Legionnaires’ Disease 

at an Automobile and 

Scrap Metal Shredding 

Facility, New York

Randy Boylstein, MS, REHS 

Rachel Bailey, DO, MPH 

Chris Piacitelli, MS, CIH 

Christine Schuler, PhD

Jean Cox-Ganser, PhD

Kathleen Kreiss, MD

Health Hazard Evaluation Report

HETA 2011-0109-3162

New York

August 2012

DEPARTMENT OF HEALTH AND HUMAN SERVICES

Centers for Disease Control and Prevention

Workplace

Safety and Health

 National Institute for Occupational 

Safety and Health
The employer shall post a copy of this report 

for a period of 30 calendar days at or near 

the workplace(s) of affected employees. 

The employer shall take steps to insure that 

the posted determinations are not altered, 

defaced, or covered by other material during 

such period. [37 FR 23640, November 7, 1972, 

as amended at 45 FR 2653, January 14, 1980].
Health Hazard Evaluation Report 2011-0109-3162 Page 1

Tables

Report Abbreviations.......................................................................2

Highlights of the NIOSH Health Hazard Evaluation.............3

Summary..............................................................................6

Introduction..........................................................................8

Background..........................................................................8

Assessment.......................................................................14

Results...............................................................................17

Discussion .........................................................................25

Conclusions.......................................................................29

Recommendations.............................................................30

References........................................................................ 34

Contents

Tables.................................................................................38

Figures...............................................................................42

Acknowledgments

Figures

Appendix A of OSHA Respiratory Protection Standard......55

Acknowledgements and Availability of Report...................77

Appendix A

Appendix B Appendix B-1 of OSHA Respiratory Protection Standard..76
Page 2 Health Hazard Evaluation Report 2011-0109-3162

CDC Centers for Disease Control and Prevention

CFR Code of Federal Regulations

CFU Colony forming unit 

Ct Cycle threshold 

DNA Deoxyribonucleic acid 

DFA Direct fluorescent antibody

°F Degrees Fahrenheit 

HHE Health hazard evaluation

mg/m3 Milligrams per cubic meter 

mL Milliliter 

L. Legionella

NAICS North American Industry Classification System

NIOSH National Institute for Occupational Safety and Health

NYSDH New York State Department of Health

OSHA Occupational Safety and Health Administration

PCR Polymerase chain reaction 

PEL Permissible exposure limit

ppm Parts per million 

REL Recommended exposure limit

VOC Volatile organic compound 

Abbreviations
Health Hazard Evaluation Report 2011-0109-3162 Page 3

The National Institute for Occupational Safety and Health 

(NIOSH) received a management request in May 2011 for a health 

hazard evaluation at an automobile and scrap metal shredding 

facility in New York. Management submitted the health hazard 

evaluation request because four cases of Legionnaires’ disease had 

been identified among facility workers between 2009 and 2011. 

Following our initial site visit, a fifth case was identified in June 

2011. 

What NIOSH Did 

● Site visit in June 2011 

o We spoke with employees about Legionnaires’ 

disease and any current symptoms they may have 

had.

o We distributed a NIOSH-prepared handout about 

the health hazard evaluation and Legionnaires’ 

disease to workers and recommended that they give 

the handout to their healthcare provider if they get 

sick. 

o We gave workers a list prepared by the local health 

department of healthcare providers, walk-in clinics, 

free clinics, and emergency departments in the area.

o We collected air, water, and swab samples at 

multiple locations around the facility and tested 

them for Legionella bacteria; water samples were also 

tested for free chlorine content and pH.

o We collected area air samples that were analyzed for 

metals, volatile organic compounds, and/or dust 

levels.

o We met with health officials from the state and 

local health departments and reviewed medical 

records for known cases of Legionnaires’ disease. 

o We recommended steps to decrease potential 

exposure to Legionella bacteria during our closing 

meeting and in a July 2011 interim letter report.

● Site visit in September 2011

o We collected water and swab samples at multiple 

locations and analyzed them for Legionella bacteria.

o We hung posters that showed how to put on and 

take off an N-95 respirator and demonstrated the 

procedures to some workers.

o We posted laminated hand-washing signs in the 

break room and restrooms and no smoking signs in 

the production area.

Highlights of the

NIOSH Health

Hazard Evaluation
Page 4

Highlights of the

NIOSH Health

Hazard Evalution

(continued)

Health Hazard Evaluation Report 2011-0109-3162

o We recommended steps to decrease potential 

exposure to Legionella bacteria during our closing 

meeting.

What NIOSH Found 

● Site visit in June 2011 

o Large quantities of standing water were observed 

throughout the facility grounds. 

o Workers stood and shoveled in or around the 

standing water; mobile equipment drove through 

puddles of water. 

o Water dripped from the exterior of the shredder 

and conveyors, and the shredder emitted clouds of 

steam.

o Only one surface drain was visible, and water was 

not draining to it.

o Shredded material on the conveyors was dirty and 

wet.

o No respirators were being used.

o Legionella was identified in water dripping from 

the exterior of the shredder onto the exit conveyor 

belt that contained the shredded material, and in 

multiple puddles of water.

o Legionella was identified from a swab sample taken 

from a conveyor belt inside the picking shed.

● Site visit in September 2011 

o Significantly less standing water was observed on 

the ground.

o A larger shredder had been installed that used less 

water.

o The facility grounds had been cleared of a buildup of dirt and mud revealing a previously unseen 

drain, resulting in improved drainage.

o Workers who shoveled or worked in the picking 

shed were wearing N-95 respirators.

o No one wearing a respirator had been fit-tested.

o Only the picking shed had been cleaned and 

sanitized.

What Managers Can Do 

● Improve surface drainage to eliminate remaining standing 

water and continue to keep the grounds cleared of debris 

that inhibits drainage.
Health Hazard Evaluation Report 2011-0109-3162 Page 5

Highlights of the

NIOSH Health

Hazard Evalution

(continued)

● Minimize shoveling activities in puddles of water.

● Wash and sanitize the shredder, conveyor systems, and 

mobile equipment twice a year.

● Perform environmental sampling for Legionella if another case 

of Legionnaires’ disease is identified. 

● Require mandatory use of fit-tested respirators (N-95 or 

higher level of protection) for workers who perform picking 

operations or shoveling in or around standing water, as well 

as for any other workers who may be exposed to aersols from 

pools of water, dripping or splashing water, or wet materials. 

Workers should also wear respiratory protection when 

dredging or emptying the drainage pond.

● Develop a respiratory protection program in compliance 

with the Occupational Safety and Health Administration 

respiratory protection standard, 29 Code of Federal 

Regulations (CFR) 1910.134. 

● Workers with respiratory or flu-like symptoms should be 

evaluated by a healthcare provider for possible Legionnaires’ 

disease. Signs of Legionnaires’ disease can include a high 

fever, chills, and a cough. Some people may also suffer from 

muscle aches and headaches. Nausea, vomiting, and diarrhea 

may also occur.

What Employees Can Do 

● Report respiratory or flu-like symptoms to your personal 

healthcare provider and, as instructed by your employer, 

to a designated individual at your workplace. Signs of 

Legionnaires’ disease can include a high fever, chills, and a 

cough. Some people may also suffer from muscle aches and 

headaches. Nausea, vomiting, and diarrhea may also occur.

● Wear a fit-tested respirator when performing picking 

operations or shoveling in or around standing water, as well 

as when you may be exposed to aerosols from pools of water, 

dripping or splashing water, or wet materials. You should also 

wear respiratory protection when dredging or performing 

maintenance on the drainage pond. 

● If your respirator gets dirty or is hard to breathe through put 

on a new respirator. 

● Do not smoke or eat in the plant production areas. 

● Always wash your hands before eating or smoking. 
Page 6 Health Hazard Evaluation Report 2011-0109-3162

On May 11, 2011, the National Institute for Occupational Safety 

and Health (NIOSH) received a request from the management 

of an automobile and scrap metal shredding facility regarding 

cases of Legionnaires’ disease that had been identified among 

their workers. The request listed concerns about dusts, mists, and 

vapors generated during the process of shredding automobiles and 

scrap metal. The health concerns were Legionnaires’ disease and 

respiratory disease. 

During telephone discussions with the New York State Department 

of Health (NYSDH), NIOSH learned that four employees from the 

shredding facility had been diagnosed with Legionnaires’ disease: 

one in 2009, two in 2010, and one in May 2011. All performed 

shoveling and/or picking activities; the latter involves manually 

removing copper and other material passing on a moving conveyor. 

In December 2010, NYSDH identified Legionella bacteria on a 

swab sample taken from a conveyor belt that exited the shredder 

and from water dripping from that same belt. An additional water 

sample obtained in May 2011 from the same conveyor belt also 

contained Legionella.

Prior to our initial site visit, NIOSH investigators contacted 

management and recommended that any employee with 

respiratory, flu-like, or gastrointestinal symptoms (e.g., fever, 

chills, cough, shortness of breath, muscle aches, nausea, vomiting, 

diarrhea) be removed from his or her job and seek evaluation 

for Legionnaires’ disease from a healthcare provider. We also 

recommended that employees who work near any aerosols or mists 

wear fit-tested N-95 respirators.

On June 1-2, 2011, NIOSH investigators visited the facility. 

We spoke briefly with all available facility employees about 

Legionnaires’ disease and any symptoms they may have or 

have had; none reported current symptoms consistent with 

Legionnaires’ disease. We observed large quantities of standing 

water throughout the facility grounds. We also observed workers 

standing and shoveling in or around the water; vehicles driving 

through puddles of water; and front-end loaders picking up and 

setting down materials in and around standing water. We observed 

no employees wearing respirators. We collected air, water, and 

swab samples at multiple locations around the facility to be tested 

for Legionella bacteria. We also collected area air samples to be 

analyzed for metals, volatile organic compounds (VOCs) and dust. 

Legionella was identified in water dripping from the exterior of the 

Five employees from the 

shredding facility who 

had performed shoveling 

and/or picking activities 

had been diagnosed with 

Legionnaires’ disease. Upon 

inspection, we observed 

large quantities of standing 

water throughout the facility 

grounds and observed 

workers standing and 

shoveling in or around 

the water. Legionella was 

identified in water and 

swab samples collected 

from numerous locations 

around the facility. We 

recommended that the 

groundwater drainage 

system be improved to 

eliminate the pools of 

water, the equipment be 

sanitized, and workers wear 

N-95 respirators. Since 

instituting recommendations 

there have been no new 

cases. 

Summary
Health Hazard Evaluation Report 2011-0109-3162 Page 7

Summary (continued)

shredder onto the exit conveyor belt that contained the shredded 

material and in multiple puddles of water. Metals detected in 

the air samples were below applicable NIOSH recommended 

exposure limits (RELs) and the Occupational Safety and Health 

Administration (OSHA) permissible exposure limits (PELs), where 

standards existed. Toluene, ethyl benzene and xylene isomers, and 

some alkyl benzenes were the major VOCs identified. The dust 

samples were below the OSHA particulates not otherwise regulated 

standard of 5 milligrams per cubic meter (mg/m3) for respirable 

particles. 

At the end of the walk-through visit, we again recommended 

implementing a formal respiratory protection program that would 

require employees working around or near aerosols or mists to 

wear fit-tested N-95 respirators. We also discussed the possibility 

of Legionella in the standing water which could be aerosolized 

during shoveling activities and while driving or walking through 

the puddled water. We reiterated that symptomatic employees 

should be removed from their jobs until they are evaluated for 

Legionnaires’ disease by a healthcare provider. We recommended 

that the groundwater drainage system be improved to eliminate 

the pools of water and that shoveling activities be avoided as much 

as possible during shredding operations because of the potential 

for generating aerosols. We recommended the shredder, conveyor 

systems, and any mobile equipment be cleaned and sanitized.

Following our initial site visit, a fifth employee was diagnosed with 

Legionnaires’ disease in June 2011. He had recently been hired 

at the facility, worked in the picking shed, and had not worn a 

respirator.

On September 23, 2011, we revisited the facility to conduct a 

follow-up assessment. Facility grounds had been cleared of a buildup of dirt, improving drainage and revealing a previously blocked 

drain. A new shredder had been installed which required only 

half the previous water flow. The plant manager reported that the 

picking room had been cleaned and sanitized but not the rest of 

the facility. Some puddles of water still existed, and Legionella was 

detected in water samples taken from multiple puddles. Legionella

was not detected in swab samples taken from the conveyor system. 

We observed workers wearing N-95 respirators; none had been 

fit-tested, and some were wearing their respirators incorrectly. 

In each of these cases, we showed the worker how to wear the 

respirator. We also hung posters in the break room and mechanical 
Page 8 Health Hazard Evaluation Report 2011-0109-3162

Summary (continued)

room that showed how to put on and take off an N-95 respirator. 

We recommended that workers wearing respirators be fit-tested. 

We also recommended that the ground drainage be improved 

to remove the remaining standing water, and that the rest of the 

facility be cleaned and sanitized.

Introduction On May 11, 2011, NIOSH received a health hazard evaluation 

(HHE) request, dated May 10, 2011, from the owner of an 

automobile and scrap metal shredding facility regarding cases of 

Legionnaires’ disease that had been identified among workers. The 

request listed concerns about dusts, mists, and vapors generated 

during the process of shredding automobiles and scrap metal. The 

health concerns were Legionnaires’ disease and respiratory disease. 

Keywords: NAICS 423930 (Recycled material merchant 

wholesalers), Legionnaires’ disease, Legionella, respiratory disease, 

personal protective equipment, PPE, water, shredding.

Background In May 2011, before we received the HHE request, we had 

telephone discussions with the director of a regional office of the 

NYSDH and an industrial hygienist from the NYSDH Bureau of 

Occupational Health. They told us that four employees from the 

shredding facility had been diagnosed with Legionnaires’ disease: 

one in 2009, two in 2010, and one in May 2011. In December 

2010, upon learning of the two recent cases, the NYSDH visited 

the facility and collected a swab sample from a conveyor belt that 

exited the shredder and a sample of water dripping from that 

same belt; Legionella bacteria were identified in both samples. An 

additional water sample obtained in May 2011 from the same 

conveyor belt also contained Legionella. The NYSDH told us 

that the local county health department had been involved in 

investigating the cases of Legionnaires’ disease since December 

2010. The local county health department made several visits to 

the facility. They prepared a fact sheet on Legionnaires’ disease 

which was distributed to employees and sent a letter to primary 

care providers in the area notifying them that employees at the 

shredding facility had been diagnosed with Legionnaires’ disease. 

The letter included guidance documents from the NYSDH about 

Legionnaires’ disease and how to diagnose it.

In April 2011, the director of the regional office of the NYSDH 

had sent a letter to the owner of the shredding facility and 

recommended that he submit an HHE request to NIOSH to assist 

with identifying potential environmental sources of exposure to 
Health Hazard Evaluation Report 2011-0109-3162 Page 9

Background (continued)

Legionella bacteria and recommend control methods. The director 

of the regional office mentioned in the letter that NIOSH might 

also be able to assist with evaluating fume and dust exposures at 

the facility. After we received the HHE request in May 2011, we 

contacted the shredding facility owner and his contract safety 

consultant. We recommended that any employee with respiratory, 

flu-like, or gastrointestinal symptoms (e.g., fever, chills, cough, 

shortness of breath, muscle aches, nausea, vomiting, diarrhea) be 

removed from his or her job and seek evaluation for Legionnaires’ 

disease from a healthcare provider. We also recommended 

that employees working around or near any aerosols or mists 

wear fit-tested N-95 respirators. We discussed that this would 

entail instituting a formal respiratory protection program that 

complied with the OSHA respiratory protection standard (29 

Code of Federal Regulations (CFR) 1910.134). We set dates for 

June 1-2, 2011 with the facility owner to visit the facility, collect 

environmental samples, and talk informally with employees.

We informed the staff of the local county health department and 

NYSDH of our initial recommendations and that we would be 

making the June site visit. 

During the site visit in June, we also met with staff from the 

NYSDH and the local county health department, who provided us 

with medical records for the four cases. At the conclusion of the 

site visit at the shredding facility, we provided recommendations to 

the facility owner and his safety consultant.

On July 12, 2011, the NYSDH notified us that a fifth case of 

Legionnaires’ disease had been diagnosed in a worker from the 

facility who had become symptomatic in mid-June 2011. 

On July 13, 2011, we had a teleconference with staff from the

NYSDH to review our findings and recommendations from our 

site visit. On July 14, 2011, we discussed the recommendations with 

the shredding facility’s safety consultant.

On July 22, 2011, we sent an interim letter containing sample 

results and additional recommendations to mitigate risk of 

Legionnaires’ disease to management of the shredding facility, their 

safety consultant, NYSDH, the county health department, and the 

OSHA regional office.

On September 23, 2011, we revisited the facility to conduct 
Page 10 Health Hazard Evaluation Report 2011-0109-3162

Background (continued)

a follow-up assessment to determine the effectiveness of any 

remediation work the company had undertaken following our site 

visit and issuing of recommendations. 

Process Description

This automobile and scrap metal shredding operation covers 

approximately 200,000 square feet with a mix of enclosed, 

canopied, and open space (Figures 1a-1b). Approximately 60 

workers are employed as yard men, drivers, shredder operators 

and laborers, eddy current workers, and office workers. Semitrailer trucks bring scrap metal in the form of cars (pre-crushed 

and drained of fluids), appliances, and other items to the facility 

from the company’s own scrap yards and a number of independent 

recycling operations. Trucks drive onto a scale embedded in the 

road for weighing, then the received material is either self-unloaded 

(dumped) or unloaded by mobile cranes fitted with grapples onto 

a large raw material pile (Figure 2). Cranes then place the material 

onto a conveyor belt that feeds the shredder. A large shredding 

machine (Figure 3) reduces the scrap metal into fist-sized pieces. An 

operator, stationed in a booth directly above the shredder (Figure 

4), controls the flow of material through the shredder and can raise 

and lower the gate that controls the amount of material being fed 

into the shredder. 

The shredder employs an electric motor to rotate a series of disks 

fitted with hammers inside a chamber (Figure 5). As the disk 

rotates, scrap is fed into the shredder where the hammers strike 

the material and fragment it into the smaller pieces. The shredded 

scrap then hits the walls of the shredder housing which contain a 

series of grates and passes through into the discharge unit (Figure 

6). The shredding chamber is cooled and lubricated with municipal 

water, which is pumped into the shredding chamber by lines 

fitted to either side of the shredder (Figure 7). While operating, 

the interior of the shredding chamber can reach 500 degrees 

Fahrenheit (°F), so much of the water evaporates immediately in 

a cloud of steam, but the shredded scrap remains wet after leaving 

the chamber. The scrap drops onto a conveyor and is diverted into 

ferrous and non-ferrous process streams via magnetic separators. 

