Attachment_04j_2015_IHS_of_93553_Shop.pdf

2015 PERIODIC INDUSTRIAL HYGIENE SURVEY

OF

93553 COMPONENT MANUFACTURE, WELD AND REPAIR SHOP

INDUSTRIAL HYGIENE DEPARTMENT

NAVAL HEALTH CLINIC

CHERRY POINT, NC 28533-0023

Enclosure (4)

TABLE OF CONTENTS

EXECUTIVE SUMMARY……………………………………………………………………………………………………..…..3

EVALUATION SUMMARY……………………………………………………………………………………….................…...5

INDIVIDUAL HEALTH HAZARD ASSESSMENT & MEDICAL SURVEILLANCE RECOMMENDATIONS

COMMON PROCESSES………………………………………………………………………………………….….8

SHEET METAL/BENCH AREA………………………………………………………………………

SHOP WELDING AREA…………………………………………………………………………………………...21

WELDING SCHOOL AREA…………………………………………………………………………………….…34

HEAT TREAT AREA……………………………………………………………………………………………….39

FOUNDRY……………………………………………………………………………………………………

TANK AND COOLER AREA & TUBING WORK AREA…………………………………………………….…48

HOSE AREA………………………………………………………………………………………………………...53

LASER CUTTER/PUNCH/WATER KNIFE OPERATIONS………………………………………

PATTERN MAKER AREA……………………………………………………………………………………...….59

GUIDELINES FOR WORKING IN HOT ENVIRONMENTS…………………………………………………………………..65

COMBUSTIBLE DUST CONTROL RECOMMENDATIONS……………………………………………………………….…67

FLAMMABLE DUSTS SAFETY INFORMATION……………………………………………………………………..………68

GLOSSARY OF TERMS APPENDIX A

CUSTOMER SATISFACTION FORM APPENDIX B

EXECUTIVE SUMMARY

A periodic industrial hygiene survey of Fleet Readiness Center-East Component Manufacture, Weld and Repair Shop (93553) was conducted by Mr. Daniel R. Gilleski, Industrial Hygienist, in August-September 2015, with additional exposure monitoring performed in November 2015. Industrial hygiene technician support was provided by Aquiles Faustino. The purpose of the survey was to evaluate any changes to work processes or work practices that have occurred since our previous survey in 2014.

Areas of particular concern or Command interest are as follows:

1. 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. Medical Surveillance Recommendations are presented in a table behind each IH survey shop section hazard assessment.

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-

9860 or 464-7045 for appointment scheduling, cancelation or changes to appointments for the required medical surveillance physicals. As staffing changes occur and medical surveillance recommendations change, FRC-East Safety department must be made aware of any changes to the registry and appointments scheduled as necessary.

2. ENGINEERING CONTROLS/VENTILATION:

Salt-bath/Foundry work areas: The exhaust ventilation system above the salt-bath work area and foundry has been repaired since our previous IH survey. We recommend anyone working in these areas to be trained on the how to turn on and off these systems when needed. During multiple days of the IH walk-through, the salt-bath ventilation was turned off even though the ventilation system was working appropriately because workers did not know how to turn it

on. We recommend keeping this system on when possible to help minimize heat in this work area. We recommend turning on the exhaust ventilation system in the foundry work area before operations, if they resume in the future.

Continue to obtain help form Maintenance Staff when needed to troubleshoot ventilation problems that may arise.

Weld School Local Exhaust Ventilation: Exhaust Hoods (1) 137-C47, (2) 137-C47, (3) 137-C46, (4) 137-C46, (5)

137-C48, (6) 137-C48, (7) 137-C70, (8) 137-C70, (9) 137-C46, (10) 137-C46, (11) 137-C47, (12) 137-C47 measured airflow velocity measurement result was significantly below the recommended airflow. It was observed on some of the welding benches that the exhaust ventilation slots have been covered by metal mesh covering because students were reported placing debris in the slots during courses. This likely attributed to the reduction in measured airflow.

We recommend placing a facilities work order to remove the metal mesh coverings positioned over the exhaust ventilation slots in order to help improve the exhaust airflow and instruct students to not place debris in the ventilation system.

Sheet Metal Work Area Ventilation Recommendation: During this survey sheet metal personnel reported that they have been primarily working Titanium metal parts. However, we still recommend the design and installation of a downdraft table in the Sheet Metal “Steel Pit” work area for pneumatic metal sanding/grinding/routing work on aluminum, Inconel, and stainless steel materials. This will help reduce personnel exposure to metal dusts during pneumatic sanding/grinding/routing work activities and to improve workplace hygiene. An example of a downdraft bench exhaust ventilation system that may be obtained from a ventilation engineering/design company is: Donaldson-

Torrit, Models DB-2000 and DB-3000 downdraft bench, and product information is provided on their website. In addition, another similar downdraft table exhaust ventilation system may be obtained from a similar ventilation engineering/design company. Another engineering control option is obtaining metal sanding/grinding/routing tools with exhaust ventilation system; low-volume high velocity exhaust system with High Efficiency Particulate Air

(HEPA) filtration, to be used as an option if large scale repair work is planned that may produce large amounts of metal dusts.

