project no. 0069.1080.0 formaldehyde & phenol exposure...
TRANSCRIPT
1725 Victory Boulevard, Glendale, California 91201 / P 818 246-2707 / F 818 246-3145 www.citadelenvironmental.com
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 92408
Re: CITADEL Project No. 0069.1080.0
Formaldehyde & Phenol Exposure Monitoring Report
September 2015 Sample Event #1
Crafton Hills College, LADM Building
Anatomy Department Room 229/230
11711 Sand Canyon Road
Yucaipa, California 92399
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 Client-
established 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) 246-2707.
Sincerely,
CITADEL ENVIRONMENTAL SERVICES, INC.
Nalinna Rasu, CAC, CDPH, CHMM, LEED AP
Director, Environmental Compliance
Enclosure
San Bernardino Community College District for Crafton Hills College 114 South Del Rosa Drive San Bernardino, California 92408
Formaldehyde & Phenol Exposure Monitoring Report September 2015 Sampling Event #1
October 14, 2015 Citadel Project Number 0069.1080.0 Crafton Hills College Anatomy Department Room 229/230 11711 Sand Canyon Road Yucaipa, California 92399
www.citadelenvironmental.com
CITADEL PROJECT NO. 0069.1080.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 ........................................................................................................................................................ 1
2.0 SCOPE OF SERVICES .............................................................................................................................................. 1
3.0 METHODOLOGY ..................................................................................................................................................... 2
4.0 OBSERVATIONS, RESULTS, AND DISCUSSION .................................................................................................... 2
5.0 RECOMMENDATIONS ............................................................................................................................................ 5
6.0 DISCLAIMER AND LIMITATIONS .......................................................................................................................... 6
7.0 SIGNATURES .......................................................................................................................................................... 6
APPENDICES
Field Documentation .................................................................................................................................................................................. A
Laboratory Report ....................................................................................................................................................................................... B
CITADEL PROJECT NO. 0069.1080.0
FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT
OCTOBER 2015 SAMPLING EVENT #1
SAN BERNARDINO COMMUNITY COLLEGE DISTRICT
CRAFTON HILLS COLLEGE
YUCAIPA, CALIFORNIA
OCTOBER 14, 2015
0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 1
1.0 BACKGROUND
The Subject Site is a community college located at 11711 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.).
CITADEL PROJECT NO. 0069.1080.0
FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT
OCTOBER 2015 SAMPLING EVENT #1
SAN BERNARDINO COMMUNITY COLLEGE DISTRICT
CRAFTON HILLS COLLEGE
YUCAIPA, CALIFORNIA
OCTOBER 14, 2015
0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 2
3.0 METHODOLOGY
Air sampling was performed by Citadel’s Project Industrial Hygienist, Ms. Jessica Small, during
cadaver dissection activities on September 24, 2015.
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
DrycalTM 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, 2015. 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.
CITADEL PROJECT NO. 0069.1080.0
FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT
OCTOBER 2015 SAMPLING EVENT #1
SAN BERNARDINO COMMUNITY COLLEGE DISTRICT
CRAFTON HILLS COLLEGE
YUCAIPA, CALIFORNIA
OCTOBER 14, 2015
0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 3
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.
hr
CTCTCTTWA nn
8
...2211
Where T is the duration in hours of the exposure to a substance at the concentration C, and 8 hours is a work day.
Figure 1.0 Calculating TWAs
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.
