**Industrial Hygiene Findings and Recommendations**

A.  Compliance with the Hazard Communication (HAZCOM) Standard (29 CFR
    1910.1200) is a deficiency noted at Antietam National Battlefield
    Park. A written hazard communication program was not available, and
    there was no documentation to indicate that employees had been
    trained to recognize the hazards of the chemicals that they come in
    contact with. The park does maintain material safety data sheets,
    and an inventory; however, the inventory was outdated.

> Implement the Hazard Communication Program. The basic goal of a HAZCOM
> Program is to ensure that employees are aware of their "right to know"
> the identities and the hazards of the chemicals that they are exposed
> to in the workplace, and how to protect themselves from such hazards.
> There are several elements to HAZCOM and all elements must be
> implemented for the program to be effective and compliant.

Elements of the Hazard Communication Program include:

-   Written Hazard Communication Program

-   Material Safety Data Sheets (MSDS). MSDS's must be obtained and
    maintained for each chemical product on site. The MSDS must be
    reviewed at the time the chemical is brought on site and/or prior to
    use. The MSDS is the first step toward protection as it lists the
    components of the chemical and the hazards associated, the personal
    protective equipment recommended, first aid procedures, etc. In
    addition, the MSDS must be readily available to employees for
    review.

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-   A Chemical inventory must be developed for all chemicals and
    maintained on site. The inventory must be updated as chemicals are
    purchased and/or depleted. It is recommended that a centralized
    purchasing program be established for the park to monitor chemical
    purchases and avoid duplicate orders. Chemicals should be ordered in
    the amount to be used to avoid long term storage and disposal
    issues.

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-   Chemical labeling of all chemicals to indicate the identity of the
    material. Manufacturer labels are sufficient, however, if the label
    is defaced the chemical container must be re-labeled to indicate the
    chemical name, manufacturer, hazard category, and target organs.
    Chemicals transferred to secondary containers must also be labeled
    and should only contain the information for the chemical in the
    container. The only exception to the requirement for labeling of
    secondary containers is if the chemical in the secondary container
    will be under complete control by the employee who made the transfer
    and will be used in its entirety by that employee during that work
    shift. *Labeling is recommended for secondary containers (even when
    the intent is to use the chemical immediately) to eliminate the
    possibility of chemicals being left unattended in the event of an
    emergency.*

-   Employee Information and Training must be provided to all employees
    who use hazardous chemicals or may be exposed to them and
    documentation of training must be maintained. Information and
    Training must be provided at the time of their initial assignment,
    whenever a new physical or health hazard is introduced into the
    workplace, or when there is evidence that training is needed.

B.  Compliance with the Hearing Conservation (29 CFR 1910.95) Standard
    is critical to the prevention of occupational hearing loss. Hearing
    loss caused by occupational noise is gradual, cumulative, and
    permanent. Employees at Antietam perform job tasks that expose them
    to occupational noise. Occupational noise exposure is exposure to
    noise at a level at or greater than 85 decibels on the "A" weighted
    network (dBA) over an eight hour period. Many of the trades within
    the parks have the potential for employee exposure at or above
    85dBA. While sound level surveys have not been performed at
    Antietam, existing research on noise generated by common industrial
    equipment has documented noise levels ranging from 75 -- 120 dBA. As
    a rule of thumb, if the work environment makes it necessary to speak
    very loudly to communicate with a person in close proximity in order
    to be understood it is possible that the exposure limit for noise is
    being exceeded. Employees at Antietam are similar to employees in
    other industries whose jobs and exposure to noise vary from day to
    day. This makes it difficult to accurately determine noise exposure.
    Many industries consider it a best practice to include all employees
    in a hearing conservation program when they are frequently exposed
    to noise greater than 85 dBA regardless of the length of exposure.
    There have been studies that show that, on average, 5% of
    individuals with long-term exposure to noise levels of 80dBA will
    have significant hearing loss. This risk increases to 5-15% with
    85dBA noise and 15-25% with 90dBA noise. Employees who are in a
    medical surveillance program are closely monitored to determine
    changes in their hearing, and therefore have a greater opportunity
    to protect their hearing from further damage. Employees at Antietam
    received audiometric surveillance in 2002. It is important that
    routine surveillance continue in an effort to protect the hearing
    abilities of employees in the park. A deficiency noted at Antietam
    with respect to Hearing Conservation is the performance of facility
    and equipment sound level surveys and posting of labels on loud
    noise producing equipment to remind employees to wear hearing
    protection devices.

> Develop and implement all elements of the Hearing Conservation
> Program. The basic goal of a Hearing Conservation Program is the
> reduction or limitation of noise induced hearing loss. There are
> several elements to the Hearing Conservation Standard and all elements
> must be implemented to demonstrate that the program is effective.
> Elements of the Hearing Conservation Program include:

-   Written Hearing Conservation Program

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-   Identify noise hazardous areas and equipment in work place and post
    warning signs.

-   Provide Hearing Protection Devices (HPD) to all employees affected
    by noise hazardous areas or equipment. HPD's come in various styles
    and various noise reduction ratings (NRR's). While the style should
    be selected based on comfort, it is most important that the HPD
    provide a high enough NRR to provide adequate protection for the
    loudest noise producing equipment at the facility.

-   Provide Medical Surveillance (Audiometric testing), baseline and
    annual. A baseline is the first test performed on the worker and
    should be performed within six months of the employees' first
    exposure. It is the reference to which all other tests should be
    compared. A follow-up test is performed annually, and the results
    are compared with the original baseline.

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-   Provide information and training annually. The training must cover
    the effects of noise on hearing, the purpose of HPDs including
    selection, fitting, use, and care, and the purpose of audiometric
    testing and procedures.

