Attachment_04t_2015_IHS_of_H-53_Line.pdf

2015 PERIODIC INDUSTRIAL HYGIENE SURVEY

OF

H-53 LINE

(95441, 95442, 95443 and 95447)

INDUSTRIAL HYGIENE DEPARTMENT

NAVAL HEALTH CLINIC

CHERRY POINT, NC 28533-0023

Enclosure (13)

TABLE OF CONTENTS

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

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

95441 H-53 Disassembly and Repair…………………………………….…………………………...8

Table 1: 95441 Noise Hazardous Equipment………………………………………………………..17

Table 2: Corrosion Cleaning, Sanding, or Grinding Process Control Requirements………………..18

Table 3: Specific OSHA Regulatory Requirements.........................................................……………….19

Table 4: 95441 Exposure Monitoring Sampling Results…………………………………………….20

95442 H-53 Buildup………………………………………………………………………………….21

Table 5: 95442 Noise Hazardous Equipment………………………………………………………..30

95443 H-53 Flight Check…………………………………………………………………………….31

Table 6: 95443 Noise Hazardous Equipment………………………………………………………..39

Table 7: 95443 Exposure Monitoring Sampling Results…………………………………………….40

95447 H-53 Component Repair……..………………………………………………………………..41

Table 2: Corrosion Cleaning, Sanding, or Grinding Process Control Requirements………………..50

Table 3: Specific OSHA Regulatory Requirements.........................................................……………….51

Table 8: 95447 Identified Noise Hazardous Equipment……………….…………………………….52

Table 9: 95447 Exposure Monitoring Sampling Results…………………………………………….53

Table 10: 95447 Noise Dosimetry Results…………………………………………………………..54

Table 11: Ventilation Evaluation Walk-in Cross Draft 5 Fan System Booth (Sponson Shop)…..…55

Table 12: Ventilation Evaluation Walk-in Cross Draft Booth (H-53 Component Room)………….56

Table 13: Ventilation Evaluation EAPs Walk-in Cross Draft Booth (Sheet Metal Artisans)………57

Glossary of Terms Appendix A

Customer Satisfaction/Complaint Form Appendix B

EXECUTIVE SUMMARY

Periodic Industrial Hygiene Surveys of shops 95441, 95442, 95443 and 95447 were conducted by Ms. Alison

Styron, Industrial Hygienist, in July 2015 and December 2015. The purpose was to evaluate any changes to work processes or work practices that have occurred since the previous survey. The H-53 Airframes Branch performs all work on H-53 aircraft under the Standard Depot Level Maintenance concept. These shops are comprised of electricians, airframe artisans and sheet metal artisans.

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.

Cadmium/Chromium VI Compliance: Past exposure monitoring has resulted in cadmium and chromate overexposures during sanding/grinding paint and corrosion removal operations conducted by sheet metal artisans.

Based on overexposures, implementation of CFR 1910.1026 (Hexavalent Chromium), CFR 1910.1027 (Cadmium) and the FRCE Cadmium Written Compliance Program for Industrial Airframes Repair and Modification Division was mandated. (An overview of these regulations is provided on Tables 2 and 3 of this report). Compliance is managed by the FRC East Safety office. Since the previous IH survey was conducted, corrosion removal tasks formerly performed by 95443 are now carried out by shop 95441 personnel. 95441 artisans that conduct sanding/ grinding paint and corrosion removal operations 30 days a year must be enrolled in Chromic Acid/Chromium VI and

Cadmium Medical Surveillance Programs. In addition, sanding/grinding paint and corrosion removal operations conducted on specific 95447 components (identified in this report) also require enrollment in these programs and adherence to specific compliance mandates. Continued Exposure Monitoring of these operations is required.

Hearing Conservation Program: 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 shop personnel are enrolled in the Hearing Conservation Program. Disposable ear plugs were readily available for employee use. Though not stocked in the SE rooms, supervisors advised that muffs were available to all employees. Personnel were observed wearing hearing protection at the time of the walkthrough. Specific identified noise hazardous equipment and available hearing protection are included in each shop assessment of this report.