In the ferrous stream, material is conveyed to a building called 

the “picking shed” (Figure 8), where approximately six to eight 

workers stand next to three conveyor lines to manually remove 
Health Hazard Evaluation Report 2011-0109-3162 Page 11

Background (continued)

(pick) contaminant materials including wiring, plastic, and copper 

“meatballs” (pieces of copper surrounded by ferrous metal), which 

were included with the ferrous stream. The non-ferrous picked 

material is dropped into hoppers for further processing. The 

meatballs are diverted to a separate pile to be sold for their copper 

content. Depending upon ambient temperature, it was reported to 

us that steam is sometimes observed above the moving conveyor. 

After passing through the picking shed, the ferrous material is 

moved by conveyor belts to the ferrous pile before being loaded 

and shipped offsite. 

The non-ferrous material, known as “fluff,” is conveyed to the 

non-ferrous shed for further separation via eddy currents and 

other separation technologies and then formed into piles to await 

shipment offsite. Some separation of materials by manual picking 

also takes place on the non-ferrous side of the facility. Fluff is a 

complex mixture of materials including non-ferrous metal, plastics, 

foam, textiles, rubber, and glass.

The facility has an underground drainage system to collect waste 

water from the shredding and sorting processes for contaminant 

removal at an onsite treatment plant. Surface water flows by 

gravity to a nearby drainage pond (Figure 9) or enters either of 

two grated drains located near the shredder and near the ferrous 

pile and flows into an underground holding tank. The tank stores 

the accumulated waste water until it reaches a predetermined 

level which activates a pump sending the water to the waste water 

treatment plant. After treatment, the water is piped to a local 

stream. 

Other buildings located on the grounds include a main office 

building, a maintenance garage, and an employee break room 

(Figures 1a-1b).

Legionnaires’ Disease

Legionnaires’ disease is a pneumonia (lung infection) caused by 

the bacterium Legionella which is commonly found in warm water 

environments and in some soils. Low natural concentrations 

are not generally associated with disease. The temperature range 

favorable for Legionella proliferation is 77°F–107.6°F (25°C–42°C) 

[ASHRAE 2000]. There are currently 54 identified species of 

Legionella [Euzeby 2012] and 70 serogroups [Fields et al. 2002]. 

Many Legionella species are known to cause health problems, 

with most human infections caused by Legionella pneumophila (L. 
Page 12 Health Hazard Evaluation Report 2011-0109-3162

Background (continued)

pneumophila) [Benin et al. 2002; Yu et al. 2009]; more than 80% of 

reported cases are caused by L. pneumophila serogroup 1 [Hilbi et 

al. 2010]. Other Legionella species [Muder and Yu 2002] known to 

cause human infections include: L. micdadei [Knirsch et al. 2000], 

L. feeleii [Sviri et al. 1997; Lee et al. 2009], L. bozemanii [Sobel et 

al. 1983; Yu et al. 2009], L. dumoffii [Yu et al. 2009], L. gormanii 

[Buchbinder et al. 2004], and L. longbeachae [Centers for Disease 

Control and Prevention (CDC) 2000; Whiley and Bentham 2011].

The symptoms of Legionnaires’ disease are similar to other forms 

of pneumonia, including high fever, chills, and cough. Some 

may also suffer from muscle aches, headaches, nausea, vomiting, 

and/or diarrhea [OSHA 2011]. Symptoms usually begin two to 

14 days after exposure to the bacteria. Pneumonia is confirmed 

either by chest x-ray or clinical diagnosis. Because the symptoms of 

Legionnaires’ disease are nonspecific, Legionnaires’ disease cannot 

be reliably distinguished from other forms of pneumonia on the 

basis of clinical presentation alone. Several laboratory tests (such as 

urine, sputum, and blood tests) can be used to detect the Legionella

bacteria within the body. A commonly used diagnostic test is the 

urinary antigen test which evaluates a urine sample for Legionella 

antigens (foreign substances that trigger an immune system 

response). If the patient has pneumonia and the urinary antigen 

test is positive, then the patient is considered to have Legionnaires’ 

disease [CDC 2011a]. However, the urinary antigen test only 

detects infections caused by L. pneumophila serogroup 1, but not 

other species or serogroups. Thus, the urinary antigen test does 

not permit matching with environmental samples collected during 

an outbreak investigation. In contrast, Legionella bacteria cultured 

from patient sputum samples can be compared to environmental 

isolates to more precisely document likely sources of exposure. 

Identification of Legionella infection in sputum is reduced when 

collection of biological samples is not performed prior to medical 

treatment. Blood specimens can also be used to confirm the 

diagnosis; a fourfold increase in antibody levels to Legionella

bacteria in blood drawn shortly after illness and several weeks 

following recovery also confirm the diagnosis of Legionnaires’ 

disease.

Outbreaks of Legionnaires’ disease have been linked to a variety 

of warm water systems or devices that produce aerosols, sprays, or 

mists, such as cooling towers [García-Fulgueiras et al. 2003; Nguyen 

et al. 2006], whirlpool spas [Den Boer et al. 2002], decorative 

fountains [Palmore et al. 2009], mist machines [O’Loughlin et al. 

2007], shower heads [Hanrahan et al. 1987; Darelid et al. 1994], 
Health Hazard Evaluation Report 2011-0109-3162 Page 13

Background (continued)

and industrial air scrubbers [Nygård et al. 2008]. Legionnaires’ 

disease caused by L. longbeachae has been associated with soil 

potting mixes and composts [Steele et al. 1990; Whiley and 

Bentham 2011]. However, L. pneumophila and other species have 

also been found in potting soil [Casati et al. 2009; Velonakis et al. 

2010] and compost [Casati et al. 2010].

Since Legionnaires’ disease is a type of pneumonia it can be very 

serious, causing death in 5% to 30% of people identified as having 

the disease [CDC 2011a]. Each year, between 8,000 and 18,000 

people in the United States are hospitalized with Legionnaires’ 

disease [CDC 2011a]. Personal risk factors include age (older 

persons at greater risk), cigarette smoking, chronic lung disease, 

immunosuppression, and certain other underlying conditions 

(e.g., end-stage renal disease, diabetes mellitus, or cancer) [Stout 

and Yu 1997; CDC 2004; CDC 2011a]. The Legionella bacteria 

enter the body when bacterially contaminated mist or vapor is 

inhaled. Legionnaires’ disease is not contagious, that is, not spread 

from one person to another [CDC 2011a]. Most infections can 

be treated successfully with antibiotics, and otherwise healthy 

individuals usually recover.

Legionella bacteria can also cause a milder infection called Pontiac 

fever. Pontiac fever is an influenza-like, self-limited illness. 

Symptoms may include fever, headaches, and muscle ache, last 

for two to five days, and usually resolve on their own [CDC 

2011a]. Thus, Pontiac fever often goes undiagnosed. Pontiac fever 

and Legionnaires’ disease may be referred to as “Legionellosis,” 

separately or together. Legionnaires’ disease and Pontiac fever are 

notifiable diseases. Healthcare providers and/or laboratories report 

cases of Legionnaires’ disease and Pontiac fever to state health 

departments, and state epidemiologists then report those cases and 

other nationally notifiable diseases to the CDC. 

During 2000-2009, the incidence of reported legionellosis in the 

United States nearly tripled from 0.39 per 100,000 persons to 1.15 

per 100,000 persons [CDC 2011b]. The reasons for the increase 

are unknown; however, increased case detection or reporting are 

possible reasons for the increase [CDC 2011b]. The reported cases 

of legionellosis are believed to be underestimated because some 

cases may have been treated empirically with antibiotics and/or 

did not require hospitalization. Also the nonspecific symptoms 

of Pontiac fever likely result in substantial underdiagnoses of this 

form of legionellosis [CDC 2011b].
Page 14 Health Hazard Evaluation Report 2011-0109-3162

Assessment

Initial site visit in June 2011

On June 1-2, 2011, NIOSH staff visited the facility. We initially 

met with the facility owner and his safety consultant to discuss 

the HHE request and our plans for the visit. NIOSH staff, the 

company’s safety consultant, and the facility process supervisory 

staff then visited each aspect of operations to learn about the work 

flow and processes. In the early afternoon, we met with staff from 

the county health department to discuss the cases of Legionnaires’ 

disease that had been identified among those who had worked at 

the facility and to obtain copies of medical records. The director 

and a public health engineer from a regional office of the NYSDH 

joined us at that meeting and also participated in the remainder of 

the walk-through later that afternoon. The facility safety consultant 

participated in the walk-through on both days. 

We spoke briefly and individually with all available facility 

employees, mostly production but some office/administrative 

workers, about Legionnaires’ disease and any current or previous 

symptoms they may have had. We distributed a NIOSH-prepared 

informational handout about the HHE at the shredding facility 

and Legionnaires’ disease to the workers and recommended that 

they retain the handout to give to their healthcare provider if they 

get sick. Additionally, we supplied workers with the county health 

department’s lists of healthcare providers, walk-in clinics, free 

clinics, and emergency departments in the area. 

During the two-day walk-through visit, we collected air, water, and 

swab samples at multiple locations around the facility (Figure 1a) to 

be tested for Legionella bacteria. We collected air samples by pulling 

air at a flow rate of 12.5 liters per minute for approximately 40 to 

50 minutes through an autoclaved all-glass impinger (AGI-30, Ace 

Glass Incorporated, Vineland, NJ) containing 20 milliliters (mL) 

of a 0.25% sterile yeast broth extract. The AGI-30 is a high-velocity 

impinger, with a stem located 30 millimeters from the bottom of 

the flask, that uses the principle of impingement and washing 

of air to trap organisms in a liquid medium [CDC 2005]. We 

collected samples of water in 50 mL polypropylene sterile plastic 

bottles. To take a swab sample, we rubbed a sterile cotton swab on 

a surface and then placed it in a sterile plastic bottle containing 

sterile distilled water. We did not measure the swabbed area or 

swab for a predetermined time. Onsite, we tested water samples 

for free chlorine content with a direct-reading digital colorimeter 

and for pH level with a swimming pool chlorine and pH test kit 

(Model 242-2, Poolmaster, Inc., Sacramento, CA). Free chlorine is 
Health Hazard Evaluation Report 2011-0109-3162 Page 15

Assessment (continued)

the chlorine that is not currently combined with contaminants in 

the water. There was no rainfall on the day before or during our 

two-day visit.

Air, water, and swab samples were analyzed for Legionella by the 

NYSDH Wadsworth Center Laboratory. The testing involved 

culture of Legionella on agar, deoxyribonucleic acid (DNA) 

fingerprinting by pulsed field gel electrophoresis, and real-time 

Legionella DNA polymerase chain reaction (PCR) analyses. Samples 

that have the same DNA fingerprinting pattern may have a 

common source. In a real-time PCR assay, a positive reaction is 

detected by accumulation of a fluorescent signal. For each sample, 

cycle threshold (Ct) value 1, Ct 2, and the average Ct value were 

reported. Ct is defined as the number of cycles required for 

the fluorescent signal to cross the PCR threshold (i.e., exceed 

background level). Ct levels are inversely proportional to the 

quantity of target nucleic acid in the sample [Wisconsin Veterinary 

Diagnostic Laboratory 2012]; the lower the Ct value, the greater 

the amount of target nucleic acid in the sample. Therefore, lower 

Ct values indicate higher numbers of Legionella bacteria present 

while higher Ct values indicate lower numbers of Legionella

bacteria. A difference of 3.3 Ct represents an approximate 10-fold 

change in concentration [Musser 2011]. A Ct value of 24 indicates 

approximately 200,000 bacteria/mL, while a Ct value of 33 

indicates approximately 200 bacteria/mL [Musser 2011]. 

Since this was a new occupational setting involving Legionella,

we attempted to gain additional perspective using a second 

analysis approach. Seven of the water samples were collected in 

duplicate. These samples were collected in 120 mL plastic bottles 

and sent to GTS Legionella Laboratory, a commercial laboratory 

in Gaithersburg, MD, to analyze using a direct fluorescent 

antibody (DFA) test. The DFA test uses antibodies tagged with 

fluorescent dye to detect the presence of Legionella. The laboratory 

concentrated the water samples 100-fold to yield a sensitivity of 

less than 10 colony forming unit (CFU)/mL [Gilpen 2011]. The 

laboratory uses a three-tiered risk approach. According to GTS, 

remedial action is generally not required for Legionella counts less 

than 20/mL; disinfection may be indicated (based on the location 

of the system and the type of employee population) for counts 

between 30/mL and 190/mL, and disinfection is recommended 

for counts between 200/mL and 1,000/mL or greater. GTS 

reported that when no Legionella is detected in a sample, this is 

equivalent to a culture test result of <1 CFU/mL if the culture 
Page 16 Health Hazard Evaluation Report 2011-0109-3162

Assessment (continued)

procedure is properly performed and validated by the DFA 

monoclonal antibody test [GTS 2010]. GTS generally handles 

samples that have been collected from cooling towers, evaporative 

condensers, and other warm water-containing mechanical systems 

connected to potable or non-potable water supplies. They were 

unsure how samples collected from standing pools of turbid water 

or swabs collected from conveyor belts would fare using their 

methods and asked that we only send them water samples relatively 

free of sediment.

As there were reports of unknown fluids draining from scrap 

automobiles and drums brought into the facility for processing 

and clouds of dust and smoke generated during the shredding 

process, we also collected area air samples at selected locations 

to be analyzed for metals using NIOSH method 7303 [NIOSH 

2003]. The samples were collected on 0.8 micrometer cellulose 

ester membrane filters at a flow rate of 2 liters per minute for 

approximately 200 to 300 minutes. We obtained additional area air 

samples for VOC screening (NIOSH method 2549) [NIOSH 2003] 

using thermal desorption tubes at a flow rate of 0.05 liters per 

minute for approximately 200 to 300 minutes; these were analyzed 

by thermal desorption-gas chromatography-mass spectrometry. We 

used a particulate monitor (pDR-1000AN personal DataRAM, 

Thermo Scientific Corp., Franklin, MA) to obtain real-time 

continuous levels of airborne dust, approximately respirable in 

size, as the instrument is optimized for detection of particles up 

to 10 micrometers. The results of the air sampling for metals and 

dust are time-weighted averages. We compared the results with 

applicable NIOSH RELs and OSHA PELs. The U.S. Department 

of Labor OSHA PELs (29 CFR 1910 [general industry]; 29 

CFR 1926 [construction industry]; and 29 CFR 1917 [maritime 

industry]) are legal limits enforceable in workplaces covered 

under the Occupational Safety and Health Act. NIOSH RELs are 

recommendations based on a critical review of the scientific and 

technical information available on a given hazard and the adequacy 

of methods to identify and control the hazard. NIOSH RELs can 

be found in the NIOSH Pocket Guide to Chemical Hazards [NIOSH 

2005].

At the end of the walk-through visit, we held a closing meeting 

with the owner and the facility safety consultant and discussed our 

preliminary findings and recommendations.
Health Hazard Evaluation Report 2011-0109-3162 Page 17

Assessment (continued) Follow-up site visit in September 2011

On September 23, 2011, we re-visited the shredding facility to 

conduct a follow-up assessment. The night before our visit, it had 

rained heavily. We collected water and swab samples at several 

locations that had been sampled during the first visit to be tested 

for Legionella bacteria: 1) four swab samples in sterile plastic bottles 

with 10 mL of sterile water added, and 2) nine water samples in 

duplicate. The samples were analyzed by the NYSDH Wadsworth 

Laboratory and GTS, as described above. For the follow-up site 

visit, GTS agreed to analyze swabs in addition to the water samples. 

For sediment-free water, GTS concentrated the water samples 

100-fold to yield a sensitivity of less than 10 CFU/mL. For water 

samples containing sediment (e.g., dirty water), the laboratory 

filtered and then concentrated the water to the lowest possible 

volume yielding varying sensitivities (e.g., less 20, 25, 30, or 50 

CFU/mL). Swab samples had the lowest sensitivity of less than 100 

CFU/mL [Gilpen 2011].

We also spoke informally with workers about the use of respirators 

and how to properly put on and take off their respirators. We 

placed NIOSH informational posters about respirator usage in 

the workers’ break room, mechanical room near the picking shed, 

and in the picking shed. We posted handouts in the workers’ 

break room informing workers that since 2009, five workers at the 

shredding facility had been diagnosed with Legionnaires’ disease. 

The handout also described Legionnaires’ disease, how workers 

could protect themselves from getting Legionnaires’ disease, and 

what to do if they felt sick. We left copies of the handout in the 

break room and with management. We also posted laminated 

hand-washing signs in the break room and restrooms and no 

smoking signs in the production area.

Results Summary of five workers with Legionnaires’ disease

The five cases were all male; their mean age was 26.8 years. All 

were production-area workers and performed picking activities 

and/or shoveling in or around standing water at the time they 

became ill. They were employed less than one month prior to 

developing symptoms. Symptom onset was in April, May and June 

for each of three, and November for the other two. Four smoked; 

the other was a past smoker who lived with a smoker. Four had 

been hospitalized; two had been in intensive care. There were no 

fatalities. In addition to smoking, two had comorbidities known 

to be risk factors for Legionnaires’ disease. All five cases were 
Page 18 Health Hazard Evaluation Report 2011-0109-3162

Results (continued)

diagnosed with urinary antigen testing for L. pneumophila serogroup 

1. Sputum was collected for culture for three of the cases; one 

culture was positive for L. pneumophila serogroup 1. In the other 

two cases, antibiotics had been started prior to the sputum 

collection, and the cultures were negative for Legionella growth.

Initial site visit - June 2011

Figure 1a shows the layout of the facility with sampling locations 

and results for Legionella. 

In June 2011, the facility employed 63 workers: 43 in production 

area jobs (crane operators, loaders, maintenance, inspector, 

shredder groundsman, shredder operators, and laborers), 10 

drivers, and 10 office and administrative staff. While at the facility, 

we spoke informally and individually with 41 employees and 

one contractor who was onsite that day, including all available 

production workers and some office workers. We determined that 

the drivers, who did not load or unload their trucks, were at little 

risk for exposure and did not speak with them. All production area 

workers were male. None of the employees with whom we spoke 

reported current symptoms consistent with Legionnaires’ disease. 