3. COMBUSTIBLE DUST HAZARDS: This shop works with metals that are considered combustible dusts (e.g. aluminum, magnesium, iron, zinc, titanium, and certain wood dusts). Continue to practice good housekeeping practices to reduce the accumulation of combustible dusts. It was observed that work surfaces are kept clean and shop workers can check out from the

Tool Room a pneumatic air attachment with an exhaust vacuum attached to a filter bag for cleaning of generated metal dusts. In addition, waste metal dusts are disposed in a separate accumulation drums in order to prevent the spread of metal dusts. Shop areas also have HEPA vacuums available in order to clean shop areas of non-metal dusts. Safety procedures were observed to keep incompatible metals separated during pedestal sanding/grinding in order to help reduce the potential fire hazard risk. Class

D fire extinguishers are readily available in the shop. A flammable dust informational fact sheet regarding these metals and some recommendations to help control the accumulation of combustible dusts is provided at the end of this report for informational purposes and additional worker training.

4. HAZARD COMMUNICATION/MATERIALS PROGRAM: Personnel receive initial training to inform them of potential job-related 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, in the Hazardous Material Management System (HMMS).

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 components present and available for exposure in any part to be worked (welding, machining, etc.). Additional training should be provided whenever process changes, employee transfers, new hazards, etc. occur.

Safety Data Sheets (SDS) are available to the employees through the HMMS. Some workers must request a copy from a fellow worker with access to the system. Shop workers are trained initially and biennially on how to access data and interpret information obtained from an SDS. Workers interviewed seemed knowledgeable about the hazards associated with their duties.

Most hazardous materials containers were appropriately labeled.

5. HEARING CONSERVATION PROGRAM: Revised Interim Navy Medicine Hearing Conservation Program Guidance

(dated 24 April 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 worn 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 dBA. Operations with SPLs exceeding 96 dBA, regardless of duration, require double hearing protection. Most personnel were observed wearing appropriate hearing protection during the survey. Hearing tests are required on employees working in areas where the 8-hour time weighted average is above 85 dBA (OEL). At this time, all personnel in the Component Manufacture, Weld and Repair Shop (93553) are enrolled in the Hearing Conservation Program and receive annual audiograms.

6. HEAT STRESS: Continue implementation of a heat stress management program which includes annual heat stress training for workers and supervisors, heat stress hygiene practices, and medical surveillance for personnel that may experience heat strain.

A heat stress fact sheet , GUIDELINES FOR WORKING IN HOT ENVIRONMENTS, is provided at the end of this report to share with shop workers for additional worker training regarding heat stress management practices.

7. PERSONAL PROTECTIVE EQUIPMENT (PPE): Adequate PPE is readily available to all personnel. During the walkthrough, the PPE in use was clean, in a usable condition and properly stored.

8. EYEWASH/SAFETY SHOWER EQUIPMENT: Five pressurized plumbed eyewash/safety shower stations are located throughout the shop (next to laser room, storage area of welding school, behind foundry, tank and cooler area and area next to shop welding between NDI station and water knife). Continue to ensure access to the units are unobstructed and kept clear and that weekly inspections are documented for all stations (this inspection should include activating for three minutes to verify proper operation and to flush the line of rust and other contaminants).

9. 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.

10. CHANGES IN WORKPLACE PROCESSES: This report reflects conditions and operations at this activity during the survey period. Please notify the 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.

11. CUSTOMER SATISFACTION/COMPLAINT FORM: A customer satisfaction/complaint form is found in Appendix B 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.

12. This report reflects conditions at (93553) Component Manufacture, Weld and Repair Shop 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

SHOP 93553

COMPONENT MANUFACTURE, WELD AND REPAIR SHOP

New or Significantly Modified Work Center Operations/Processes?

No significant changes in operations/processes were identified.

The following changes were identified: (see comments)

Comments: A new laser punch/cutter, TruMatic 6000 laser cutter and punch machine, has been installed since our previous IH survey. Workers are in progress of training on use of this new laser punch machine. Personnel use as needed for workload in addition to the Strippit Laser cutter. In addition, Foundry work tasks have not been performed during the survey period. 25 August

2015 was the most recent day of foundry work operations. No further work was reported. Contact IH when processes resume.

Program Findings and Recommendations

1. Medical Surveillance Program Status: Medical surveillance requirements are included in each shop section report to ensure

Medical Surveillance Program enrollment(s) for applicable shop personnel. The FRC East Division Secretaries will compile registries and schedule the required medical surveillance physicals with the Naval Health Clinic Occupational Medicine

Department.

No Medical Surveillance is Recommended.

Medical Surveillance is Recommended.

No Change in Medical Surveillance Recommendations.

Medical Surveillance Recommendations have changed as follows:

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

AUL Y N N/A Accurate Y N

MSDS & Hazardous Waste Profile Y N N/A Accurate Y N

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

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

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. It is recommended that wherever possible the work center reduce, minimize, and/or eliminate the reproductive hazards and personnel exposure.

4. Noise and Hearing Conservation Program (HCP):

Hearing Conservation Program (HCP) DoDI 6055.12, December 3, 2010 has been implemented since the last survey. Occupational

Exposure limit is 85 dBA with a 3 db exchange rate.

Are personnel recommended for the HCP? Y N

Are personnel receiving audiograms? Y N N/A (Note: IH does not track training.)

Is hearing protection (HP) readily available? Y N N/A

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

Comments: All personnel in 93553 are enrolled in the Hearing Conversation and Noise Medical Surveillance Programs.

