SAN BERNARDINO COMMUNITY COLLEGE DISTRICT FOR CRAFTON HILLS COLLEGE

Transcription

1 October 4, 2016 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 and Phenol Exposure Monitoring Report September 2016 Sampling Event - Cadaver Dissection Crafton Hills College, Canyon Hall Canyon Hall Room Sand Canyon Road Yucaipa, California Dear Mr. Strong: Enclosed please find a copy of the Formaldehyde and Phenol Exposure Monitoring Report prepared by Citadel Environmental Services, Inc. All work was conducted in accordance with Client-established protocols. Employees should be notified of the monitoring results within 15 working days after the receipt of the monitoring results either individually in writing or by posting the results in an appropriate location that is accessible to employees (29 CFR Section (d)(6) and Title 8 Section 5217(d)(6)). If employee exposure is above the PEL, affected employees shall be provided with a description of the corrective actions being taken by the employer to decrease exposure. If after your review you have any questions or require additional information, please do not hesitate to telephone me at the Citadel Office in Valencia at (661) Sincerely, CITADEL ENVIRONMENTAL SERVICES, INC. Natasha Stratton, MS Manager, Occupational Safety and Training Enclosure Kelly Johnson Parkway, Suite 250, Valencia, California / P /

2 San Bernardino Community College District for Crafton Hills College 114 South Del Rosa Drive San Bernardino, California Formaldehyde and Phenol Exposure Monitoring Report September 2016 Sampling Event Cadaver Dissection October 4, 2016 Citadel Project Number Crafton Hills College Canyon Hall Room Sand Canyon Road Yucaipa, California

3 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT- CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, 2016 Table of Contents 1.0 BACKGROUND SCOPE OF SERVICES METHODOLOGY OBSERVATIONS, RESULTS, AND DISCUSSION RECOMMENDATIONS DISCLAIMER AND LIMITATIONS SIGNATURES... 7 APPENDICES Field Documentation... A Laboratory Report... B Photographic Documentation... C

4 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, BACKGROUND The Subject Site is a community college located at Sand Canyon Road in Yucaipa, California (Site). Citadel Environmental Services, Inc. (Citadel) was contracted by San Bernardino Community College District (Client), C/O Crafton Hills College (CHC), to provide industrial hygiene air monitoring services. This sampling is conducted by Citadel in accordance with the CHC Formaldehyde and Phenol Program. Citadel understands that per the current CHC Formaldehyde and Phenol Program, personal exposure monitoring for formaldehyde and phenol is required for individuals (1 person at any one time) working with cadavers in the CHC Anatomy Department. Citadel also understands that, in December 2015-January 2016, the Anatomy and Physiology (A&P) Department relocated to a newly constructed building (Canyon Hall), and the new Cadaver Room (CYN 212) is equipped with a downdraft anatomy dissection table. Citadel conducted personal exposure monitoring for formaldehyde on March 31, Subsequently, Citadel was contracted by the Client to return and conduct personal exposure monitoring in the Cadaver Room during work with embalming fluid, known to contain formaldehyde and phenol, during cadaver dissection activities anticipated to involve the highest potential exposure (opening of chest cavity). 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 personal 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 prepared and submitted for formaldehyde and phenol. 2) Submitting the samples to an independent accredited laboratory for analysis. 3) Preparing a Formaldehyde and Phenol 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 a Laboratory Technician (employee ID#6850) working in the Cadaver Room (CYN 212) in Canyon Hall, with embalming fluid containing formaldehyde and phenol during the aforementioned cadaver dissection activities. Equipment and media appropriate to the specific sampling protocols were utilized to obtain samples during dissection activities involving use of the embalming fluid, to determine the long-term 8-hour time weighted average (TWA) exposures and short-term exposures for the employee. The monitoring results were compared with recognized occupational exposure limits (Permissible Exposure Limits, Short-Term Exposure Limits, Recommended Exposure Limits, Threshold Limit Values, etc.). 1 Citadel provided _CHC_Mar_2016_Formaldehyde_Exposure_Monitoring_Report_NS_MLC dated April 14, _CHC_092316_Formaldehyde_Phenol_Exposure_Monitoring_Report_NS... 1