Continue to ensure that all noise hazardous equipment is labeled.

Respiratory Protection Program: Respirators are required to be worn by 95441 sheet metal personnel conducting extensive sanding/grinding operations. 95447 personnel conducting sanding operations on select components are also required to wear respiratory protection. Personnel wear half face and full face respirators with P100 filtration, as well as, Bullard supplied air hood respirators. Personnel conducting H-53 tail pylon sanding are required to wear full face respirators at a minimum based on past cadmium overexposures >38x PEL. (Full-face respirators and

Bullard supplied air hoods are acceptable, however, the use of half-face respirators is prohibited during this activity).

Eyewash Stations: Plumbed eyewash stations are located throughout the 137 Hangar 3 and in the adjacent metal working area, in the component repair shops and in the Bldg. 3766 walk-in ventilated booth. At the time of the walkthrough eyewash stations were accessible and appeared to be maintained. Tags were attached reflecting weekly inspections. FRCE Safety personnel manage eyewash stations, including placement, testing and maintenance.

Personal Protective Equipment (PPE): In general, personnel were observed wearing appropriate PPE during the walkthrough. However, anti-vibration gloves were not available for issue during the walkthrough. Supervisory staff report that circumaural muffs were readily available. The use of double hearing protection should continue to be enforced. (Please refer to the Identified Noise Hazardous Equipment Tables included in this report.) Ensure that personnel continue to receive PPE as needed.

Thermal Stress: Personnel are subject to thermal stress in all shop assignments in the bldg.137 work spaces as well as on the flightline. Of particular concern is the 95447 component room in the bldg. 137 annex. Thermal stress monitoring conducted on 9 July 2014 in the 95447 component room resulted in WBGT values > 31°C (31.62 C or

88.92°F). No improvements had been made to improve the thermal comfort issues at the time of the walkthrough.

Based on the employees "moderate" metabolic rate of work (Table 3: Metabolic Rate Categories and the

Representative Metabolic Rate with Example Activities, ACGIH TLVs and BEIs) personnel are expected to exceed both the Action Limit and TLV for heat stress during the summer months. General temperature readings in this shop exceeded 34°C (94°F).

Engineering controls should be implemented to improve thermal comfort in the component repair space. Ensure personnel hydrate appropriately and take frequent rest breaks. Personnel assigned to the component room space in summer months will be enrolled in Medical Surveillance Program 502 (based on NMCPHC-TM OM 6260, Heat).

Ensure all personnel are trained in thermal stress recognition and prevention. Contact the FRC East 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 H-53 Airframes shops (95441, 95442, 95443 and 95447) 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

H-53 Airframes (95441, 95442, 95443 and 95447)

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).

-Since the previous survey, sheet metal artisans have been added to shops 95441 and 95442. Sheet metal personnel in 95441 have been tasked with large scale corrosion removal operations and these operations are no longer conducted by shop 95443.

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 the 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: 95441 and 95442 personnel now have sheet metal artisans. 95441 personnel now conduct operations requiring enrollment in cadmium and chromium VI medical surveillance.

95443 personnel no longer conduct operations requiring cadmium and chromium VI medical surveillance enrollment(s).

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 wear at a minimum single hearing protection in all work areas. Particular emphasis should be placed on use of double hearing protection during identified noise hazardous operations exceeding 96 dBA noted in this report. Ensure all applicable identified noise hazardous equipment is labeled appropriately.

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 large scale abrasive paint and corrosion removal activities. 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. Half face respiratory protection is not acceptable for tail pylon sanding/grinding operations based on documented overexposures. (Personnel should wear a full face respirator with P100 filtration or a Bullard supplied air hood while conducting this work.) A FRC East 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: Walk-in ventilated booths are available in the sponson, EAPS and component room shops as well as in Bldg. 3766.

