JOB TITLE/ ESTIMATED

NUMBER OF WORKERS/

C…