SAN BERNARDINO COMMUNITY COLLEGE DISTRICT FOR CRAFTON HILLS COLLEGE

Transcription

1 October 14, 2015 Michael Strong Vice President of Administrative Services SAN BERNARDINO COMMUNITY COLLEGE DISTRICT FOR CRAFTON HILLS COLLEGE 114 South Del Rosa Drive San Bernardino, California Re: CITADEL Project No Formaldehyde & Phenol Exposure Monitoring Report September 2015 Sample Event #1 Crafton Hills College, LADM Building Anatomy Department Room 229/ Sand Canyon Road Yucaipa, California Dear Mr. Strong: Enclosed please find a copy of the Exposure Monitoring Report prepared by Citadel Environmental Services, Inc. All work was conducted in accordance with Clientestablished protocols. If after your review you have any questions or require additional information, please do not hesitate to telephone me at the Citadel Office in Glendale at (818) Sincerely, CITADEL ENVIRONMENTAL SERVICES, INC. Nalinna Rasu, CAC, CDPH, CHMM, LEED AP Director, Environmental Compliance Enclosure 1725 Victory Boulevard, Glendale, California / P / F

2 San Bernardino Community College District for Crafton Hills College 114 South Del Rosa Drive San Bernardino, California Formaldehyde & Phenol Exposure Monitoring Report September 2015 Sampling Event #1 October 14, 2015 Citadel Project Number Crafton Hills College Anatomy Department Room 229/ Sand Canyon Road Yucaipa, California

3 CITADEL PROJECT NO P FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, 2015 Table of Contents 1.0 BACKGROUND SCOPE OF SERVICES METHODOLOGY OBSERVATIONS, RESULTS, AND DISCUSSION RECOMMENDATIONS DISCLAIMER AND LIMITATIONS SIGNATURES... 6 APPENDICES Field Documentation... A Laboratory Report... B

4 CITADEL PROJECT NO FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, BACKGROUND The Subject Site is a community college located at Sand Canyon Road in Yucaipa, California. Citadel Environmental Services, Inc. (Citadel) was contacted by San Bernardino Community College District (Client), C/O Crafton Hills College, to provide industrial hygiene air monitoring services. Citadel understands that personal exposure monitoring for formaldehyde and phenol is required for individuals (1-2 people at any one time) working with cadavers in the Crafton Hills College (CHC) Anatomy Department to evaluate existing engineering, respiratory and personal protective equipment needs. As such, Citadel was contacted by the Client to conduct exposure monitoring in the Cadaver Room during work with embalming fluid (containing formaldehyde and phenol). 2.0 SCOPE OF SERVICES All work was conducted by a knowledgeable and qualified Industrial Hygienist. Citadel s scope of work included the following: 1) Conducting employee exposure monitoring for formaldehyde and phenol in accordance with NIOSH Method 2016 and NIOSH Method 2546, respectively, and applicable standard industry sampling practices. Samples were collected during cadaver dissection activities. A total of four (4) air samples were taken: two (2) for formaldehyde and two (2) for phenol. Additionally, a total of two (2) field blanks were collected: one (1) for formaldehyde and one (1) for phenol. 2) Submitting the samples to an independent accredited laboratory for analysis. 3) Preparing an Exposure Monitoring Report to include all of Citadel s observations, sampling data and methodologies, results and conclusions, and any subsequent recommendations. The sampling and monitoring activities, as described above, were completed to determine the degree of exposure for an instructor working with embalming fluid, containing formaldehyde and phenol. Equipment and media appropriate to the specific sampling protocols were utilized to obtain samples during activities involving use of the embalming fluid, to determine the 8-hour time weighted average (TWA) exposures and short-term exposure limits (STEL) for the worker. The monitoring results were compared with recognized occupational exposure limits (Permissible Exposure Limits, Recommended Exposure Limits, Threshold Limit Values, etc.) _CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 1

