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June 2007

Introduction
The Industrial Hygiene/Occupational Safety Special Interest Group (IH/OS SIG) Steering Committee held their annual workshop on June 8, 2007, at the Philadelphia Marriott Downtown Hotel in Philadelphia, Pennsylvania.  Steering Committee members and guests participated either in person or via teleconference format.  IH/OS SIG Steering Committee Advisory Chair Bob Kapolka, Oak Ridge Institute for Science and Education (ORISE), facilitated the workshop in which the following Steering Committee members/guests participated:
Attended in Person:

• Mike Brisson, Westinghouse Savannah River Company Analytical Laboratories

• Harvey Grasso, DOE National Nuclear Security Administration, Livermore Site Office

• Mark Hoover, National Institute for Occupational Safety and Health (NIOSH)

• Bob Kapolka, ORISE
• Daniel Marsick, DOE, HS-11, Office of Worker Safety and Health Policy

• Deborah McFalls, ORISE
• John Peters, Brookhaven National Laboratory (BNL)
• John Seabury, Lawrence Berkeley National Laboratory
• Jim Slawski, Federal Aviation Administration
• Bruce Stockmeier, Argonne National Laboratory  
• David Weitzman, HS-11, Office of Worker Safety and Health Policy

Attended via Teleconference:

• John Davis, Argonne National Laboratory

• Ralph Hinterman, Argonne National Laboratory 

• Bruce Murdoch, Argonne National Laboratory 

• Robin Nicholas, Los Alamos National Laboratory (LANL)

• David O’Connor, Occupational Safety and Health Administration (OSHA)

• Linda Taylor, Honeywell FM&T

The following Steering Committee member notified the IH/OS SIG Coordinator that he could not participate in the meeting:

• Michael Hurshman, S.M. Stoller

Practical Approaches to Facility and Activity Walkdowns - An Executive Guide to Field Observation
DOE is unique among Federal agencies in its commitment to a strong onsite presence in the management of agency missions throughout regional, field, and site offices.  It is the Department’s objective to enhance the safety and reliability of all DOE activities by promoting a strong operational awareness, facilitated by periodic onsite visits to the field by senior DOE executives.  When executives from Headquarters tour a site, they do not usually have the same level of knowledge or operational awareness as the onsite DOE staff.  The Practical Approaches to Facility and Activity Walkdowns - An Executive Guide to Field Observationdocument has been developed for those senior executives with line management responsibilities to enable them to ask relevant safety and procedural questions. This document might also serve as a resource to a site’s management or a building safety representative who does have some safety walkthrough responsibilities.  This guide does not contain detailed lines of inquiry related to specific safety systems, structures or components because they require more technical knowledge, insights, and familiarity with engineering and safety analyses than would normally be expected from a senior executive. It is not necessary for visitors to ask all of the items on the reference card. Rather, visitors are encouraged to take the cards into the field and use them to refresh their memory of such details and thereby promote a more informative tour.  

The Steering Committee agreed to list this resource on the SIG’s Web site and make an announcement about the posting through the DOE TSL Listserv. The document is available at url: http://www.hss.energy.gov/2007_Field_Observation_Guide.pdf.

Questions related to this presentation should be directed to Daniel Marsick at:  Dan.Marsick@eh.doe.gov.

10 CFR 851 News David Weitzman provided news related to 10 CFR 851.  The rule required that work at DOE sites would not be allowed to continue after May 25th unless the contractor had an approved worker and safety health program that met the requirements of DOE 10 CFR 851.
DOE believes that they are in substantial compliance with that requirement based on the sites telling them that the contractors have submitted and received approval for their plans.  There could be a couple of loose areas, especially with some of the more problematic areas like medical services being provided to lower tier subcontractors however DOE is pleased with the level of compliance with getting the plans submitted and approved.  They have been working diligently with the programs and general counsel to work through various implementation issues that have come up over the last year.   DOE has a Web site dedicated to 851 rule related information that includes (http://www.hss.energy.gov/HealthSafety/WSHP/rule851/851final.html): 10 CFR Part 851 Rule Frequently Asked Questions 851 Position Papers and Letters Implementation Guide Worker Safety and Health Program Approval Contractor Worker Safety and Health Poster (English and Spanish versions) 851 Rule Advisory Variances Occupational Safety and Health Administration / DOE Memoranda of Understanding General Counsel Interpretive Rulings

David report that DOE Officials is considering updating the Implementation Guide.   

It was noted that DOE has a DOE Worker Safety and Health Standards Response Line.  Daniel Marsick manages the response line.  A new feature for the response line has been added that will allow the user to ask for the responses on 851 questions only.  David reminded participants that his office can deliver technical interpretations in responses to inquiries however when it comes to legal inquiries, general counsel has to provide the interpretations.  David’s office still works closely with general counsel because almost everything has a legal impact especially in the enforcement related areas.  