-   Provide and post a copy of 29 CFR 1910.95, Occupational Noise
    Exposure Standard, in the workplace.

-   Recordkeeping -- Maintain audiometric tests and exposure
    measurements.

C.  Factors that influence indoor air quality range from thermal comfort
    to pollutant sources with one of the most important factors being
    the presence of pollutant sources. Commonly found pollutant sources
    include carbon monoxide, carpet, cleaning materials, paints,
    adhesives, disinfectants, biological contaminants (mold, mildew)
    from dirty ventilation systems, and water damaged walls, ceiling
    tiles and carpets. Although many pollutants are invisible, they can
    seriously impact health, environment, and quality of life. An indoor
    air quality issue that is visible at Antietam is mold. Mold has
    generated a lot of public awareness in past years. There are
    presently no standards or threshold limit values for "acceptable"
    levels of mold in buildings. In addition, there are no standards to
    say how much mold is hazardous to your health.

> Most people have no reaction when exposed to molds. However, there
> have been some reports linking health effects in workers to offices
> contaminated with moldy surfaces. People with respiratory conditions,
> or allergies and asthma are in a group of people who may be affected
> more severely and quickly than others.
>
> Mold growth observed or suspected must be cleaned-up as soon as
> possible. The source of the moisture problem must be located and
> completely fixed and visible mold, mold-damaged materials, and moldy
> odors must be remediated. If mold is permitted to grow, it can cause
> considerable damage such as discoloration and/or rotting to building
> materials and furnishings and it may also lead to health complaints
> and/or physical symptoms by building occupants. Additionally, the site
> of the mold growth and moisture problem must be re-evaluated
> periodically to ensure that remediation effort and moisture control
> measures were adequate to prevent future mold contamination.

D.  Compliance with the Personal Protective Equipment (PPE) standard (29
    CFR 1910.132 --General Requirements, .133 -- Eye and Face
    Protection, .135 -- Head Protection, .136 -- Foot Protection, .138
    -- Hand Protection) is essential for employee protection from
    chemical, physical, environmental, and process hazards. Employees at
    Antietam perform a variety of tasks that requires the use of
    personal protective equipment. Observations made of personal
    protective equipment indicate a lack of respect for, and
    understanding for the equipment provided to protect employees from
    occupational hazards. Personal protective equipment was observed in
    unsanitary condition and/or improperly stored.

> **Develop and maintain a PPE program.** The purpose of a PPE program
> is to protect employees from the risk of injury by creating a barrier
> against workplace hazards. Personal protective equipment is not a
> substitute for good engineering or administrative controls or good
> work practices, but is used in conjunction with these controls to
> ensure the safety and health of employees. Elements of an effective
> PPE program include:

-   Hazard Assessment and equipment selection.

-   Written certification of hazard assessment.

-   Training to recognize what PPE is necessary, when PPE is necessary,
    how to properly wear PPE, the limitations of the PPE, and the proper
    care, maintenance, useful life and disposal of PPE. It is important
    that all PPE be kept clean and properly maintained. Cleaning is
    particularly important for eye and face protection where dirty or
    fogged lenses could impair vision. PPE should be inspected, cleaned,
    and maintained at regular intervals so that the PPE provides the
    required protection. Personal protective equipment shall not be
    shared between employees until it has been properly cleaned and
    sanitized.

E.  The **Medical services and first aid standard (29 CFR 1910.151)** is
    a small standard with lasting results. The standard states: "The
    employer shall ensure the ready availability of medical personnel
    for advice and consultation on matters of plant health. In the
    absence of an infirmary, clinic or hospital in near proximity to the
    workplace that is used for the treatment of all injured employees, a
    person or persons shall be adequately trained to render first aid.
    Adequate first aid supplies shall be readily available. Where the
    eyes or body of any person may be exposed to injurious corrosive
    materials, suitable facilities for quick drenching or flushing of
    the eyes and body shall be provided within the work area for
    immediate emergency use." The standard does not go into detail on
    the requirements for first aid supplies, or for quick drenching or
    eye flushing facilities. Instead OSHA uses industry standards,
    specifically ANSI Z308.1-2003, Minimum Requirements for Industrial
    Unit-type First-aid Kits (Appendix C) and ANSI Z358.1-2004,
    Emergency Eye Wash and Shower Equipment.

> An understanding of both ANSI standards is paramount for the
> administration of first aid and the prevention of eye injury. First
> aid supplies must be stocked and readily available. In addition,
> eyewash stations must be maintained and inspected. Medical statistics
> show that after the first ten seconds that a contaminant comes into
> contact with the eye, chances of full recovery become fleeting. This
> statistic is why proper maintenance and inspection of eye wash
> stations are so important. The ANSI standard requirements for plumbed
> and self-contained units include:

-   Plumbed eyewashes should be activated weekly to verify proper
    operation.

-   placed within 10 seconds travel time of a hazard, within 10 ft of
    strong acids or caustics

-   be able to flush out both eyes simultaneously

-   nozzles must be protected from airborne contaminants

-   able to maintain a minimum flushing rate of 0.4 GPM for eyewash and
    20 GPM for shower for 15 minutes

-   use "stay open" valves to keep hands free to hold eyelids open

-   begin flushing within one second of activation

-   identify location with a highly visible sign

-   ensure that the location is readily accessible and free of
    obstructions

-   plumbed device should be checked weekly to test equipment
    performance and to flush debris or bacterial sediment. This includes
    checking all devices, including flushing fluids (per manufacturers'
    instructions). Records of those inspections should be kept on the
    device.

-   employee training in the use and inspection of equipment

-   use of water at "tepid" temperatures

-   Manufacturers specifications should be consulted for maintenance and
    water change out schedule for self contained units.