Transcript OSHA Sampling Strategy - California Industrial Hygiene Council

Industrial Hygiene in the BP Oil Spill Event:
What's Public and What We Should Learn
From the Event
Thomas Grumbles, CIH
Senior Consultant
Cardno ENTRIX
California Industrial Hygiene Council
December 6, 2010
Chronology
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April 20th 2010 the event began
July 15th the well was capped
September 19th the well was permanently sealed
BP staff, contractors, governmental and industry employees and
volunteers are still at sites providing ongoing response
 The most “public” emergency response event to date
Scope Of Work
 At the peak of activity
– 47,848 workers
– 8,044 vessels
– 123 aircraft
 September 20
– 25,200 workers
– 2,600 vessels
– dozens of aircraft
 Federal response led by the U.S. Coast Guard under the National
Contingency Plan
– Spill of National Significance designation
OSHA Activity thru 10/1/10
 OSHA averaged over 146 professionals throughout the Gulf Region
during the event
 OSHA staff made over 4,266 site visits to
– vessels of opportunity,
– staging areas,
– decontamination sites,
– Offshore and onshore clean up activities
 The Agency developed a sampling protocol and strategy and has taken
samples resulting in over 5,731 exposure assessments (exposure
assessments )
 To date, no air sampling by OSHA has detected any hazardous
chemical at levels of concern. (Spill Home Page)
 All OSHA results are posted (sampling results )
OSHA Sampling Strategy
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What hazards to evaluate in an event like this?
Most of the cleanup workers are exposed to “weathered oil”,
– more volatile substances have evaporated
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Potential health effects from inhaling other non oil chemicals
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oil dispersants, cleaning agents, and others are an ongoing concern
Among the many hazards workers face--such as falls, drowning, fatigue, sharp
objects and animal bites--the number one health concern was heat stress
– more than 700 incidents reported by 8/16
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OSHA devised a systematic approach to assess hazards and created a
Sampling Strategy to characterize and document hazards of commonly
observed work activities.
“OSHA is also analyzing the "soup" of crude oil, oil by-products, dispersants,
and any other material to determine what hazards the mixture might present
workers as they respond to and cleanup the oil spill”
OSHA Sampling Strategy
Summary of Air Sampling
Oil
Media
Analyte(s)
Sampling time and flow rate
Method
SKC 575-002 Passive Sampler or
charcoal tube
Benzene, cyclohexane, toluene, ethyl
benzene, xylene, trimethylbenzes
4 hour for SKC 575-002,
OSHA Method 7
OSHA Method 111
OSHA Method 1002
OSHA Method 1005
4 hour at 0.05 L/min for charcoal tube
Charcoal tube
Petroleum distillates
4 hour at 0.05 L/min
OSHA Method 48
ULTRA I Passive Sampler containing
Tenax TA
Heavy aliphatics and aromatics
Minimum of 4 hours, maximum of 16
hours
OSHA Maries Project Study
Assay Technology ChemDisk Aldehyde
Monitor
Formaldehyde
4 hour (TWA)
OSHA Method 1007
OSHA Sampling Strategy
Dispersants
Media
Analyte(s)
Sampling time and flow rate
Method
SKC 575-002 Passive Sampler or
charcoal tube
2-butoxyethanol
4 hour for SKC 575-002,
4 hour at 0.05 L/min for charcoal tube
OSHA Method 83 (must be separate
sample from other analytes due to
different extracting solvent)
2 hour at 1 L/min
OSHA Method PV2051
OVS-7 tube
Propylene glycol
Acid Gases/Mist
Media
Analyte(s)
Sampling time and flow rate
Method
Silica Gel Tube with pre-filter
Acid Gases and Mists
0.2 L/Min for eight hours
OSHA Method ID-165SG
APPLICABLE OEL’S
 OSHA recognizes that most of its PELs are outdated and
inadequate measures of worker safety.
 Crude oil is a complex mixture of chemical constituents that are not
easily addressed by exposure limits for individual substances.
 In characterizing worker exposure OSHA instead relies on more upto-date recommended protective limits set by organizations such as
NIOSH, ACGIH, and AIHA, not on the older, less protective PELS.
 Results of air monitoring are compared to the lowest known OEL for
the listed contaminant for purposes of risk assessment and
protective equipment recommendations.
BP IH Activity
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Engaged more than 200 industrial hygienists and technicians to monitor area
and personal exposures in the identified work areas
– As of 15th October 2010, approximately 70 industrial hygienists providing support to
the ongoing restoration.
