Attachment_04o_2015_IHS_of_95202_Shop.pdf

2015 PERIODIC INDUSTRIAL HYGIENE SURVEY

OF

H-1 SHEETMETAL REPAIR

(95202)

INDUSTRIAL HYGIENE DEPARTMENT

NAVAL HEALTH CLINIC

CHERRY POINT, NC 28533-0023

Enclosure (11)

TABLE OF CONTENTS

Executive Summary……………………………………………………………………………3

Evaluation Summary…………………………………………………………………………...5

95202 UH-1/H-1 Sheetmetal...…………………………………………………………………7

Table 1: Corrosion Cleaning, Sanding, or Grinding Process Control

Requirements………………………………………………………………………..14

Table 2: Specific 1910.1026 OSHA Regulations……………………………………………..15

Table 3: Identified Noise Hazardous Equipment Survey…………………………………….16

Glossary of Terms………………………………………………………………….Appendix A

Customer Satisfaction/Complaint Form……………………………………………Appendix B

EXECUTIVE SUMMARY

The Periodic Industrial Hygiene Survey of H-1 Airframes Sheetmetal Shop 95202 was conducted by Ms. Alison

Styron, Industrial Hygienist, in November 2015. The purpose of this survey was to evaluate any changes to work processes or work practices that have occurred since our previous survey in 2014.

This branch performs UH-1 and YH-1 rework, part and component replacement and upgrades. Personnel consist of airframe, electrical and sheet metal repair artisans. This branch is located in building 137, Hangar 1.

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 and 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, physician assistant, audiologist, or other health care provider to detect any insidious or acute ill effects. This information is provided within this survey report. The FRC

East Division Secretaries will compile the registries and schedule the required medical surveillance physicals with the Naval Health Clinic Occupational Medicine Department.

Chromium VI Compliance: 95202 exposure monitoring has revealed chromate overexposures for H-1 and UH-1 sanding operations. Based on this data, implementation of CFR 1910.1026 Hexavalent Chromium and the FRCE

Hexavalent Chromium Written Compliance Program for Industrial Airframes Repair and Modification Division was mandated. Compliance is managed by the FRC East Safety Office and requirements are summarized in Tables 1 and

2 of this report. Chromium VI overexposures continue to occur during sanding/grinding operations for paint removal, corrosion removal and fiberglass/composite repair purposes. Compliance sampling (CEM) will continue for chromium VI in shops 95202 for H-1 sanding operations. Personnel should contact the Naval Health Clinic

Industrial Hygiene department at 466-3251 or 4564 to schedule required monitoring of these tasks.

Eyewash Stations: Plumbed eyewash stations are located throughout the hangar as well as in the adjacent sheet metal working room. At the time of the walkthrough, eyewashes were tagged with documentation reflecting inspection and appeared to be in good condition. FRC East Safety personnel manage eyewash stations, including placement, testing and maintenance.

Hearing Conservation Program: Interim Navy Medicine Hearing Conservation Program Guidance 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 Protective Device (HPD) requirements.

Operations with Sound Pressure Levels (SPLs) in excess of 85 dBA require single hearing protection. Operations with SPLs exceeding 96 dBA require double hearing protection. A noise hazardous equipment table is included in this report. All 95202 personnel are enrolled in the Hearing Conservation Program. Hearing protection was readily available for employee use, including muffs and a variety of disposable ear plugs. Personnel were observed wearing hearing protection at the time of the walkthrough. Specific identified noise hazardous equipment and available hearing protection are included in Table 3 of this report. Continue to ensure that all noise hazardous equipment is labeled.

Respiratory Protection Program: Respirators are worn by sheet metal personnel conducting extensive sanding/grinding operations. Personnel wear 3M half face, North full face and Bullard supplied air hood respirators.

Continue to ensure that personnel are fit tested and trained. Contact the RPPM at the FRC East Safety Office with any questions regarding the Respiratory Protection Program.

Personal Protective Equipment (PPE): PPE was readily available to personnel. However, employees did express concerns that on occasion some sizes of disposable coveralls are unavailable. The use of vibration reducing gloves is recommended during rivet gun operation.

Thermal Stress: Personnel are subject to thermal stress in bldg. 137 work spaces as well as on the flightline.

Continue to ensure all personnel are trained in thermal stress recognition and prevention. Contact the FRCE Safety

Office if assistance is required.

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 the Industrial Hygiene department 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 B of this report. Please complete this form as deemed necessary and return to the Naval Health Clinic Industrial Hygiene

Department Head.

This report reflects conditions and operations in 95202 during the survey period. Periodic Industrial Hygiene

Surveys are required for work places by DODINST 6055.5 and OPNAVINST 5100.23G with a frequency of every year. In addition, changes in procedures, processes, or workload that may significantly alter personnel exposures 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 FRCE Safety Office when significant changes occur. The next periodic industrial hygiene survey will be conducted in 2016.