More than half reported being current smokers. We talked with 15 

workers who performed shoveling and/or picking activities. The 

laborers generally perform the picking and/or shoveling activities. 

Four laborers were not present on the day we talked with the 

workers.

Walk-through observations

We noted large quantities of standing water throughout the facility 

grounds (Figure 10). Workers frequently walked through the water. 

Debris and dirt would fall off moving conveyors. We observed 

workers shoveling this debris and dirt off the ground. The 

shoveling work often occurred in and around the standing water. 

We also observed workers using their shovels to scrape material out 

of the standing water.

Vehicles (e.g., sweeper, mobile cranes, front end loaders, Bobcats®) 

drove through the standing water resulting in splashing. We saw 

only one surface water drain in the pavement (Figure 11), between 

the shredder and the picking shed; it was dry while water pooled in 

the surrounding area. Employees reported that standing water was 

a problem and was not limited to after rainfall. 
Health Hazard Evaluation Report 2011-0109-3162 Page 19

Results (continued)

We observed dripping water from conveyors and occasional clouds 

of steam emitted from the shredder (Figure 12). The shredded 

material on the conveyors throughout the facility, including the 

picking shed, was dirty and very wet. We observed no respirator 

use. 

The workers’ break room and restroom area were orderly but very 

dusty and soiled. The shower stall in the restroom was used as a 

storage area; the shower head was missing. The break room is an 

allowed smoking area. Smoking is not allowed in the production 

areas.

Near the raw material shed, we observed a new larger shredder that 

was being prepared for installation in the near future (Figure 13). 

Based on the walk-through observations, we again recommended 

implementing a formal respiratory protection program that would 

require employees working around or near aerosols or mists to wear 

fit-tested N-95 respirators. We discussed the issue of standing water 

in various places at the facility, the possible presence of Legionella

in the standing water, and the potential for generation of aerosols 

during shoveling activities in the ferrous (near the picking shed) 

and non-ferrous sides of the plant and while driving or walking 

through puddled water. We reiterated that symptomatic employees 

should be evaluated by a healthcare provider for Legionnaires’ 

disease. We provided management with copies of the informational 

handout that we had given to the workers. We recommended that 

the workers’ break room and restroom be cleaned. 

Environmental results

Table 1 and Figure 1a summarize the June 2011 visit results of 

water, swab, and air samples analyzed for Legionella. Six water 

samples (C, L, N, O, P, Q) were tested using the DFA test, 

Legionella was detected in four samples. The highest levels of 

Legionella (L. pneumophila and other Legionella species) were detected 

in three areas: 1) the water drainage ditch on the south side of the 

grounds (sample P, Figure 14); 2) in a large collection of stagnant 

water near the picking shed by the final ferrous pile (sample Q, 

Figure 15); and 3) in water dripping from the conveyor at the exit 

of the shredder (sample L, Figure 16).

L. pneumophila was cultured from a swab sample taken from the 

conveyor belt in the picking shed (sample R, Figure 17a), from 
Page 20 Health Hazard Evaluation Report 2011-0109-3162

Results (continued)

water dripping from the shredder onto the conveyor belt (sample 

L); and in six puddles sampled. The puddles were located along 

the production process as follows: 1) by the raw feed pile (sample 

Y, Figure 18a); 2) under the shredder conveyor belt exit (sample 

M, Figure 16); 3) by the final ferrous pile near the picking shed 

(sample Q, Figure 15); 4) under a non-ferrous conveyor (sample 

U, Figure 19a); 5) near a non-ferrous conveyor (sample W, Figure 

19a); and 6) from water drainage (towards the drainage pond) on 

the south side of the grounds (sample P, Figure 9). The drainage 

pond itself did not have culturable Legionella; Legionella bacteria 

were detected by the DFA test noted above. L. pneumophila DNA 

was also detected in the pond (Table 1). L. feeleii was cultured from 

water dripping from a gap between a water supply pipe and the 

shredder (sample A). 

L. pneumophila serogroup 1 isolates that were detected in the 

puddle water under the shredder conveyor exit (sample M) and the 

puddle near the non-ferrous conveyor (sample W) had the same 

fingerprinting pattern (LpnS13169) and are thus considered to be 

related (Table 2). L. pneumophila serogroup 1 isolates detected in 

water from a puddle near the final ferrous pile (sample Q) and in 

water from the drainage ditch south of the shredder (sample P) 

had a different common pattern (LpnS13160); this same pattern 

was also found in a L. pneumophila serogroup 1 isolate detected 

in a sample of water dripping from the exit shredder conveyor 

belt collected in December 2010 by the NYSDH. This latter 

water sample also had a L. pneumophila serogroup 6 isolate with 

a fingerprinting pattern (LpnS13161) that matched one of two 

L. pneumophila serogroup 6 isolates detected in a swab sample 

taken from the exit shredder conveyor belt on the same day by 

the NYSDH. Samples L (L. pneumophila serogroups 1 and 6), R 

(L. pneumophila serogroup 6), U (L. pneumophila serogroup 1), and 

Y (L. pneumophila serogroup 1), and a second isolate in sample W 

(L. pneumophila serogroup 6) as well as two isolates (L. pneumophila

serogroup 1) from a sample of water collected by the NYSDH from 

a conveyor belt in May 2011 had unique fingerprinting patterns 

(Table 2). 

Using real-time PCR, L. pneumophila, L. feeleii, and other Legionella

species were detected in multiple air, swab, and water samples 

taken throughout the facility (Table 1, Figure 1). Five samples (O, 

P, Q, U, and W), all collected from standing water, had average 

Ct values that ranged from 24.78 to 28.52 which correlates to 

roughly 200,000 to 20,000 bacteria/mL. The rest of the samples 
Health Hazard Evaluation Report 2011-0109-3162 Page 21

Results (continued)

had average Ct values from 30.26 to 38.78 which would represent 

approximately 2,000 to virtually zero bacteria/mL.

Table 1 also includes values for pH and free chlorine concentration 

in water samples. The pH for all samples ranged from 7.4 to 7.8, 

indicating normal tap water levels. The water from the sink in the 

break room (sample N) and at the supply pipe for the shredder 

(samples A and C) had free chlorine concentrations that ranged 

from 0.58 to 0.77 parts per million (ppm). Water dripping from 

the outside of the shredder (sample L), the pond (sample O), and 

from puddles (samples P and Q) had free chlorine concentrations 

that ranged from 0 to 0.11 ppm. Most municipalities are required 

to keep chlorine concentration in drinking water between 

detectable and 4 ppm [EPA 2011].

Aluminum, barium, calcium, iron, magnesium, strontium, and 

zinc were detected in every air sample for metals (Table 3). Also, 

beryllium, cadmium, chromium, copper, lead, titanium, and 

vanadium were detected in some samples. All levels were well below 

the NIOSH RELs and OSHA PELs for those metals. 

Major compounds identified from the VOC screening of area air 

samples were toluene, ethyl benzene and xylene isomers, and some 

alkyl benzenes. Other compounds identified include isopentane, 

trichlorofluoromethane, and various hydrocarbons. Traces of 

dichloro- and trichlorobiphenyl isomers and a disulfide compound 

were identified on some samples. 

Dust measurements were collected over 200 to 300 minutes from 

six different locations: 1) outside grappler crane cab, 2) outside 

shredder operator’s booth, 3) near shredder discharge, 4) inside 

picking shed, 5) non-ferrous shed conveyor entry area, and 6) near 

the drainage pond upwind of the facility (data not shown). Timeweighted average levels ranged from 0.11 mg/m3

 to 0.33 mg/m3

at the non-ferrous shed, picking shed, and two shredder locations. 

A higher time-weighted average concentration of 0.83 mg/m3 was 

measured at the grappler crane as it loaded materials onto the 

shredder conveyor. The background sample taken at the upwind 

location measured 0.02 mg/m3. All samples were below the OSHA 

PEL of 5 mg/m3 for respirable particulate not otherwise regulated; 

NIOSH does not have an applicable REL. 

Follow-up after the initial site visit

On July 12, 2011, the NYSDH notified us that a fifth case of 
Page 22 Health Hazard Evaluation Report 2011-0109-3162

Results (continued)

Legionnaires’ disease had been diagnosed in a worker from the 

facility who had become symptomatic in mid-June 2011. 

On July 14, 2011, the safety consultant for the facility notified us 

that a respiratory protection program had been implemented at 

the facility around the end of June or first week of July 2011. He 

reported that employees working in the picking shed or shoveling 

under and near the picking shed were currently wearing N-95 

respirators. He was unsure if the workers had been qualitatively or 

quantitatively fit-tested; we recommended quantitative fit-testing, 

as it provides a more precise indicator of the tight fit necessary 

to reduce the potential for leakage of outside air around the edge 

of the mask. We emphasized to him that all workers exposed 

to water, including pools of water, dripping or splashing water, 

or wet materials, should wear fit-tested respirators, at least until 

engineering control measures were implemented and evaluated 

for efficacy. We also discussed the environmental sample results 

and the need to eliminate all standing pools of water by providing 

proper drainage. The safety consultant told us he would share our 

conversation with the owner.

In August 2011, staff from the local county health department 

visited the shredding facility. They observed large areas of standing 

water. The larger shredder had been installed. The owner of the 

shredding facility reported that he planned to adjust the drainage 

at the facility. The health department staff did not observe any 

manual shoveling during their visit. They noted that the break 

room was cleaner than it had been in the past. They observed 

workers wearing N-95 respirators, sometimes incorrectly. They 

also observed workers wearing dirty and soiled N-95 respirators. 

The county health department recommended giving each worker 

a picture instruction sheet on how to properly wear and check 

the fitness of their respirator, as well as posting signs instructing 

workers to change their respirators when they become soiled 

and dirty or hard to breathe through. They also recommended 

posting signs telling workers what to do if they felt sick. The health 

department offered to provide the signs. 

Second site visit - September 2011 

The plant manager reported that the shredder and picking room 

had been cleaned and sanitized as recommended in our interim 

letter; however, the rest of the equipment had not been cleaned or 
Health Hazard Evaluation Report 2011-0109-3162 Page 23

Results (continued)

sanitized. We discussed the importance of cleaning and sanitizing 

the entire facility and gave him a copy of our recommended 

cleaning and sanitizing procedure. While we were onsite, he 

contacted a company to schedule a time to have the entire plant 

cleaned and sanitized. After the site visit, the facility safety 

consultant notified us the cleaning and sanitizing of the facility had 

been completed during the last week of September.

Walk-through observations

The new larger shredder had been installed. The plant manager 

reported that the new shredder requires 40 gallons of water a 

minute for cooling and lubrication, compared to 80 gallons 

a minute for the old shredder. The scrap material handled by 

workers in the picking shed was much drier compared to the first 

visit (Figures 17a and b).

Dripping and standing water were much reduced (Figure 1b), even 

after the previous night’s heavy rainstorm. The facility grounds 

had been cleared of a build-up of fine debris, which uncovered 

a blocked drain (Figure 20) near the ferrous pile and improved 

drainage. A smaller pool of standing water remained under the 

shredder conveyor; we were told that a sump pump is used regularly 

to pump the water from the puddle into the drainage holding tank. 

There was also an area of standing water between the break room 

and the non-ferrous shed. No plans were in place to remove or 

prevent the build-up of water in this area. 

We observed workers who shoveled or worked in the picking shed 

wearing N-95 respirators. The plant manager reported that none 

of the workers had been fit-tested. Some workers were wearing 

their respirators incorrectly. In each of these cases, we showed 

the worker how to wear his respirator. We did not observe any 

hand-washing signs in the workers’ break room or restrooms, nonsmoking signs in the production area, or informational materials 

about respirators or Legionnaires’ disease. We posted 1) NIOSH 

posters on the break room wall, mechanical room door, and 

in the picking shed that showed how to put on and take off an 

N-95 respirator (Figure 21); 2) handouts on the break room wall 

describing Legionnaires’ disease and informing workers that since 

2009 five workers had been diagnosed with Legionnaires’ disease; 

3) laminated hand-washing signs on the break room and restroom 

walls; and 4) laminated no smoking signs in the production area. 

We left additional copies of the handouts in the break room and 

with management. 
Page 24 Health Hazard Evaluation Report 2011-0109-3162

Results (continued)

We talked with the plant manager about the importance of fittesting and informed him that this was a requirement of the 

OSHA Respiratory Protection Standard (29 CFR 1910.134). 

During our site visit, the plant manager scheduled quantitative fittesting for the following week. 

The production workers’ break room and restrooms were neater 

and cleaner compared to our first visit.

After the site visit, the facility safety consultant notified us that 

fit-testing had not been completed. He reported that workers 

are shown how put on and take off their respirators and how to 

conduct a positive and negative pressure user seal check each time 

they wear their respirators.

Environmental results

Figure 1b shows the layout of the facility with sampling locations 

and results for Legionella from the second site visit. Table 1 presents 

results of water and swab samples analyzed for Legionella.

Legionella was not detected in any water or swab samples using the 

DFA test; see Table 1 for the levels of detection.

L. pneumophila was detected by culture from six of the nine water 

samples including: 1) water dripping from shredder onto belt 

(sample L, figure 16); 2) the puddle under shredder conveyor belt 

exit (sample M, Figure 16); 3) the puddle near shredder conveyor 

belt exit (sample DD, Figure 16); 4) the puddle between the break 

room and the non-ferrous shed (sample CC, no photo taken); 5) 

the drainage ditch on the south side of the grounds (sample P, 

Figure 14); and 6) the pond (sample O, Figure 9). L. pneumophila

DNA was detected by PCR in water samples from all these sites, 

too, and in water dripping from a gap between the water supply 

pipe and the shredder (sample A). 

L. pneumophila was not detected by culture from the four swab 

samples taken. The sites swabbed were: 1) the shredder exit 

conveyor belt (sample K); 2) a conveyor belt in the picking shed 

(sample R); 3) the road sweeper nozzle (sample Z); and 4) sink 

faucet in the break room (sample N). L. pneumophila DNA was 

detected by PCR from swab samples taken from the road sweeper 

nozzle and the conveyor belt in the picking shed (Table 1). 

The six water samples (CC, DD, M, L, O, P) in which L. 
Health Hazard Evaluation Report 2011-0109-3162 Page 25

Results (continued)

pneumophila was detected by culture had average Ct values that 

ranged from 28.71 to 34.49 which represent approximately 20,000 

(under the shredder exit conveyor belt, sample M) to almost 

zero bacteria/mL (in water dripping from the shredder onto the 

conveyor belt, sample L). There were approximately 2,000 Legionella

bacteria/mL in the puddle near shredder exit conveyor belt (sample 

DD, Ct value 30.96) and in the drainage ditch south of the 

shredder (sample P, Ct 30.86). Sample A (water dripping from a 

gap between the water supply pipe and the shredder) did not grow 

Legionella; however, Legionella DNA was detected (Ct 35.61). The 

swab samples that tested positive for Legionella DNA (samples K, R, 

Z) had average Ct values that ranged from 35.29 to 36.33 (Table 1). 

The samples collected during the second visit had unique 

fingerprinting patterns, both among themselves and compared to 

those from our first site visit (Table 2) and the NYSDH visits. 

The pH for the water samples ranged from 6.0 to 7.0 (Table 1), 

in the range of normal tap water levels. The concentration of free 

chlorine was 0.47 ppm in water from the sink in the break room 

and 2.20 ppm in the road sweeper tank. The other water samples 

had free chlorine concentrations that ranged from 0 to 0.10 ppm.

Discussion Between January 2009 and July 2011, nine people had been 

diagnosed with Legionnaires’ disease in the county where the 

shredding facility is located; the county had a population of 51,125 

at the time of the 2010 census [U.S. Census Bureau 2012]. Five 

of those nine individuals worked at the shredding facility when 

they got sick, consistent with a disease cluster related to exposure 

at work. The purpose of this HHE was to verify that Legionella

bacteria were present at the facility, to determine the possible 

sources and/or primary locations, and to suggest remediation 

efforts to eliminate the problem.

All of the workers who were diagnosed with Legionnaires’ disease 

shoveled in or around the standing water and/or performed 

picking activities. The five cases occurred in a small subset of the 

workforce. Pickers and shovelers account for 30% of the current 

workforce. We were unable to enumerate the total number of 

pickers and shovelers who worked at the company in the 2009-

2011 period. Despite an uncertain denominator of pickers and 

shovelers at risk, the occurrence of all five cases in this subgroup 

of employees suggests that they had a disproportionate exposure to 
Page 26 Health Hazard Evaluation Report 2011-0109-3162

Discussion (continued)

Legionella contaminated aerosols. At this facility, the aerosolization 

of puddles contaminated with Legionella bacteria likely resulted 

in exposure to Legionella bacteria. During our first site visit, we 

observed splashing of surface water when materials were dropped 

into it and when workers shoveled in or around standing water. 

Aerosolization also occurred when cranes, front-end loaders, 

Bobcats®, and sweepers drove though puddles of water. We 

also observed water dripping from wet conveyor belts and from 

manually and mechanically lifted wet materials.

We identified L. pneumophila serogroup 1 and other Legionella 

bacteria in multiple areas around the plant. Except for supply water 

in the break room and to the shredder and the water in the tank of 

the road sweeper, we identified Legionella bacteria by culture (which 

grows the Legionella bacteria), PCR (which detects Legionella DNA), 

or DFA (which detects Legionella bacteria with an antibody tagged 

with a fluorescent dye) in all the environmental samples collected 

during the our first site visit (Table 1). Some samples had higher 

quantities of Legionella bacteria than others. Based on samples that 

had a PCR Ct value below 28.53 or a DFA test Legionella count of 

200/mL or greater, six samples collected during our first visit had 

more Legionella bacteria compared to the others: 

1. water dripping from the shredder onto the exit conveyor belt 

(sample L, L. pneumophila serogroups 1 and 6) 

2. standing water near the ferrous pile by the picking shed 

(sample Q, L. pneumophila serogroup 1) 

3. standing water near a non-ferrous conveyor 

(sample W, L. pneumophila serogroups 1 and 6)

4. standing water under a non-ferrous conveyor 

(sample U, L. pneumophila serogroup 1) 

5. drainage area with standing water south of the shredder 

(sample P, L. pneumophila serogroup 1) 

6. drainage pond (sample O, no culture growth) 

A limitation of PCR and the DFA test is that they cannot 

differentiate between living and dead organisms and may give false 

negative results [Hung et al. 2005]. Of the six samples noted above, 

the first five samples (L, Q, W, U, and P) had positive Legionella 

cultures, showing the presence of living bacteria. Four additional 

samples during our first visit also had positive Legionella cultures: 
Health Hazard Evaluation Report 2011-0109-3162 Page 27

Discussion (continued)

1. standing water by the raw feed pile 

(sample Y, L. pneumophila serogroup 1) 

2. water dripping from gap between 

water supply pipe and shredder 

(sample A, L. feeleii ) 

3. standing water under the shredder conveyor belt exit 

(sample M, L. pneumophila serogroup 1) 

4. conveyor belt in the picking shed 

(sample R, L. pneumophila serogroup 6) 

The laboratory results showed the absence or presence of 

Legionella growth, the Legionella species, as well as serogroup 1 or 

6 for L. pneumophila. However, the test results did not show the 

concentration or quantity of bacteria that was cultured, so we were 

unable to evaluate the potential amplification of Legionella in the 

samples. Samples M and W had the same DNA fingerprinting 

pattern for L. pneumophila serogroup 1, suggesting a common 

source; similarly, samples P and Q and a sample collected 

previously by the NYSDH had different identical fingerprinting 

patterns. All other samples had unique patterns, suggesting 

multiple sources of Legionella. 