5 CITADEL PROJECT NO FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, METHODOLOGY Air sampling was performed by Citadel s Project Industrial Hygienist, Ms. Jessica Small, during cadaver dissection activities on September 24, Air Sampling and Laboratory Analyses All of the air samples were delivered via courier to L.A. Testing in Garden Grove, California for analysis through appropriate test methods. L.A. Testing is accredited for the analysis of environmental and industrial hygiene samples by the American Industrial Hygiene Association (AIHA) and the National Environmental Laboratory Accreditation Program (NELAP). All samples were collected during the use of the formaldehyde and phenol mixture. Employee exposure monitoring and air sampling for formaldehyde and phenol was in accordance with NIOSH Method 2016 and NIOSH Method 2546, respectively, and applicable standard industry sampling practices. Samples were collected on solid sorbent tubes, attached to personal pumps via Tygon tubing. Sampling was performed during cadaver dissection tasks (opening of chest cavity). The flow rates of the sampling pumps were calibrated using a Drycal TM primary standard. Formaldehyde: A total of two (2) air samples were taken, in addition to one (1) field blank. Personal sampling pumps were calibrated to a flow rate of approximately 0.2 liters per minute (L/min) for the TWA sample and approximately 0.5 L/min for the STEL sample. Phenol: A total of two (2) air samples were taken, in addition to one (1) field blank. Personal sampling pumps were calibrated to a flow rate of approximately 0.1 L/min for the TWA sample and approximately 0.1 L/min for the STEL sample. 4.0 OBSERVATIONS, RESULTS, AND DISCUSSION The monitoring was performed on September 24, A walkthrough and brief interview with the instructor were completed to review chemical product use and existing safety controls. Field notes are presented in Appendix A. Walkthrough and Visual Inspection The following observations were noted during the investigation on September 24, 2015: The Anatomy & Physiology (A&P) Laboratory Technician (Employee ID #6850), donned appropriate personal protective equipment (PPE) prior to entering the Cadaver Room. PPE included full-face respirator with 3M 6005 formaldehyde/organic vapor cartridges and integrated glasses holder; scrubs, chemical-resistant full length apron, and chemical resistant gloves and sleeves. STEL and TWA samples for both formaldehyde and phenol were taken during the chest cracking procedure, when exposure is expected to be highest. Citadel placed pumps on the instructor around 09:20am before she entered the Cadaver Room. Citadel removed the STEL samples at 9:35am and TWA samples at 9:35am. Citadel noted a strong odor each time the A&P Lab Technician stepped out of the Cadaver Room to remove the STEL samples and TWA samples _CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 2

6 CITADEL PROJECT NO FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, 2015 Formaldehyde and Phenol Sampling Per the sampling strategy outlined in the scope of work and CHC s Formaldehyde and Phenol Program, Citadel collected personal (TWA and short-term) samples for both formaldehyde and phenol. TWA sample results were calculated to reflect an 8-hour time-weighted average. The TWA and STEL were compared to the following regulatory limits that are also in Table 1.0: Cal- OSHA Permissible Exposure Limit (PEL) time-weighted average (TWA), the Cal-OSHA action level (AL), the Cal-OSHA Short Term Exposure Limit (STEL), and recommended American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value-Ceiling (TLV-C). It is important to note that the ACGIH TLVs are only recommended guidelines used by industrial hygiene professionals and are not developed for use as legal standards, such as OSHA PELs. Personal Sampling The long-term personal sampling was collected for approximately fifty-six (56) minutes, during tasks directly involving work in the Cadaver Room and exposure to the embalming fluid (including formaldehyde and phenol). The short-term personal sample was collected during this same period of time, for approximately fifteen (15) minutes. Time weighted averages (TWAs) were calculated over an eight (8) hour work day. It is calculated by the following equation in Figure 1.0. Sample results were extrapolated to reflect an 8-hour time-weighted average shift, with zero concentrations assumed when working with the cadaver was not taking place, in order to more accurately compare with recognized occupational exposure limits. TWA T C T C hr 1 Where T is the duration in hours of the exposure to a substance at the concentration C, and 8 hours is a work day. T C Figure 1.0 Calculating TWAs n n Results Formaldehyde: The long-term personal sample concentration exceeded the Cal-OSHA AL but was lower than Cal-OSHA PEL TWA. The short-term personal sample concentration exceeded the Cal-OSHA STEL and the recommended ACGIH TLV-C (STEL-C). Phenol: The long-term and short-term personal sample concentrations were lower than the Cal- OSHA PEL, NIOSH STELs, and recommended ACGIH TLV (TWA). A summary of the results and applicable exposure limits is presented below in Tables 1.0 and 2.0. The laboratory analytical report is presented in Appendix B _CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 3