Ventilation assessments are included in this report. (Assessment of this booth is captured in FRCE 93000 clean shops). HEPA vacuums are available throughout the workspaces. Personnel should utilize provided ventilation for paint and corrosion removal activities.

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, stools and cushions 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 continue to receive ergonomic training including specific guidance identified in OPNAVINST 5100.23G, Ch.

23. Training emphasis should be placed on Hand-Arm Vibration injury prevention, including the use of anti-vibration gloves.

The acquisition of vibration dampening tools is recommended. Contact the FRCE Ergonomics Program manager 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.

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: Noise exposure data was collected during shop and flightline operations and is included in shop assessments.

3. Findings and Recommendations:

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

The following significant findings were identified:

Comments: Personnel shall wear double hearing protection during pneumatic rivet gun operation. The use of provided ventilation should be used during paint/corrosion removal operations.

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

Exposure monitoring needs were identified.

No New exposure monitoring needs were identified.

There are no changes to the previous Exposure Monitoring Plan.

Comments: Additional noise monitoring and reassessment of manual wire brushing (corrosion removal) conducted by electricians has been requested.

INDIVIDUAL HAZARD ASSESSMENT

DATE: DECEMBER 2015

RECORDED BY: Alison N. Styron

INSTALLATION: FRCE/Airframes

BUILDING NUMBER: 137 (Hangar 3)

SHOP NAME: 95441/Disassembly

SUPERVISOR: 1ST BILL WILKINSON/

2ND BOBBY MANNING

PHONE: 464-5349

TOTAL PERSONNEL: 45 (+2 SUPV)

SHOP OPERATIONS: This shop is tasked with disassembly and repair of H-53 aircraft. The shop is comprised of airframers, electricians and sheet metal artisans. Since the previous survey, airframers and sheet metal personnel have been added to this shop.

(95441 sheet metal personnel perform corrosion removal operations that were previously conducted by 95443 artisans.)

OPERATIONS AND

ASSOCIATED

HAZARDS/NUMBER OF

WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

General Shop Operations: Work is performed in Hangar 3 with multiple artisans perform a variety of noise generating operations that include, but are 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 and bldg.137 workspace are subject to extreme temperatures/

Thermal stress/All

~7 hrs/daily PPE: Single hearing protection (at a minimum)

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, neohexane, phenol, phenolic resin, polychloroprene, propane, silica (fumed), titanium dioxide, toluene, xylene/30

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: 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

(breaking fasteners, etc.): aliphatic alcohol, aromatic naphtha, 2-butoxy-ethanol, carbon dioxide propellant, diacetone alcohol, glycol either, petroleum distillates, sec-butyl alcohol/30

Variable/5 min/weekly

Adequate ventilation/PPE:

safety glasses1, Aerosol Corrosion Preventative

Compound (CPC) Use (occasional use on connectors): butyl alcohol, aliphatic mineral spirits/petroleum distillates, isopropyl alcohol, stoddard solvent, toluene, 1,1,1,2-tetraflouroethane/15

2 min/1- 2x/weekly

Adequate ventilation/PPE:

safety glasses1, nitrile gloves2

Aircraft/aircraft component surface cleaning: acetone or isopropyl is applied and wiped with a cloth/30

Variable/10-15 min/2-3x weekly

Adequate ventilation/PPE:

chemical splash goggles (based on liquid use), Aircraft fuel handling: JP-5, JP-8

(defuel only), (kerosene, naphthalene), noise (conducted on flight line)

-Sampling process

-Fueling (trucks/pits)

(Variable numbers; Qualified personnel only)

Aircraft/work-load dependent

Sampling:

Variable:10-15 min

Closed system/ adequate ventilation/PPE:

single hearing protection/

(double on flightline – cranial w/muffs), face shield, safety glasses1, nitrile gloves2

Noise: UNACCEPTABLE based on existing data. Enrollment in medical surveillance required. Noise is a developmental reproductive hazard.

Other stressors: ACCEPTABLE based on acquired sampling data and existing controls.

