Evaluation of 

respiratory concerns 

at a snack food 

production facility

Kristin J. Cummings, MD, 

MPH, Chris Piacitelli, MS, 

CIH, Marcia Stanton, BS, 

Rachel L. Bailey, DO, MPH

Health Hazard Evaluation Report

HETA 2011-0037-3172

New York

March 2013

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 2011-0037-3172 Page 1

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

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

Summary .............................................................................7

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

Process Description.............................................................9

Assessment.......................................................................13

Results...............................................................................15

Discussion .........................................................................24

Conclusions.......................................................................28

Recommendations.............................................................29

Update since Site Visit.......................................................32

References ........................................................................33

Contents

Table 1 ..............................................................................35

Table 2 ..............................................................................36

Table 3 ..............................................................................37

Acknowledgments

Tables

Acknowledgments and Availability of Report.....................38
Page 2 Health Hazard Evaluation Report 2011-0037-3172

ACGIH® American Conference of Governmental Industrial Hygienists

BOOP Bronchiolitis obliterans organizing pneumonia

CFR Code of Federal Regulations

FEV1 Forced expiratory volume in one second

FVC Forced vital capacity

HEPA High-efficiency particulate air

HHE Health hazard evaluation

Ig Immunoglobulin 

L Liters

Lpm Liters per minute

mg/m3 Milligrams per cubic meter

MSDS Material safety data sheet

NAICS North American Industry Classification System

NIOSH National Institute for Occupational Safety and Health

NSIP Non-specific interstitial pneumonia 

OSHA Occupational Safety and Health Administration

PBZ Personal breathing zone

PEL Permissible exposure limit

ppb Parts per billion

PPE Personal protective equipment

REL Recommended exposure limit

STEL Short-term exposure limit 

TLV Threshold Limit Value

TWA Time-weighted average

VOC Volatile organic compound

VPP Voluntary Protection Program

Abbreviations
Health Hazard Evaluation Report 2011-0037-3172 Page 3

In December 2010, the National Institute for Occupational Safety 

and Health (NIOSH) received a confidential employee request for a 

health hazard evaluation (HHE) at a snack food production facility 

in New York. The employees submitted the HHE request because 

of concerns about exposures to flavoring chemicals, seasonings, 

and materials encountered during cleaning activities, and concerns 

about lung disease. NIOSH investigators conducted an evaluation 

that included a visit to the facility in May 2012.

What NIOSH Did

● We interviewed employees, managers, and the company’s 

medical consultant by telephone.

● We reviewed documents, including material safety data 

sheets, environmental sampling reports, medical records, and 

the facility’s respiratory protection program.

● We toured the facility.

● We conducted in-person, private interviews with 25 

employees who were randomly selected by NIOSH from the 

facility’s roster.

● We collected air samples for volatile chemicals during nacho 

cheese tortilla chip production.

● We collected bulk samples of seasonings and analyzed them 

in a laboratory for volatile chemicals given off into the air.

● We qualitatively assessed a seasoning hopper’s local exhaust 

ventilation. 

● We observed sanitation employees cleaning the processed 

potato crisp line.

● We collected air samples for sodium hydroxide during 

sanitation activities.

What NIOSH Found

● Previous air sampling results indicated low concentrations 

of the butter flavoring chemical diacetyl and higher 

concentrations of a diacetyl substitute, 2,3-hexanedione, for 

which toxicity has not been determined. 

● Many of the ingredients used at the facility are potential 

respiratory irritants and/or allergens.

Highlights of the

NIOSH Health

Hazard Evaluation
Page 4

Highlights of the

NIOSH Health

Hazard Evaluation

(continued)

Health Hazard Evaluation Report 2011-0037-3172

● Many of the cleaning chemicals used at the facility are 

potential respiratory irritants.

● Material safety data sheets for some seasonings commented 

on the ability of steam or hot water used during cleaning to 

increase vapor concentrations. They recommended keeping 

all heated processes at the lowest necessary temperature to 

minimize emission of volatile chemicals into the air. 

● Material safety data sheets for some seasonings recommended 

avoiding contact with strong acids, alkali, or oxidizing agents. 

● Material safety data sheets for some seasonings recommended 

the use of chemical-resistant gloves while handling the 

seasoning.

● An employee developed an uncommon lung disease, 

hypersensitivity pneumonitis, that treating physicians 

concluded was related to exposures to organic dusts at the 

facility.