There is an electronic variance process available that is not being used much at this time by the contractors.  It is not clear why usage is low.

There are some basic concerns about the medical services requirement of the rule.  It was written for a comprehensive, progressive medical services program that a prime contractor could easily accommodate which most prime contractors have something like.  However, the rule says that it applies to all tiers of contractors.  If a contract is subcontracted, it applies.  DOE has encouraged sites to use small businesses over the last decade which have resulted in thousands of contracts with small businesses.  The small businesses do not know how to address the medical service requirement. They do not have an outpatient medical services provider.  It is very difficult to sort out the logistics of how to accomplish this requirement with small subcontractors.  Some of the basic parameters are that DOE has experience where some of the subcontractors get a lot of the very serious work in which the workers become ill and get injured. People agree that these workers need to be covered but this kind of provision is not in their contract currently and there is no money to cover it.  DOE wants to address this issue in the rule over the next few years but in the meantime are developing guidance about it.  

Another issue relates to the statement in the requirement that “a DOE site is a site that is owned or leased by DOE or controlled by DOE.”  There is an attorney organization that believes DOE is being too expansive in its interpretation of “controlled by.”  Within this interpretation is the vendor and supply ratio.  The rule says that organizations that provide commercial items are not covered by the rule because they basically are just vendors.  All the work that is done for DOE could look like a commercial item if you want to interpret the rule that way.  So the regulation is in conflict.  The association of attorneys believes DOE is over interpreting the coverage in many of the organizations that have contracts that DOE says are now included in the rule.

DOE Official Joe Hopkins is working with the general counsels of DOE and OSHA to write another memorandum of understanding between the two agencies about jurisdiction.  The regulation notes that if OSHA has jurisdiction then the space is exempt from the 851.  Representatives of OSHA are saying that if DOE exert their jurisdiction then OSHA will not and DOE saying if OSHA exerts their jurisdiction than DOE will not.  In Joe’s current draft, DOE will list the contractors that are DOE controlled which means everyone else will fall under OSHA jurisdiction.  It will be difficult to keep the list current with thousand of contractors involved.  

Questions related to this presentation should be directed to David Weitzman at:  David.Weitzman@eh.doe.gov.

Activities of the Beryllium Health and Safety Committee Michael Brisson provided news about the activities of the Beryllium Health and Safety Committee (BHSC).  Michael began his presentation by sharing background information on beryllium occupational exposure limits:

• 1999:   Members of the American Conference of Government Industrial Hygienists (ACGIH) began proposing various changes to the beryllium threshold limit value but none have been adopted to date.
• 2000:   DOE Beryllium Rule (10 CFR 850) took effect which included 0.2 mg/m3 TLV-TWA along with surface limits.
•  2002:  OSHA began the process of revising the OSHA permissible exposure limits (PEL) but has made little progress toward finalizing a decision.
• 2005:   More ACGIH proposed changes or notices of intended change were made. Currently a proposal is pending that would drop the exposure limit to .05 micrograms per cubic meter 8 hour time limit average and short term exposure limit of 2/10 of a microgram per cubic meter.  
• 2006:   Cal OSHA has adopted the DOE action level as its PEL (0.2 mg/m3 ) and Quebec adopted an even lower one (0.15 mg/m3).  

The BHSC is an ad hoc group that has representatives primarily from DOE, Department of Defense, United Kingdom Atomic Weapons Establishment, NIOSH, Brush-Wellman, and others.  Their mission is to prevent beryllium sensitization and Chronic Beryllium Disease (CBD) and other adverse health effects that can be caused by workplace exposure to beryllium.  The function of the BHSC is to share information through meetings, conference calls, and their Web site (http://www.behsc.com/).  The Committee generates guidance documents such as whitepapers, fosters voluntary consensus standards through the American Society for Testing and Materials (ASTM) and through the International Standards Organization (ISO).  The Committee is not an advisory committee.  The Committee includes subcommittees and working groups:

• CBD Prevention Subcommittee: Chaired by Steve Jahn from the Savannah River Site.  The CBD Subcommittee is completing a whitepaper on CBD prevention that will be available later this year.  
• Research Needs Subcommittee:  Chaired by Mike Macawly, whose is retired from NIOSH and is a consultant to LANL.  The Research Committee is tracking ongoing research as well as seeking funding for research.  They have a special interest in alternative medical tests (alternatives to the Beryllium Lymphocyte Proliferation Test).  
• Technical Practices, Standards, and Measures Subcommittee:   Chaired by David Weitzman from DOE. The Subcommittee is chartered to look at best management practices and operational guidance.  
• Medical/Epidemiological Subcommittee:  Chaired by Donna Cragle from ORISE.  They foster improved detection of BeS and CBD and improved medical protection programs.  They are currently working with the Research Needs Subcommittee on the alternative medical tests white paper.