EVALUATION SUMMARY

PERIODIC INDUSTRIAL HYGIENE SURVEY

95202

New or Significantly Modified Work Center Operations/Processes?

No significant changes in operations/processes were identified. *

The following changes were identified:

*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: 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 Files Y N N/A Accurate Y N

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. Hazards and corresponding work tasks are identified in each shop assessment.

3. Management of Reproductive Hazards:

Reproductive Hazards Present? Y N

Any change from previous survey? Y N

Comments: Reproductive hazards identified by the Navy and Marine Corps Public Health Center (NMCPHC) have been identified in this division. 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):

Are personnel recommended for the HCP? Y N

Are personnel receiving audiograms? Y N N/A (Note: IH does not track 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 personnel SHALL continue to wear appropriate hearing protection in H-1 repair workspaces as well as on the flightline. All personnel participate in the Hearing Conservation Program. As noted in previous surveys, the use of double hearing protection is required for those personnel conducting pneumatic rivet installation processes and for those in immediate proximity.

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: Respiratory protection is required for paint and corrosion removal and fiberglass/composite sanding (conducted by sheet metal artisans). Half and full face air purifying respirators and supplied air Bullard hoods are used. 29 CFR 1910.134(g)

(Respiratory Protection) states that tight fitting (elastomeric half face and full face) respirators shall not be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face. An FRCE safety representative manages the Respiratory Protection Program including training and fit testing administration.

6. Ventilation:

Are ventilation systems used to control workplace exposures? Y N

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

Comments: Individual HEPA vacuums are available for use. Some ventilated rotary tools continue to be assessed by sheet metal artisans.

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

Comments and/or Recommendations: Adjustable tables, chairs and stools were observed. Personnel are at risk of developing

Work Related Musculoskeletal Disorders (WMSDs) as they are exposed to multiple risk factors including assumption of awkward postures, standing for long periods of time and exposure to excessive vibration. It is recommended that all personnel receive ergonomic training including specific guidance identified in OPNAVINST 5100.23G, Ch. 23. Training emphasis should be placed on Hand-Arm Vibration injury prevention. Contact the FRCE Ergonomics Program manager for assistance with this training. The use of EN/ISO/ANSI certified full fingered anti-vibration reducing gloves is highly recommended during pneumatic rivet installation.

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.

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:

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:

3. Findings and Recommendations:

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

The following significant findings were identified:

Comments: Double hearing protection shall be worn during pneumatic rivet gun use, in addition to other noise hazardous operations identified in this 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 466-4564 or 466-3362 to schedule requested exposure monitoring identified in this report.

INDIVIDUAL HAZARD ASSESSMENT

DATE: NOVEMBER 2015

RECORDED BY: Alison N. Styron

INSTALLATION: FRCE/Airframes

BUILDING NUMBER: 137 (Hangar 1)

SHOP NAME: 95202

SUPERVISOR: CRAIG DAUGHETY

PHONE: 464-9586

TOTAL PERSONNEL: 17

SHOP OPERATIONS: Responsible for sheet metal repair, rework, and fabrication on UH-1N, UH-1Y and AH-1W aircraft.

Personnel working in this shop are sheet metal mechanics.

OPERATIONS AND

ASSOCIATED HAZARDS/

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

General Shop Operations: Work is performed in hangar 1 of bldg. 137.

Multiple artisans perform a variety of operations in these areas that generate noise including, but not limited to, operation of pneumatic tools, vacuums and Ground Support

Equipment (GSE). In addition the hangar is adjacent to an active flightline/Noise

Adjacent abrasive operations can generate miscellaneous dusts/Flying

Debris

Ground Support Equipment operation is sometimes conducted on the hangar deck/Diesel exhaust/carbon monoxide

Some operations require personnel to work in awkward/static positions/

Ergonomic stressors/work-related musculoskeletal disorders:

The hangar is subject to extreme temperatures/ Thermal stress/All

7-8 hrs/daily PPE: Single hearing protection (at a minimum;

specific operations may require double)

Safety glasses 1

Adequate ventilation

Ergonomic training

Training in thermal stress recognition and prevention/use of fans and heaters

Noise: UNACCEPTABLE. Existing noise data indicates personal exposures are expected to exceed the Bureau of Medicine and Surgery

(BUMED) Occupational Exposure Limit (OEL).

Enrollment in the Hearing Conservation Program is required. Noise is a developmental reproductive hazard.

Flying debris: ACCEPTABLE based on existing controls.

Exhaust gases: ACCEPTABLE based on existing natural ventilation. Carbon monoxide is a reproductive hazard (developmental). Diesel exhaust particulates identified as suspected carcinogens.