The use of double hearing protection (muffs and insert plugs) is required at the sheet metal area when using the pneumatic

Vibropeen etcher/engraver, and during operation of other tools and equipment producing sound pressure levels above 96dBA as identified in this IH survey. However, the majority of shop personnel were observed using single hearing protection when needed.

Both insert plugs and muffs were readily available for usage as needed.

5. Respiratory Protection:

Are respirators used to control workplace exposures? Y N Note: Respirators in 93553 are not routinely used.

Are they effective? Y N N/A

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

Comments: Workers do not routinely use respirators in this shop because of available engineering controls. Personnel in this program must be medically qualified and receive annual fit tests and training. Respirators equipped with particulate filters, (e.g.

N95 or higher filtering efficiency), should be offered to workers with health concerns when workers perform “heavy” sanding, grinding, deburring, or routing of aluminum, stainless steel, nickel alloy containing or other aircraft metal materials. Sanding of chromate primed aviation parts was reportedly not performed by shop workers; however, if performed to remove small areas of parts, the use of a half face air purifying respirator equipped with HEPA filters (e.g. P-100 series filters) is recommended. Some workers may choose to use respirators voluntary during some foundry work and pattern making work tasks identified in this survey, even though no overexposures to chemical stressors above occupational exposure limits are anticipated based on previous monitoring and/or evaluation of the work task. We recommend enrollment of those workers in the respiratory protection program.

An FRCE safety representative manages the Respiratory Protection Program including training, fit testing, and respirator selection requirements.

6. Ventilation:

Are ventilation systems used to control workplace exposures? Y N

Are the systems effective and operating properly? Y N N/A

Comments: Weld School Local Exhaust Ventilation: Exhaust Hoods (1) 137-C47, (2) 137-C47, (3) 137-C46, (4) 137-C46, (5)

137-C48, (6) 137-C48, (7) 137-C70, (8) 137-C70, (9) 137-C46, (10) 137-C46, (11) 137-C47, (12) 137-C47 measured airflow velocity measurement result was significantly below the recommended airflow. It was observed on some of the welding benches that the exhaust ventilation slots have been covered by metal mesh covering because students were reportedly placing debris in the slots during courses. This likely attributed to the reduction in measured airflow. We recommend placing a facilities work order to remove the metal mesh coverings positioned over the exhaust ventilation slots in order to help improve the exhaust airflow and instruct students to not place debris in the exhaust ventilation system.

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

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

Comments and/or Recommendations: Workers 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 are unwieldy and/or weigh more than 50 lbs. It is recommended that all personnel receive ergonomic training including specific guidance identified in OPNAVINST 5100.23G, Ch. 23. Contact the Training Coordinator for assistance with this training.

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. No exposures to carcinogens above health-based occupational exposure limits are anticipated.

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

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 below.

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: -A noise survey was performed for the majority of work areas and the majority of samples collected when using shop pneumatic tools exceeded the Navy/Marine Corps Occupational Exposure Limit of 85 dBA. Sample results are provided in each shop hazard assessment report.

-Air sampling was performed during welding operations including TIG welding. All sample results for metals (chromium, manganese, and nickel) were below the OSHA PEL and ACGIH TLV.

-Air sampling was performed in the Pattern Making Area during a trial run using ABS plastic material. Results for total and respirable particulate were below the analytical laboratory limit of quantification.

3. Findings and Recommendations:

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

The following significant findings were identified:

Comments: (Repeat from 2014 IH Survey), Any worker machining material that produces metal dust must ensure Aluminum;

Titanium and Magnesium dusts are not comingled. Aluminum can become explosive when mixed with any ferrous (iron) based metal dust. Separate vacuums should be used for cleaning after each metal and areas should be wiped clean before changing to another metal. Dust should not be allowed to accumulate. Please review the flammable and combustible dust hazard informational sheet at the end of this IH report.

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: Please contact the Naval Health Clinic Industrial Hygiene office 466-7643/3833 to schedule requested exposure monitoring identified in this report.

SHOP HAZARD ASSESSMENT

DATE: August/September 2015

RECORDED BY: Daniel R. Gilleski

INSTALLATION: FRCE

BUILDING NUMBER: 137

SHOP NAME: 93553 Component Manufacture, Weld, &

Repair Shop (Common Shop Processes)

SUPERVISOR: Jim McDougal

PHONE: 464-7922/9422

TOTAL PERSONNEL: 34

MALE: 34

FEMALE: 0

GENERAL SHOP OPERATIONS: Personnel assigned to this shop perform a variety of metal manufacturing and repair operations including:

sheet metal fabrication, tubing and hose, lifting, welding, steel repair, heat treatment, pattern making, and photo template. Processes common to many of the shop areas are included below.

OPERATIONS AND ASSOCIATED

HEALTH HAZARDS

DURATION/

FREQUENCY

OF EXPOSURE

NUMBER

OF

WORKERS

CONTROLS EXPOSURE

ASSESSMENT

1. Machining -Hand and small machine

Operations (Dry): Making, repairing and finishing various aircraft metal parts with pneumatic hand tools (sanding, grinding, routing, blending, deburring etc.), saws

(band and circular saws, chop saw), pedestal sanders (belt sanders, disk sanders), bucking and installing rivets.

Hand tools are used primarily in the sheet metal, welding and steel pit areas, but may be found in all areas of the shop.