Naphthalene is a suspected human carcinogen.

Aliphatic naphtha use (surface prep for rubber strip application):

toluene, cyclohexane/15

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)/30

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

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Component removal/handling/ installation incidental exposure to aircraft fuel, hydraulic fluid and lubricants: ethyl benzene, kerosene, molybdenum disulfide, petroleum distillates, tricresyl phosphate, naphthalene, diisononyl ester, polyalphaolefins and noise (based on pneumatic tool use)/30

Noise hazardous pneumatic wrenches including, but not limited to*:

-Air Ratchet ¼” Drive Snap-On

FAR-25: 105.5

-CP Ratchet Impact Gun 3/8” Drive:

104.9

*Sound Pressure Levels (SPLs) in dBA.

Variable/5-20 min/daily

Adequate ventilation/ appropriate hygiene practices/PPE:

safety glasses1, nitrile gloves2, single/double hearing protection

(depending on pneumatic tool selection; see Table 1)

ACCEPTABLE based on existing controls.

Ethyl benzene and naphthalene are suspected human carcinogens.

Cryogenics Handling (used for de-bonding sheet metal): carbon dioxide (dry ice), dermal injury/15

20-30 min/2-3x weekly

SOPs/Training

PPE: cryogenics gloves, tongs, safety glasses1

Engine Oil sampling/handling/ administration: petroleum distillates, tricresyl phosphate/15

Variable/5-30 min/monthly

PPE: safety glasses1, nitrile gloves2, face shield

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.

Toluene is a developmental reproductive hazard.

Titanium dioxide is a suspected carcinogen.

Fuel cell work: Personnel perform a variety of tasks inside fuel cells.

Tasks require hand and arm entry as well as full body entry. Fuel cells must be evaluated before entry and personnel adhere to applicable permits. No entries are made into fuel cells that would require the use of a respirator. Personnel are confined space trained/confined space hazard, JP-5/JP-8 fuel vapors

(naphthalene, kerosene), awkward postures (work related musculo-skeletal injury), oxygen deficiency, heat stress/Variable

*Note: The Gas Free Engineering program is managed by FRCE

Safety representatives. Employees should continue to adhere to all program requirements.

Variable durations/~ 6x monthly

SOPs/Gas Free

Engineering/

Confined space entry training/Heat stress training/

Proper hygiene procedures/

Mechanical ventilation/PPE:

safety glasses1, nitrile gloves2 coveralls, goggles

Exposures are highly variable. Based upon ambient monitoring and adherence to Gas Free

Engineering permit requirements, exposures are expected to be ACCEPTABLE.

Contact the FRCE Safety Office with questions regarding this program.

Naphthalene is a suspected human carcinogen.

Ensure all personnel receive training on prevention of ergonomic injury (Reference

OPNAVINST 5100.23G, Ch. 23)

Ensure personnel continue to take adequate rest breaks to minimize heat stress and ergonomic injury.

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Glove box Blasting Unit Operation

(plastic and glass bead media):

metal and paint dusts including cadmium, lead, chromium, chromium

VI/any of 15

5-30 min/weekly

Closed system operation/

Training/

SOPS/PPE:

gloves, proper hygiene practices

ACCEPTABLE based on existing controls.

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.

Grease application (on various items including bolts and landing gear): petroleum distillates, molybdenum disulfide, tricresyl phosphate/15

5-15 min/weekly

Adequate ventilation/PPE:

safety glasses1, Hydraulic fluid sampling/ handling/administration/removal:

diisononyl ester, polyalphaolefins/15

5-30 min/1-2x monthly

PPE: safety glasses1, nitrile gloves2

Magnesium treatment application on transmission and gear box components (brush application):

chromic acid/15

10-15 min/per aircraft

Adequate ventilation/PPE:

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

ACCEPTABLE based on minimal exposure duration and application method. Exposures above the Action Level are not anticipated.

Existing controls are adequate.