• Sampling and Analysis Subcommittee:  Chaired by Melecita Archuleta from Sandia National Laboratories. It is the largest of the subcommittees with about 40 members.  Due to their size they are divided into working groups to focus on Beryllium oxide/digestion, standard methods, sampling, accreditation, and validation.

Beryllium Oxide Digestion Working Group:   This working group is addressing the need for reference materials.  For years there have been issues with samples collected in the field that have to be dissolved before they are analyzed.  The analysis usually requires a hot acid mix or an extraction technique that involves polonium bichloride where you have to ensure that all of the beryllium various form get into the solution.  Beryllium oxide is the most difficult and a lot of laboratories are not validating that all the beryllium oxide get into the solution.  Reference materials are needed to solve the problem of how to validate the digestion methods in the labs. The Working Group is working with other organizations on a project to establish beryllium oxide reference materials.  Once the reference materials are developed, they will test different digestion methods to see which ones are effective on beryllium oxide.

Standard Sampling Working Group:   Numerous surface wipes are done within the DOE complex.  There are also numerous issues with the sampling media that are used including issues related to different kinds of surfaces such as smooth surfaces, porous surfaces, rough surfaces, oily surfaces, etc. What works well in one situation may not work well in another situation.   Some improvement goals and issues for the Working Group include waste minimization for regular beryllium analysis.  The goal is to generate less liquid waste that is difficult and costly to dispose of appropriately.  The Group recently came up with a dry wiping method for wiping surfaces that could be damaged by the wet wiping method.  They have issued this method through the American Society for Testing Materials (ASTM) last year.  The Group’s major project now is the ISP map spec method.  In a March meeting, a presentation was made about a surface sampling tutorial.

Accreditation Working Group:  The Working Group has an on-going dialogue with the American Industrial Hygiene Association (AIHA) on accreditation issues about such matters as the reference materials being developed.  The Committee would like to also develop real time beryllium monitoring equipment.  Currently, the AIHA Accreditation Program does not fit field programs.  They are working with AIHA on a modified program that would have flexibility for field situations.  

Validation Working Group:  The Working Group is focusing on generic validation guidance.  They have a newly formed data reporting task force that is addressing several issues.  There is a never ending push for laboratories to report lower and lower values but at the same time AIHA Accreditation Program says you will not report below the reported limit.  They are looking at providing standardized guidance on how to generate reporting limits that are more consistent and in some cases lower than the reporting limits from where they presently are in the laboratories.  They are also looking at instances where they could provide number below those reporting limits data that would otherwise be censored.  And if they are successful in this endeavor, they may be permitted to do fewer samples and still get the same desired result and save money.  

• Symposium Subcommittee: This Subcommittee is chaired by Tony Quinn from the United Kingdom Atomic Weapons Establishment.  It is a one person subcommittee at this time.  The Committee would like to get more people involved in this group.  The purpose for this group is to interface between the Committee and other beryllium related symposia.  Often symposia are organized and people do not become aware of them until it is too late.  The activities of this Subcommittee would address some of these issues.

The Committee considers training an issue that should be addressed.  There is some generic training posted on the Committee’s Web site, however there is training needed that is not currently available.  Another issue for the Committee is the need to have higher volume personal air samplers that would help with analytical detection limits.  

Questions related to this presentation should be directed to Michael Brisson at: mike.brisson@srs.gov.

DOE Nanoscale Science Research Centers Safety Committee Activities
Bruce Stockmeier briefed the Committee about the DOE Nanoscale Science Research Centers (NSRcs) Safety Committee activities.  The Committee is made up of representatives from the 5 centers.  The centers are funded by the DOE Office of Science through Basic Energy Sciences and include:

• Center for Functional Nanomaterials (Located at BNL)
• Center for Nanophase Materials Science (Located at Oak Ridge National Laboratory)
• The Molecular Foundary (Located at Lawrence Berkeley National Laboratory)
• Center for Integrated Nanotechnologies (Located at LANL)
• Center for Nanoscale Materials (Located at Argonne National Laboratory)

NSRCs are user facilities that are part of the National Nanotechnology Initiative (NNI).  People outside the DOE complex submit proposals to use the centers. The approved users bring their own funding for their project(s) and are able to use the facility at no cost unless it is proprietary work.  All of the centers have conventional facilities that are essentially complete.  Installation commissioning is underway or completed at most of the centers.  Most of the centers, but the one located at Brookhaven, have user operations at this time.  