During our first visit in June 2011, the drainage system was 

inadequate, as could be seen by the numerous pools of standing 

water and wet dirt on the asphalt and concrete areas throughout 

the facility. During our second visit, there was significantly less 

water on the ground, and most of the dirt had been removed 

(Figures 22 to 24). Also a larger shredder had been installed that 

used less water, resulting in less water dripping onto the ground 

during the shredding process. However, some standing water 

still existed. Legionella was cultured from four puddles (samples 

CC, DD, M, and P), the drainage pond (sample O), as well as 

from water dripping from the shredder onto the conveyor belt 

(sample L). As before, we could not determine the concentration 

or quantity of Legionella bacteria that was cultured; however, 

the PCR average Ct values in the water samples with Legionella 

growth for the second visit ranged from 28.71 to 34.49 indicating 

approximately 20,000 Legionella bacteria/mL (in the puddle under 

the shredder exit conveyor belt) to almost zero Legionella bacteria/

mL (in water dripping from the shredder onto the conveyor 

belt). The DFA test was below the limit of detection for all the 

samples; however, the sensitivity varied among the samples. For 

sediment-free water, GTS concentrated the water samples 100-fold 
Page 28 Health Hazard Evaluation Report 2011-0109-3162

Discussion (continued)

to yield a sensitivity of less than 10 CFU/mL. For water samples 

containing sediment (e.g., dirty water), the laboratory filtered, 

then concentrated the water to the lowest possible volume yielding 

varying sensitivities (e.g., less 20, 25, 30, or 50 CFU/mL). Swab 

samples had the lowest sensitivity of less than 100 CFU/mL 

[Gilpen 2011]. The fingerprinting patterns were different than 

the patterns identified during our first visit and from the NYSDH 

samples, indicating various sources of Legionella bacteria. 

We do not believe the shredder was a source of Legionella. In the 

shredder itself, low concentrations of Legionella DNA were detected 

in samples taken during our first visits; however, Legionella was not 

cultured from these samples. The high temperatures inside the 

shredder during operation are not conducive to the growth of the 

bacteria. The interior of the shredding chamber can reach 500°F, 

and most of the water evaporates during the shredding operation 

and produces a plume of steam above and around the shredder. 

Although a large portion of the standing water has been removed, 

the rest of the standing water needs to be removed to reduce the 

potential for exposure to Legionella. Standing water when heated 

by sunlight is an ideal environment for Legionella growth [OSHA 

1999]. L. pneumophila has been isolated in puddles of rainwater 

on asphalt roads, especially during warm weather [Sakamoto et al. 

2009]. When standing water at the shredding facility is disturbed, 

workers are at risk for exposure to Legionella bacteria. The free 

chlorine content of the water from puddles was low relative to 

the water entering the shredder. Free chlorine is the chlorine 

that is not currently combined with contaminants in the water. 

In other words, it is not occupied and still available (measurable) 

in the water. The relatively low free chlorine measured in the 

puddles could be attributed to the proportion of the puddles from 

rainwater (and thus absent of chlorine) and/or water from the 

shredding operation which may have lost available free chlorine 

due to interaction with oil, dirt, debris, and heat. 

Because standing water still exists and there is potential for 

aerosolization of water contaminated with Legionella bacteria, 

we recommend that workers who perform picking operations or 

shoveling in or around standing water, as well as any other workers 

exposed to pools of water, dripping or splashing water, or wet 

materials wear fit-tested N-95 respirators. In addition to removing 

the standing water and wearing respirators, we also recommend 

that the equipment at the facility be cleaned and sanitized twice 

a year. This is necessary to remove any biofilm (containing
Health Hazard Evaluation Report 2011-0109-3162 Page 29

Discussion (continued)

Legionella bacteria) on the equipment. In cooling towers, traditional 

oxidizing agents such as chlorine and bromine have proven 

effective in controlling Legionella [OSHA 1999; ASHRAE 2000]. 

At this facility, we recommended in our interim letter a mixture 

of regular unscented household bleach (5.25% chlorine as 

sodium hypochlorite) with water at a concentration of 65 to 200 

ppm (see recommendations below) for the sanitization process. 

Because chlorine loses its effectiveness quickly in the presence of 

oil, dirt, and organic material [OSHA 1999], we recommended 

a cleaning step with a detergent solution to remove excess dirt 

before the sanitizing treatment (with the bleach solution). 

Scrubbing is necessary during the cleaning step to remove any 

biofilm containing Legionella bacteria. Periodic cleaning and 

sanitizing of the equipment will likely be necessary to reduce the 

nutrients available for Legionella regrowth. Because aerosols may be 

generated during the cleaning and sanitizing process, respiratory 

protection for workers engaged in cleaning is critical to preventing 

legionellosis.

All dust concentrations were below the OSHA PEL of 5 mg/m3 for 

respirable particulate not otherwise regulated. Although NIOSH 

does not have a REL for respirable particulate matter to compare 

with, all samples for metals in the dust were found to be below 

both NIOSH and OSHA guidelines. The samples collected on the 

first site visit for a VOC screening detected toluene (a common 

solvent), ethyl benzene (a paint ingredient), trichlorofluoromethane 

(refrigerant), and a variety of other solvents and chemical 

components of materials used in the manufacturing of automobiles 

and appliances. Detection of these VOCs by the highly sensitive 

analytical method indicates presence of the compounds but cannot 

indicate levels of actual exposure. 

Conclusions Legionnaires’ disease is generally considered to be preventable 

because controlling or eliminating the bacterium in certain 

reservoirs will prevent cases of the disease. No new cases of 

Legionnaires’ disease have been identified in workers from this 

facility since standing water was reduced, equipment was cleaned 

and sanitized, and respiratory protection was implemented. 

In this type of industrial setting, standing water can be aerosolized, 

resulting in potential exposure to Legionella bacteria. Legionnaires’ 

disease should be considered when persons who work in industrial 

settings around standing water with potential for aerosolization 

present with an acute febrile respiratory illness with systemic 

symptoms. 
Page 30 Health Hazard Evaluation Report 2011-0109-3162

Based on our findings, we recommend the following actions to 

create a more healthful workplace. We encourage you to use these 

recommendations to develop an action plan based, if possible, on 

the “hierarchy of control” approach. This approach groups actions 

by their likely effectiveness in reducing or removing hazards. In 

most cases, the preferred approach is to first eliminate hazardous 

materials or processes and, secondly, to install engineering controls 

to reduce exposure or shield employees. Until such controls are 

in place, or if they are not effective or feasible, administrative 

measures and/or personal protective equipment may be needed. 

Eliminating hazards

1. Continue to maintain the outdoor ground surface area 

of the facility so the surface water drainage system can 

eliminate all stagnant/standing pools of water. 

2. Fill in the depression under the shredder (Figure 16) so 

water will flow to the drainage grate rather than using a 

sump pump to remove the water. This would be a more 

permanent solution and would prevent the accumulation of 

water in this area. Until then, ensure that the sump pump is 

used under a rigidly enforced daily schedule.

3. Improve drainage to prevent pooling of water in the area 

between the non-ferrous building and the break room to 

improve drainage. 

4. Continue to maintain the integrity of the drainage system to 

assist in the elimination of run-off water. 

Engineering controls and work practices 

5. Minimize shoveling activities in puddles of water as much as 

possible. 

6. Twice a year, wash and sanitize the shredder, conveyor 

systems, and mobile equipment.

a). Scrub the equipment with brushes and a 

detergent solution. 

b). Rinse off the equipment with water to remove 

the detergent and any oil, dirt, and debris. Avoid 

the used of high-pressure power washers or other 

cleaning equipment that create aerosols. 

Recommendations
Health Hazard Evaluation Report 2011-0109-3162 Page 31

Recommendations

(continued) c). Mix regular unscented household bleach (5.25% 

chlorine as sodium hypochlorite) with water at a 

concentration of 65 to 200 ppm. 

Amount of 5.25% sodium 

hypochlorite bleach Amount of water Concentration of bleach solution

One teaspoon One gallon 65 ppm

One tablespoon One gallon 200 ppm

d). Put the bleach and water solution into 

a container and spray the solution onto the 

equipment surfaces and allow the solution to sit on 

the equipment for approximately 10-20 minutes. 

Prior to this step, check with the manufacturers of 

your equipment to determine if a bleach solution* 

would damage the equipment.

*The recommended pH level for an effective and safe sanitizing solution is 

6.5 to 7.5. Solutions with pH greater than 8 lose their sanitizing effectiveness, 

while solutions with a pH lower than 6 are more corrosive and may potentially 

damage equipment. Potentially harmful levels of chlorine gas may be generated 

if the pH of the solution is lower than 5 [McGlynn 2004]. Never mix bleach or 

bleach-containing products with ammonia or ammonia-containing products.

 

e). Scrub the equipment surfaces with brushes. 

f ). Rinse off the equipment with water to remove 

the bleach solution.

7. Avoid the release of highly chlorinated water into the 

drainage pond and stream as this could be a violation of 

environmental standards because of its detrimental effects 

to living organisms. 

8. Personnel cleaning and sanitizing the equipment should 

be trained in the cleaning/sanitizing procedure and wear 

personal protective equipment: 

a). Eye protection (goggles or a full-face respirator)

b). Gloves (natural rubber, neoprene, nitrile, 

polyvinyl chloride, or polyurethane) 

c). Respirator with a high-efficiency particulate air 

filter and chemical cartridge 

9. Perform environmental sampling for Legionella if another 

case of legionellosis is identified. 

10.Regularly clean the workers’ break room and restroom. 
Page 32 Health Hazard Evaluation Report 2011-0109-3162

Recommendations

(continued) Respiratory Protection

11. Require mandatory use of respirators (at least at the N-95 

level of protection) for workers who perform picking 

operations or shoveling in or around standing water, as well 

as for any other workers who may be exposed to pools of 

water, dripping or splashing water, or wet materials. Workers 

should also wear respiratory protection when dredging or 

emptying the drainage pond. 

12.Ensure workers wear fit-tested respirators (after they 

have been medically cleared). Appendix A of the OSHA 

respiratory protection standard details the mandatory fit-test 

protocols (found in appendix A of this report). Qualitative 

fit-testing may be used for negative-pressure air-purifying 

respirators, which must achieve a fit factor of 100 or less 

(such as the N-95 respirators which have a fit factor of 

10). In contrast, quantitative fit-testing is an appropriate 

approach for all classes of respirators. For tight-fitting 

respirators (such as an N-95 respirator) also ensure that 

workers perform a “user seal check” (positive and negative 

pressure checks) each time they wear their respirator. 

The procedure is outlined in appendix B1 of the OSHA 

respiratory protection standard (found in appendix B of this 

report). 

13.Workers should change their N-95 respirator when it 

becomes dirty or hard to breathe through.

14. Develop a respiratory protection program. The OSHA 

respiratory protection program includes the following 

elements: 

a). Written policy.

b). Change-out schedule for cartridges/filters. 

c). Medical evaluation prior to use to determine 

fitness.

d). Fit-testing and training prior to use and annually.

e). Establishment and implementation of procedures 

for proper respirator use, such as: prohibiting use 

with facial hair when this would impair the seal; 

ensuring user seal-check and inspection of respirators 

prior to each use; ensuring proper cleaning, 

disinfection, and maintenance of respirators; and 

ensuring proper storage of respirators to protect 

respirators from damage, contamination, dust, 

sunlight, and extreme temperatures. 
Health Hazard Evaluation Report 2011-0109-3162 Page 33

Recommendations

(continued) Details about the OSHA Respiratory Protection Standard (29 CFR 

1910.134) are available at http://www.osha.gov/pls/oshaweb/

owadisp.show_document?p_table=STANDARDS&p_id=12716

Information about respirators can be found on the NIOSH website 

at http://www.cdc.gov/niosh/topics/respirators/

Hazard Communication

15.Ensure that workers understand the hazards associated 

with working at the shredding facility and how to protect 

themselves. OSHA’s Hazard Communication Standard 

(29 CFR 1910.1200), also known as the “Right to Know 

Law,” requires that employees are informed and trained 

about potential work hazards and associated safe practices, 

procedures, and protective measures. In your facility, 

workers should understand the symptoms and potential 

seriousness of Legionnaires’ disease and the importance of 

seeking appropriate medical attention when ill, including 

informing their healthcare provider of the legionellosis risk.

Medical surveillance

16. Workers should report respiratory or flu-like symptoms to 

their personal healthcare provider and, as instructed by their 

employer, to a designated individual at your workplace. 

17. Workers with respiratory or flu-like symptoms should 

be evaluated by a healthcare providers for possible 

Legionnaires’ disease. Signs of Legionnaires’ disease can 

include a high fever, chills, and a cough. Some people 

may also suffer from muscle aches and headaches. Nausea, 

vomiting, and diarrhea may also occur.

18. Do not smoke or eat in the plant production areas. Always 

wash hands before eating or smoking. Smoking causes 

many diseases and reduces the health of smokers in general, 

and smoking itself increases the chances that a person will 

develop Legionnaires’ disease if that person is exposed to

Legionella bacteria. We recommend implementing a smoking 

cessation program to assist employees to stop smoking. 
Page 34 Health Hazard Evaluation Report 2011-0109-3162

American Society of Heating, Refrigeration and Air-conditioning Engineers (ASHRAE) [2000]. ASHRAE 

guideline 12-2000, Minimizing the risk of legionellosis associated with building water systems. 

Benin AL, Benson RF, Besser RE [2002]. Trends in legionnaires’ disease, 1980-1998: declining mortality 

and new patterns of diagnosis. Clin Infect Dis. 35(9):1039-46. 

Buchbinder S, Leitritz L, Trebesius K, Banas B, Heesemann J [2004]. Mixed lung infection by Legionella 

pneumophila and Legionella gormanii detected by fluorescent in situ hybridization. Infection. 32:242-5.

Casati S, Gioria-Martinoni A, Gaia V [2009]. Commercial potting soils as an alternative infection source 

of Legionella pneumophila and Legionella species in Switzerland. Clin Microbiol Infect. 15:571–5.

Casati S, Conza L, Bruin J, Gaia V [2010]. Compost facilities as a reservoir of Legionella pneumophila and 

other Legionella species. Clin Microbiol Infect. 16:945-7.

Centers for Disease Control and Prevention (CDC) [2000]. Legionnaires’ disease associated with potting 

soil--California, Oregon, and Washington, May-June 2000. MMWR Morb Mortal Wkly Rep. Sep 

1;49(34):777-8.

CDC [2004]. Guidelines for preventing health-care--associated pneumonia, 2003: recommendations of 

CDC and the healthcare infection control practices advisory committee. MMWR Morb Mortal Wkly Rep.

53(No. RR-3). 

CDC [2005]. Procedures for the recovery of Legionella from the environment. Atlanta GA: U.S. 

Department of Health and Human Services, Centers for Disease Control and Prevention. http://www.

cdc.gov/legionella/files/legionellaprocedures-508.pdf.

CDC [2011a]. Patient facts: learn more about Legionnaires’ disease. Legionellosis Resource Site 

(Legionnaires’ Disease and Pontiac Fever). http://www.cdc.gov/legionella/patient_facts.htm. Date 

accessed: August 2012.

CDC [2011b]. Legionellosis — United States, 2000-2009. MMWR Morb Mortal Wkly Rep. Aug 

19;60(32):1083-6.

CFR. Code of Federal Regulations. Washington, DC: U.S. Government Printing Office, Office of the 

Federal Register.

Darelid J, Bengtsson L, Gästrin B, Hallander H, Löfgren S, Malmvall BE, Olinder-Nielsen AM, Thelin AC

[1994]. An outbreak of Legionnaires’ disease in a Swedish hospital. Scand J Infect Dis. 26:417-25.

References
Health Hazard Evaluation Report 2011-0109-3162 Page 35

References (continued)

Den Boer JW, Yzerman EP, Schellekens J, Lettinga KD, Boshuizen HC, Van Steenbergen JE, Bosman A, 

Van den Hof S, Van Vliet HA, Peeters MF, Van Ketel RJ, Speelman P, Kool JL, Conyn-Van Spaendonck 

MA [2002]. A large outbreak of Legionnaires’ disease at a flower show, the Netherlands, 1999. Emerg 

Infect Dis. 8:37-43.

Environmental Protection Agency (EPA) [2011]. Basic information about disinfectants in drinking water: 

chloramine, chlorine and chlorine dioxide. http://water.epa.gov/drink/contaminants/basicinformation/

disinfectants.cfm. Date accessed: August 2012.

Euzeby JP. List of prokaryotic names with standing in nomenclature—genus Legionella. http://www.

bacterio.cict.fr/l/legionella.html. Date accessed: August 2012.

Fields BS, Benson RF, Besser RE [2002]. Legionella and Legionnaires’ disease: 25 years of investigation. 

Clin Microbiol Rev. 15:506–26. 

García-Fulgueiras A, Navarro C, Fenoll D, García J, González-Diego P, Jiménez-Buñuales T, Rodriguez M, 

Lopez R, Pacheco F, Ruiz J, Segovia M, Balandrón B, Pelaz C [2003]. Legionnaires’ disease outbreak in 

Murcia, Spain. Emerg Infect Dis. 9:915–21. 