Hexavalent chromium compounds are identified carcinogens.

Manual corrosion removal performed on various electrical components with wire brush, including ground studs: metal dusts

(including cadmium), paint dusts, “AeroKroil”, isopropyl alcohol, “CPC” (petroleum distillates/oil)/15

Variable/10-15 min/weekly

Training/ use of wet method/PPE:

safety glasses1, nitrile gloves2

ACCEPTABLE based on use of wet method.

Existing controls are adequate.

Cadmium is an identified carcinogen and a reproductive hazard.

Minor sanding/grinding/cutting and drilling of aircraft and component painted/primed surfaces including minor manual and pneumatic abrasive operations on sheet metal and fiberglass/composite surfaces: paint dusts, bonding/sealant dusts, chromates, cadmium (from rivets, anchor nuts and other cadmium coated hardware), lead, fiberglass/ composite fibers (synthetic vitreous fibers/manmade mineral fibers), nuisance dusts, noise (based on pneumatic tool use and vacuum use)/15

Variable/5 min-

30 min/daily

HEPA

vacuums/PPE:

safety glasses1, nitrile gloves2, single hearing protection

(double required during specific pneumatic equipment use;

see Table 1)

Miscellaneous dusts including hexavalent chromium (CrVI): ACCEPTABLE based on existing data on minor sanding and paint removal operations. Hexavalent chromium compounds are known carcinogens. 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. Lead is a reproductive hazard

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

Polyurethane pen 2-part sempen application on ground studs (8010014416020): HDI oligomers , xylene, mesitylene, n-butyl acetate, solvent naphtha/15

Variable/10-15 min/

Sempen/brush application/

PPE: safety glasses1, nitrile gloves2

ACCEPTABLE based on application method.

Existing controls are adequate.

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

RTV 3145 Application: methanol, methyltrimethoxy-siloxane, titanium dioxide, trimethylated silica/30

Variable/10-15 min/2x monthly

Adequate ventilation/PPE:

safety glasses1, ACCEPTABLE. Existing controls are adequate.

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/15

Rivet installation 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 hrs/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.

Flying debris: ACCEPTABLE. Existing controls are adequate.

Rivet gun (adjacent operations):

Sheet metal artisans operate rivet guns on aircraft in close proximity to other artisans. Most rivet guns produce noise levels >104 dBA. All personnel in close proximity (<6 ft) to rivet gun operations must wear double hearing protection/All

6-7 hrs/daily PPE: Double hearing protection

Noise: UNACCEPTABLE based on noise data.

Enrollment in the Hearing Conservation Program is required.

Noise is a developmental reproductive hazard.

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, polysulfide polymer, calcium carbonate, carbon black, diethylene glycol, diethylene-triamine, diphenyl guanidine, epichlorohydrin, isopropyl alcohol, manganese oxide/dioxide, methyl ethyl ketone, hydrogenated terpheynyls, phenol, polyamine, silicon dioxide, talc, toluene, titanium dioxide, triethylene tetramine, magnesium chromate (chromium VI compounds)/30

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.

NUMBER OF WORKERS

DURATION/

FREQUENCY

OF

EXPOSURE

CONTROLS EXPOSURE

ASSESSMENT

Sheet metal fabrication/repair/ including, but not limited to, use of bender, brake, grinder, roller, drill press, band saw, pneumatic drill, pneumatic router (cutting wheel/disc), shrinker/stretcher, cutter and fixed dual sander: noise, flying debris, cut/laceration/puncture/ abrasion/ vibration/15

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 hrs/daily

SOPs/machine guards/PPE:

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

(equipment dependent; see

Table 1), cut resistant gloves

(not to be 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.

Soldering including soldering flux and flux remover use: 60% tin/37% lead solder and tin alloy solder lead fumes, copper, silver, antimony, soldering flux (ammonium chloride, zinc chloride, petrolatum)/15

Variable,10-20 min/weekly

Training

(including proper hygiene practices)/ adequate ventilation/PPE:

safety glasses1

ACCEPTABLE based on existing controls.