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As of 15th October 2010, approximately 23,000 personal samples collected
Personal monitoring results mostly indicate there are no significant exposures to
airborne concentrations of chemicals of interest
Weathered crude also a factor in sampling strategy
Source strategy different from on shore/near shore strategy
– Source Strategy ( BP Source Monitoring Strategy )
– On shore strategy ( BP Onshore Monitoring Strategy )
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Sampling results are published in two ways:
– Summary form
– Full details
On Shore and Near Shore Monitoring
 Area and personnel monitoring during:
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Beach clean up
Vessel decontamination
Wildlife decontamination
Skimming operations
Boom deployment and retrieval operations
Area monitoring in response to odor complaints
 4 “strike teams”
– PBZ for BTEX, Total hydrocarbons (THC)
– Area for VOC’s, CO, LEL and Benzene
 Priority is decontamination activity
– General goal to sample 10% of identified groups
– Professional judgment for additional monitoring
 Action levels developed for taking specific control actions
Off Shore (Source) Monitoring Strategy
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Monitoring plan purpose:
– Protect potential downwind receptors
– Protect worker health
– Support safe operations with task monitoring
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Area and personnel monitoring for:
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VOC’s (THC)
Benzene
H2S
Oxygen
LEL
CO
PM10
SO2
Action levels developed for taking specific control actions
Every vessel assigned to the source area was equipped for monitoring
BP Sampling Results Summary
Full Details
NIOSH Health Hazard Evaluations
 On May 28, 2010, NIOSH BP requested the
first health hazard evaluation (HHE)
 Since then multiple investigations and 8 Interim
reports have been issued
 Investigations included quantitative sampling
and medical symptom surveys
 The last Interim report was issued October 26
NIOSH Health Hazard Evaluations
 Evaluation of the hospitalization of 7 Fishermen on May 26
 Conclusion: Given the various descriptions and unspecified
sources of the reported odors, the uncertain timing of the
symptoms in relation to use of a new cleaner , and symptoms
that be related to a variety of causes:
– it is unlikely that a single specific trigger for the reported
symptoms can be determined
– Dispersant use appears unlikely to be the source of the
symptoms
– symptoms were more likely to have been aggravated by sever
al contributing factors, including unpleasant odors, heat, and
fatigue.
NIOSH Health Hazard Evaluations
 June 4‐5 evaluation of M/V International Peace and
MV Warrior Dispersant Mission
– Industrial hygiene surveys, health symptom survey
and medical interviews during a small scale
dispersant mission
– PBZ and area air concentrations of the
contaminants measured were all well below OELs
– NIOSH investigators did observe the potential for dermal
contact with the dispersant
 On June 14-16 PBZ and area air concentrations of the
contaminants measured during an oil skimming mission
aboard the M/V Queen Bee were below occupational
exposure limits
NIOSH HHEs
 June 8–10 evaluation of In-situ Oil Burns
 Based on sampling conducted over two days on ignition boats and
vessels towing boom during burns, NIOSH investigators found
exposures for all compounds sampled to be well below applicable
OELs
 One exception: peak exposures to CO recorded on the vessels due
to exhaust from gasoline powered engines
NIOSH HHEs
 June 25 evaluation of Barge Oil Vacuuming Operations in Coup Abel
Pass Louisiana was conducted
 Limited activity to sample
 Safety and noise observations:
– For example: A few workers wore safety harnesses. The harnesses
were not tied off to any structure on the barges to arrest the workers’ fall
NIOSH HHEs
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June 21-25 industrial hygiene surveys and self-administered health
symptom surveys aboard two vessels at the site of the oil release
– Airborne concentrations for all contaminants evaluated were well below
applicable OELs
– Some increase in psychosocial symptoms, reported on one vessel
NIOSH HHEs
 September evaluation of 1,899 workers at 67 work sites in
Louisiana, Alabama, Florida, and Mississippi
– Surveys and interviews
– Heat stress was the primary occupational health hazard for most shore
cleaning workers
– Shore cleaning workers faced ergonomic hazards from the unique work
required to clean oil residue from sandy beaches
– Use of tools that were never designed for this task
– Workers had designed “homemade” tools that were more effective than
standard tools
NIOSH HHEs
 October evaluation and quantitative exposure assessment at two
decontamination sites in Port Fourchon, Louisiana
– Heat stress was the primary occupational health hazard for most
repair/decontamination and waste management workers and was
exacerbated by the use of personal protective equipment
– Where measured, airborne concentrations of measured contaminants,
including 2-butoxyethanol and other glycol ethers, limonene, benzene, ethyl
benzene, toluene, xylenes, total hydrocarbons, diesel exhaust, PAHs, and
CO were all well below Occupational Exposure Limits (OELs)
– Exposure monitoring showed the potential for noise exposures above the
NIOSH REL during pressure washing
– Repair/decontamination and waste management workers faced ergonomic
hazards from unique work activities such as handling and moving booms
and other equipment to be cleaned and the actions associated with
operating the pressure washers
Lessons Learned
 To be added