Inhalation and Skin Exposures:

Metal dusts and chips created from machining parts: INCONEL/MONEL

(Ni, Cr,); Titanium, Stainless Steel (may contain – C, Cr, Mo, Ni, Fe, N, S), steel

(may contain - C, Mn, Cr, Mo, Ni, Fe, P, S, Si, Al, Cu, Zn, Ti, Zr, O, N. H, B, Co, W,V), Nickel, chromium, molybdenum, niobium, aluminum, titanium, cobalt and magnesium Aluminum, Iron, Magnesium and Dusts

Carcinogens and suspected carcinogens: Nickel and Chromium(Cr+6)

Note: Metallic nickel is reasonably anticipated to be a human carcinogen based on sufficient evidence of carcinogenicity from studies in experimental animals (National Toxicology

Program, Report on Carcinogens, 13th edition;

Oct 2014)

Reproductive hazards: nickel, noise and vibration

Noise: compressed air, pneumatic hand tools, vibropen use, riveting and bucking rivets, saws and pedestal equipment

Intermittent/

As needed/

4-8 hrs./daily/

Generally less than 30 minutes total per time of grinding/sanding/ blending on

INCONEL/

MONEL aviation alloy materials during repair tasks.

Personal Protective

Equipment (PPE):

Safety glasses, face shields, leather or

Zorbit gloves, insert plugs or muffs hearing protection, safety shoes.

Safety procedures

Engineering Controls:

General and local exhaust ventilation

(weld shop, weld school, etc.)

Inhalation Exposure for all elements

(metals), excluding metallic Nickel when machining Stainless Steel or INCONEL alloy: ACCEPTABLE - Based on air sample results. Historical Personal breathing zone air sample results collected were below the OSHA PEL & ACGIH TLV for sampled elements.

Pneumatic sanding, grinding, blending, routing INCONEL/MONEL and stainless steel materials at the Sheet Metal “Steel

Pit” work area & Welding Shop table top benches:

UNCERTAIN, but interim assessment is

Acceptable based on generally short task duration of grinding on these types of materials.

Additional air samples are recommended to be collected for metallic nickel when machining (grinding) stainless steel or nickel alloy aviation parts.

Note: Exposure Monitoring Plan is below behind the Sheet Metal Shop Hazard

Assessment

Skin Exposure: Nickel can cause contact dermatitis in sensitive individuals. Gloves are required when machining these materials.

Noise Exposure: UNACCEPTABLE based on noise exposure data. Must wear hearing protection where posted and enrollment in the Hearing Conservation Program is required. All tools must be labeled. Noise survey data is presented at the end of each shop hazard assessment.

DURATION/

FREQUENCY

OF EXPOSURE

NUMBER

OF

WORKERS

CONTROLS EXPOSURE

ASSESSMENT

2. Machining aircraft panels/parts that have a zinc chromate primer coating:

The majority of metals include aluminum, titanium, and stainless steel. Interviewed artisans indicated that they do not work on zinc chromate containing painted surfaces; parts are already stripped before they arrive at this shop or they send primed parts to the strip shop if observed.

However, parts may have residual alodine conversion coating on surfaces.

Work task is reportedly not performed;

Times vary, primer coated parts are received on a sporadic basis.

N/A Administrative controls:

Safety procedures

(training, sending primed or painted parts to the strip shop if observed on parts in the shop area).

ACCEPTABLE based on existing controls.

3. Spray/Wipe Cleaning Machinery and shop area: 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. Parts are cleaned as needed with small amounts of acetone.

Inhalation and Skin exposures :

organic vapors-acetone, residual dust from shop processes.

5-10 minutes / shift /

Up to 1 hr/day

1/month up to 4 hours

34 PPE: Safety glasses with side shields, butyl rubber gloves, safety shoes, Engineering controls:

HEPA Vacuum and wet methods for cleaning procedures

Inhalation: ACCEPTABLE: Based on small quantities of cleaner used, the minimal occurrence and good general ventilation.

Wet methods and HEPA vacuum use.

Skin exposure: Minimal occurrence.

Continue to wear impermeable gloves (butyl rubber) when working with these solvents.

4. Brush Application of Layout Fluids, Dyes, & Removers

Inhalation and Skin exposures:

Steel Blue Layout Fluid: Butyl ester acetic acid (603), n-butyl alcohol (603s), nitrocellulose, 2-propyl alcohol, ethanol

(603) carcinogens: none

Reproductive hazards: none

Total 5 minutes month/ intermittent/

Rarely performed

Any 1 of 34

PPE: Safety glasses with side shields, butyl rubber gloves, safety shoes

Inhalation: ACCEPTABLE based on minimal occurrence and general ventilation

Skin exposure:

Minimal occurrence. Continue to wear impermeable gloves (butyl rubber) when working with these solvents.

5. Heavy lifting, awkward positions.

Aerial lift usage; Several areas and processes of the shop require lifting of heavy items. Some of these items are also shaped to make lifting them even more difficult (e.g. large sheets of metal treated in the salt bath).

Physical injury

Ergonomic Hazards: cumulative trauma injuries, bending, lifting, twisting, awkward positions, static positions etc.