The NSRCs Safety Committee is a working group made up of representatives of the sites where the centers are located.  The Safety Committee exchanges information on operations and lessons learned.  Their efforts include working together to help stay abreast of current safety information. More than 10 people from the centers are a part of this working group. They have been collaborating informally with NIOSH since 2003. They draw guidance from the DOE policy statement on safety management systems (DOE P 450.4).  Formerly DOE order 440.1A, now 10 CFR 851, makes it important to understand that there are also other standards that apply to the centers.  Chief among the other standards that apply is 29 CFR 1910 and under that (1910.1450) is the occupational exposure to hazardous chemicals in laboratories rule.  There has also been a secretarial policy statement issued that states “DOE and its contractors will identify and manage potential health and safety hazards and potential environmental hazards at their sites through the use of existing integrated safety management systems including the environmental management systems.”  It is believed that DOE provided for emerging technologies such as nanotechnology initiatives when they implemented the Integrated Safety Management (ISM) process.

The Committee is working on a document for the centers called Nanoscale Science Research Centers Approach to Nanomaterial ES&H that addresses:

• Conceptual foundations
• Controls for R&D laboratory operations
• Verifying program effectiveness
• Transportation of nanomaterials
• Management of nanomaterials-bearing waste streams
• Management of nanomaterial spills
• Example industrial hygiene sampling protocol

In developing the document the Committee drew heavily from the following sources:

• National Research Council’s Prudent Practices in the Laboratory
• NIOSH’s Approaches to Safe Nanotechnology
• British Health and  Safety Executive’s Horizon Scanning (WWW-Based) Nanotechnology Information

It is not intended that the centers adopt this document but rather build site specific programs using the concepts in the document.  The Committee is trying to ensure that they do not make unwarranted assumptions about the risks posed by nanomaterials.  They want to create a reasonable guidance for managing uncertainty.  The goal is to reduce the risks to an acceptable level.  The risks cannot be totally eliminated.  They want to avoid worker injury, effects to worker health, and negative environmental impacts.  They want to promote consistency in policy and procedures.  There is growing evidence that indicates some of the controls used in conventional laboratories will work effectively for nanomaterials which is a key point this document builds on.  The document has relatively conservative policies in risk control strategies. The document rest heavily on statements in prudent practices: basically that engineered nanomaterials will be treated as though they are toxic and otherwise hazardous until evidence shows otherwise.  Once nanomaterials have been studied and associated risks are better understood, they will fine tune how to address the risks.  The document focuses on the unknown things.  The NSRCs Safety Committee found sufficient direction for developing approaches for tailoring approaches to deal with their needs that are mostly the laboratory environment.  When the document is finalized, it will be made available through the IH/OS SIG Web site (since this presentation, the document has been posted at:  http://orise.orau.gov/ihos/Nanotechnology/nanotech_DOE_Nanoscale_SC.html).

The Committee, with the Center for Nanophase Materials Science as the lead, is currently developing training on nanotechnology.  

Questions related to this presentation should be directed to Bruce Stockmeier at: bcs@anl.gov.

Nanotechnology Safety and Health News from NIOSH
Mark Hoover briefed the Committee on some nanotechnology related activities that NIOSH is currently involved in. As a representative of NIOSH, Mark is scheduled to meet with a working group organized by the Nation Science Foundation (NSF) to discuss how to share safety and health information related to nanomaterial activities.  He mentioned taking what the IH/OS SIG has developed for their Web site, the Nanotechnology Safety and Health Repository, and building on it in conjunction with what NIOSH has on their Web site about nanotechnology safety and health topics.  NFS wants to create a compendium of nano-manufacturing processes that would be documented.  People involved in nanomaterial activities could access the library to obtain and share related safety and health information.  The library may provide an opportunity to build on information related to health effects.  The questions often asked are:

• Is nanotechnology or are nanoparticles the next asbestos? 
• Is this something that a lot of people are going to become ill from in the future?  

If nanoparticles are the next asbestos or beryllium particles as we understand them today, we can use the knowledge from handling them to address handling nanoparticles. A lot has been learned about fundamental safe handling procedures that are required to control toxic materials.  They understand that there are some forms of asbestos that have negligible toxicity and there are other forms of asbestos that have substantial toxicity.  If they can determine which nanoparticles are toxic and which are not, they will control the ones that are needed and use regular safety precautions with the other ones. This will permit them to then focus on the ones that are particularly dangerous.  

Mark mentioned that are 5 top measurement issues that have been identified by the NNI Nanotechnology Environment and Health Implication Subcommittee.  Of particular interest is the metrology instrumentation measurements area of developing ways to detect nanoparticles.  An example would be if someone was working in a clean room environment and if the background aerosol is 3,000 particles per cc, any activity that creates more than 1,500 particles above that level should be controlled more effectively.  This is a simple approach that is a very good first step in areas that are pretty clean.  The second measurement goal is to understand effective modifications on the properties of nanomaterials.  In NIOSH toxicity studies, they have seen that if there are nanoparticle carbon atom tubes that have the iron catalyst still in them they can cause fibrosis and granulomas.  If the iron is washed out, the health effects are substantially lower.  These small modifications can be important.  It would be good to have reference materials that could point people toward classes that are okay and classes that are not okay.  There is a need for methods for standardizing the assessment of particle size and size distribution. There are different ways to measure particle size and distribution that need to be cataloged with examples included.  Standard reference materials need to be developed.