Ergonomic: Ensure all personnel receive training on recognition and prevention of ergonomic injury (Reference OPNAVINST 5100.23G, Ch.

23).

Thermal Stress: Ensure all personnel are trained in thermal stress recognition and prevention.

Adhesive applications on aircraft and/or components including, but not limited to, Accrabond, Edge

Sealer, Instabond 124, Loctite 242, Superbonder 495 and Scotchweld:

Acetone, acrylonitrile, butadiene copolymer, cumene hydroperoxide, cyanoacrylate, cyclohexane, diisopropyl, dimethyl ether, ethanol, isobutane, isohexane, n-hexane, magnesium resonate, methoxy phenol, methyl ethyl ketone, 3-methyl pentane, methyl isobutyl ketone, naphtha solvent, phenol, phenolic resin, polychloroprene, propane, silica

(fumed), titanium dioxide, toluene, xylene/17

5 min/1-2x monthly

Adequate ventilation/PPE:

safety glasses1, nitrile gloves2

ACCEPTABLE based on existing controls.

Toluene is a developmental reproductive hazard.

Acrylonitrile is identified as a possible human carcinogen.

Xylene is a reproductive hazard

(female/developmental)

Titanium dioxide is a suspected carcinogen.

Administrative duties: supervisors conduct extensive work at computer stations/ergonomic injury/2

6-8 hrs/daily Ergonomic training

No reported issues, however, potential exists for ergonomic injuries to occur. Ensure all personnel receive training on recognition and prevention of ergonomic injury (Reference OPNAVINST

5100.23G, Ch. 23).

OPERATIONS AND

ASSOCIATED HAZARDS/

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

“Aerokroil” Aerosol Application:

aliphatic alcohol, aromatic naphtha, 2-butoxy-ethanol, carbon dioxide propellant, diacetone alcohol, glycol either, petroleum distillates, sec-butyl alcohol/17

Variable/5 min/weekly

Adequate ventilation/PPE:

safety glasses1, Aerosol Corrosion Preventative

Compound (CPC) Use (So Sure):

butyl alcohol, aliphatic mineral spirits/petroleum distillates, isopropyl alcohol, toluene, 1,1,1,2- tetraflouro-ethane/17

10-15 min/weekly

Adequate ventilation/PPE:

safety glasses1, nitrile gloves2

Aircraft or aircraft component surface cleaning (minor): acetone or isopropyl is applied and wiped with a cloth/17

10-15 min/2-3x daily

Adequate ventilation/PPE:

chemical splash goggles, nitrile gloves2

Aliphatic naphtha use: toluene, cyclohexane/17 Variable/rare

Adequate ventilation/PPE:

nitrile gloves2 , chemical splash goggles

ACCEPTABLE based on existing controls.

Toluene is a developmental reproductive hazard.

Alodine metal treatment with sempen (1132): chromic acid

(hexavalent chromium compounds)/17

5-10 min/daily Sempen application method/PPE:

safety glasses1, nitrile gloves2

ACCEPTABLE. Existing controls are adequate.

Hexavalent chromium compounds are identified carcinogens.

Alodine metal treatment (1201) with dip tank use: chromic acid

(hexavalent chromium compounds)/

5-10 min/daily Adequate natural ventilation/PPE:

chemical splash goggles, face shield, butyl gloves, butyl apron

Cryogenics Handling (debonding sheet metal): Carbon dioxide (dry ice), dermal injury/17

20-30mins/2-3x weekly

SOPs/Training/

PPE: cryogenics gloves, tongs

Cutting fluid use (Anchorlube G-

771): mica, triethanolamine, calcium carbonate, formaldehyde (<.1%)/17

5-10 mins/1-2x weekly

Adequate ventilation/PPE:

safety glasses1, Epoxy priming with sempen and 2 part epoxy primer kit: acetone, amyl methyl ketone, benzyl alcohol, 1-butyl alcohol, bisphenol-A, epichlorohydrin, epoxy resin, carbon black, cyclohexanone, methyl isobutyl ketone, methyl propyl ketone, quartz, strontium chromate, titanium dioxide, toluene/All

Variable/5-10 mins/1-2x/ weekly

Adequate ventilation/

Sempen and brush application method/PPE:

safety glasses1, nitrile gloves2

ACCEPTABLE based on existing controls.

Hexavalent chromium compounds and quartz are identified carcinogens.

Epichlorohydrin is a reproductive hazard (male) and a suspected carcinogen.

ASSOCIATED HAZARDS/

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Glove box Blasting Unit Operation

(plastic and glass bead media units available): metal and paint dusts including cadmium, lead, chromium, chromium VI/17

5-30 min/weekly

Closed system operation/

Training/

SOPs/PPE:

gloves, proper hygiene practices

All stressors: ACCEPTABLE. Existing controls are adequate.