Gilpen, R. (gilpen@legionella.com) [2011]. Sampling sensitivity. E-mail message to Randy Boylstein (zig1@

cdc.gov), October 3.

GTS Legionella Laboratory [2010]. Laboratory Test Request and Information. http://www.legionella.com/

index.html. Date accessed: August 2012. 

Hanrahan JP, Morse DL, Scharf VB, Debbie JG, Schmid GP, McKinney RM, Shayegani M [1987]. A 

community hospital outbreak of legionellosis. Transmission by potable hot water. Am J Epidemiol.

125:639-49.

Hilbi H, Jarraud S, Hartland E, Buchrieser C [2010]. Update on Legionnaires’ disease: pathogenesis, 

epidemiology, detection and control. Mol Microbiol. 76:1-11. 

Hung LL, Miller JD, Dillon HK, eds. [2005]. Field guide for the determination of biological contaminants 

in environmental samples. 2nd ed. Fairfax, VA: American Industrial Hygiene Association, pp. 129–40. 

Knirsch CA, Jakob K, Schoonmaker D, Kiehlbauch JA, Wong SJ, Della-Latta P, Whittier S, Layton 

M, Scully B [2000]. An outbreak of Legionella micdadei pneumonia in transplant patients: evaluation, 

molecular epidemiology, and control. Am J Med. 108:290–295.

Lee J, Caplivski D, Wu M, Huprikar S [2009]. Pneumonia due to Legionella feeleii: case report and review 

of the literature. Transpl Infect Dis. 11:337–40. 
Page 36 Health Hazard Evaluation Report 2011-0109-3162

References (continued)

McGlynn W [2004]. Guidelines for the use of chlorine bleach as a sanitizer in food processing operations. 

Oklahoma Cooperative Extension Service, Division of Agricultural Science and Natural Resources. 

http://pods.dasnr.okstate.edu/docushare/dsweb/Get/Document-963/FAPC-116web.pdf. Date accessed: 

August 2012.

Muder RR, Yu VL [2002]. Infection due to Legionella species other an L. pneumophila. Clin Infect Dis. 

35:990-8.

Musser K (musser@wadsworth.org) [2011]. PCR Ct values. E-mail message to Randy Boylstein (zig1@cdc.

gov), July 14.

National Institute for Occupational Safety and Health (NIOSH) [2003]. In: Schlecht P, O’Connor P, eds. 

Manual of Analytical Methods (NMAM), 4th ed., Third Supplement. Cincinnati, OH: U.S. Department 

of Health and Human Services, DHHS (NIOSH) Publication No. 2003-154. http://www.cdc.gov/niosh/

docs/2003-154/method-i.html.

NIOSH [2005]. NIOSH pocket guide to chemical hazards. Cincinnati, OH: U.S. Department of Health 

and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational 

Safety and Health, DHHS (NIOSH) Publication No. 2005-149. http://www.cdc.gov/niosh/npg/. Date 

accessed: August 2012.

Nygård K, Werner-Johansen O, Ronsen S, Caugant DA, Simonsen O, Kanestrom A, Ask E, Ringstad J, 

Ødegård R, Jensen T, Krogh T, Høiby EA, Ragnhildstveit E, Aaberge IS, Aavitsland P [2008]. An outbreak 

of Legionnaires’ disease caused by long-distance spread from an industrial air scrubber in Sarpsborg, 

Norway. Clin Infect Dis. 46:61–9. 

Nguyen TM, Ilef D, Jarraud S, Rouil L, Campese C, Che D, Haeghebaert S, Ganiayre F, Marcel F, Etienne 

J, Desenclos JC [2006]. A community-wide outbreak of Legionnaires disease linked to industrial cooling 

towers--how far can contaminated aerosols spread? J Infect Dis. 193:102-11. 

O’Loughlin RE, Kightlinger L, Werpy MC, Brown E, Stevens V, Hepper C, Keane T, Benson RF, Fields 

BS, Moore MR [2007]. Restaurant outbreak of Legionnaires’ disease associated with a decorative fountain: 

an environmental and case–control study. BMC Infect Dis. 7:93. 

Occupational Safety and Health Administration (OSHA) [1999]. Legionnaires’ disease. In: 

OSHA technical manual. Washington, DC: U.S. Department of Labor, Occupational Safety and Health 

Administration, DOL (OSHA) Directive TED 01-00-015 [TED 1-0.15A]. http://www.osha.gov/dts/osta/

otm/otm_iii/otm_iii_7.html. Date accessed: August 2012.

Occupational Safety and Health Administration (OSHA) [2011]. Section I: what is Legionnaires’ disease? 

eTools Home: Legionnaires’ Disease. http://www.osha.gov/dts/osta/otm/legionnaires/disease_rec.

html#Causative. Date accessed: August 2012.
Health Hazard Evaluation Report 2011-0109-3162 Page 37

References (continued)

Palmore TN, Stock F, White M, Bordner M, Michelin A, Bennett JE, Murray PR, Henderson DK [2009]. 

A cluster of cases of nosocomial Legionnaires’ disease linked to a contaminated hospital decorative water 

fountain. Infect Control Hosp Epidemiol. 30:764-8.

Sakamoto R, Ohno A, Nakahara T, Satomura K, Iwanaga S, Kouyama Y, Kura F, Kato N, Matsubayashi 

K, Okumiya K, Yamaguchi K [2009]. Legionella pneumophila in rainwater on roads. Emerg Infect Dis.

15:1295-7.

Sobel JD, Krieger R, Gilpin R, Griska L, Agarwal P [1983]. Legionella bozemanii. Still another cause of 

pneumonia. 250:383-5.

Steele TW, Lanser J, Sangster N [1990]. Isolation of Legionella longbeachae serogroup 1 from potting mixes. 

Appl Environ Microbiol. 56:49–53.

Stout JE, Yu VL [1997]. Legionellosis. N Engl J Med. 337:682–7.

Sviri S, Raveh D, Boldur I, Safadi R, Libson E, Ben-Yehuda A [1997]. Legionella feeleii pneumonia and 

pericarditis. J Infect. 34:277-9.

U.S. Census Bureau [2012]. State and county quickfacts. http://quickfacts.census.gov/qfd/states/. Date 

accessed: August 2012.

Velonakis EN, Kiousi IM, Koutis C, Papadogiannakis E, Babatsikou F, Vatopoulos A [2010]. First isolation 

of Legionella species, including L. pneumophila serogroup 1, in Greek potting soils: possible importance for 

public health. Clin Microbiol Infect. 16:763-6. 

Wisconsin Veterinary Diagnostic Laboratory [2012]. Real Time PCR Ct Values. http://www.wvdl.wisc.

edu/PDF/WVDL.Info.PCR_Ct_Values.pdf. Date accessed: August 2012.

Whiley H, Bentham R [2011]. Legionella longbeachae and legionellosis. Emerg Infect Dis. 17:579-83.

Yu H, Higa F, Koide M, Haranaga S, Yara S, Tateyama M, Li H, Fujita J [2009]. Lung abscess caused by 

Legionella species: implication of the immune status of hosts. Intern Med. 48:1997-2002. 
Page 38 Health Hazard Evaluation Report 2011-0109-3162 TABLES

Table 1. Results of air, water, and swab samples collected for Legionella analyses by culture, real-time polymerase chain reaction (PCR) and direct fluorescent antibody (DFA) test at a shredding facility, New York, June and September 2011Sample type Sample

ID*

Location Sub-location

Culture†

L. 

pneumophila 

with

Serogroup 

identification

PCR‡

L. species

 DNA

PCR‡

L. pneum.

DNA

PCR‡

L. feeleii

DNA

DFA§

L.

species

DFA§

L. 

pneum

Water 

sample

pH

Water 

sample

Free 

chlorine 

(ppm)¶

 First site visit (June 1-2, 2011)Air A-01 Shredder Upper level – – + – . . . .

A-02 Shredder Pin puller – – + – . . . .A-03 Non-ferrous Central – – + – . . . .A-04 Non-ferrous-Under corner Near conveyor – – + – . . . .A-05 Picking shed (outside) Under stairs, near monitor screen – – + – . . . .A-06 Picking shed (inside) On wall, middle area, next to door – – + – . . . .A-07 Blank Blank – – – – . . . .

Swab B Shredder-Inside Water nozzle, north side – – + – . . . .

C Shredder-Inside Water nozzle, south side – – + – . . . .D Shredder-Inside Upper portion, east side – – + – . . . .E Shredder-Inside Lower ledge, east side – – + – . . . .F Shredder-Inside Above feed roll, west side – + – – . . . .G Shredder-Inside Feed roll, west side – + – – . . . .H Shredder-Inside Chute, west side – + – – . . . .I Shredder-Inside Base of lift piston, south side – – + – . . . .J Shredder-Exit conveyor North side – – + – . . . .K Shredder-Exit conveyor South side – + – – . . . .N Break room Sink faucet – – – – . . . .R Picking shed-Conveyor Conveyor belt 6 inc @ inc.@ – . . . .S Drain Fluff pile – – + – . . . .T Non-ferrous-Conveyor Conveyor belt – – + – . . . .V Non-ferrous Conveyor Conveyor belt – + – – . . . .X Eddy current-Conveyor Conveyor belt – + – – . . . .Z Road sweeper Nozzle – – + – . . . .Blank Distilled water Distilled water for swabs – – – – . . . .

Water A Shredder-Outside Water dripping from gap between water supply pipe and shredder Feeleii ** + – + . . 7.6 0.65

C Shredder-Inside Water nozzle, south side – – – – <10 <10 7.6 0.58
Health Hazard Evaluation Report 2011-0109-3162 Page 39 Tables (continued) Sample type Sample ID* Location Sub-location Culture† L. pneumophila with Serogroup identification PCR‡ L. species DNA PCR‡ L. pneum. DNA PCR‡ L. feeleii DNA DFA§ L. species DFA § L. pneum Water sample pH Water sample Free chlorine (ppm)¶ L Shredder-Exit conveyor Dripping from shredder onto belt 1,6 – + – 400 200 7.6 0 M Puddle Under shredder conveyor belt exit 1 – + – . . . . N Break room Sink faucet – – – – 10 <10 . 0.77 O Pond Pond – – ++ – 60 80 7.4 0.01 P Puddle Drainage ditch south of shredder 1 – ++ – 600 800 7.8 0.04 Q Puddle Ferrous pile 1 – ++ – 400 600 7.8 0.11 U Puddle Under non-ferrous conveyor 1 – ++ – . . . . W Puddle Near non-ferrous conveyor 1,6 – ++ – . . . . Y Puddle Raw feed pile 1 – + – . . . . Second site visit (September 23, 2011) Water BB Road sweeper Tank – – – – <10 <10 7.0 2.20 N Break room Sink faucet – – – – <10 <10 6.5 0.47 CC Puddle Between non-ferrous shed and breakroom 3 – + – <30 <30 7.0 0.10 DD Puddle Near shredder conveyor belt exit 1 – + – <50 <50 6.5 0 M Puddle Under shredder conveyor belt exit 1 – ++ – <100 <100 6.5 0.07 A Shredder-Outside Water dripping from gap between water supply pipe and shredder – – + – <10 <10 6.0 0.01 L Shredder-Exit conveyor Dripping from shredder onto belt 3 – + – <20 <20 7.0 0.02 P Puddle Drainage ditch south of shredder 1,6 – + – <100 <100 7.0 0.06 O Pond Pond 1,3,6,12,†† – + – <25 <25 6.5 0.10 Swab Z Road sweeper Nozzle – – + – <100 <100 . . N Break room Sink faucet – – – – <100 <100 . . K Shredder-Exit conveyor South side – + – – <100 <100 . . R Picking shed-Conveyor Conveyor belt – – + – <100 <100 . . *Bold sample IDs indicate samples that were taken at similar locations during both visits. †A number in this column indicates a positive finding of that serogroup type, a negative (-) sign indicates a negative test. ‡If L. pneumophila DNA was solely detected then a positive sign is only notated in that column and not in L. species column. Ct value: number of cycles before sample crosses PCR threshold. In general, lower Ct values indicate higher numbers of Legionella bacteria while higher Ct values indicate lower numbers of Legionella bacteria. Specifically, a Ct of 24 is approximately 200,000 bacteria/mL while a Ct of 33 is approximately 200 bacteria/mL, with every difference of 3.3 Ct being a 10-fold change in the concentration [Musser 2011]. A negative sign (–) means DNA was not detected; one plus sign (+) indicates average Ct value was between 30.25 and 38.79; two plus signs (++) indicates average Ct value was between 24.77 and 28.72. § A dot (.) indicates no sample was taken, a < sign indicates result below the limit of detection, and a number represents Legionella CFU/mL.

¶ A dot (.) indicates no sample was taken.** Only L. feelei was found in this sample; @ indicates inconclusive result.Table 1. (cont.) Results of air, water, and swab samples collected for †† Sero undetermined. 

Legionella analyses by culture, real-time polymerase chain reaction (PCR) and direct 

fluorescent antibody (DFA) test at a shredding facility, New York, June and September 2011
Page 40 Health Hazard Evaluation Report 2011-0109-3162

Tables (continued)

Table 2. DNA fingerprinting patterns of cultured Legionella bacteria 

Sample ID Location Sub-location Organism Cultured* Fingerprinting PatternNew York State Department of Health visit (December 16, 2010)1 Shredder-Conveyor Dripping from shredder Lp1 Lp6 LpnS13160 LpnS131612 Shredder-Conveyor Conveyor belt Lp6 Lp6 LpnS13161 LpnS13162New York State Department of Health visit (May 17, 2011)1 Shredder-Conveyor Conveyor belt Lp1 Lp1 LpnS13167 LpnS13168First site visit (June 1-2, 2011)A Shredder-Outside Water dripping from gap between water supply pipe and shredder feeleii Lfe13001L Shredder-Exit conveyor Dripping from shredder onto belt Lp1 Lp6 LpnS13171 LpnS13170M Puddle Under shredder conveyor belt exit Lp1 LpnS13169P Puddle Drainage ditch south of shredder Lp1 LpnS13160Q Puddle Final ferrous pile Lp1 LpnS13160R Picking shed-Conveyor Conveyor belt Lp6 LpnS13172U Puddle Under non-ferrous conveyor Lp1 LpnS13175W Puddle Near non-ferrous conveyor Lp1 Lp6 LpnS13169 LpnS13174Y Puddle Raw feed pile Lp1 LpnS13173Second site visit (September 23, 2011)CC Puddle Non-ferrous Lp3 LpnS13191DD Puddle Near shredder conveyor belt exit Lp1 LpnS13185M Puddle Under shredder conveyor belt exit Lp1 LpnS13186L Shredder-Exit conveyor Dripping from shredder onto belt Lp3 LpnS13199P Puddle Drainage ditch south of shredder Lp1 Lp6 LpnS13187 LpnS13190O Pond Pond

Lp1Lp3Lp6

Lp12

Lp sero undetermined

LpnS13196LpnS16195LpnS13192LpnS13194LpnS13197

*Lp – L. pneumophila; the number indicates the serogroup (e.g., Lp1 is L. pneumophila serogroup 1).
Health Hazard Evaluation Report 2011-0109-3162 Page 41 Tables (continued) Table 3. Air sampling results for metals in microgram per cubic meter (μg/m3) collected on June 1-2, 2011 Location Shredder Picking shed (inside) Picking shed (outside) Near non- ferrous building West of pond Outside shredder control room Grappler crane Non- ferrous shed NIOSH REL† (μg/m3) OSHA PEL‡ (μg/m3) Aluminum 5.10 3.38 3.31 2.75 (1.08) 2.69 21.25 6.29 10,000 (total) – 5,000 (respirable) 10,000 (total) – 5,000 (respirable) Antimony <1.70 <1.30 <1.74 <1.72 <1.30 <1.68 <2.50 <1.66 500 500 Arsenic <3.40 <2.60 <3.48 <3.44 <2.60 <3.37 <5.00 <3.31 2 (15 minute ceiling), Ca 500 Barium 0.95 0.40 (0.26) 0.57 (0.06) 0.74 2.40 0.71 500 500 Beryllium <0.01 <0.01 <0.01 <0.01 (0.01) <0.01 <0.01 <0.01 0.5, Ca 2 Cadmium <0.05 <0.04 (0.05) <0.05 <0.04 <0.05 <0.08 (0.05) Lowest feasible, Ca 5 Calcium 20.41 12.99 10.10 13.40 2.08 13.97 90.00 21.52 - - Chromium <0.17 <0.13 <0.17 <0.17 <0.13 (0.27) (0.43) <0.17 500 500 Cobalt <0.34 <0.26 <0.35 <0.34 <0.26 <0.34 <0.50 <0.34 50 100 Copper <0.51 <0.39 <0.52 <0.52 <0.39 <0.51 (0.95) (0.63) 1,000 1,000 Iron 61.22 51.95 33.10 37.80 3.38 38.72 217.50 71.19 5,000 10,000 Lanthanum <0.34 <0.26 <0.35 <0.34 <0.26 <0.34 <0.50 <0.33 - - Lead <1.19 (1.03) <1.22 <1.20 <0.91 <1.18 (3.00) (1.52) 50 50 Lithium <0.34 <0.26 <0.35 <0.34 <0.26 <0.34 <0.50 <0.33 - - Magnesium 4.08 (2.21) (1.64) (1.68) 0.78 (2.02) 12.75 3.81 - 15,000 Manganese <3.40 <2.60 <3.48 <3.44 <2.60 <3.37 <5.00 <3.31 1,000 5,000 (ceiling) Molybdenum <0.68 <0.52 <0.70 <0.69 <0.52 <0.67 <1.00 <0.66 - 15,000 Nickel <1.02 <0.78 <1.05 <1.03 <0.78 <1.01 <1.50 <0.99 15, Ca 1,000 Phosphorus <3.40 <2.60 <3.48 <3.44 <2.60 <3.37 <5.00 <3.31 100 100 Potassium <10.20 <7.79 <10.45 <10.31 <7.79 <10.10 <15.00 <9.93 - - Selenium <5.10 <3.90 <5.23 <5.15 <3.90 <5.05 <7.50 <4.97 200 - Silver <0.17 <0.13 <0.17 <0.17 <0.13 <0.17 <0.25 <0.17 10 10 Strontium 0.19 0.12 (0.07) (0.09) (0.03) (0.12) 0.58 0.20 - - Tellurium <1.53 <1.17 <1.57 <1.55 <1.17 <1.52 <2.25 <1.49 100 100 Thallium <1.70 <1.30 <1.74 <1.72 <1.30 <1.68 <2.50 <1.66 100 100 Tin <1.70 <1.30 <1.74 <1.72 <1.30 <1.68 <2.50 <1.66 2,000 2,000 Titanium (0.15) (0.09) (0.16) <0.10 <0.08 (0.10) 0.55 <0.10 - - Vanadium <0.17 <0.13 <0.17 <0.17 <0.13 <0.17 <0.25 (0.20) - - Yttrium <0.07 <0.05 <0.07 <0.07 <0.05 <0.07 <0.10 <0.07 1,000 1,000 Zinc 6.97 5.45 3.14 4.30 (0.16) 3.87 18.00 6.95 - - Zirconium <0.12 <0.09 <0.12 <0.12 <0.09 <0.12 <0.18 <0.12 5,000 5,000 †REL: recommended exposure limit; ‡PEL: permissible exposure limit; ( ): values between the limit of detection and the limit of quantification (green); <: value below the limit of detection (purple); Ca: carcinogen.
Page 42 Health Hazard Evaluation Report 2011-0109-3162 Figures

Figure 1a. Map of facility with Legionella sampling locations and results from first visit (June 1-2, 2011).*Samples with high Legionella DNA had a lower Ct value while samples with low Legionella DNA had a higher Ct value. A Ct value is the cycle in which the sample crossed the PCR threshold. In general, lower Ct values indicate higher numbers of Legionella bacteria present while higher Ct values indicate lower numbers of Legionella bacteria. †DFA: direct fluorescent antibody.
Health Hazard Evaluation Report 2011-0109-3162 Page 43 Figures (continued)

Figure 1b. Map of facility with Legionella sampling locations and results from second visit (September 23, 2011).*Samples with high Legionella DNA had a lower Ct value while samples with low Legionella DNA had a higher Ct value. A Ct value is the cycle in which the sample crossed the PCR threshold. In general, lower Ct values indicate higher numbers of Legionella bacteria present while higher Ct values indicate lower numbers of Legionella bacteria. †DFA: direct fluorescent antibody.
Page 44 Health Hazard Evaluation Report 2011-0109-3162

Figures (continued)

Figure 2. Grappler crane unloading scrap material from truck.