Mark will visit the National Institute of Standards and Technology (NIST) in June to discuss nanomaterial activities. There is progress being made for NIST, NIOSH, and DOE to co-sponsor a workshop that addresses developing reference materials for nanoparticle activities.  Funding for such an activity may be an issue.  Funding mostly likely would come from a program that had a need for such information. NIST has a workable model that might help in determining the protocols for how the reference materials would be made and stored and the criteria for them.

Mark noted there is a proposal that a job exposure matrix be created to use for each time period, for each worker involved in nanoparticle activities.  Information would be documented about the work process including the particle size, distribution, concentration, etc. that could be reviewed later if there were some health effects.  This data might help in determining why the health effects occurred.  

They have been creating a new system that brings together some key historical approaches to use in a control banding approach for the safe handling of nanoparticles.  The first approach would be to assign a health hazard band.  Would identify what the target concentrations are that should not be exceeded.  Band A might be 100 to 500 micrograms per meter cubed and Band B might be 10 to 100 and C might be 1 to 10 and D might be less than 1 microgram per meter cubed.  How to do control banding for different processes are known.  Put in a hazard band and then find some kind of control that would be appropriate to keep the amount of material being handled, the dustiness, etc. managed.  There might be laboratory band 1 or 2 that could involve anything from the open bench for solid materials to a hood such as a glove box.  Moving into production scale, there might be production scale 1-4 where 1 might be hoods and 4 might be remote systems or even robotics. Helping in determining classes of control could be obtained through shared lessons learned about the efficacy of these various techniques.  The third step is controlled verification which should be a requirement in the control banding process.  There would be minimal verification where there was sufficient evidence about processes that worked.  The fourth step would be a periodic review that includes addressing the following questions:

• Has anything changed? 
• Is there new toxicological information? 
• Has the amount being handled changed? 
• Is there new equipment being used? 
• Is there a new group of workers doing the process? 

It might be reasonable to do some monitoring of those workers so that they would have the benefit of some immediate feedback on their ability to run the process with the expected controls.  

NIOSH participates in field team activities that include collaborating with companies who would like to have the scientists from the NIOSH Nanotechnology Research Center visit their site to take measurements and provide suggestions as appropriate to use in their efforts.

Additional information about NIOSH nanotechnology activities can be obtained from the NIOSH Web site at:  http://www.cdc.gov/niosh/topics/nanotech/default.html.  Questions related to this presentation should be directed to Mark Hoover at: zij3@cdc.gov.

NOvA NuMI Off-Axis Ve Appearance Experiment - Industrial Hygiene Considerations

John David provided information about the NOvA Neutrino Detector Projector at Argonne National Laboratory. The goal at Argonne is to develop a larger and more efficient detector than the MINOS detector which is currently operating.  The NOvA will involve two detectors.  One will be placed at Fermi National Accelerator Laboratory and another will be placed in Minnesota.

The goal is to build the detector from commercially available materials.  The 1st graphic is an illustration of a Neutrino detector currently being developed. The detector will be filled with liquid scintillation fluid and each cell will be equipped with light-detection electronics.  The primary industrial hygiene concerns are the size of this detector and the tons of liquid scintillation that will be used.  Also of concern are the estimated tons of the epoxy type adhesive that will be used to glue the detector together.  A summary of industrial hygiene concerns are:

• Amounts of material used
• Toxicity and handling
• Air monitoring for adhesive application

  New 2-part adhesive contains methyl methacrylate (an irritant)

  Airborne methacrylate level during adhesive application = up to 20 ppm (Below TLV, but above odor threshold - trying to come up with techniques for application and ventilation design in the area above the odor threshold)

• Ventilation design
• Emission and adhesive weight loss tests

The ventilation design considerations are a configuration of how to do the local exhaust for the assembly process and what air cleaning might be needed because recirculation is a possibility.  There are prime concerns for heat loss in a cold climate because the location of one of the detectors will be at a plant in northern Minnesota.  Argonne has been involved in some volatile emission and weight loss tests to answer critical questions that will speak to the design load for the ventilation system.

The 2nd graphic shows the proposed location of the near detector which would be at the at Fermi National Accelerator laboratory.

The 3rd graphic is a depiction of the detector building.  A complex building will have to be built just to house the service of this sector.
The 4th graphic is a rough mock-up of how they propose to build this detector within the building.  It will involve large assembly cables and mechanics of placing the detector panels together.