5 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, METHODOLOGY Air sampling was performed by Citadel s Industrial Hygiene Technician, Ms. Sabrina Chan, during cadaver dissection activities, including the opening of the chest cavity, on September 23, Air Sampling and Laboratory Analyses All of the air samples were delivered via courier to L.A. Testing in Huntington Beach, 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 embalming fluid and/or dissection. Employee exposure monitoring for formaldehyde and phenol was performed 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, which included the opening of the chest cavity. The flow rates of the sampling pumps were verified prior to and following sample collection 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 8-hour time weighted average (TWA) sample and approximately 0.5 L/min for the 15-minute short-term exposure 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 8-hour TWA sample and approximately 0.1 L/min for the 15-minute short-term exposure sample. 4.0 OBSERVATIONS, RESULTS, AND DISCUSSION The monitoring was performed on September 23, A brief interview with the Laboratory Technician was completed to review the dissection protocol and existing safety controls. Field notes are presented in Appendix A. Walkthrough and Visual Inspection The following observations 2 were noted during the investigation on September 23, 2016: The Cadaver Dissection Room is equipped with spill clean-up supplies, a barrel to collect embalming fluid, a barrel to collect cadaver tissue, a barrel to collect residue at downdraft anatomy dissection table and personal protective equipment (e.g., second layer apron, etc.). The Cadaver Room is equipped with a Mopec HB300 dissection table with downdraft capabilities. o The downdraft table is located at the center of the room with one end collecting fluid and the other end linking to a dedicated exhaust system. It is operated 2 Citadel did not access the Cadaver Dissection Room (CYN 212) as the cadaver package was opened. Information regarding equipment and set-up in CYN 212 was provided by Employee ID #6850 during the interview _CHC_092316_Formaldehyde_Phenol_Exposure_Monitoring_Report_NS... 2

6 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, 2016 throughout the cadaver dissection for approximately seventy (70) minutes. o Per the manufacturer specifications, the table is designed for dissection of cadavers and includes a downdraft system which provides ventilation. Air volume should be adjustable and between cubic feet per minute (cfm) to draw vapors down and away from the user. This was not field verified during the exposure assessment. o Ventilation connects to the building exhaust system on one end of the dissecting table using a flexible duct. o Ventilation Tie-in includes (1) 6" diameter connector located on one end of the table. The Gowning Room (CYN 210) is equipped with personal protective equipment including aprons, nitrile gloves, goggles, full face respirators, cleaning wipes, shoe sleeves and labeled hazardous waste container for respirator cartridges. The A&P Laboratory Technician (Employee ID #6850), donned appropriate personal protective equipment (PPE) prior to entering the Cadaver Room. PPE included full-face air purifying respirator with 3M 6005 formaldehyde/organic vapor cartridges and integrated glasses holder; scrubs, chemical-resistant full length apron, and chemical resistant gloves and sleeves. The long-term samples for formaldehyde and phenol were collected over an approximate 70 minute period. The short-term samples for formaldehyde and phenol were collected over an approximate 15 minute period, during the chest opening procedure, when potential exposure is expected to be highest. Citadel placed pumps on the Laboratory Technician at approximately 01:23pm, prior to entering the Cadaver Dissection Room (CYN 212). Citadel removed the short-term exposure sample at 01:38pm and long-term samples at 02:33pm. Citadel noted a mild odor each time the A&P Lab Technician stepped out of the Cadaver Room. Formaldehyde and Phenol Sampling Per the sampling strategy outlined in the scope of work and the CHC Formaldehyde and Phenol Program, Citadel collected personal (TWA and short-term) samples for formaldehyde and phenol. TWA sample results were calculated to reflect an 8-hour time-weighted average. The long-term and short-term exposure samples 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), the National Institute for Occupational Safety and Health (NIOSH) recommended exposure limits (RELs), and recommended American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value-Ceiling (TLV-C). 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 not working with the cadaver and/or embalming fluid, in order to more accurately compare with recognized occupational exposure limits. Figure 1.0 Calculating TWAs TWA T C1 T2C2... 8hr 1 T C Where T is the duration in hours of the exposure to a substance at the concentration C, and 8 hours is a work day. n n _CHC_092316_Formaldehyde_Phenol_Exposure_Monitoring_Report_NS... 3