Figure 3. Shredder.
Health Hazard Evaluation Report 2011-0109-3162 Page 45

Figures (continued)

Figure 4. Shredder operator booth.

Figure 5. Shredder (top open).
Page 46 Health Hazard Evaluation Report 2011-0109-3162

Figures (continued)

Figure 6. Shredder discharge grate. 

Figure 7. Shredder during operation showing lines that feed water into 

shredder for cooling. 
Health Hazard Evaluation Report 2011-0109-3162 Page 47

Figures (continued)

Figure 8. Inside of ferrous metal picking shed where workers remove 

nonferrous material and copper “meatballs.”

 Figure 9. Drainage pond where excess surface water flows by gravity.
Page 48 Health Hazard Evaluation Report 2011-0109-3162

Figures (continued)

 Figure 10. Standing water typical of that found throughout the facility. 

Figure 11. Drain between shredder and picking shed.
Health Hazard Evaluation Report 2011-0109-3162 Page 49

Figures (continued)

 Figure 12. Steam emitted from shredder during operation.

 Figure 13. New shredder being prepared for installation.
Page 50 Health Hazard Evaluation Report 2011-0109-3162

Figures (continued)

 Figure 14. Pool of standing water on the south side of the facility (looking 

 east).

Figure 15. Conveyor (foreground) that exits picking shed near ferrous pile. 

Non-ferrous conveyor, pile, and shed are in the background. Standing water 

is present in the foreground and between the two piles.
Health Hazard Evaluation Report 2011-0109-3162 Page 51

Figures (continued)

Figure 16. Conveyor at the exit of the shredder. Standing water is present near 

the shredder, under the conveyor, and in the background of the photograph. 

Water drips from the shredder onto the belt and from the belt onto the 

ground.

 

 (a) (b)

Figure 17. Conveyor belt in picking shed with (a) wet material during first visit and (b) drier 

material during second visit.
Page 52 Health Hazard Evaluation Report 2011-0109-3162

Figures (continued) 

 (a) (b)

Figure 18. (a) Loader driving through a large pool of water while moving scrap from the raw feed 

pile to the shredder feed conveyor during first visit. (b) Area under conveyor as in Figure (a), but 

taken from a different angle during the second visit. Green crane is in same position as yellow 

loader in Figure (a). Less water is evident.

 (a) (b)

Figure 19. Worker removing debris from under a conveyor in the non-ferrous shed during (a) first 

visit and (b) second visit. Pooled water eliminated between visits.
Health Hazard Evaluation Report 2011-0109-3162 Page 53

Figures (continued)

Figure 20. A drain grate that was uncovered during re-grading 

operations.

Figure 21. NIOSH poster in picking shed showing how to put on and take off an 

N-95 respirator.
Page 54 Health Hazard Evaluation Report 2011-0109-3162

Figures (continued)

 (a) (b)

Figure 22. (a) Pool of standing water in the non-ferrous shed during the first visit. (b) Same area 

during second visit showing the reduction in water.

 (a) (b)

Figure 23. (a) Pool of standing water near the non-ferrous shed during the first visit. (b) Same area 

during second visit showing the reduction in water.

 (a) (b)

Figure 24. (a) Worker shoveling debris in non-ferrous shed during first visit. Standing water 

and tracks from mobile equipment can be seen. (b) Same area during second visit showing the 

reduction in water.
Health Hazard Evaluation Report 2011-0109-3162 Page 55

Appendix A: Appendix A to § 1910.134: Fit Testing Procedures (Mandatory) 

Part I. OSHA-Accepted Fit Test Protocols

A. Fit Testing Procedures -- General Requirements 

The employer shall conduct fit testing using the following procedures. The requirements in this appendix 

apply to all OSHA-accepted fit test methods, both QLFT and QNFT. 

1. The test subject shall be allowed to pick the most acceptable respirator from a sufficient number of 

respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user. 

2. Prior to the selection process, the test subject shall be shown how to put on a respirator, how it should 

be positioned on the face, how to set strap tension and how to determine an acceptable fit. A mirror shall 

be available to assist the subject in evaluating the fit and positioning of the respirator. This instruction may 

not constitute the subject’s formal training on respirator use, because it is only a review. 

3. The test subject shall be informed that he/she is being asked to select the respirator that provides the 

most acceptable fit. Each respirator represents a different size and shape, and if fitted and used properly, 

will provide adequate protection. 

4. The test subject shall be instructed to hold each chosen facepiece up to the face and eliminate those that 

obviously do not give an acceptable fit. 

5. The more acceptable facepieces are noted in case the one selected proves unacceptable; the most 

comfortable mask is donned and worn at least five minutes to assess comfort. Assistance in assessing 

comfort can be given by discussing the points in the following item A.6. If the test subject is not familiar 

with using a particular respirator, the test subject shall be directed to don the mask several times and to 

adjust the straps each time to become adept at setting proper tension on the straps. 

6. Assessment of comfort shall include a review of the following points with the test subject and allowing 

the test subject adequate time to determine the comfort of the respirator: 

(a) Position of the mask on the nose 

(b) Room for eye protection 

(c) Room to talk 

(d) Position of mask on face and cheeks

7. The following criteria shall be used to help determine the adequacy of the respirator fit: 

(a) Chin properly placed; 

(b) Adequate strap tension, not overly tightened; 

Appendix A: Appendix A of OSHA Respiratory Protection Standard
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(c) Fit across nose bridge; 

(d) Respirator of proper size to span distance from nose to chin; 

(e) Tendency of respirator to slip; 

(f) Self-observation in mirror to evaluate fit and respirator position.

8. The test subject shall conduct a user seal check, either the negative and positive pressure seal checks 

described in Appendix B-1 of this section or those recommended by the respirator manufacturer which 

provide equivalent protection to the procedures in Appendix B-1. Before conducting the negative and 

positive pressure checks, the subject shall be told to seat the mask on the face by moving the head from 

side-to-side and up and down slowly while taking in a few slow deep breaths. Another facepiece shall be 

selected and retested if the test subject fails the user seal check tests. 

9. The test shall not be conducted if there is any hair growth between the skin and the facepiece sealing 

surface, such as stubble beard growth, beard, mustache or sideburns which cross the respirator sealing 

surface. Any type of apparel which interferes with a satisfactory fit shall be altered or removed. 

10. If a test subject exhibits difficulty in breathing during the tests, she or he shall be referred to a 

physician or other licensed health care professional, as appropriate, to determine whether the test subject 

can wear a respirator while performing her or his duties. 

11. If the employee finds the fit of the respirator unacceptable, the test subject shall be given the 

opportunity to select a different respirator and to be retested. 

12. Exercise regimen. Prior to the commencement of the fit test, the test subject shall be given a 

description of the fit test and the test subject’s responsibilities during the test procedure. The description 

of the process shall include a description of the test exercises that the subject will be performing. The 

respirator to be tested shall be worn for at least 5 minutes before the start of the fit test. 

13. The fit test shall be performed while the test subject is wearing any applicable safety equipment that 

may be worn during actual respirator use which could interfere with respirator fit. 

14. Test Exercises. 

(a) Employers must perform the following test exercises for all fit testing methods prescribed in this 

appendix, except for the CNP quantitative fit testing protocol and the CNP REDON quantitative 

fit testing protocol. For these two protocols, employers must ensure that the test subjects (i.e., 

employees) perform the exercise procedure specified in Part I.C.4(b) of this appendix for the 

CNP quantitative fit testing protocol, or the exercise procedure described in Part I.C.5(b) of this 

appendix for the CNP REDON quantitative fit-testing protocol. For the remaining fit testing 

methods, employers must ensure that employees perform the test exercises in the appropriate test 

environment in the following manner: 

(1) Normal breathing. In a normal standing position, without talking, the subject shall 
Health Hazard Evaluation Report 2011-0109-3162 Page 57

Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

breathe normally. 

(2) Deep breathing. In a normal standing position, the subject shall breathe slowly and 

deeply, taking caution so as not to hyperventilate. 

(3) Turning head side to side. Standing in place, the subject shall slowly turn his/her head 

from side to side between the extreme positions on each side. The head shall be held at 

each extreme momentarily so the subject can inhale at each side. 

(4) Moving head up and down. Standing in place, the subject shall slowly move his/her 

head up and down. The subject shall be instructed to inhale in the up position (i.e., when 

looking toward the ceiling). 

(5) Talking. The subject shall talk out loud slowly and loud enough so as to be heard clearly 

by the test conductor. The subject can read from a prepared text such as the Rainbow 

Passage, count backward from 100, or recite a memorized poem or song. 

Rainbow Passage 

When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. 

The rainbow is a division of white light into many beautiful colors. These take the shape 

of a long round arch, with its path high above, and its two ends apparently beyond the 

horizon. There is, according to legend, a boiling pot of gold at one end. People look, but 

no one ever finds it. When a man looks for something beyond reach, his friends say he is 

looking for the pot of gold at the end of the rainbow. 

(6) Grimace. The test subject shall grimace by smiling or frowning. (This applies only to 

QNFT testing; it is not performed for QLFT) 

(7) Bending over. The test subject shall bend at the waist as if he/she were to touch his/her 

toes. Jogging in place shall be substituted for this exercise in those test environments such 

as shroud type QNFT or QLFT units that do not permit bending over at the waist. 

(8) Normal breathing. Same as exercise (1).

(b) Each test exercise shall be performed for one minute except for the grimace exercise which shall 

be performed for 15 seconds. The test subject shall be questioned by the test conductor regarding 

the comfort of the respirator upon completion of the protocol. If it has become unacceptable, 

another model of respirator shall be tried. The respirator shall not be adjusted once the fit test 

exercises begin. Any adjustment voids the test, and the fit test must be repeated.

B. Qualitative Fit Test (QLFT) Protocols 

1. General 

(a) The employer shall ensure that persons administering QLFT are able to prepare test solutions, 

calibrate equipment and perform tests properly, recognize invalid tests, and ensure that test 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

equipment is in proper working order. 

(b) The employer shall ensure that QLFT equipment is kept clean and well maintained so as to 

operate within the parameters for which it was designed.

2. Isoamyl Acetate Protocol 

Note: This protocol is not appropriate to use for the fit testing of particulate respirators. If used to fit test 

particulate respirators, the respirator must be equipped with an organic vapor filter. 

(a) Odor Threshold Screening 

Odor threshold screening, performed without wearing a respirator, is intended to determine if the 

individual tested can detect the odor of isoamyl acetate at low levels. 

(1) Three 1 liter glass jars with metal lids are required. 

(2) Odor-free water (e.g., distilled or spring water) at approximately 25 deg. C (77 deg. F) 

shall be used for the solutions. 

(3) The isoamyl acetate (IAA) (also known at isopentyl acetate) stock solution is prepared 

by adding 1 ml of pure IAA to 800 ml of odor-free water in a 1 liter jar, closing the lid and 

shaking for 30 seconds. A new solution shall be prepared at least weekly. 

(4) The screening test shall be conducted in a room separate from the room used for 

actual fit testing. The two rooms shall be well-ventilated to prevent the odor of IAA from 

becoming evident in the general room air where testing takes place. 

(5) The odor test solution is prepared in a second jar by placing 0.4 ml of the stock solution 

into 500 ml of odor-free water using a clean dropper or pipette. The solution shall be 

shaken for 30 seconds and allowed to stand for two to three minutes so that the IAA 

concentration above the liquid may reach equilibrium. This solution shall be used for only 

one day. 

(6) A test blank shall be prepared in a third jar by adding 500 cc of odor-free water. 

(7) The odor test and test blank jar lids shall be labeled (e.g., 1 and 2) for jar identification. 

Labels shall be placed on the lids so that they can be peeled off periodically and switched to 

maintain the integrity of the test. 

(8) The following instruction shall be typed on a card and placed on the table in front of 

the two test jars (i.e., 1 and 2): “The purpose of this test is to determine if you can smell 

banana oil at a low concentration. The two bottles in front of you contain water. One of 

these bottles also contains a small amount of banana oil. Be sure the covers are on tight, 

then shake each bottle for two seconds. Unscrew the lid of each bottle, one at a time, 
Health Hazard Evaluation Report 2011-0109-3162 Page 59

Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

and sniff at the mouth of the bottle. Indicate to the test conductor which bottle contains 

banana oil.” 

(9) The mixtures used in the IAA odor detection test shall be prepared in an area separate 

from where the test is performed, in order to prevent olfactory fatigue in the subject. 

(10) If the test subject is unable to correctly identify the jar containing the odor test 

solution, the IAA qualitative fit test shall not be performed. 

(11) If the test subject correctly identifies the jar containing the odor test solution, the test 

subject may proceed to respirator selection and fit testing.

(b) Isoamyl Acetate Fit Test 

(1) The fit test chamber shall be a clear 55-gallon drum liner suspended inverted over 

a 2-foot diameter frame so that the top of the chamber is about 6 inches above the test 

subject’s head. If no drum liner is available, a similar chamber shall be constructed using 

plastic sheeting. The inside top center of the chamber shall have a small hook attached. 

(2) Each respirator used for the fitting and fit testing shall be equipped with organic vapor 

cartridges or offer protection against organic vapors. 

(3) After selecting, donning, and properly adjusting a respirator, the test subject shall 

wear it to the fit testing room. This room shall be separate from the room used for odor 

threshold screening and respirator selection, and shall be well-ventilated, as by an exhaust 

fan or lab hood, to prevent general room contamination. 

(4) A copy of the test exercises and any prepared text from which the subject is to read shall 

be taped to the inside of the test chamber. 

(5) Upon entering the test chamber, the test subject shall be given a 6-inch by 5-inch piece 

of paper towel, or other porous, absorbent, single-ply material, folded in half and wetted 

with 0.75 ml of pure IAA. The test subject shall hang the wet towel on the hook at the top 

of the chamber. An IAA test swab or ampule may be substituted for the IAA wetted paper 

towel provided it has been demonstrated that the alternative IAA source will generate an 

IAA test atmosphere with a concentration equivalent to that generated by the paper towel 

method. 

(6) Allow two minutes for the IAA test concentration to stabilize before starting the fit test 

exercises. This would be an appropriate time to talk with the test subject; to explain the fit 

test, the importance of his/her cooperation, and the purpose for the test exercises; or to 

demonstrate some of the exercises. 

(7) If at any time during the test, the subject detects the banana-like odor of IAA, the test is 

failed. The subject shall quickly exit from the test chamber and leave the test area to avoid 

olfactory fatigue. 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(8) If the test is failed, the subject shall return to the selection room and remove the 

respirator. The test subject shall repeat the odor sensitivity test, select and put on another 

respirator, return to the test area and again begin the fit test procedure described in (b) (1) 

through (7) above. The process continues until a respirator that fits well has been found. 

Should the odor sensitivity test be failed, the subject shall wait at least 5 minutes before 

retesting. Odor sensitivity will usually have returned by this time. 

(9) If the subject passes the test, the efficiency of the test procedure shall be demonstrated 

by having the subject break the respirator face seal and take a breath before exiting the 

chamber. 

(10) When the test subject leaves the chamber, the subject shall remove the saturated 

towel and return it to the person conducting the test, so that there is no significant IAA 

concentration buildup in the chamber during subsequent tests. The used towels shall be 

kept in a self-sealing plastic bag to keep the test area from being contaminated.

3. Saccharin Solution Aerosol Protocol 

The entire screening and testing procedure shall be explained to the test subject prior to the conduct of 

the screening test. 

(a) Taste threshold screening. The saccharin taste threshold screening, performed without wearing 

a respirator, is intended to determine whether the individual being tested can detect the taste of 

saccharin. 

(1) During threshold screening as well as during fit testing, subjects shall wear an enclosure 

about the head and shoulders that is approximately 12 inches in diameter by 14 inches tall 

with at least the front portion clear and that allows free movements of the head when a 

respirator is worn. An enclosure substantially similar to the 3M hood assembly, parts # FT 

14 and # FT 15 combined, is adequate. 

(2) The test enclosure shall have a 3/4-inch (1.9 cm) hole in front of the test subject’s nose 

and mouth area to accommodate the nebulizer nozzle. 

(3) The test subject shall don the test enclosure. Throughout the threshold screening test, 

the test subject shall breathe through his/her slightly open mouth with tongue extended. 