	A photo was shown of the prototyping of the adhesive application that was done with an air operated gun.  Soon they will move to an automated adhesive applicator.
A photo was also showed of their IH Chamber emissions test that was conducted in a sealed chamber.

Another photo was shown of their adhesive weight loss test which is a very basic test of putting a panel on a scale.   A panel calibration duct was used to provide low level air movement across the material.  They took weight loss readings every minute for the first 1 to 2 hours, and then took readings every 5 minutes after that.  There was a steady process of release of volatiles from the adhesive which most occurred within the first 2 hours of the application.  

Other serious concerns included:

• Physical safety concerns

• Slips, trips and falls
• Fall protection
• Hoisting and rigging
• Pressurized equipment
• Materials movement

• Fire protection concerns
• Environmental concerns

• Site
• Spill control and containment
• Environmental fate conceerns
  
  This project involved communication efforts that were essential in a large collaborative project of this nature.  

Questions related to this presentation should be directed to Ralph Hinterman at: hint@anl.gov.

ANSI Z136.1 (2007) Laser Standard – Changes and Impact on 10 CFR 851
Bruce Murdoch shared information about changes to the 2007 ANSI Z136.1 Laser Standard and the related impact on compliance with 10 CFR 851.  Bruce obtained information about the changes from a briefing paper presentation made at the 8th Biennial International Laser Safety Conference.

There have been many changes in the standard that are quite significant for both the technical and administrative aspects of it. Overall, there have been many portions of the standard that have moved from what could be called the informal up to normal which means it is required. The most outstanding changes are a complete change in the laser classification scheme.  There is no more a 3A laser.  There are 3 new classes.  There’s a 1M, a 2M and a 3R which are new ways of subdividing the lower powered lasers depending on whether they have expanded beams or not. The old two tiered 3A has been dropped.  The DOE sites will have to address what to do with the old 3A lasers that are a part of their policies.  

The methods of computing the maximum permissible exposure and required eyewear have been modified.  In some cases, you will have to compute several different ways. Photochemical MPE computation has been changed some: have to do both thermal and photochemical calculations to determine which ones are the lowest.  The software being use for MPE or the old algorithms will not be quite right in some cases. Sites may have to buy new software to do the calculations.  

There have been some significant requirements added to the laser disposal requirement section which is the responsibility of the laser safety officer (LSO) in the organization.  What happens to the laser being donated?   According to the new change, the LSO is now responsible for:

• Ensure the person receiving the laser is educated about the proper operations;
• Ensure the laser is up to standards; and
• Ensure users are properly educated.  

Changes to how to dispose of a laser includes:

• Laser must be completely electrically deactivated;
• Ensure the laser goes into the proper waste disposal channels; and
• If the laser uses gas and the health, flammability or activity rating is 3 or 4, the gas cabinet must be monitored and alarmed.  

The requirement for medical surveillance has been downgraded to suggestions for class 3 and 4.  It will be up to management to determine whether they want to do medical surveillance on laser users of higher class lasers.

In many of the laboratories the nominal hazards have not been computed by the LSO but have simply been said to be for the entire laser lab.  The old standard required that you compute it with indications of how the computation is done.  The new standard allows for the LSO to declare an area to be a nominal hazard zone without having to back it up with computations.  

The standard now requires the formation of a laser safety committee under certain conditions where it was a suggestion in the old standard.  

There is a revised posting format for the laser laboratories that is in harmony with the European standards.  The graphics are different but does allow for grandfathering in of the old postings.  The sites will not have to replace the postings unless there is a change to the classification of a laser in a room.  The eyewear OD is now required to be listed on the entry postings.  The issue with this new requirement is that the sites have laboratories with more than one laser in a room.  The eyewear requirement may be different for each laser.  Sites may have to modify the signage requirement to note on the signage to see the standard operating procedure document for eyewear requirements.  It is not practical to list numerous eyewear requirements on a posting to a room.  

There is now a requirement for evaluating the physical and chemical hazards including keeping documentation of the review.  This requirement will impact the way laboratory safety is reviewed.  
The ANSI Z136.1 document is now available in PDF format which makes it easier to search.  The document is expensive to obtain and the license only permits one back up copy.  At Bruce’s site, when they write new policy chapters in policy manuals they are required to make a table if there is a source document such as a standard.  They must now back up everything noted with a reference to the standard or the federal code.   They really did not do this kind of analysis on the previous ANSI 2000 standard because of the difficulty to do it manually.  Bruce’s is not sure how his site will deal with the new standard.  The standard differences in many ways including some requirements being reduced which could put the site into noncompliance with the 10 CFT 851 if adopted. The sites will have to be extremely careful about which requirements are adopted.   There are many improvements in the new standard.  The new lasers that are purchased will speak to the new classifications scheme.  No one will be receiving a class 3A laser. They will be a 3R or something similar.  How the sites will deal with the old 3A lasers are not recognized in the new standard.  The sites will have to address both the previous 3As and the new 3Rs.  They will have to be careful about adopting any part of the new standard that is less than in the previous standard.  The site will have to consider if they want to exceed the requirements in 851. In determining implementation of the 2007 standard, the following will have to be considered:

• Must comply with 10 CFR 851;
• 10 CFR 851 specifies ANSI Z136.1 (2000 version); and
• Some requirements are reduced in the 2007 version.