As needed with certain jobs

<1 hr/day

34 workers Training, medical surveillance, team lifting, cranes, hoists, lift table, jack carts, rolling carts, forklift, steel toed shoes, safety glasses, leather or cut resistant gloves when handling sharp pieces

Physical/ Ergonomic Hazards:–Physical injuries have occurred. Contact the FRCE

Safety office to evaluate a work station when physical and/or ergonomic injuries are reported (back sprains, etc.)

DURATION/

FREQUENCY

OF EXPOSURE

NUMBER

OF

WORKERS

CONTROLS EXPOSURE

ASSESSMENT

6. Glove Box Blasting: Parts received for processing are stripped of primer, paint, plating, rubber etc.

Blasting media, chromium/chromic acid from primer and paint, cadmium from plating, metal dusts, rubber dust Note:

see operation #2. No anticipated exposure to chromium or cadmium.

Noise Hazards: Blasting, compressed air carcinogens: cadmium, chromium

Reproductive hazards: cadmium and noise

Welding area, Steel pit area and tanks and cooler area all use the glove box.

Any 1 of 34 workers –

1-2 hours/day

Intermittent

Engineering controls:

(enclosed system), PPE: Safety glasses, ear plugs, safety shoes, nitrile gloves

Admin control: “wait time”

Inhalation Exposure: ACCEPTABLE -

Based on enclosed system, “wait time”, SOP and training. Overexposures are not anticipated. Respiratory protection is not required.

Skin Exposure: Enclosed system, SOP and training. nitrile gloves should be worn to reduce potential hygiene issues resulting from shared PPE (i.e. gloves attached to blasting box)

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

Conservation Program is required.

OBSERVATIONS/ FINDINGS/ RECOMMENDATIONS:

MACHINING (HAND AND SMALL MACHINE) OPERATIONS (DRY): Observation(s): Interviewed sheet metal personnel indicated that lately the primary type of metal worked is Titanium. It was observed that there is not an exhaust ventilation system available in the sheet metal work area and the workers that work at the Sheet Metal “Steel Pit” do not use local exhaust ventilation or ventilated tool when they grind/sand metal surfaces. They use pedestal fans to help ventilate their work area and keep work surfaces clean after work. It was observed that work surfaces are kept clean and shop workers can check out from the Tool Room a pneumatic air attachment with an exhaust vacuum attached to a filter bag for cleaning of generated metal dusts. In addition, metal dusts are disposed in a separate 55-gallon accumulation drum in order to prevent the spread of metal dusts. Shop areas also have HEPA vacuums available in order to clean shop areas of non-metal dusts. Safety procedures were observed to keep incompatible metals separated during pedestal sanding/grinding in order to help reduce the potential fire hazard risk.

It was observed that the shop Welders sand/grind/route metal surfaces directly into their welding exhaust booths and use their exhaust booths for metal dust ventilation, in addition to welding gas and fume exposure control. However, for small jobs such as using pneumatic sanders to debur and smooth aluminum sheet metal panels, the use of exhaust ventilation or respiratory protection is not required based on current air sample results (see sheet metal hazard assessment).

Recommendations: We recommend the use of ventilated tools with a HEPA filter or the installation of an exhaust ventilation system (e.g. downdraft table) when feasible to minimize metal dust generation if work is performed on aluminum, Inconel, and stainless steel. Consider obtaining a portable dust/fume extractor with movable hood (local exhaust system) or recommend the design and installation of a down draft local exhaust system in order to help control metal dusts when sanding/grinding/routing aluminum, Inconel, and stainless steel metal surfaces. An example of a downdraft bench exhaust ventilation system that may be obtained from a ventilation engineering/design company, (e.g. Donaldson- Torrit, Models DB-2000 and DB-3000 downdraft bench), is provided on their website or another system may be obtained from a similar ventilation engineering/design company. For the shop welders, continue to utilize available exhaust ventilation when grinding stainless steel or nickel-containing alloys until additional engineering controls are obtained and implemented.

1. 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

SHOP 93553

WORK AREA

WORK

OPERATION/TASK

RECOMMENDED

MEDICAL

SURVEILLANCE

PROGRAM

MEDICAL

PROGRAM

NUMBER

ESTIMATED

NUMBER OF

WORKERS

ALL Shop 93553

Work Areas

Machining Operations, Forming and Drop

Hammer, Pneumatic air and hand tools operation, pedestal sander/grinder operation, Varsol Spray, Various Ventilation, Welding

Noise and enrollment in

Hearing

Conservation

Program (HCP)

ALL Applicable

Shop 93553 Work

Areas

Weight Handling

Equipment Operators

(required for any crane operators) associated with a variety of processes

Weight Handling

Equipment

Operators

All shop personnel qualified to operate weight handling equipment

DATE: 25 August 2015

RECORDED BY: Daniel R. Gilleski

INSTALLATION: FRCE

BUILDING NUMBER: 137

SHOP NAME: 93553 Component Manufacture, Weld, &

Repair Shop (Sheet Metal/Bench Area)

SUPERVISOR: Jim McDougal

PHONE: 464-7922/9422

TOTAL PERSONNEL: 20

MALE: 20 Sheet Metal Mechanics

FEMALE: 0

GENERAL SHOP OPERATIONS: Personnel assigned to this shop perform a variety of metal manufacturing and repair operations including:

sheet metal fabrication, tubing and hose, lifting, welding, steel repair, heat treatment, pattern making, and photo template. Sheet

Metal/Bench Area: Personnel manipulate metal (primarily Titanium; and also work Aluminum, Stainless Steel, & INCONEL) by bending, cutting, stretching, shaping, shrinking, sanding and grinding with a variety of machines and hand tools (manual and pneumatic).