The subject is instructed to report when he/she detects a sweet taste. 

(4) Using a DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent, the 

test conductor shall spray the threshold check solution into the enclosure. The nozzle 

is directed away from the nose and mouth of the person. This nebulizer shall be clearly 

marked to distinguish it from the fit test solution nebulizer. 

(5) The threshold check solution is prepared by dissolving 0.83 gram of sodium saccharin 

USP in 100 ml of warm water. It can be prepared by putting 1 ml of the fit test solution 

(see (b)(5) below) in 100 ml of distilled water. 
Health Hazard Evaluation Report 2011-0109-3162 Page 61

Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(6) To produce the aerosol, the nebulizer bulb is firmly squeezed so that it collapses 

completely, then released and allowed to fully expand. 

(7) Ten squeezes are repeated rapidly and then the test subject is asked whether the 

saccharin can be tasted. If the test subject reports tasting the sweet taste during the ten 

squeezes, the screening test is completed. The taste threshold is noted as ten regardless of 

the number of squeezes actually completed. 

(8) If the first response is negative, ten more squeezes are repeated rapidly and the test 

subject is again asked whether the saccharin is tasted. If the test subject reports tasting 

the sweet taste during the second ten squeezes, the screening test is completed. The taste 

threshold is noted as twenty regardless of the number of squeezes actually completed. 

(9) If the second response is negative, ten more squeezes are repeated rapidly and the test 

subject is again asked whether the saccharin is tasted. If the test subject reports tasting the 

sweet taste during the third set of ten squeezes, the screening test is completed. The taste 

threshold is noted as thirty regardless of the number of squeezes actually completed. 

(10) The test conductor will take note of the number of squeezes required to solicit a taste 

response. 

(11) If the saccharin is not tasted after 30 squeezes (step 10), the test subject is unable to 

taste saccharin and may not perform the saccharin fit test. 

Note to paragraph 3. (a): If the test subject eats or drinks something sweet before the 

screening test, he/she may be unable to taste the weak saccharin solution. 

(12) If a taste response is elicited, the test subject shall be asked to take note of the taste for 

reference in the fit test. 

(13) Correct use of the nebulizer means that approximately 1 ml of liquid is used at a time 

in the nebulizer body. 

(14) The nebulizer shall be thoroughly rinsed in water, shaken dry, and refilled at least each 

morning and afternoon or at least every four hours.

(b) Saccharin solution aerosol fit test procedure. 

(1) The test subject may not eat, drink (except plain water), smoke, or chew gum for 15 

minutes before the test. 

(2) The fit test uses the same enclosure described in 3. (a) above. 

(3) The test subject shall don the enclosure while wearing the respirator selected in section 

I. A. of this appendix. The respirator shall be properly adjusted and equipped with a 

particulate filter(s). 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(4) A second DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent is used 

to spray the fit test solution into the enclosure. This nebulizer shall be clearly marked to 

distinguish it from the screening test solution nebulizer. 

(5) The fit test solution is prepared by adding 83 grams of sodium saccharin to 100 ml of 

warm water. 

(6) As before, the test subject shall breathe through the slightly open mouth with tongue 

extended, and report if he/she tastes the sweet taste of saccharin. 

(7) The nebulizer is inserted into the hole in the front of the enclosure and an initial 

concentration of saccharin fit test solution is sprayed into the enclosure using the same 

number of squeezes (either 10, 20 or 30 squeezes) based on the number of squeezes 

required to elicit a taste response as noted during the screening test. A minimum of 10 

squeezes is required. 

(8) After generating the aerosol, the test subject shall be instructed to perform the exercises 

in section I. A. 14. of this appendix. 

(9) Every 30 seconds the aerosol concentration shall be replenished using one half the 

original number of squeezes used initially (e.g., 5, 10 or 15). 

(10) The test subject shall indicate to the test conductor if at any time during the fit test the 

taste of saccharin is detected. If the test subject does not report tasting the saccharin, the 

test is passed. 

(11) If the taste of saccharin is detected, the fit is deemed unsatisfactory and the test is 

failed. A different respirator shall be tried and the entire test procedure is repeated (taste 

threshold screening and fit testing). 

(12) Since the nebulizer has a tendency to clog during use, the test operator must make 

periodic checks of the nebulizer to ensure that it is not clogged. If clogging is found at the 

end of the test session, the test is invalid.

4. BitrexTM (Denatonium Benzoate) Solution Aerosol Qualitative Fit Test Protocol 

The BitrexTM (Denatonium benzoate) solution aerosol QLFT protocol uses the published saccharin test 

protocol because that protocol is widely accepted. Bitrex is routinely used as a taste aversion agent in 

household liquids which children should not be drinking and is endorsed by the American Medical 

Association, the National Safety Council, and the American Association of Poison Control Centers. The 

entire screening and testing procedure shall be explained to the test subject prior to the conduct of the 

screening test. 

(a) Taste Threshold Screening. 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

The Bitrex taste threshold screening, performed without wearing a respirator, is intended to 

determine whether the individual being tested can detect the taste of Bitrex. 

(1) During threshold screening as well as during fit testing, subjects shall wear an enclosure 

about the head and shoulders that is approximately 12 inches (30.5 cm) in diameter by 14 

inches (35.6 cm) tall. The front portion of the enclosure shall be clear from the respirator 

and allow free movement of the head when a respirator is worn. An enclosure substantially 

similar to the 3M hood assembly, parts # FT 14 and # FT 15 combined, is adequate. 

(2) The test enclosure shall have a \3/4\ inch (1.9 cm) hole in front of the test subject’s 

nose and mouth area to accommodate the nebulizer nozzle. 

(3) The test subject shall don the test enclosure. Throughout the threshold screening test, 

the test subject shall breathe through his or her slightly open mouth with tongue extended. 

The subject is instructed to report when he/she detects a bitter taste 

(4) Using a DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent, the test 

conductor shall spray the Threshold Check Solution into the enclosure. This Nebulizer 

shall be clearly marked to distinguish it from the fit test solution nebulizer. 

(5) The Threshold Check Solution is prepared by adding 13.5 milligrams of Bitrex to 100 

ml of 5% salt (NaCl) solution in distilled water. 

(6) To produce the aerosol, the nebulizer bulb is firmly squeezed so that the bulb collapses 

completely, and is then released and allowed to fully expand. 

(7) An initial ten squeezes are repeated rapidly and then the test subject is asked whether 

the Bitrex can be tasted. If the test subject reports tasting the bitter taste during the ten 

squeezes, the screening test is completed. The taste threshold is noted as ten regardless of 

the number of squeezes actually completed. 

(8) If the first response is negative, ten more squeezes are repeated rapidly and the test 

subject is again asked whether the Bitrex is tasted. If the test subject reports tasting the 

bitter taste during the second ten squeezes, the screening test is completed. The taste 

threshold is noted as twenty regardless of the number of squeezes actually completed. 

(9) If the second response is negative, ten more squeezes are repeated rapidly and the test 

subject is again asked whether the Bitrex is tasted. If the test subject reports tasting the 

bitter taste during the third set of ten squeezes, the screening test is completed. The taste 

threshold is noted as thirty regardless of the number of squeezes actually completed. 

(10) The test conductor will take note of the number of squeezes required to solicit a taste 

response. 

(11) If the Bitrex is not tasted after 30 squeezes (step 10), the test subject is unable to taste 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

Bitrex and may not perform the Bitrex fit test. 

(12) If a taste response is elicited, the test subject shall be asked to take note of the taste for 

reference in the fit test. 

(13) Correct use of the nebulizer means that approximately 1 ml of liquid is used at a time 

in the nebulizer body. 

(14) The nebulizer shall be thoroughly rinsed in water, shaken to dry, and refilled at least 

each morning and afternoon or at least every four hours.

(b) Bitrex Solution Aerosol Fit Test Procedure. 

(1) The test subject may not eat, drink (except plain water), smoke, or chew gum for 15 

minutes before the test. 

(2) The fit test uses the same enclosure as that described in 4. (a) above. 

(3) The test subject shall don the enclosure while wearing the respirator selected according 

to section I. A. of this appendix. The respirator shall be properly adjusted and equipped 

with any type particulate filter(s). 

(4) A second DeVilbiss Model 40 Inhalation Medication Nebulizer or equivalent is used 

to spray the fit test solution into the enclosure. This nebulizer shall be clearly marked to 

distinguish it from the screening test solution nebulizer. 

(5) The fit test solution is prepared by adding 337.5 mg of Bitrex to 200 ml of a 5% salt 

(NaCl) solution in warm water. 

(6) As before, the test subject shall breathe through his or her slightly open mouth with 

tongue extended, and be instructed to report if he/she tastes the bitter taste of Bitrex. 

(7) The nebulizer is inserted into the hole in the front of the enclosure and an initial 

concentration of the fit test solution is sprayed into the enclosure using the same number 

of squeezes (either 10, 20 or 30 squeezes) based on the number of squeezes required to 

elicit a taste response as noted during the screening test. 

(8) After generating the aerosol, the test subject shall be instructed to perform the exercises 

in section I. A. 14. of this appendix. 

(9) Every 30 seconds the aerosol concentration shall be replenished using one half the 

number of squeezes used initially (e.g., 5, 10 or 15). 

(10) The test subject shall indicate to the test conductor if at any time during the fit test the 

taste of Bitrex is detected. If the test subject does not report tasting the Bitrex, the test is 

passed. 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(11) If the taste of Bitrex is detected, the fit is deemed unsatisfactory and the test is failed. A 

different respirator shall be tried and the entire test procedure is repeated (taste threshold 

screening and fit testing).

5. Irritant Smoke (Stannic Chloride) Protocol 

This qualitative fit test uses a person’s response to the irritating chemicals released in the “smoke” 

produced by a stannic chloride ventilation smoke tube to detect leakage into the respirator. 

(a) General Requirements and Precautions 

(1) The respirator to be tested shall be equipped with high efficiency particulate air (HEPA) 

or P100 series filter(s). 

(2) Only stannic chloride smoke tubes shall be used for this protocol. 

(3) No form of test enclosure or hood for the test subject shall be used. 

(4) The smoke can be irritating to the eyes, lungs, and nasal passages. The test conductor 

shall take precautions to minimize the test subject’s exposure to irritant smoke. Sensitivity 

varies, and certain individuals may respond to a greater degree to irritant smoke. Care shall 

be taken when performing the sensitivity screening checks that determine whether the test 

subject can detect irritant smoke to use only the minimum amount of smoke necessary to 

elicit a response from the test subject. 

(5) The fit test shall be performed in an area with adequate ventilation to prevent exposure 

of the person conducting the fit test or the build-up of irritant smoke in the general 

atmosphere.

(b) Sensitivity Screening Check 

The person to be tested must demonstrate his or her ability to detect a weak concentration of the 

irritant smoke. 

(1) The test operator shall break both ends of a ventilation smoke tube containing stannic 

chloride, and attach one end of the smoke tube to a low flow air pump set to deliver 200 

milliliters per minute, or an aspirator squeeze bulb. The test operator shall cover the other 

end of the smoke tube with a short piece of tubing to prevent potential injury from the 

jagged end of the smoke tube. 

(2) The test operator shall advise the test subject that the smoke can be irritating to the 

eyes, lungs, and nasal passages and instruct the subject to keep his/her eyes closed while the 

test is performed. 

(3) The test subject shall be allowed to smell a weak concentration of the irritant smoke 

before the respirator is donned to become familiar with its irritating properties and to 

determine if he/she can detect the irritating properties of the smoke. The test operator 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

shall carefully direct a small amount of the irritant smoke in the test subject’s direction to 

determine that he/she can detect it.

(c) Irritant Smoke Fit Test Procedure 

(1) The person being fit tested shall don the respirator without assistance, and perform the 

required user seal check(s). 

(2) The test subject shall be instructed to keep his/her eyes closed. 

(3) The test operator shall direct the stream of irritant smoke from the smoke tube toward 

the faceseal area of the test subject, using the low flow pump or the squeeze bulb. The 

test operator shall begin at least 12 inches from the facepiece and move the smoke stream 

around the whole perimeter of the mask. The operator shall gradually make two more 

passes around the perimeter of the mask, moving to within six inches of the respirator. 

(4) If the person being tested has not had an involuntary response and/or detected the 

irritant smoke, proceed with the test exercises. 

(5) The exercises identified in section I.A. 14. of this appendix shall be performed by the 

test subject while the respirator seal is being continually challenged by the smoke, directed 

around the perimeter of the respirator at a distance of six inches. 

(6) If the person being fit tested reports detecting the irritant smoke at any time, the test 

is failed. The person being retested must repeat the entire sensitivity check and fit test 

procedure. 

(7) Each test subject passing the irritant smoke test without evidence of a response 

(involuntary cough, irritation) shall be given a second sensitivity screening check, with the 

smoke from the same smoke tube used during the fit test, once the respirator has been 

removed, to determine whether he/she still reacts to the smoke. Failure to evoke a response 

shall void the fit test. 

(8) If a response is produced during this second sensitivity check, then the fit test is passed.

C. Quantitative Fit Test (QNFT) Protocols 

The following quantitative fit testing procedures have been demonstrated to be acceptable: Quantitative fit 

testing using a non-hazardous test aerosol (such as corn oil, polyethylene glycol 400 [PEG 400], di-2-ethyl 

hexyl sebacate [DEHS], or sodium chloride) generated in a test chamber, and employing instrumentation 

to quantify the fit of the respirator; Quantitative fit testing using ambient aerosol as the test agent and 

appropriate instrumentation (condensation nuclei counter) to quantify the respirator fit; Quantitative fit 

testing using controlled negative pressure and appropriate instrumentation to measure the volumetric leak 

rate of a facepiece to quantify the respirator fit. 

1. General 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(a) The employer shall ensure that persons administering QNFT are able to calibrate equipment 

and perform tests properly, recognize invalid tests, calculate fit factors properly and ensure that test 

equipment is in proper working order. 

(b) The employer shall ensure that QNFT equipment is kept clean, and is maintained and 

calibrated according to the manufacturer’s instructions so as to operate at the parameters for which 

it was designed.

2. Generated Aerosol Quantitative Fit Testing Protocol 

(a) Apparatus. 

(1) Instrumentation. Aerosol generation, dilution, and measurement systems using 

particulates (corn oil, polyethylene glycol 400 [PEG 400], di-2-ethyl hexyl sebacate [DEHS] 

or sodium chloride) as test aerosols shall be used for quantitative fit testing. 

(2) Test chamber. The test chamber shall be large enough to permit all test subjects to 

perform freely all required exercises without disturbing the test agent concentration or 

the measurement apparatus. The test chamber shall be equipped and constructed so that 

the test agent is effectively isolated from the ambient air, yet uniform in concentration 

throughout the chamber. 

(3) When testing air-purifying respirators, the normal filter or cartridge element shall be 

replaced with a high efficiency particulate air (HEPA) or P100 series filter supplied by the 

same manufacturer. 

(4) The sampling instrument shall be selected so that a computer record or strip chart 

record may be made of the test showing the rise and fall of the test agent concentration 

with each inspiration and expiration at fit factors of at least 2,000. Integrators or computers 

that integrate the amount of test agent penetration leakage into the respirator for each 

exercise may be used provided a record of the readings is made. 

(5) The combination of substitute air-purifying elements, test agent and test agent 

concentration shall be such that the test subject is not exposed in excess of an established 

exposure limit for the test agent at any time during the testing process, based upon the 

length of the exposure and the exposure limit duration. 

(6) The sampling port on the test specimen respirator shall be placed and constructed so 

that no leakage occurs around the port (e.g., where the respirator is probed), a free air flow 

is allowed into the sampling line at all times, and there is no interference with the fit or 

performance of the respirator. The in-mask sampling device (probe) shall be designed and 

used so that the air sample is drawn from the breathing zone of the test subject, midway 

between the nose and mouth and with the probe extending into the facepiece cavity at least 

1/4 inch. 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(7) The test setup shall permit the person administering the test to observe the test subject 

inside the chamber during the test. 

(8) The equipment generating the test atmosphere shall maintain the concentration of test 

agent constant to within a 10 percent variation for the duration of the test. 

(9) The time lag (interval between an event and the recording of the event on the strip 

chart or computer or integrator) shall be kept to a minimum. There shall be a clear 

association between the occurrence of an event and its being recorded. 

(10) The sampling line tubing for the test chamber atmosphere and for the respirator 

sampling port shall be of equal diameter and of the same material. The length of the two 

lines shall be equal. 

(11) The exhaust flow from the test chamber shall pass through an appropriate filter (i.e., 

high efficiency particulate filter) before release. 

(12) When sodium chloride aerosol is used, the relative humidity inside the test chamber 

shall not exceed 50 percent. 

(13) The limitations of instrument detection shall be taken into account when determining 

the fit factor. 

(14) Test respirators shall be maintained in proper working order and be inspected regularly 

for deficiencies such as cracks or missing valves and gaskets.

(b) Procedural Requirements. 

(1) When performing the initial user seal check using a positive or negative pressure check, 

the sampling line shall be crimped closed in order to avoid air pressure leakage during 

either of these pressure checks. 

(2) The use of an abbreviated screening QLFT test is optional. Such a test may be utilized 

in order to quickly identify poor fitting respirators that passed the positive and/or 

negative pressure test and reduce the amount of QNFT time. The use of the CNC QNFT 

instrument in the count mode is another optional method to obtain a quick estimate of fit 

and eliminate poor fitting respirators before going on to perform a full QNFT. 

(3) A reasonably stable test agent concentration shall be measured in the test chamber prior 

to testing. For canopy or shower curtain types of test units, the determination of the test 

agent’s stability may be established after the test subject has entered the test environment. 

(4) Immediately after the subject enters the test chamber, the test agent concentration 

inside the respirator shall be measured to ensure that the peak penetration does not exceed 

5 percent for a half mask or 1 percent for a full facepiece respirator. 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(5) A stable test agent concentration shall be obtained prior to the actual start of testing. 

(6) Respirator restraining straps shall not be over-tightened for testing. The straps shall 

be adjusted by the wearer without assistance from other persons to give a reasonably 

comfortable fit typical of normal use. The respirator shall not be adjusted once the fit test 

exercises begin. 

(7) The test shall be terminated whenever any single peak penetration exceeds 5 percent for 

half masks and 1 percent for full facepiece respirators. The test subject shall be refitted and 

retested. 

(8) Calculation of fit factors. 

