**Industrial Hygiene Findings and Recommendations**

A.  Development of a written plan and compliance with the Hazard
    Communication (HAZCOM) Standard (29 CFR 1910.1200) should be a
    priority at the Museum Resource Center. Hazard Communication focuses
    on direct and indirect issues relating to chemical exposure.
    Employees who handle artifacts should understand that a potential
    health hazard may exist from exposure to known chemicals applied to
    artifacts, and also to unknown chemical application. The Museum
    Resource Center did not have a written hazard communication program.

> 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 and known chemicals
    that have been applied to artifacts. 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 Personal Protective Equipment (PPE) standard (29
    CFR 1910.132 --General Requirements, .133 -- Eye and Face
    Protection, .138 -- Hand Protection) is essential for employee
    protection from occupational hazards. Employees at MRC handle
    various artifacts during museum preservation work that may be
    encrusted with dust, dirt, surface scrapings, and unknown chemicals.
    Dermal contact with these materials presents not only a contact
    hazard (dermatitis), but may also present an inhalation hazard.

> **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.

> The types of PPE and some engineering, administrative, and/or good
> work practice guidelines include:

-   Nitrile gloves while handling artifacts. When removing the gloves,
    do not touch the exterior surface of the gloves.

-   Wash hands with soap and water after handling objects, and
    especially before eating, drinking or smoking.

-   Wear a lab coat or other protective clothing to keep dust off
    clothing. Do not wear coat outside work area.

-   Ensure that there is adequate ventilation when working with
    materials.

-   Do not permit eating and/or drinking in store room or work area.

-   Ensure that work surfaces are well cleaned after they have been in
    contact with artifacts.