OPERATIONS AND ASSOCIATED

HEALTH HAZARDS

DURATION/

FREQUENCY

OF EXPOSURE

NUMBER

OF

WORKERS

CONTROLS EXPOSURE

ASSESSMENT

7. Forming machines: Forms parts

(bending, cutting stretching, shaping and forming metal) using pressure and molds.

Verson Form Machine, Farquhar Hydro

Press, NC Wysong brake, large machines and smaller pedestal equipment located throughout sheet metal areas

(several shrinking and stretching machines, rollers, sheers, presses, formers and brakes) are used to repair cracks and dents and shape/form new parts

Noise: compressed air, machines, hand held hammer and riveter used to assist in shaping parts and surrounding shop noises.

Ergonomic injury:

Awkward postures including, lifting, reaching, twisting and bending and high hand force (pinching and gripping), repetitive motion and handling flimsy and unusually shaped raw materials. Lifting heavy form blocks.

Physical Injury: crushing, pinching etc.

AS NEEDED/

INTERMITTENT/

up to

4-6 hours a day

≈20 Sheet

Metal

Mechanics

PPE: Safety glasses with side shields, Steel toed shoes, leather or zorbit gloves and hearing protection (e.g.

ear plugs), Administrative controls: Training, team lifting, hoist and lift carts, machine guards

Noise Exposure: UNACCEPTABLE based on noise data. Must wear hearing protection while conducting these processes.

Enrollment in the Hearing Conservation

Program is required.

Ergonomic 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). Two man lifts are used when necessary due to weight, shape or structure of the raw material.

8. Drop Hammer:

Form parts by dropping excessive weight onto a part between two molds.

Hammering is conducted between drops to help assist in the shaping process.

Noise: Drop hammer - intermittent in excess of 96 dB(A). Hand held hammer also requires hearing protection for impact noise.

Physical Hazards: Crushing

Ergonomic injury:

Awkward postures including lifting, twisting and bending

AS NEEDED/

INTERMITTENT/

up to

8 hours/day

2 workers

PPE: Safety glasses, safety shoes, double hearing protection (ear plugs and muffs), Administrative controls: Training, crane used for lifting, interlocks

Noise Exposure: UNACCEPTABLE based on noise data. Must wear double hearing protection while conducting this process and notify rest of shop when “drop” is about to occur. Enrollment in the Hearing

Conservation Program is required.

Ergonomic 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)

FINDINGS/OBSERVATIONS/ RECOMMENDATIONS:

Findings/Observations: Interviewed artisans indicated that they do not grind/sand/route or drill on zinc-chromate primed/ painted or toxic heavy metal coated aircraft part surfaces. Artisans indicated that parts are stripped prior to arriving to the shop or if the part is found to contain zinc-chromate primer the part is sent to be stripped prior to work. It was observed that sheet metal workers that work at the “Sheet Metal Pit” do not use any local exhaust ventilation and their pneumatic tools are not equipped with exhaust ventilation when they grind/sand metal surfaces such as stainless steel, and titanium aircraft part surfaces. They use pedestal fans to help ventilate their work area. In addition, shop welders also grind/route without the use of ventilated tools.

-Some tools generated sound pressure levels above 96 dBA intermittently, and require the use of double hearing protection during those work tasks. See the below noise survey and hearing protection requirements.

Recommendations: We recommend obtaining metal sanding/grinding/routing tools with exhaust ventilation system, (low-volume high velocity exhaust system HEPA filtration). Another option that we also recommend the design and installation of a downdraft table in the Sheet Metal “Steel Pit” work area for work on aluminum, stainless steel, nickel-containing alloy (e.g. Inconel & Monel) metals, although inhalation exposures are not expected to exceed the

OSHA PEL for metals. Exhaust ventilation should be used to help protect sensitive personnel from metal dust and should help reduce inhalation exposures and help with workplace hygiene. An example of a downdraft bench exhaust ventilation system that may be obtained from a ventilation engineering/design company is: (e.g. Donaldson- Torrit, Models DB-2000 and DB-3000 downdraft bench); information is provided on their website or another similar ventilation engineering/design company. However, for small jobs such as using pneumatic sanders to debur and smooth aluminum sheet metal panels, the use of exhaust ventilation or respiratory protection is not required based on current air sample results (see sample results below) when a sheet metal worker buff/smoothed H-53 aircraft aluminum panels using a pneumatic grinder.

-We recommend that sheet metal workers and welders that use pneumatic routers/sanders/and grinders on stainless steel aircraft or nickel containing alloy surfaces that perform large scale sanding/grinding/routing, be enrolled in the respiratory protection program due to lack of use of engineering controls-ventilated tools or exhaust ventilation system, for this work task although exposures are not expected to exceed the OSHA PEL or AL.

-We recommend the use of air purifying respirators equipped with particulate filters be offered for usage for precautionary health measures when perform large scale sanding/grinding/routing work tasks. An N95 filtering face piece respirator or half face air purifying respirator equipped with higher filtering efficiency respirator filters, (e.g. N95, N99, N100, or P95, P100), may be used until we collect additional air samples to evaluate metal dust concentrations, especially nickel metal, and in the interim of use of tools with local exhaust or the installation of a stationary local exhaust system.