7 CITADEL PROJECT NO FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, 2015 Sample Number F01 Sample Description Personal Sample (TWA) Table 1.0 Summary of Results for Formaldehyde Sample Results Calculated TWA 1 Results Regulatory Limits for Formaldehyde Cal- OSHA PEL TWA Cal- OSHA AL Cal-OSHA STEL ACGIH TLV-C N/A N/A F02 Personal Sample (STEL) 7.1 N/A N/A N/A F03 Field Blank N/A N/A N/A N/A N/A N/A *It is important to note that ACGIH TLVs are only recommended guidelines used by industrial hygiene professionals and are not developed for use as legal standards, such as OSHA PELs. N/A = Not Applicable ppm = parts per million Sample Number PO1 PO2 Sample Description Personal Sample (TWA) Personal Sample (STEL) Table 2.0 Summary of Results for Phenol Sample Results Calculated PEL TWA 1 Results <0.92 <0.11 Cal-OSHA PEL TWA Regulatory Limits for Phenol NIOSH STEL ACGIH TLV 5 N/A 5 <3.5 N/A N/A 15.6 N/A PO3 Field Blank N/A N/A N/A N/A N/A *It is important to note that ACGIH TLVs are only recommended guidelines used by industrial hygiene professionals and are not developed for use as legal standards, such as OSHA PELs. N/A = Not Applicable ppm = parts per million 1 Sample results were extrapolated to reflect an 8-hour time-weighted average shift, with zero concentrations assumed when chemicals were not in use, in order to more accurately compare with recognized occupational exposure limits _CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 4

8 CITADEL PROJECT NO FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, RECOMMENDATIONS During the monitoring performed on September 24, 2015: Formaldehyde: The long-term personal sample concentration exceeded the Cal-OSHA AL but was lower than Cal-OSHA PEL TWA. The short-term personal sample concentration exceeded the Cal-OSHA STEL and the recommended ACGIH TLV-C (STEL-C). Citadel notes that ACGIH TLVs are only recommended exposure limits used by industrial hygiene professionals, and are not developed for use as legal standards (such as OSHA PELs). The TWA result that was higher than the Cal-OSHA AL indicates that the cadaver dissection activities within the Cadaver Room are subject to the sampling and monitoring requirements promulgated by the OSHA Formaldehyde standard (29 CFR ). Exposure monitoring shall occur every six (6) months for formaldehyde. Phenol: The long-term personal sample concentration was lower than the Cal-OSHA PEL TWA and the recommended ACGIH TLV (TWA). The short-term personal sample concentration was lower than the NIOSH STEL. Citadel notes that ACGIH TLVs are only recommended exposure limits used by industrial hygiene professionals, and are not developed for use as legal standards (such as OSHA PELs). While these results indicate that the cadaver dissection activities within the Cadaver Room are not subject to the sampling and monitoring requirements promulgated by the OSHA Guidance for Phenol, Citadel recommends annual exposure monitoring for phenol given the lack of historical phenol exposure monitoring data. Based upon sample results, Citadel additionally recommends that the following: Continued implementation of existing engineering controls including isolation activation of the exhaust system during periods of formaldehyde and phenol use/exposure. Continued implementation of the existing safety programs, including (but not limited to): o Adhering to the policies and procedures described in CHC s Formaldehyde and Phenol Program and Chemical Hygiene Plan; o Providing, maintaining, and ensuring the employees don appropriate respiratory protection. The use of respirators shall be in accordance with the OSHA Respiratory Protection Standard 29 CFR Employees must also receive training and be medically approved and fit-tested prior to donning a respirator; o Providing, maintaining, and ensuring the employees don appropriate PPE; o Ensuring that employees receive initial and annual hazard communication and formaldehyde and phenol safety training; o Ensuring proper storage, handling, labeling, decontamination and disposal procedures for formaldehyde and phenol use are being followed. Continue providing medical surveillance and air monitoring, per the OSHA Formaldehyde standard (29 CFR ) and OSHA Guidance for Phenol, on instructors who perform dissections in the Cadaver Room. o Based on the sample results, this shall include monitoring every six (6) months for formaldehyde and annual monitoring for phenol, or more often if employees experience signs or symptoms of respiratory or dermal conditions associated with the formaldehyde and phenol exposure. o Periodic monitoring for employees may be discontinued if results from two consecutive sampling periods (taken at least 7 days apart) show that employee _CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 5