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

Touch-up spray painting of aircraft/components (non-polyurethane painting): acetone, butyl alcohol, propane, toluene, xylene/30

~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 (Mina Vacs, Tiger Vac and

Nilfisk HEPA vacuums available during walkthrough) /noise/All

Tiger Vac: 98.1-104.1

Nilfisk Vacuum Cleaner “Blue”

GS/GM 811: 85.4

15-20 min/daily PPE: Double hearing protection

UNACCEPTABLE based on collected Sound

Pressure Levels (SPLs). See Table 1.

Personnel exposures are expected to exceed the

OEL. Enrollment in the Hearing Conservation

Program Required. Noise is a developmental reproductive hazard.

Weight/balance of aircraft involving transport and use of large ~84 pound plate scales: work related musculoskeletal disorders (ergonomic injury)/2

Variable/1hr/2- 3x monthly

Ergonomic training/Proper lifting procedures

Ergonomic Injury: UNACCEPTABLE based on weight and size of scales. The procurement of a mechanical lift (arm) or another weight bearing tool is recommended.

Further analysis of the scale handling/ transport operation by an FRCE ergonomics specialist is recommended.

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

-Ensure electrician/avionics personnel continue to receive regular training on the health hazards associated with lead soldering operations, per 29 CFR 1910.1025, Appendices A and B (OSHA lead standard). Although overexposures to lead are not anticipated, all personnel should use good hygiene practices, e.g., washing hands thoroughly after conducting soldering operations to prevent accidental ingestion of lead.

-Continue to follow requirements set forth in GFE/Confined Space Permits as managed by the FRCE Safety Office.

The use of anti-vibration tools is recommended. Ensure personnel are trained in the recognition and prevention of Work Related

Musculoskeletal Disorders.

-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. Personnel with facial hair that interferes with a respirator seal are permitted to wear Bullard supplied air hoods.

-Ensure personnel conducting sanding/grinding operations comply with the Cadmium and Hexavalent written compliance program managed by Fleet Readiness Center East. Conducting this work without HEPA vacuums or vacuum assisted tools is prohibited. Fans should not be used in proximity of these operations. Additional requirements identified in Tables 2 and 3 of this report are also mandated.

-Personnel within 6 feet of rivet gun operation shall utilize double hearing protection.

-Based on weight of plate scales, ensure personnel utilize proper lifting techniques to move this equipment. The procurement of a mechanical lift for movement of these scales is recommended.

- Ensure that double hearing protection is worn while performing identified noise hazardous operations at 96 dBA or greater.

FINDINGS/RECOMMENDATIONS:

Findings: Multiple artisans share gloves in glove box ports as well as during some chemical uses posing potential hygiene concerns.

Recommendations: It is recommended that personnel use nitrile gloves inside any “shared” gloves such as those found at glove boxes.

Findings: Chemical splash goggles are required to be worn, IN ADDITION to face shields during alodine dip tank use. Placards attached to these tanks do not include chemical splash goggles as required PPE.

Recommendations: Placards should incorporate the use of chemical splash goggles.

Findings: Artisans conducting rivet operations should utilize full fingered anti-vibration gloves. (No anti-vibration gloves were available for checkout in the SE/Tool room at the time of the walkthrough.)

Recommendations: It is recommended that full-fingered appropriately certified EN/ANSI/ISO gloves are acquired and made available to sheet metal artisans. (Contact the FRCE ergonomics program manager with questions regarding these products.)

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: DECEMBER 2015

RECORDED BY: Alison N. Styron

INSTALLATION: FRCE/Airframes

BUILDING NUMBER: 137 (HANGAR 3)

SHOP NAME: 95441

SUPERVISOR: 1ST BILL WILKINSON/

2ND BOBBY MANNING

PHONE: 464-5349

TOTAL PERSONNEL: 45 (+2 SUPV)

Operation Potential Hazard #No.