-Continue to utilize proper eye protection (face shields/safety glasses) during these work tasks. Contact the Industrial Hygiene Department at 466-7643/3833 prior to the next “large scale” sanding/grinding/routing aluminum, stainless steel, and nickel alloy aircraft part(s) job so air sampling can be scheduled.

- In addition, continue to utilize double hearing protection when operating the drop hammer and when performing pneumatic routing on aluminum surfaces, and when using the pneumatic Vibropeen, (with compressed air attachment), to etch on titanium and other metals. Continue enrollment in the Hearing

Conservation Program and Noise Medical Surveillance Program.

USE THE FOLLOWING EXPOSURE CODES:

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

SHOP 93553 WORK

AREA

RECOMMENDED

MEDICAL

SURVEILLANCE

PROGRAM

MEDICAL

PROGRAM

NUMBER

ESTIMATED

Sheet Metal, “Steel Pit”

“Heavy” Pneumatic

Sanding/Grinding/Routing

Aluminum, Nickel alloy materials (e.g.

Inconel/Monel), &

Stainless Steel aircraft parts during repair work when exhaust ventilation is not utilized

Respirator User

20 Sheet Metal

Mechanics

Sheet Metal, “Steel Pit”

Pneumatic air and hand tools operation, pedestal sander/grinder operation, Metal engraving using pneumatic Vibropeen etcher

Noise and enrollment in Hearing

Conservation Program

(HCP)

20 Sheet Metal

Mechanics

NOISE SURVEY - SOUND PRESSURE LEVEL SUMMARY TABLE

COMMAND: Fleet Readiness Center East

Shop: 93553 Component Manufacture, Weld, and Repair Shop

Date Collected: 25 August 2015 & 21, 28 August 2014

Location: Bldg. 137

Industrial Hygienist/IH Tech: Daniel Gilleski

IH Log #(s) EQUIPMENT

TYPE

LOCATION

SOUND

PRESSURE

LEVELS in

Decibels (dBA)

HAZARD

RADIUS

COMMENTS

15-0560 Pneumatic Vibropeen

Etcher Sheet Metal “Steel

Pit”; Operator hearing zone while he etched work numbers on a

Titanium part (<30 seconds), for numerous metal work pieces

96 – 103.5;

103.5 (peak)

Entire sheet metal work area

Sound pressure levels exceeded 96 dBA at operator hearing zone, The use of double hearing protection is required.

14-0818 90 degree pneumatic router

Sheet Metal Repair

Work Area “Steel Pit”;

Operator hearing zone while he smoothed aluminum stock angle using the pneumatic router.

84.0 – 89.0 Entire sheet metal work area

Sound pressure levels exceeded 85 dBA at operator hearing zone, Single hearing protection is required and is utilized.

14-0885 “Dotco” 90 degree pneumatic sander

Sheet Metal Repair

Work Area “Steel Pit”;

Operator hearing zone while operator sanded stainless steel aircraft component..

95- 99.0 Entire sheet metal work area

Sound pressure levels exceeded 96 dBA at operator hearing zone, The use of double hearing protection is required.

14-0821 Pneumatic drill Sheet Metal Assembly

Work Area;

Operator hearing zone while the worker drilled on titanium. .

79 – 81

(85.5 peak for a few seconds)

N/A Sound pressure levels exceeded 85 dBA at operator hearing zone for a few seconds

14-0822 Pneumatic rivet gun Sheet Metal Assembly

Work Area;

Operator hearing zone while operator shoots rivets into titanium aircraft metal work piece (work task only takes a few seconds per panel).

93- 102

(102 peak)

Entire sheet metal work area

Sound pressure levels exceeded 96 dBA at operator hearing zone, The use of double hearing protection is recommended.

Key: ‘ --- ‘ means not obtained ‘N/A’ means Not Applicable

Measurements made with a Type II Sound Level Meter on Slow Response

SPLs measured greater than 85 dBA – 96 dBA = Single Hearing Protection Device Required (e.g. muffs or insert plugs)

SPLs measured greater than 96 dBA = Double Hearing Protection Devices Required (e.g. muffs and insert plugs)

2015 NOISE DOSIMETRY SUMMARY

FRCE SHOP 93553

SAMPLE

NUMBER

SAMPLE

DATE

OCCUPATION LOCATION WORK

PROCESS/

TASKs

TIME

Results

Lavg

Decibels

(dBA)

8-

Hour

TWA

(dBA)

% DOSE NOISE

EXPOSURE

ASSESSMENT:

ACCEPTABLE/

UNACCEPTABLE

CP16-

November

Sheet Metal

Mechanic

BLDG. 137,

SHOP

93553/

Steel Pit work on aircraft part

(blast shield)/

7 hours, and 41 minutes

85.7

85.5

113.4%

Note: Lavg is the average sound level measured over the sampling run time.

8-Hour TWA is the averaged sampled sound level over an 8-hour period.

% Dose = Related to the Criterion Level, a dose reading of 100% is the maximum allowable exposure to accumulated noise. For the DOD (Navy/Marine Corps), 100% dose occurs from an average sound level of 85 dB over an 8 hour period. An exchange rate of 3 dBA was used.