Hexavalent chromium compounds identified as a known carcinogens.

Cadmium is a reproductive hazard

(male/developmental) and a known carcinogen.

Lead is a reproductive hazard (male/ female/ developmental) and a suspected carcinogen.

Ground Support Equipment (GSE)

Operation and adjacent operations including, but not limited to, operation of hydraulic generator, air compressor and NC-10/carbon monoxide, diesel exhaust, noise/Qualified personnel

-Hydraulic Generator (T-15 Diesel power Supply): 100.2 dBA

-NC-10 (Mobile electric power plant):

99.9 dBA

Variable/30 min/1-2x daily

Training/ adequate natural ventilation/

SOPs/PPE:

double hearing protection (ear muffs and earplugs)

(See Table 3)

Noise: UNACCEPTABLE based on existing data. Enrollment in the Hearing Conservation

Program is required. Noise is a developmental and female reproductive hazard.

Diesel exhaust/Carbon monoxide:

Diesel exhaust particulates identified as suspected carcinogens.

Carbon monoxide is a reproductive hazard

(developmental).

Minor sanding/ grinding and drilling on component painted/ primed surfaces in “Panel room”

(bench work) including manual and pneumatic abrasive operations on sheet metal and fiberglass/composite surfaces: paint dusts, bonding/sealant dusts, chromates, cadmium (from select cadmium coated hardware), lead, fiberglass/composite fibers

(synthetic vitreous fibers/manmade mineral fibers), nuisance dusts, noise

(based on pneumatic tool use) /17

Variable/5 min- 30 min/daily

HEPA vacuums/

PPE: safety glasses1, nitrile gloves2, single or double hearing protection

(specific pneumatic equipment dependent; (see

Table 3)

Noise: UNACCEPTABLE based on use of pneumatic tools. Personnel exposures are expected to exceed the OEL. Enrollment in

Hearing Conservation Program Required.

Other stressors: ACCEPTABLE based on existing sampling data. Existing controls are adequate.

Lead is a reproductive hazard

(male/female/developmental).

Cadmium is a reproductive hazard (male/ developmental) and a known carcinogen.

Hexavalent chromium compounds are known carcinogens.

Pneumatic rivet installation Personnel utilize pneumatic rivet guns often with “bucking bars” that require forceful gripping for long periods of time: ergonomic injury

(hand arm vibration, awkward postures, repetitive motion, forceful exertions, contact stresses), flying debris and noise/17

Equipment including, but not limited to, the following*:

-CP-444 Pneumatic hammer: 120.9

-3x Chicago pneumatic rivet gun:

106.7

-Cherry Max Blind Rivet Installer

(Model #6704B): 90.9

*Sound Pressure Levels (SPLs) in dBA.

15 min- 4 hours/daily

(variable)

Ergonomic

Training/PPE:

Double hearing protection, safety glasses1, anti-vibration gloves

Hand Arm Vibration (HAV):

UNACCEPTABLE based on duration and frequency. Ensure all personnel receive training on recognition and prevention of ergonomic injury (Reference OPNAVINST 5100.23G, Ch.

23).

Noise: UNACCEPTABLE based on existing data. Noise is a developmental reproductive hazard. Enrollment in Hearing Conservation Program Required.

All personnel within 6 ft. of rivet gun operation must wear double hearing protection

Flying debris: ACCEPTABLE. Existing controls are adequate.

RTV (3145) Application: methanol, methyltrimethoxy-siloxane, titanium dioxide, trimethylated silica/17

Variable/10-15 min/2x monthly

Adequate ventilation/PPE:

safety glasses1, nitrile gloves2

ASSOCIATED HAZARDS/

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Sealing compound use (870 B1/2, PR 1440 (CS 3204), 8802 and PR

1826) and Sealant/adhesive agent applications (EA 9320, Hysol 9309 and 9394): aliphatic amines, aluminum, bisphenol –A, calcium carbonate, carbon black, diethylene glycol, diethylenetriamine, diphenyl guanidine, epichlorohydrin, isopropyl alcohol, manganese oxide/dioxide, magnesium chromate, methyl ethyl ketone, hydrogenated terpheynyls, phenol, polyamine, polysulfide polymer, silicon dioxide, talc, toluene, titanium dioxide, triethylene tetramine /17

Variable, 5-10 min/daily

Adequate ventilation/

Syringe/tube application/

PPE: safety glasses1, nitrile gloves2

ACCEPTABLE. Existing controls are adequate

Carbon black is identified as possibly carcinogenic to humans.

Hexavalent chromium is an identified carcinogen.