Samples

Sample location

Method Sample

Freq

ManHr

/yr

Compliance Exposure Monitoring

Full scale corrosion removal

(sanding/grinding)

Sheetmetal Artisan

(Bldg 3766/1 st and 2 nd

Shifts)

*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

General work performance in Bldg. 137

(Hangar 3)

Noise 1-2 HZ PD 4 32

Reassessment Exposure Monitoring

Soldering Lead (Pb) 2 BZ F 2 16

Manual wire brushing corrosion removal from electrical components and associated hardware

(conducted by electricians)

Cadmium (Cd) 2 BZ F 2 16

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

95441 Supervisors: Please contact the Naval Health Clinic, Industrial Hygiene Department at 466-3251 or 466-

4564 prior to the next evolution of the above operations for evaluation/sampling.

NHCCP IH Staff:

Personnel from 95441, 95442 or 95443 can be monitored to meet this requirement. Please document all equipment utilized by artisans.

Signed:

Title: Industrial Hygienist Date: December 15

MEDICAL SURVEILLANCE DATE: December 2015

INSTALLATION: FRCE/Airframes

BUILDING NUMBER: 137 (Hangar 3)

SHOP NAME: 95441

SUPERVISOR: 1ST BILL WILKINSON/

2ND BOBBY MANNING

PHONE: 464-5349

TOTAL PERSONNEL: 45 (+2 SUPV)

RECOMMENDED MEDICAL SURVEILLANCE PROGRAMS

Recommended Program Work Operation # Emp. Rationale

#503 Noise General shop operations, pneumatic tool operation, vacuum operations, flightline activity

45 Noise levels above OEL.

#133 Chromic

Acid/Chromium VI

Full scale corrosion removal from aircraft

“nose to tail” clean/treat operations conducted in Bldg 3766 1 st /2 nd shift

15 Exposure above the AL for 30 days or greater

#124 Cadmium Full scale corrosion removal from aircraft

“nose to tail” clean/treat operations conducted in Bldg 3766 1 st /2 nd shift

15 Exposure above the AL for 30 days or greater.

#716 Respirator User Full scale corrosion removal from aircraft

“nose to tail” clean/treat operations conducted in Bldg 3766 1 st /2 nd shift

15 Exposure above the AL for

Cadmium and Chromium VI

#508 Hand arm vibration Use of pneumatic rivet guns 15 Based on duration and frequency

TABLE 1

95441 IDENTIFIED NOISE HAZARDOUS EQUIPMENT SURVEY

95441 Building: 137 (H-53 Hangar 3) 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

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

Source IH Log# Labeled? dBA 2

Eng. Control, abatement feasibility note

Cherry Max Blind Rivet Installer (Model #G704B) 16-0091 YES 91.4 PPE (SHP)3

Chicago Pneumatic, Pneumatic Hammer CP-4441

(adjacent operations)

12-1919 YES 120.9 PPE (DHP)4

3x Chicago Pneumatic Rivet Gun

(adjacent operations)

12-1992 YES 106.7 PPE (DHP)

Chicago Pneumatic Rivet Hammer “Huck Bolt” Removal 16-0095 YES 124.3 PPE (DHP)

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)

Mobile Start Unit “Huffer” 12-0905 NO 122.7 PPE (DHP) 3

Electric Power Supply Unit A/M 27T-14 (at controls) 14-0612 YES 88.9 PPE (SHP)

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

Nilfisk Vacuum Cleaner “Blue” GS/GM 811 12-1984 NO 85.4 PPE (SHP)

Nilfisk Vacuum Cleaner “Blue” GS/GM 811 (at nozzle) 12-1910 NO 97.2 PPE (DHP)

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)

Clayton “Wart Hog” Vacuum Cleaner 12-1965 NO 97.6 PPE (DHP)

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

Nilfisk Euroclean WD 200 Series 12-1990 NO 88.1 PPE (SHP)