Hearing Protection Used: 3M UltraFit Triple Flange Insert (NRR = 27 dBA)

Time Course of Events during Monitoring: Noise dosimetry was conducted while the sampled Sheet Metal Mechanic repaired an aircraft part, a blast shield. During the repair, he used various tools- he grinded using a 2 inch red disk attached to a

90 degree pneumatic router. He switched attachment to a red scotchbrite 2 inch disk. He also used a Pneumatic Chicago CP444

ROTAB hammer to rivets brackets in place using titanium rivets. Worker used the shop glove box abrasive blast booth. He also was exposed to noise from workers using pneumatic tools at their workbenches at the shop 93553 “Steel Pit”. The Personal

Noise Dosimetry 8-hr TWA result exceeded the Occupational Exposure Limit (OEL) for hazardous noise during this sampling period.

COMMENTS: Continue enrollment of personnel in the Noise Medical Surveillance Programs based on noise exposure data in this shop area. Continue enrollment of personnel in Hearing Conservation Program based on noise sources in shop.

SAMPLE

DATE

OCCUPATION LOCATION WORK

PROCESS/

TASKs

Decibels

(dBA)

8-

Hour

TWA

(dBA)

% DOSE NOISE

EXPOSURE

ASSESSMENT:

aircraft part/

Use of pneumatic tools and

Metal

Engraving

86.2

126.3%

% Dose = Related to the Criterion Level, a dose reading of 100% is the maximum allowable exposure to accumulated noise. For the DOD (Navy/Marine Corps), 100% dose occurs from an average sound level of 85 dB over an 8 hour period. An exchange rate of 3 dBA was used.

Hearing Protection Used: 3M UltraFit Triple Flange Insert (NRR = 27 dBA)

Time Course of Events during Monitoring: Noise dosimetry was conducted while the sampled Sheet Metal Mechanic repaired an aircraft part using various hand and pneumatic tools. During the repair, he used various tools- he used a drill to drill holes in the metal aircraft part. He grinded a metal part for less than 10 minutes Also, for approximately 15 minutes in the afternoon, he used a pneumatic Vibropeen etcher to etch numbers into the part. He also was exposed to noise from workers using pneumatic tools at their workbenches at the shop 93553 “Steel Pit”. The Personal Noise Dosimetry 8-hr TWA result exceeded the

Occupational Exposure Limit (OEL) for hazardous noise during this sampling period.

Personal Protective Equipment worn consisted of insert hearing protection, safety glasses, and steel toed boots. Hearing protection consisted of 3M Ultra Fit flanged hearing protection (NRR = 27 dB). However, the use of the pneumatic Vibropeen etcher produces sound pressure levels above 96 dBA, and during use double hearing protection (muffs and plugs) is required.

COMMENTS: Continue enrollment of personnel in the Noise Medical Surveillance Programs based on noise exposure data in this shop area. Continue enrollment of personnel in Hearing Conservation Program based on noise sources in shop.

SAMPLE

DATE

OCCUPATION LOCATION WORK

PROCESS/

TASKs

Decibels

(dBA)

8-

Hour

TWA

(dBA)

% DOSE NOISE

EXPOSURE

ASSESSMENT:

aircraft part

(AV8 heat shield)/

Using hand and pneumatic tools

89.4

89.1

262.9 %

% Dose = Related to the Criterion Level, a dose reading of 100% is the maximum allowable exposure to accumulated noise. For the DOD (Navy/Marine Corps), 100% dose occurs from an average sound level of 85 dB over an 8 hour period. An exchange rate of 3 dBA was used.

PPE Used: Safety glasses, steel-toe shoes, 3M Ultra Fit flanged hearing protection (NRR = 27 dB)

Time Course of Events during Monitoring: Noise dosimetry was conducted while the sampled Sheet Metal Mechanic repaired an aircraft part, an AV-8 heat shield at the shop “Steel Pit.” During the repair, he used a 90 degree pneumatic router with a red sanding disk and red scotchbrite buffing disk attachments intermittently in the morning for approximately 50 minutes. He also was exposed to noise from workers using pneumatic tools including a rivet gun at their workbenches at the shop “Steel Pit”.

Also, at 0930 the FRCE Fire Alarm sounded in the shop area. The Personal Noise Dosimetry 8-hr TWA result exceeded the

Occupational Exposure Limit (OEL) for hazardous noise during this sampling period.

COMMENTS: Continue enrollment of personnel in the Noise Medical Surveillance Programs based on noise exposure data in this shop area. Continue enrollment of personnel in Hearing Conservation Program based on noise sources in shop.

SAMPLE

DATE

OCCUPATION LOCATION WORK

PROCESS/

TASKs

Decibels

(dBA)

8-

Hour

TWA

(dBA)

% DOSE NOISE

EXPOSURE

ASSESSMENT:

aircraft part/

Using hand and pneumatic tools , and shop industrial band saw

100.8

100.3

3,446.2 %

% Dose = Related to the Criterion Level, a dose reading of 100% is the maximum allowable exposure to accumulated noise. For the DOD (Navy/Marine Corps), 100% dose occurs from an average sound level of 85 dB over an 8 hour period. An exchange rate of 3 dBA was used.

PPE Used: Safety glasses, face shield, steel-toe shoes, double hearing protection (plugs and muffs).

Time Course of Events during Monitoring: Noise…