Toluene is a developmental reproductive hazard.

Titanium dioxide is identified as possibly carcinogenic to humans.

Epichlorohydrin is a reproductive hazard (male) and a suspected carcinogen.

Sheet metal fabrication/repair including, but not limited to, use of bender, brake, grinder, drill press, band saw, pneumatic drill, pneumatic router (cutting wheel/disc): noise, flying debris, cut/laceration/puncture/ abrasion/vibration/17

Noise hazardous metal working equipment including, but not limited to, the following*:

-DOTCO 90° Router (Model

10L1201636): 107.5

-Tennsmith “Shear”: 97.0

-Rockwell Industries “Buckeye”

Drill: 107.0

- Wilton Dual Sander: 93.6

*Sound Pressure Levels (SPLs) in dBA.

Variable/10 min-4 hours/daily

SOPs/machine guards/PPE:

safety glasses1, face shield (with metal cutting/ grinding equipment), single OR double hearing protection

(equipment dependent; see

Table 3), cut resistant gloves

(not to worn with certain machines;

refer to specific machine SOP)

Noise: UNACCEPTABLE based on existing sampling data. Personnel are expected to exceed the OEL. Enrollment in Hearing Conservation required. Noise is a developmental reproductive hazard.

Other stressors: ACCEPTABLE. Existing controls are adequate.

Sheet metal sanding/grinding for corrosion removal purposes (2nd shift, Hangar 137) :

Operation primarily conducted with pneumatic tools but with manual wire brush as well: metal dusts including cadmium, lead, aluminum, chromium, paint and sealant dusts (including hexavalent chromium, titanium dioxide, quartz, nuisance dust), noise/any of 17

Noise hazardous equipment including, but not limited to:

DOTCO 90 Router: 107.5

Pneumatic Straight Router: 96.7

*Sound Pressure Levels (SPLs) in dBA.

Variable/30 min

- 6 hrs/weekly

SOPs/training/ demarcation/

HEPA vacuums/

PPE: nitrile gloves2, Bullard supplied air hood or full face respirator with

P100 filtration, disposable coveralls, single or double hearing protection

(depending on pneumatic tool)

Hexavalent Chromium (CrVI):

UNACCEPTABLE (inhalation) based on existing data. Exposures are expected to exceed the Permissible Exposure Limit (PEL).

Hexavalent chromium compounds are known carcinogens. Compliance with OSHA CFR

1910.1026 (Chromium VI) required. See Tables

1 and 2 in this document for additional guidance.

Enrollment in the Respiratory Protection

Program and Medical Surveillance required.

Noise: UNACCEPTABLE based on use of pneumatic tools. Personnel exposures are expected to exceed the OEL. Enrollment in the

Hearing Conservation Program Required. Noise is a developmental reproductive hazard.

Other stressors: ACCEPTABLE based on existing sampling data.

Lead is a reproductive hazard

(male/female/developmental).

Cadmium is a reproductive hazard

(male/developmental) and a known carcinogen.

ASSOCIATED HAZARDS/

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Touch up spray painting (non-polyurethane painting): toluene, acetone, xylene/17

~5 min/ 2-3x monthly

Adequate ventilation/PPE:

safety glasses1, nitrile gloves2

ACCEPTABLE based on existing controls.

Toluene is a developmental reproductive hazard.

Xylene is a reproductive hazard

(female/developmental)

Vacuum cleaner during sanding operations and for post work area cleanup (Clayton, Nilfisk and Tiger

Vac HEPA vacuums observed during walkthrough)/noise/All

Sound Level Meter Results

(06/20/13):

Nilfisk Model 118 EXP: 97.8-104.2

Tiger Vac: 98.1-104.1

Variable/15-20 min/2x daily

PPE: Double hearing protection

UNACCEPTABLE based on collected Sound

Pressure Levels (SPLs). See Table 3.

Personnel exposures are expected to exceed the

OEL. Enrollment in the Hearing Conservation

Program Required. Noise is a developmental reproductive hazard.

Varsol tank use (PD-680 Type II):

petroleum distillates/All 5-10 min/1-2x weekly

Adequate ventilation/PPE:

face shield, goggles, apron, nitrile gloves2 (mid-arm length)

ACCEPTABLE based on existing controls.

COMMENTS/RECOMMENDATIONS: 1Safety glasses shall have side shields; 2Nitrile gloves should be > .3mm thick.

-Personnel operating a pneumatic rivet gun and personnel in immediate proximity shall wear double hearing protection. Artisans conducting rivet operations should utilize full fingered anti-vibration gloves. The procurement of anti-vibration tools is recommended. Ensure personnel are trained in the recognition and prevention of Work Related Musculoskeletal Disorders.