7 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, 2016 Results Formaldehyde: The long-term personal sample concentration was below the Cal-OSHA AL and the Cal-OSHA PEL TWA. The short-term personal sample concentration was below the Cal-OSHA STEL, but exceeded the recommended ACGIH TLV-C. Phenol: The long-term and short-term personal sample concentrations were lower than the Cal- OSHA PEL, NIOSH RELs, 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. Sample Number F F001 Sample Description Personal Sample Employee ID #6850 (TWA) Personal Sample Employee ID #6850 (STEL) Table 1.0 Summary of Results for Formaldehyde Sample Results (ppm) Calculated TWA 3 Results (ppm) Regulatory Limits for Formaldehyde Cal- OSHA PEL TWA (ppm) Cal- OSHA AL (ppm) Cal-OSHA STEL (ppm) ACGIH TLV-C 4 (ppm) N/A N/A 0.38 N/A N/A N/A F003 Field Blank N/A N/A N/A N/A N/A N/A N/A = Not Applicable ppm = parts per million Sample Number Sample Description Table 2.0 Summary of Results for Phenol Sample Calculated PEL Regulatory Limits for Phenol Results TWA 3 Results NIOSH REL (ppm) (ppm) (ppm) Cal-OSHA PEL TWA (ppm) ACGIH TLV (ppm) Personal Sample P001 Employee ID <0.11 N/A #6850 (TWA) P002 Personal Sample Employee ID <0.11 N/A N/A 15.6 (Ceiling) N/A #6850 (STEL) P003 Field Blank N/A N/A N/A N/A N/A N/A = Not Applicable ppm = parts per million 3 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. 4 It is important to note that ACGIH TLVs are only recommended guidelines used by industrial hygiene professionals and are not legal standards, such as OSHA PELs 5 Citadel notes that it is not appropriate to calculate a PEL TWA in cases where the sample results are found to be below the limit of detection for the method of analysis _CHC_092316_Formaldehyde_Phenol_Exposure_Monitoring_Report_NS... 4

8 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, RECOMMENDATIONS During the monitoring performed on September 23, 2016, the long-term personal sample concentration for formaldehyde was below the Cal-OSHA AL and the Cal-OSHA PEL TWA. The short-term personal sample concentration was below the Cal-OSHA STEL, but exceeded the recommended ACGIH TLV-C. The long-term and short-term personal sample concentrations for phenol were lower than the Cal-OSHA PEL, NIOSH RELs, and recommended ACGIH TLV (TWA). Citadel notes that NIOSH RELs and ACGIH TLVs are recommended exposure limits used by industrial hygiene professionals to characterize exposures and implement best practices, and are not legal standards (such as Cal-OSHA PELs). Based on aforementioned laboratory results and observations during the sampling event, Citadel recommends that the following: Results from two consecutive sampling events 6 indicating exposures below the Cal-OSHA AL and the Cal-OSHA PELs (TWA and STEL) indicate that adherence with the sampling and monitoring requirements 7 promulgated by the Cal-OSHA Formaldehyde standard (CCR Title, 5174) is no longer required. Short-term formaldehyde exposures exceeding the TLV-C indicates the need for continued implementation of best practices including existing engineering controls. Specifically, continued implementation of existing engineering controls including use of the downdraft anatomy dissection table and activation of the exhaust system during periods of formaldehyde 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 use are being followed. 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 6 Citadel refers to documented sampling events on March 31, 2016 and September 23, Per CCR Title Periodic monitoring for employees may be discontinued if results from two consecutive sampling periods (taken at least 7 days apart) show that employee exposure is below the Cal-OSHA action level and STEL and TLV- C for formaldehyde _CHC_092316_Formaldehyde_Phenol_Exposure_Monitoring_Report_NS... 5