The new standard should be studied carefully before adoption.  A detailed requirements crosswalk should occur to compare the 2 standards before adjusting a site’s safety policy.

A copy of the standard can be obtained at: http://www.laserinstitute.org/store/ANSI/106AE.
Questions related to this presentation should be directed to Bruce Murdoch at: btmurdoch@anl.gov

Occupational Exposure to Hexavalent Chromium [Cr(VI)] David O’Connor, as a representative of OSHA, provided information about his agency’s Occupational Exposure to Hexavalent Chromium [Cr(VI)] Standard.  Hexavalent chromium is a toxic form of chromium metal that is used in many industrial applications (primarily for its anti-corrosive properties). It is created during certain “hot” work processes where the original form of chromium was not hexavalent (e.g., welding on stainless steel).
The workplace deals not just with hexavalent chromium where it is present in a hexavalent chromium form, but also with chromium because of the work process that is being performed creates hexavalent chromium through an oxidation process such as welding on stainless steel or chromium alloys.
The reason for the new standard is primarily because of health effects occurring from exposure to hexavanent chromium.  Major health effects include: Lung cancer Nasal septum ulcerations and perforations Asthma Skin ulcers Allergic and irritant contact dermatitis

Hexavalent chromium is a very potent carcinogen.  It is estimated that between 3,000 and 4,000 currently employees who are exposed to hexavalent chromium will suffer from lung cancer because of the exposure that they are incurring now.  Hexavalent chromium exposure occurs through inhalation of mists, dusts, or fumes as well as through eye and skin contact.

As of February 28, 2006, OSHA published three new standards for hexavalent chromium in the Federal Register: 

• 1910.1026       General Industry
• 1926.1126       Construction
• 1915.1026       Shipyards

The standards for construction and shipyards are nearly identical but the general industry standard differs in a couple of respects.  The major provisions of the standards are:

• Scope
• Permissible exposure limit
• Exposure determination
• Regulated areas **
• Methods of compliance
• Respiratory protection
• Protective work clothing and equipment
• Hygiene areas and practices
• Housekeeping **
• Medical surveillance
• Communication of hazards
• Recordkeeping
• Dates

** General industry only

These are separate paragraphs of the standards that have different requirements that apply for occupational exposure to hexavalent chromium. Two of the paragraphs deal with regulated areas and housekeeping that are included in the general industry standard but are not included in the standards for construction and shipyards because the provisions would be impractical in the construction and shipyard environments.  

The new PEL is 5 micrograms per cubic meter of air which is a substantial reduction from the previous PEL.  A lot of people who were not previously affected by OSHA’s hexavalent chromium limits are now brought into the scope of the standard.  New controls will have to be implemented for these people.  

Employers are allowed the option of following 2 different approaches for performing an exposure determination.  The first option is a scheduled monitoring option which mirrors the approach that OSHA has taken in previous standards where the frequency of periodic monitoring was dictated by the results of that monitoring.  If results indicate exposures were above the PEL, monitoring will need to be done every 3 months. This standard allows employers to follow that option or to follow a separate performance oriented option.  The performance oriented option gives employers some flexibility. The reason for the second option is that different employers have reported that their job tasks changed so frequently that it does not make sense to perform monitoring on a periodic basis of that nature.  If they were to sample every 3 months, the sampling would not necessarily reflect the exposures that were occurring.  In the construction environments, situations are constantly changing.  The performance oriented option relies upon some body of data which could indicate in general what the exposures were going to be in the workplace.  It is essentially a control banding approach that given certain work parameters, a certain type of welding for example being done on certain materials in a certain environment, can expect the exposure to be in a particular range and then take the measures that would be appropriate for exposures in that range.  

Employers need to be in compliance now.  The exception is with regards to engineering controls. Employers have until May 31, 2010 to have the engineering controls in place.  

The major industries in operations that are covered include:

• Electroplating
• Welding on stainless steel or Cr(VI) painted surfaces
• Painting

• Aerospace
• Auto body repair

• Chromate pigment and chemical production
• Chromium dye and catalyst production
• Glass manufacturing
• Plastic colorant production
• Construction

• Traffic painting
• Refractory brick restoration
• Paint removal from bridges

The top 3 industries/operations covered are:

• Welding - 269,380 (48%)* employees
• Painting - 81,893 (15%)* employees                                     
• Electroplating - 66,857 (12%)* employees
  * % of total employees (558,451) covered by the standard

The top 3 industries/occupations cover about 75 percent of the employees who are exposed to hexavalent chromium.  