-Continue to ensure personnel conducting sanding/grinding operations comply with the Hexavalent written compliance program managed by Fleet Readiness Center East including the use of established barriers. ALL personnel within the established barrier shall wear appropriate PPE. The presence of personnel working inside the barrier without appropriate PPE is strictly prohibited.

-29 CFR 1910.134(g) (Respiratory Protection) states that tight fitting (elastomeric half face and full face) respirators shall not be worn by employees who have facial hair that comes between the sealing surface of the face piece and the face. Personnel with facial hair that interferes with a respirator seal are permitted to wear Bullard supplied air hoods.

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

EXPOSURE MONITORING PLAN DATE: NOVEMBER 2015

RECORDED BY: Alison N. Styron

INSTALLATION: FRCE/Airframes

BUILDING NUMBER: 137, Hangar 1

SHOP NAME: 95202

SUPERVISOR: CRAIG DAUGHETY

PHONE: 464-9586

TOTAL PERSONNEL: 17

Operation Potential Hazard #No.

Samples

Sample location

Method Sample

Freq

ManHr

/yr

Required Compliance Exposure Monitoring

Sanding/Grinding Aircraft

Corrosion Removal, Sheet metal Artisan on H-1

Aircraft(Hangar 2nd shift)

**CrVI: 18540-29-9

Cadmium: 7440-43-9

Chrome Metal: 7440-47-3A

Quartz: 14808-60-7

1-2 BZ F 4 32

Exposure Monitoring

Sheet metal fabrication/repair work performance in Hangar 1

Noise 1-2 HZ PD 4 32

I=intermittent DR=Direct Reading BZ=Breathing Zone HZ=Hearing Zone

C=continuous BI=Bubbler/impinger PD=Personal Dos. AT=Adsorption Tube

Y=Yes/N=No IT=indicator Tube GA=General Area SZ=Source Zone

F=Filter O=Other

95202 Supervisor(s): Please contact the Naval Health Clinic, Industrial Hygiene Department at 466-3362, prior to the next evolution of the above operations for evaluation/sampling.

NHCCP IH Staff: Please document all tools used including brand and model. If rivet operations are conducted please identify what size/type rivets are being used.

Signed:

Title: Industrial Hygienist Date: November 15

MEDICAL SURVEILLANCE

DATE: NOVEMBER 2015

RECORDED BY: Alison N. Styron

INSTALLATION: FRCE/Airframes

BUILDING NUMBER: 137, HANGAR 1

SHOP NAME: 95202

SUPERVISOR: CRAIG DAUGHETY

PHONE: 464-9586

TOTAL PERSONNEL: 17

RECOMMENDED MEDICAL SURVEILLANCE PROGRAMS

Recommended

Program

Work Operation #

Emp.

Rationale

#503 Noise Pneumatic tool operation, flightline activity, GSE operation, vacuum cleaning

17 Noise levels above OEL

#716 Respirator User UH-1/AH-1 Sheet metal sanding/grinding for corrosion removal purposes (2nd shift main

Hangar 137)

17 Exposure above the AL for

Chromium VI (program requirement)

#133 Chromic

Acid/Chromium VI

UH-1/AH-1 Sheet metal sanding/grinding for corrosion removal purposes (2nd shift main

Hangar 137)

17 Exposure above the AL for

Chromium VI (program requirement)

All sheet metal personnel conducting sanding/grinding paint and corrosion removal operations at least 15 days a quarter or 30 days a year shall be enrolled Chromic

Acid/Chromium VI (133).

Table 1

Corrosion Cleaning, Sanding, or Grinding Process Control Requirements

Control All Corrosion Cleaning, Sanding, or Grinding

(Hazard is CrVI)

Engineering Controls

(ventilation) R

Regulated Area (No food, drink, tobacco, gum, or cosmetics) R

Barrier R

Signs R

Respirator R

Coveralls R

Tyvek (hooded) R

Booties R

Handwashing facilities R

Break Area R

Housekeeping R

All surfaces as clean as practicable R

Spills/releases cleaned ASAP R

HEPA vacuum for cleaning R

Sealed, labeled Containers for Waste Disposal R

Hygiene Facilities R

Shower after shift C

Key: R=Required

C=Recommended *Do not use compressed air for cleaning (dust removal)!

TABLE 2

SPECIFIC OSHA REGULATORY REQUIREMENTS

CHROMIUM VI (29 CFR 1910.1026)

1910.1026 (c) Permissible exposure limit (PEL). The employer shall ensure that no employee is exposed to an airborne concentration of chromium (VI) in excess of five micrograms per cubic meter of air (5 ug/m3), calculated as an eight hour time weighted average (TWA).