9 CITADEL PROJECT NO FORMALDEHYDE EXPOSURE MONITORING REPORT SEPTEMBER 2016 SAMPLING EVENT CADAVER DISSECTION SAN BERNARDINO COMMUNITY COLLEGE DISTRICT CRAFTON HILLS COLLEGE YUCAIPA, CALIFORNIA OCTOBER 4, 2016 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] Sabrina Chan Industrial Hygiene Technician Report Prepared By: Natasha Stratton, MS Manager, Occupation Safety and Training Report Reviewed By: Michelle Campbell, CMC, CDPH, CAC, CIH Director, Industrial Hygiene and Occupational Safety and Training Attachments _CHC_092316_Formaldehyde_Phenol_Exposure_Monitoring_Report_NS... 6

10 Appendix A Field Documentation

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14 Appendix B Laboratory Report

15 LA Testing 5431 Industrial Dr., Huntington Beach, CA Order ID: Attn: Natasha Stratton Citadel Environmental Kelly Johnson Parkway, Suite 250 Valencia, CA Customer ID: Customer PO: Date Received: 32CITA50B 09/26/16 Fax: LA Testing Order: Phone: Project: Air Monitoring-Formaldehyde and Phenol (1 st Sampling Event) Report Date: 09/28/16 Date Analyzed: 09/27/16 Phenol in SKC with NIOSH 2546M Lab ID Sample ID Volume (L) Analyte mg/tube ppm Reporting Limit (mg/tube) P Phenol <0.11 < P Phenol <0.11 < P003 NA Phenol <0.11 NA 0.11 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-LAP, LLC Accredited - Laboratory ID # Page 1 of 1

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18 Attn: Proj: LA Testing 5431 Industrial Drive Huntington Beach, CA Phone/Fax: (714) / (714) / gardengrovelab@latesting.com Natasha Stratton Citadel Environmental Kelly Johnson Parkway Suite 250 Valencia, CA Phone: Fax: Collected: Received: Analyzed: / Air Monitoring-Formaldehyde and Phenol (1st Sampling Event) (661) /26/2016 9/27/2016 LA Testing Order ID: Customer ID: Customer PO: Project ID: CITA50B Test Report:Formaldehyde Analysis by HPLC of Solid Sorbent Tubes via NIOSH 2016, Issue 2, 3/15/03 modified Sample ID Identification Volume Sample Weight Sample Concentration Reporting Limit F001 Employee ID L 5.8 µg 0.40 mg/m³ 0.33 ppm mg/m³ TWA F002 Employee ID L 3.6 µg 0.46 mg/m³ 0.38 ppm mg/m³ STEL F003 Field Blank N/A <0.05 µg N/A N/A N/A N/A = Not Applicable Analyst(s) Dang Jenny Michael Chapman, Laboratory Manager Any questions please contact Michael Chapman. Report amended: 10/04/ :21:21 Replaces initial report from:09/30/ :38:42 Reason Code: Client-Change to Location 1. Samples were received in acceptable condition unless otherwise noted. 2. These results relate only to the samples tested. 3. Sample results are blank corrected. Reporting Limits for samples without volumes, such as Field Blanks, are ug. 4. A discernable Field Blank was submitted if listed above as a discrete sample. Samples analyzed by LA Testing Huntington Beach, CA Test Report IHSParaM Printed: 10/04/ :21:21PM Page 1 of 1

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21 Appendix C Photographic Documentation

22 San Bernardino Community College District Citadel Project No PHOTO A: Gowning Room CYN210 View of biohazard trash can for nitrile gloves disposal. Formaldehyde Exposure Monitoring Report Crafton Hills College Sand Canyon Road Yucaipa, California PHOTO B: Gowning Room CYN210 View of labeled hazardous waste container for respirator cartridges. PHOTO C: Gowning Room CYN210 View of wipes, safety glasses and cartridges supplies. PHOTO D: Gowning Room CYN210 View of apron and shoe sleeves supplies. PHOTO E: Gowning Room CYN210 View of safety glasses, nitrile gloves and wipes supplies. PHOTO F: Gowning Room CYN210 View of clean clothes prior to entering CYN 212.