CITADEL PROJECT NO. 0069.1080.0
FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT
OCTOBER 2015 SAMPLING EVENT #1
SAN BERNARDINO COMMUNITY COLLEGE DISTRICT
CRAFTON HILLS COLLEGE
YUCAIPA, CALIFORNIA
OCTOBER 14, 2015
0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 4
Table 1.0 Summary of Results for Formaldehyde
Sample
Number
Sample
Description
Sample
Results
(ppm)
Calculated
TWA1 Results
(ppm)
Regulatory Limits for Formaldehyde
Cal-
OSHA PEL
TWA
(ppm)
Cal-
OSHA AL
(ppm)
Cal-OSHA
STEL
(ppm)
ACGIH
TLV-C
(ppm)
F01
Personal
Sample –
(TWA)
4.7 0.56
0.75
0.5
N/A
N/A
F02
Personal
Sample –
(STEL)
7.1 N/A
N/A N/A 2 0.3
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
Table 2.0 Summary of Results for Phenol
Sample Number
Sample
Description
Sample
Results
(ppm)
Calculated
PEL TWA1
Results (ppm)
Regulatory Limits for Phenol
Cal-OSHA
PEL TWA
(ppm)
NIOSH STEL
(ppm)
ACGIH TLV
(ppm)
PO1
Personal
Sample –
(TWA)
<0.92 <0.11
5
N/A
5
PO2
Personal
Sample –
(STEL)
<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.
CITADEL PROJECT NO. 0069.1080.0
FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT
OCTOBER 2015 SAMPLING EVENT #1
SAN BERNARDINO COMMUNITY COLLEGE DISTRICT
CRAFTON HILLS COLLEGE
YUCAIPA, CALIFORNIA
OCTOBER 14, 2015
0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 5
5.0 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 1910.1048). 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.1910.134. 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 1910.1048) 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
CITADEL PROJECT NO. 0069.1080.0
FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT
OCTOBER 2015 SAMPLING EVENT #1
SAN BERNARDINO COMMUNITY COLLEGE DISTRICT
CRAFTON HILLS COLLEGE
YUCAIPA, CALIFORNIA
OCTOBER 14, 2015
0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 6
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
AppendixAFieldDocumentation
AppendixBLaboratoryReports
LA Testing 11652 Knott Street, Unit F5, Garden Grove, CA 92841
Order ID: 331517533
Attn:
Fax:
Phone:
Email:
Report Date:
Nalinna Rasu
Citadel Environmental Services, Inc.
1725 Victory Boulevard
Glendale, CA 91201
818-246-2707
10/01/15
Customer ID:
Customer PO:
Date Received:
LA Testing Order:
Project:
Date Analyzed:
32CITA50
0069.1080.0
09/24/15
331517533
CHC 2015 Form / Phen Personal
Sampling / 0069.1080.0
09/28/15
FORMALDEHYDE by NIOSH 2016M, Issue 2, March 2003
SKC 226-119
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 #101650
Page 1 of 1
LA Testing
Sample ID
Client ID
Air
Volum
e
(L)
Component Result
(µg/sample)
Result
(ppm)
Reporting
Limit
(µg/sample)
331517533-0001 F01 11.4 Formaldehyde 66 4.7 0.10
331517533-0002 F02 7.5 Formaldehyde 66 7.1 0.10
331517533-0003 F03 - Formaldehyde <0.10 N/A 0.10
OrderID: 331517533
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2
OrderID: 331517533
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2
LA Testing 11652 Knott Street, #F-5, Garden Grove, CA 92841
Order ID: 331517545
Attn: Nalina Rasu
Citadel Environmental Services, Inc.
1725 Victory Boulevard
Glendale, CA 91201
Customer ID:
Customer PO:
Date Received:
32CITA50
0069.1080.0
09/24/15
Fax:
Phone:
818-462-2707
LA Testing Order: 331517545
E-mail:
Project:
CHC 2015 FORM/PHENOL
Personal Sampling
Report Date: 10/01/15 Date Analyzed: 09/29/15
Phenol in SKC 226-95 with NIOSH 2546M
MNH
Analyst Michael Chapman, Laboratory Manager
Or other approved signatory
AIHA Accredited - Laboratory ID #101650
Page 1 of 1
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.
Sample ID
Volume
(L)
Lab ID
Analyte
mg/tube
ppm
Reporting Limit
(mg/tube)
PO1 5498300803 5.7 331517545-0001 Phenol <0.020 <0.92 0.020
PO2 5498300795 1.5 331517545-0002 Phenol <0.020 <3.5 0.020
PO3 5498300797 NA 331517545-0003 Phenol <0.020 NA 0.020
OrderID: 331517545
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2
OrderID: 331517545
Page 2 Of
2