1910.1026 (e) Regulated areas. (1) Establishment. The employer shall establish a regulated area wherever an employee’s exposure to airborne concentrations of chromium (VI) is, or can reasonably be expected to be, in excess of the PEL.

1910.1026 (f) Methods of compliance. (1) Engineering and work practice controls. (i) Except as permitted in paragraph (f) (1) (ii) and (f) (1) (iii) of this section, the employer shall use engineering and work practice controls to reduce and maintain employee exposure to chromium (VI) to or below the

PEL, unless the employer can demonstrate that such controls are not feasible. Wherever feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the

PEL, the employer shall use them to reduce employee exposure to the lowest levels achievable, and shall supplement them by the use of respiratory protection that complies with the requirements of paragraph (g) of this section.

1910.1026 (f) (1) (2) Prohibition of rotation. The employer shall not rotate employees to different jobs to achieve compliance with the PEL.

1910.1026 (f) (1) (iii) Where the employer can demonstrate that a process or task does not result in any employee exposure to chromium (VI) above the PEL for 30 or more days per year (12 consecutive months), the requirement to implement engineering and work practice controls to achieve the PEL does not apply to that process or task.

TABLE 3

IDENTIFIED NOISE HAZARDOUS EQUIPMENT SURVEY

95202

Building: 137 (Hangar 1)

IH POC

Alison Styron 466-3362

Area

Labeled?

Available Hearing Protection Devices (HPDs) (including, but not limited to):

Adequate?

In use?

Manufacturer/Name Type NRR1

YES Sound Guard Foam Plug 29 Y Y

3M Skull Screws (Corded) Foam Plug 30 Y Y

3M Express Pod (Corded) Plug 25 Y Y

Tasco Golden Eagle (Over the Head) Muff 29 Y Y

EAR Ultrafit Triple Flange (Corded) Plug 25 Y Y

Sperian by Honeywell, Howard Leight MAX Foam Plug 33 Y Y

IDENTIFIED NOISE HAZARDOUS SOURCES (including, but not limited to):

Source IH Log# Labeled? dBA 2

Eng. Control, abatement feasibility note

Wilton Dual Sander 12-2128 YES 93.6 PPE (SHP)3

Hydraulic Generator (at full run up) 12-0895 No 100.2 PPE (DHP)4

“Do-All” Contour Machine Bandsaw (while cutting metal)

12-2070 YES 101.9 PPE (DHP)

Mobile Start Unit “Huffer” 12-0905 No 122.7 PPE (DHP)

Chicago Pneumatic, Pneumatic Hammer CP-444 12-1919 YES 120.9 PPE (DHP)

3x Chicago Pneumatic Rivet Gun 12-1992 YES 106.7 PPE (DHP)

Cherry Max Blind Rivet Installer (Model #6704B) 12-2131 YES 90.9 PPE (SHP)

Air Ratchet ¼” Drive Snap-On FAR-25 12-1918 YES 105.5 PPE (DHP)

CP Ratchet Impact Gun 3/8” Drive 12-1915 YES 104.9 PPE (DHP)

DOTCO 90° Router Model 10L1201636 12-1917 YES 107.5 PPE (DHP)

Pneumatic Straight Router 12-1913 YES 96.7 PPE (DHP)

Ingersoll Rand Model 3AL1 1/4” Drill 12-1916 YES 94.3 PPE (SHP)

ARO 90° Drill 12-1914 YES 97.8 PPE (DHP)

Rockwell Industries “Buckeye” Drill 12-1911 YES 107.0 PPE (DHP)

90° Pneumatic Drill Flex Collet 0-3000 RPM 12-1912 YES 88.6 PPE (SHP)

Nilfisk Vacuum Cleaner CFM Model 118 EXP at unit 13-0644 NO 97.8 PPE (DHP)

Nilfisk Vacuum Cleaner CFM Model 118 EXP (at nozzle)

13-0645 NO 104.2 PPE (DHP)

Tiger Vac EXP 1-10(25) LDS Vacuum Cleaner (at unit)

13-0646 NO 98.1 PPE (DHP)

Tiger Vac EXP 1-10(25) LDS Vacuum Cleaner (at nozzle)

13-0647 NO 104.1 PPE (DHP)

Mina Vac Compressed Air Vacuum Bag 12-1991 NO 101.9 PPE (DHP)

Dual Grinder (while grinding metal on belt) 12-2065 YES 108.9 PPE (DHP)

Tennsmith “Shear” 12-2068 YES 97.0 PPE (DHP)

NOISE SURVEY DATA OVERVIEW

Building Room/Location Noise Source Noise Level(s) dBA

Duration Hearing Protection

Required

137 Hangar 1 Flight operations, pneumatic tool operation, vacuum cleaners, select GSE operation

Variable 6-8 hrs/daily Single/Double

(Task dependent)

Note: * Miscellaneous equipment was assessed from various FRCE shops with the same trades and exact or similar equipment in operation. Specific Ground Support Equipment, pneumatic tool and vacuum models may vary.