OSHA has a number of documents to aid employers on the standards:

• Small Entity Compliance Guide – available at: http://www.osha.gov/Publications/OSHA_small_entity_comp.pdf
• Compliance Directive
• Other guidance products

For specifics of the provisions of the standards and how they apply, a good document to use is the Small Entity Compliance Guide which is available on the OSHA Web site.  The guide provides detailed description of those provisions, what they entail, and how OSHA is interpreting them.  Another support document is the Compliance Directive document that is designed primarily for OSHA’s compliance staff so that they can interpret the provisions of the standards when they are conducting inspections.  This document will be available to the public through their Web site in the next few weeks. The document will help the public gauge how OSHA is going to interpret the standards when they are looking at a particular operation in a facility.  Another group of guidance documents are in the works at this time.  One will deal with control measures that are appropriate for different types of operations.  Another one is going to specifically address electroplating. A general guidance document will address a number of things that might be more relevant to DOE such as in the area of welding.  Some fact sheets will be available that will summarize the health affects of hexavalent chromium and the provisions of the standards.  These fact sheets will be specific for the health care professionals who are providing medical surveillance under the standards to guide them in how to perform that medical surveillance.  

A couple of interpretation issues have surfaced.  First is an exception from the rule.  There is an exception for employers who are able to demonstrate that employees are going to be exposed below point 5 micrograms per cubic meter of air as an 8 hour TWA under any expected condition of use which can be demonstrated with objective data.  Some people have misinterpreting that to mean that if they monitor once or twice and the results are less than .5, they are exempt which is not the case.  The second interpretation issue was the application of the performance oriented approach previously mentioned.  It is incumbent on the employer to demonstrate and to accurately characterize the exposures that their employees are going to have in the workplace.  It is not a corner that can be cut with regard to the exposure determination, but rather just an alternative approach. It is important that exposures be accurately characterized no matter which option is chosen.  

A number of parties challenged the standard in court after it was issued.  The challenges were consolidated in the third circuit.  OSHA reached a settlement agreement with a number of parties:

• Surface Finishing Industry Council
• Building and Construction Trades Department – AFL-CIO, Laborers’ International Union of North America, and International Brotherhood of Teamsters
• National Association of Manufacturers and Specialty Steel Industry of North America

There are a couple of petitions that are currently pending in the court of appeals that mainly deal with lowering the PEL. There is also a challenge to the application of the standard to the electric utility industry.  

Questions related to this presentation should be directed to David O’Connor at: Oconnor.David@dol.gov.

Air Suit Approval Process
Daniel Marsick provided news about the air suit approval process.  There are about 4 sites that are using air suits.  In 2003, DOE developed a new standard for air suit approvals.  In the past, LANL tested air suits in their laboratory facilities to make ensure that the configuration met the requirements for safe and productive suits.  Since 2000 when their task funding ended, DOE has encouraged the new configurations be tested separately in independent laboratories.  Most of the DOE facilities have continued to use the old suits.  Some of the newer suit configurations are coming from Europe.  The DOE 2003 standard said that if you can prove new suits are equivalent you will be allowed to use them:  the site office determine whether those suits can be used or not.  So far the only one who has gone through that process is the Oak Ridge facility that has ordered and used some air suits.  European suits can be used if it has been approved by the site office and it has been determined that all the tests have been completed.  

Questions related to this presentation should be directed to Daniel Marsick at:  Dan.Marsick@eh.doe.gov.

Hexavalent Chromium and DOE Safety Bulletins and Advisories
The Safety and Health Bulletins and Advisories are a useful way of disseminating information to DOE offices.  Because of the use of hexavalent chromium, and the possibility of hexavalent chromium toxicity due to stainless steel welding, DOE published a Hexavalent Chromium Safety Bulletin which discussed the background, the hazards, the standards, and the exposure that may be due to the use of hexavalent chromium in the DOE complex.  This bulletin is specific to the DOE complex and meant to be used by those people within the DOE complex.  The bulletin presents questions managers, supervisors, and workers should asked to ensure that sites have an effective program for hexavalent chromium.

Bulletins and Advisories can be found at: http://orise.orau.gov/ihos/index_DOEnotices.htm.

Questions related to this presentation should be directed to Daniel Marsick at:  Dan.Marsick@eh.doe.gov.

Future Steering Committee Conference Call Meeting

For additional information, please contact:
Deborah McFalls, IH/OS SIG Coordinator
Oak Ridge Institute for Science and Education
P. O. Box 117, MS 10
Oak Ridge, TN 37831-0117