NOISE SURVEY DATA OVERVIEW

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

Duration Hearing Protection

Required 137 Hangar 3 and adjacent flightline

Flight operations, pneumatic tool operation, vacuum cleaners, select

GSE operation

Variable 6-8 hrs/daily Single/Double (Task dependent; see above)

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

Table 2

Corrosion Cleaning, Sanding, or Grinding Process Control Requirements

Control All Corrosion Cleaning, Sanding, or Grinding (Hazard is CrVI)

Corrosion Cleaning, Sanding, or

Grinding (on non-stainless steel)

Engineering Controls

(ventilation) R R

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

Barrier R R

Signs R R

Respirator R R

Coveralls R R

Tyvek (hooded) R R

Booties R R

Handwashing facilities R R

Break Area R R

Housekeeping R R

All surfaces as clean as practicable R R

Spills/releases cleaned

ASAP

R R

HEPA vacuum for cleaning R R

Sealed, labeled Containers for Waste Disposal R R

Hygiene Facilities R R

Shower after shift C R

Key: R=Required

C=Recommended

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

TABLE 3

SPECIFIC OSHA REGULATORY REQUIREMENTS

CADMIUM (29 CFR 1910.1027) CHROMIUM VI (29 CFR 1910.1026)

1910.1027 (c) Permissible Exposure Limit (PEL). The employer shall assure that no employee is exposed to an airborne concentration of cadmium in excess of five micrograms per cubic meter of air (5 ug/m3), calculated as an eight-hour-time-weighted average exposure (TWA).

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).

1910.1027 (e) Regulated areas—(1) Establishment. The employer shall establish a regulated area wherever an employee’s exposure to airborne concentrations of cadmium is, or can reasonably be expected to be in excess of the permissible exposure limit (PEL).

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.

1910.1027 (f) Methods of compliance—(1) Compliance hierarchy. (i) Except as specified in paragraphs (f) (1) (ii), (iii), and (iv) of this section the employer shall implement engineering and work practice controls to reduce and maintain employee exposure to cadmium at or below the PEL, except to the extent that the employer can demonstrate that such controls are not feasible.

1910.1027 (f) (1) (iv) Wherever engineering and work practice controls are required and are not sufficient to reduce employee exposure to or below the PEL, or, where applicable, the

SECAL, the employer nonetheless shall implement such controls to reduce exposures to the lowest levels achievable.

The employer shall supplement such controls with respiratory protection that complies with the requirements of paragraph (g) of this section and the PEL.

1910.1027 (f) (1) (v) The employer shall not use employee rotation as a method of compliance.

1910.1027 (f) (2) Compliance Program. (i) Where the PEL is exceeded, the employer shall establish and implement a written compliance program to reduce employee exposure to or below the PEL by means of engineering and work practice controls, as required by paragraph (f) (1) of this section. To the extent that engineering and work practice controls cannot reduce exposures to or below the PEL, the employer shall include in the written compliance program the use of appropriate respiratory protection to achieve compliance with 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.

1910.1027 (f) (1) (iii) The requirement to implement engineering and work practice controls to achieve the PEL or, where applicable, the SECAL does not apply where the employer demonstrates the following:

1910.1027 (f) (1) (iii) (A) The employee is only intermittently exposed; and

1910.1027 (f) (1) (iii) (B) The employee is not exposed above the PEL on 30 or more days per year (12 consecutive months).

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 4

2015 95441 SAMPLING RESULTS

NOISE DOSIMETRY SUMMARY TABLE

SAMPLE

NUMBER

SAMPLE

DATE

Task LOCATION SAMPLE TIME

(minutes)

8-Hour*

TWA (dBA)

CP15-0518 27 JUL 15 Electrical connector handling performed by electrician (with adjacent sheet metal rivet installation operations)

Bldg. 137, Hangar 3 464 93.1

CP15-0519 28 JUL 15 Aircraft wiring operations (with adjacent sheet metal rivet installation operations)

Bldg. 137, Hangar 3 461 89.9

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

Continued…