Key:

(1) NRR – Noise Reduction Rating of Device.

(2) dBA – Sound Pressure Level in Decibels, A-Weighted Scale.

(3) SHP – Single hearing protection

(4) DHP – Double hearing protection

GLOSSARY OF TERMS

AL, or

Action Level

The level of contaminant that requires medical surveillance, usually one-half the

PEL.

ACGIH American Conference of Governmental Industrial Hygienists.

AIHA The American Industrial Hygiene Association.

ANSI American National Standards Institute.

Biohazard Organisms or products of organisms that present a risk to humans.

Carcinogen, Carcinogenic Cancer producing.

Ceiling (TLV - Ceiling) The concentration that should not be exceeded during any part of the working exposure.

Combustible Liquids Those liquids having a flash point at or above 37.8 o C (100 o F).

Compound A substance composed of two or more chemical elements. Each compound has its own characteristic properties different from those of its constituent elements.

Corrosive A substance that causes visible destruction or permanent changes in human skin tissue at the site of contact.

dBA Sound level in decibels read on the A-scale of a sound level meter. The A-scale discriminates against very low frequencies (as does the human ear) and is, therefore, better for measuring general sound levels.

Dermatitis Inflammation of the skin from any cause.

Dosimetry A method of measuring, which quantifies an individual's exposure to a physical or chemical stressor. Expressed as quantity per unit of time.

Flammable Liquids Those liquids having a flash point below 37.8 o C (100 o F).

Flash Point The lowest temperature at which a liquid gives off enough vapor to form an ignitable mixture with air, and produce a flame when a source of ignition is present.

Fume Airborne particulate formed by the evaporation of solid materials, e.g., metal fume emitted during welding. Usually less than one micron in diameter.

General Ventilation System of ventilation consisting of either natural or mechanically induced fresh air movements to mix with and dilute contaminants in the workroom air.

Heat Stress Relative amount of thermal strain from the environment.

Humidity An indication of the amount of water vapor in the air.

IDLH Immediately Dangerous to Life or Health. Used to describe atmospheres where employee exposure can cause serious injury or death within a short time or serious delayed effects.

LEL Lower Explosive Limit. The lower-limit of flammability of a gas or vapor at ordinary ambient temperatures, expressed in percent of the gas or vapor in air by volume.

Appendix A

Personal Protective

Equipment (PPE)

Devices worn by the worker to protect against hazards in the environment.

Respirators, gloves, and hearing protectors are examples.

PEL Permissible Exposure Limit. An exposure limit that is published and enforced by

OSHA.

Radiation Source An apparatus or material emitting or capable of emitting ionizing radiation.

Respirable Size Particles Particulates in the size range that permit them to penetrate deep into the lungs upon inhalation.

Sensitize Rendering an individual sensitive to the action of a chemical. Can cause an individual to develop an allergic reaction.

Short Term Exposure

Limit (STEL)

ACGIH-recommended exposure limit. Maximum concentration to which workers can be exposed for a short period of time (15 minutes) for only four times throughout the day, with at least one hour between exposures.

Sound Level A measurement of the sound pressure level usually weighted to reflect human ear capabilities.

Synergistic Pertaining to the action of two or more substances, the effect of which is greater than the additive effects of each alone.

Systemic Spread throughout the body, affecting all body systems and organs not localized in one spot or area.

TWA - Time-Weighted

Average Concentration

Refers to concentrations of airborne toxic materials that have been averaged for a certain time duration, usually 8 hours.

TLV - Threshold Limit

Value

A time weighted average concentration to which a worker can be exposed and expect no harmful effects.

Customer Satisfaction/Complaint Form

Thank you for participating in this program. Your response to this evaluation will assist us in improving customer satisfaction and quality assurance in our services.

Department: Position:

Name: Phone:

Industrial Hygienist (IH)/Industrial Hygiene Technician (IHT): Yes No NA

Was the IH/IHT responsive and helpful?

Was the IHIHT knowledgeable about the potential health hazards associated with this work area?

Did the IH/IHT conduct his/her service in a professional manner?

Industrial Hygiene Survey Report/Correspondence: Yes No NA

Were reports clear, concise and easily understandable?

Was information accurate and informative?

Were all work processes/concerns addressed?

Please comment on what you thought were the best aspects of our services:

Please comment on how we may improve services provided to you:

Specific Complaint:

Date: Time: POC/Phone #:

Source of Complaint (Name/Organization):

Please return evaluation via guard mail to the Naval Health Clinic Industrial Hygiene Department

Appendix B