9 CITADEL PROJECT NO FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT OCTOBER 2015 SAMPLING EVENT #1 SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 14, 2015 exposure is below the Cal-OSHA action level and STEL for formaldehyde, and below the PEL for Phenol. 6.0 DISCLAIMER AND LIMITATIONS This report has been prepared by Citadel Environmental Services, Inc. exclusively for our Client and their Authorized Representatives. The information contained herein pertains only to issues reported by the Client to be present at the referenced property which were evaluated in accordance with a mutually agreed upon scope of work. The findings and recommendations presented are based upon observations of present conditions, and may not necessarily indicate future conditions. Citadel Environmental Services, Inc. implies no warranty to the accuracy of information provided to them by the Client or outside agents and transmitted herein. The information contained herein may not be used, disclosed, or copied without written permission of the Client. 7.0 SIGNATURES All work was conducted in accordance with Client-established protocols, and the standards of care and diligence normally practiced by recognized consulting firms in performing services of a similar nature. Work Completed By: [see field documentation for signature] Jessica Small Project Industrial Hygienist Report Reviewed By: Nalinna Rasu, CAC, CDPH, CHMM, LEED AP Director, Environmental Compliance Attachments _CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 6

10 Appendix A Field Documentation

11

12

13 Appendix B Laboratory Reports

14 LA Testing Knott Street, Unit F5, Garden Grove, CA Order ID: Attn: Nalinna Rasu Citadel Environmental Services, Inc Victory Boulevard Glendale, CA Customer ID: Customer PO: Date Received: LA Testing Order: 32CITA /24/ Fax: Phone: Report Date: /01/15 Project: Date Analyzed: CHC 2015 Form / Phen Personal Sampling / /28/15 FORMALDEHYDE by NIOSH 2016M, Issue 2, March 2003 SKC LA Testing Sample ID Client ID Air Volum e (L) Component Result (µg/sample) Result Reporting Limit (µg/sample) F Formaldehyde F Formaldehyde F03 - Formaldehyde <0.10 N/A 0.10 Sample received in acceptable condition unless otherwise noted. This report relates only to the samples reported above. This report may not be reproduced except in full, without written approval by LA Testing. Quality Control Data associated with this sample set is within acceptable limits. The results for this sample set have not been blank corrected. Tube front and tube back analyzed separately, tube backs are ND unless otherwise indicated. JD Analyst Michael Chapman, Laboratory Manager AIHA Accredited - Laboratory ID # Page 1 of 1

15 OrderID: Page 1 Of 2

16 OrderID: Page 2 Of 2

17 LA Testing Knott Street, #F-5, Garden Grove, CA Order ID: Attn: Fax: Phone: Project: Nalina Rasu Citadel Environmental Services, Inc Victory Boulevard Glendale, CA Customer ID: Customer PO: Date Received: 32CITA /24/15 LA Testing Order: CHC 2015 FORM/PHENOL Personal Sampling Report Date: 10/01/15 Date Analyzed: 09/29/15 Sample ID Phenol in SKC with NIOSH 2546M Volume (L) Lab ID Analyte mg/tube ppm Reporting Limit (mg/tube) PO Phenol <0.020 < PO Phenol <0.020 < PO NA Phenol <0.020 NA Sample received in acceptable condition unless otherwise noted. This report may not be reproduced except in full, without written approval by LA Testing. Unless otherwise noted, the results in this report have not been blank corrected. Quality Control Data associated with this sample set is within acceptable limits, unless otherwise noted. MNH Analyst Michael Chapman, Laboratory Manager Or other approved signatory AIHA Accredited - Laboratory ID # Page 1 of 1

18 OrderID: Page 1 Of 2

19 OrderID: Page 2 Of 2