(i) The fit factor shall be determined for the quantitative fit test by taking the ratio 

of the average chamber concentration to the concentration measured inside the 

respirator for each test exercise except the grimace exercise. 

(ii) The average test chamber concentration shall be calculated as the arithmetic 

average of the concentration measured before and after each test (i.e., 7 exercises) or 

the arithmetic average of the concentration measured before and after each exercise 

or the true average measured continuously during the respirator sample. 

(iii) The concentration of the challenge agent inside the respirator shall be 

determined by one of the following methods: 

(A) Average peak penetration method means the method of determining 

test agent penetration into the respirator utilizing a strip chart recorder, 

integrator, or computer. The agent penetration is determined by an average 

of the peak heights on the graph or by computer integration, for each 

exercise except the grimace exercise. Integrators or computers that calculate 

the actual test agent penetration into the respirator for each exercise will 

also be considered to meet the requirements of the average peak penetration 

method. 

(B) Maximum peak penetration method means the method of determining 

test agent penetration in the respirator as determined by strip chart 

recordings of the test. The highest peak penetration for a given exercise is 

taken to be representative of average penetration into the respirator for that 

exercise. 

(C) Integration by calculation of the area under the individual peak for each 

exercise except the grimace exercise. This includes computerized integration. 

(D) The calculation of the overall fit factor using individual exercise fit 

factors involves first converting the exercise fit factors to penetration values, 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

determining the average, and then converting that result back to a fit factor.

This procedure is described in the following equation:

here ff1, ff2, ff3, etc. are the fit factors for exercises 1, 2, 3, etc. 

(9) The test subject shall not be permitted to wear a half mask or quarter facepiece 

respirator unless a minimum fit factor of 100 is obtained, or a full facepiece respirator 

unless a minimum fit factor of 500 is obtained. 

(10) Filters used for quantitative fit testing shall be replaced whenever increased breathing 

resistance is encountered, or when the test agent has altered the integrity of the filter 

media.

3. Ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol. 

The ambient aerosol condensation nuclei counter (CNC) quantitative fit testing (Portacount TM ) 

protocol quantitatively fit tests respirators with the use of a probe. The probed respirator is only used for 

quantitative fit tests. A probed respirator has a special sampling device, installed on the respirator, that 

allows the probe to sample the air from inside the mask. A probed respirator is required for each make, 

style, model, and size that the employer uses and can be obtained from the respirator manufacturer or 

distributor. The CNC instrument manufacturer, TSI Inc., also provides probe attachments (TSI sampling 

adapters) that permit fit testing in an employee’s own respirator. A minimum fit factor pass level of at least 

100 is necessary for a half-mask respirator and a minimum fit factor pass level of at least 500 is required for 

a full facepiece negative pressure respirator. The entire screening and testing procedure shall be explained 

to the test subject prior to the conduct of the screening test. 

(a) Portacount Fit Test Requirements. 

(1) Check the respirator to make sure the sampling probe and line are properly attached to 

the facepiece and that the respirator is fitted with a particulate filter capable of preventing 

significant penetration by the ambient particles used for the fit test (e.g., NIOSH 42 CFR 

84 series 100, series 99, or series 95 particulate filter) per manufacturer’s instruction. 

(2) Instruct the person to be tested to don the respirator for five minutes before the fit 

test starts. This purges the ambient particles trapped inside the respirator and permits the 

wearer to make certain the respirator is comfortable. This individual shall already have 

been trained on how to wear the respirator properly. 

(3) Check the following conditions for the adequacy of the respirator fit: Chin properly 

placed; Adequate strap tension, not overly tightened; Fit across nose bridge; Respirator 

of proper size to span distance from nose to chin; Tendency of the respirator to slip; Selfobservation in a mirror to evaluate fit and respirator position. 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

(4) Have the person wearing the respirator do a user seal check. If leakage is detected, 

determine the cause. If leakage is from a poorly fitting facepiece, try another size of the 

same model respirator, or another model of respirator. 

(5) Follow the manufacturer’s instructions for operating the Portacount and proceed with 

the test. 

(6) The test subject shall be instructed to perform the exercises in section I. A. 14. of this 

appendix. 

(7) After the test exercises, the test subject shall be questioned by the test conductor 

regarding the comfort of the respirator upon completion of the protocol. If it has become 

unacceptable, another model of respirator shall be tried.

(b) Portacount Test Instrument. 

(1) The Portacount will automatically stop and calculate the overall fit factor for the entire 

set of exercises. The overall fit factor is what counts. The Pass or Fail message will indicate 

whether or not the test was successful. If the test was a Pass, the fit test is over. 

(2) Since the pass or fail criterion of the Portacount is user programmable, the test operator 

shall ensure that the pass or fail criterion meet the requirements for minimum respirator 

performance in this Appendix. 

(3) A record of the test needs to be kept on file, assuming the fit test was successful. The 

record must contain the test subject’s name; overall fit factor; make, model, style, and size 

of respirator used; and date tested.

4. Controlled negative pressure (CNP) quantitative fit testing protocol. 

The CNP protocol provides an alternative to aerosol fit test methods. The CNP fit test method 

technology is based on exhausting air from a temporarily sealed respirator facepiece to generate and then 

maintain a constant negative pressure inside the facepiece. The rate of air exhaust is controlled so that 

a constant negative pressure is maintained in the respirator during the fit test. The level of pressure is 

selected to replicate the mean inspiratory pressure that causes leakage into the respirator under normal 

use conditions. With pressure held constant, air flow out of the respirator is equal to air flow into the 

respirator. Therefore, measurement of the exhaust stream that is required to hold the pressure in the 

temporarily sealed respirator constant yields a direct measure of leakage air flow into the respirator. The 

CNP fit test method measures leak rates through the facepiece as a method for determining the facepiece 

fit for negative pressure respirators. The CNP instrument manufacturer Occupational Health Dynamics 

of Birmingham, Alabama also provides attachments (sampling manifolds) that replace the filter cartridges 

to permit fit testing in an employee’s own respirator. To perform the test, the test subject closes his or 

her mouth and holds his/her breath, after which an air pump removes air from the respirator facepiece 

at a pre-selected constant pressure. The facepiece fit is expressed as the leak rate through the facepiece, 

expressed as milliliters per minute. The quality and validity of the CNP fit tests are determined by the 

degree to which the in-mask pressure tracks the test pressure during the system measurement time of 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

approximately five seconds. Instantaneous feedback in the form of a real-time pressure trace of the in-mask 

pressure is provided and used to determine test validity and quality. A minimum fit factor pass level of 

100 is necessary for a half-mask respirator and a minimum fit factor of at least 500 is required for a full 

facepiece respirator. The entire screening and testing procedure shall be explained to the test subject prior 

to the conduct of the screening test. 

(a) CNP Fit Test Requirements. 

(1) The instrument shall have a non-adjustable test pressure of 15.0 mm water pressure. 

(2) The CNP system defaults selected for test pressure shall be set at -- 15 mm of water 

(-0.58 inches of water) and the modeled inspiratory flow rate shall be 53.8 liters per minute 

for performing fit tests. 

(Note: CNP systems have built-in capability to conduct fit testing that is specific to unique 

work rate, mask, and gender situations that might apply in a specific workplace. Use 

of system default values, which were selected to represent respirator wear with medium 

cartridge resistance at a low-moderate work rate, will allow inter-test comparison of the 

respirator fit.) 

(3) The individual who conducts the CNP fit testing shall be thoroughly trained to perform 

the test. 

(4) The respirator filter or cartridge needs to be replaced with the CNP test manifold. The 

inhalation valve downstream from the manifold either needs to be temporarily removed or 

propped open. 

(5) The employer must train the test subject to hold his or her breath for at least 10 

seconds. 

(6) The test subject must don the test respirator without any assistance from the test 

administrator who is conducting the CNP fit test. The respirator must not be adjusted once 

the fit-test exercises begin. Any adjustment voids the test, and the test subject must repeat 

the fit test. 

(7) The QNFT protocol shall be followed according to section I. C. 1. of this appendix with 

an exception for the CNP test exercises.

(b) CNP Test Exercises. 

(1) Normal breathing. In a normal standing position, without talking, the subject shall 

breathe normally for 1 minute. After the normal breathing exercise, the subject needs 

to hold head straight ahead and hold his or her breath for 10 seconds during the test 

measurement. 

(2) Deep breathing. In a normal standing position, the subject shall breathe slowly and 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

deeply for 1 minute, being careful not to hyperventilate. After the deep breathing exercise, 

the subject shall hold his or her head straight ahead and hold his or her breath for 10 

seconds during test measurement. 

(3) Turning head side to side. Standing in place, the subject shall slowly turn his or her 

head from side to side between the extreme positions on each side for 1 minute. The head 

shall be held at each extreme momentarily so the subject can inhale at each side. After the 

turning head side to side exercise, the subject needs to hold head full left and hold his or 

her breath for 10 seconds during test measurement. Next, the subject needs to hold head 

full right and hold his or her breath for 10 seconds during test measurement. 

(4) Moving head up and down. Standing in place, the subject shall slowly move his or 

her head up and down for 1 minute. The subject shall be instructed to inhale in the up 

position (i.e., when looking toward the ceiling). After the moving head up and down 

exercise, the subject shall hold his or her head full up and hold his or her breath for 10 

seconds during test measurement. Next, the subject shall hold his or her head full down 

and hold his or her breath for 10 seconds during test measurement. 

(5) Talking. The subject shall talk out loud slowly and loud enough so as to be heard clearly 

by the test conductor. The subject can read from a prepared text such as the Rainbow 

Passage, count backward from 100, or recite a memorized poem or song for 1 minute. After 

the talking exercise, the subject shall hold his or her head straight ahead and hold his or 

her breath for 10 seconds during the test measurement. 

(6) Grimace. The test subject shall grimace by smiling or frowning for 15 seconds. 

(7) Bending Over. The test subject shall bend at the waist as if he or she were to touch his 

or her toes for 1 minute. Jogging in place shall be substituted for this exercise in those test 

environments such as shroud-type QNFT units that prohibit bending at the waist. After the 

bending over exercise, the subject shall hold his or her head straight ahead and hold his or 

her breath for 10 seconds during the test measurement. 

(8) Normal Breathing. The test subject shall remove and re-don the respirator within a 

one-minute period. Then, in a normal standing position, without talking, the subject 

shall breathe normally for 1 minute. After the normal breathing exercise, the subject shall 

hold his or her head straight ahead and hold his or her breath for 10 seconds during the 

test measurement. After the test exercises, the test subject shall be questioned by the test 

conductor regarding the comfort of the respirator upon completion of the protocol. If it 

has become unacceptable, another model of a respirator shall be tried.

(c) CNP Test Instrument. 

(1) The test instrument must have an effective audio-warning device, or a visual-warning 

device in the form of a screen tracing, that indicates when the test subject fails to hold 

his or her breath during the test. The test must be terminated and restarted from the 
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Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

beginning when the test subject fails to hold his or her breath during the test. The test 

subject then may be refitted and retested. 

(2) A record of the test shall be kept on file, assuming the fit test was successful. The record 

must contain the test subject’s name; overall fit factor; make, model, style and size of 

respirator used; and date tested.

5. Controlled negative pressure (CNP) REDON quantitative fit testing protocol. 

(a) When administering this protocol to test subjects, employers must comply with the 

requirements specified in paragraphs (a) and (c) of Part I.C.4 of this appendix (“Controlled 

negative pressure (CNP) quantitative fit testing protocol”), as well as use the test exercises described 

below in paragraph (b) of this protocol instead of the test exercises specified in paragraph (b) of 

Part I.C.4 of this appendix. 

(b) Employers must ensure that each test subject being fit tested using this protocol follows the 

exercise and measurement procedures, including the order of administration, described below in 

Table A-1 of this appendix. 

Table A-1. -- CNP REDON Quantitative Fit Testing Protocol

Exercises(1) Exercise procedure Measurement procedure 

Facing Forward Stand and breathe normally, without talking, for 30 

seconds.

Face forward, while holding breath for 

10 seconds.

Bending Over Bend at the waist, as if going to touch his or her toes, for 

30 seconds.

Face parallel to the floor, while holding 

breath for 10 seconds

Head Shaking For about three seconds, shake head back and forth 

vigorously several times while shouting.

Face forward, while holding breath for 

10 seconds.

REDON 1 Remove the respirator mask, loosen all facepiece straps, 

and then redon the respirator mask.

Face forward, while holding breath for 

10 seconds.

REDON 2 Remove the respirator mask, loosen all facepiece straps, 

and then redon the respirator mask again.

Face forward, while holding breath for 

10 seconds.

1

 Exercises are listed in the order in which they are to be administered.

(c) After completing the test exercises, the test administrator must question each test subject 

regarding the comfort of the respirator. When a test subject states that the respirator is 

unacceptable, the employer must ensure that the test administrator repeats the protocol using 

another respirator model. 

(d) Employers must determine the overall fit factor for each test subject by calculating the harmonic 

mean of the fit testing exercises as follows: 

Where:

N = The number of exercises;

FF1 = The fit factor for the first exercise;

FF2 = The fit factor for the second exercise; and

FFN = The fit factor for the nth exercise. 
Health Hazard Evaluation Report 2011-0109-3162 Page 75

Appendix A: Appendix A of OSHA Respiratory Protection Standard (cont)

Part II. New Fit Test Protocols 

A. Any person may submit to OSHA an application for approval of a new fit test protocol. If the 

application meets the following criteria, OSHA will initiate a rulemaking proceeding under section 6(b)(7) 

of the OSH Act to determine whether to list the new protocol as an approved protocol in this Appendix 

A. 

B. The application must include a detailed description of the proposed new fit test protocol. This 

application must be supported by either: 

1. A test report prepared by an independent government research laboratory (e.g., Lawrence 

Livermore National Laboratory, Los Alamos National Laboratory, the National Institute for 

Standards and Technology) stating that the laboratory has tested the protocol and had found it to 

be accurate and reliable; or 

2. An article that has been published in a peer-reviewed industrial hygiene journal describing the 

protocol and explaining how test data support the protocol’s accuracy and reliability. 

C. If OSHA determines that additional information is required before the Agency commences a 

rulemaking proceeding under this section, OSHA will so notify the applicant and afford the applicant 

the opportunity to submit the supplemental information. Initiation of a rulemaking proceeding will be 

deferred until OSHA has received and evaluated the supplemental information. 

[63 FR 20098, April 23, 1998; 69 FR 46993, August 4, 2004]
Page 76 Health Hazard Evaluation Report 2011-0109-3162

Appendix B: Appendix B-1 of OSHA Respiratory Protection Standard

Appendix B. Appendix B-1 to § 1910.134: User Seal Check Procedures (Mandatory)

The individual who uses a tight-fitting respirator is to perform a user seal check to ensure that an adequate 

seal is achieved each time the respirator is put on. Either the positive and negative pressure checks listed in 

this appendix, or the respirator manufacturer’s recommended user seal check method shall be used. User 

seal checks are not substitutes for qualitative or quantitative fit tests. 

I. Facepiece Positive and/or Negative Pressure Checks 

A. Positive pressure check. Close off the exhalation valve and exhale gently into the facepiece. The 

face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece 

without any evidence of outward leakage of air at the seal. For most respirators this method of 

leak testing requires the wearer to first remove the exhalation valve cover before closing off the 

exhalation valve and then carefully replacing it after the test. 

B. Negative pressure check. Close off the inlet opening of the canister or cartridge(s) by covering with 

the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the facepiece collapses 

slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges 

cannot be effectively covered with the palm of the hand. The test can be performed by covering 

the inlet opening of the cartridge with a thin latex or nitrile glove. If the facepiece remains in its 

slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator 

is considered satisfactory. 

II. Manufacturer’s Recommended User Seal Check Procedures 

The respirator manufacturer’s recommended procedures for performing a user seal check may be used 

instead of the positive and/or negative pressure check procedures provided that the employer demonstrates 

that the manufacturer’s procedures are equally effective. 

[63 FR 1152, Jan. 8, 1998]
Health Hazard Evaluation Report 2011-0109-3162 Page 77

Acknowledgements and

Availability of Report

The Respiratory Disease Hazard Evaluation and Technical 

Assistance Program (RDHETAP) of NIOSH conducts field 

investigations of possible health hazards in the workplace. These 

investigations are conducted under the authority of Section 20(a)

(6) of the Occupational Safety and Health (OSH) Act of 1970, 29 

U.S.C. 669(a)(6), or Section 501(a)(11) of the Federal Mine Safety 

and Health Act of 1977, 30 U.S.C. 951(a)(11), which authorizes 

the Secretary of Health and Human Services, following a written 

request from any employers or authorized representative of 

employees, to determine whether any substance normally found 

in the place of employment has potentially toxic effects in such 

concentrations as used or found.

RDHETAP also provides, upon request, technical and consultative 

assistance to federal, state, and local agencies; labor; industry; and 

other groups or individuals to control occupational health hazards 

and to prevent related trauma and disease. 

Mention of any company or product does not constitute 

endorsement by NIOSH. In addition, citations to websites 

external to NIOSH do not constitute NIOSH endorsement of 

the sponsoring organizations or their programs or products. 

Furthermore, NIOSH is not responsible for the content of these 

websites. All web addresses referenced in this document were 

accessible as of the publication date.

This report was prepared by Randy Boylstein, Rachel Bailey, Chris 

Piacitelli, Christine Schuler, Jean Cox-Ganser, and Kathleen 

Kreiss of the Field Studies Branch, Division of Respiratory Disease 

Studies. Desktop publishing was performed by Tia McClelland. 

We acknowledge David Brittain, Anne Marie Gibson, Kimberlee 

Musser, Brenda Naizby, Dianna Schoonmaker-Bopp, and Erin 

Spier, New York State Department of Health; and Johannes Peters, 

Sally Wheeland, Marilyn Reynolds, and Justin Lewis, county health 

department. 

Copies of this report have been sent to the shredding facility, local 

county health department, New York State Department of Health, 

and the OSHA Regional Office. This report is not copyrighted and 

may be freely reproduced. The report may be viewed and printed 

at www.cdc.gov/niosh/hhe/. Copies may be purchased from the 

National Technical Information Service (NTIS) at 5825 Port Royal 

Road, Springfield, Virginia 22161.
Below is a recommended citation for this report:

NIOSH [2012]. Health Hazard Evaluation Report: Legionnaires’ disease at an 

automobile and scrap metal shredding facility, New York. Morgantown, WV: U.S. 

Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, NIOSH HETA 

No. 2011-0109-3162.

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