● Compressed air is used for cleaning in many areas of the 

facility.

● Sanitation employees periodically clean organic sludge off 

the surface of an outdoor clarifying tank using pressurized 

water and no respiratory protection.

● Sanitation employees routinely clean the metered dispensing 

system and storage containers for a potentially hazardous 

catalyst used in the production process.

● Handling ventilation filters from the seasoning hoppers, 

cleaning the carton baler, filling the seasoning bag baler, and 

sweeping the corn sorting room may generate organic dust in 

the air. 

● Interviewed employees noted respiratory irritation from 

certain spicy seasonings, but otherwise did not report workrelated respiratory symptoms.

● Interviewed employees indicated awareness of the availability 

of disposable respirators for voluntary use.

● Diacetyl was detected in three air samples at levels that 

were too low to quantify, and 2,3-pentanedione and 2,3-

hexanedione were not detected in any samples.

● Trace amounts of diacetyl were detected in four of the 

seasoning bulk samples.

● Sodium hydroxide was detected in one air sample at a level 

that was too low to quantify.
Health Hazard Evaluation Report 2011-0037-3172 Page 5

Highlights of the

NIOSH Health

Hazard Evaluation

(continued)

What the Employer Can Do

● Until more is known about the safety of diacetyl substitutes, 

ensure that ingredients containing these butter flavors are 

handled as respiratory hazards. 

● Follow seasoning manufacturers’ recommendations on 

keeping all heated processes (including sanitation processes 

using hot water) at the lowest necessary temperature in order 

to minimize emissions of volatile chemicals into the air.

● Consult with seasoning suppliers and cleaning product 

suppliers about the possible incompatibility of seasonings 

with cleaning agents and any need for elimination or 

substitution.

● Follow seasoning manufacturers’ recommendations regarding 

the use of chemically-resistant gloves. 

● Substitute vacuum cleaning with HEPA filters for compressed 

air cleaning and sweeping wherever feasible.

● Discourage employees from openly shaking or otherwise 

removing seasoning dust from ventilation filters, and 

investigate measures that could avoid clogging of the filters. 

● Continue to explore ways to reduce dust generation during 

the handling of seasoning bags, particularly related to filling 

the seasoning bag baler.

● Require mandatory use of a fit-tested full-facepiece respirator 

with particulate cartridges for cleaning the clarifying tank.

● Require mandatory use of respiratory protection with 

HEPA/P100 filters for cleaning the metered dispensing 

system and storage containers for the catalyst.

● Consider requiring mandatory respiratory protection for 

other potential dust-generating tasks.

● Encourage employees to report new or ongoing respiratory 

symptoms, particularly those with a work-related pattern, to 

the facility’s nurse.

● The occurrence of new or ongoing respiratory symptoms in 

the workforce should prompt consideration of work-related 

lung disease and re-evaluation of the potential for exposure 

to respiratory hazards.

 
Page 6 Health Hazard Evaluation Report 2011-0037-3172

Highlights of the

NIOSH Health

Hazard Evaluation

(continued)

What Employees Can Do

● Use local exhaust ventilation systems as instructed by your 

employer.

● Use caution when handling seasoning bags and ventilation 

filters to reduce dust generation.

● Follow your employer’s rules about mandatory use of 

respiratory protection and other personal protective 

equipment and clothing.

● Consider voluntary use of respiratory protection for other 

tasks that seem dusty.

● Report new or ongoing respiratory symptoms, particularly 

those with a work-related pattern, to the facility’s nurse and 

your personal physician.
Health Hazard Evaluation Report 2011-0037-3172 Page 7

In December 2010, the National Institute for Occupational Safety 

and Health (NIOSH) received a confidential employee request 

for a health hazard evaluation (HHE) at a snack food production 

facility in New York. The facility produces potato chips, corn 

chips, and other savory snack foods. The employees submitted the 

HHE request because of concerns about exposures to flavoring 

chemicals, seasonings, and materials encountered during cleaning 

activities, and concerns about breathing problems and lung disease. 

We initiated the evaluation by interviewing employees, managers, 

treating physicians, the facility’s nurse, and the company’s medical 

consultant by telephone. We also reviewed documents provided to 

NIOSH prior to the site visit, including material safety data sheets. 

From May 14-16, 2012, we visited the facility. We toured the 

facility, interviewed managers, the facility’s nurse, the respiratory 

protection program administrator, and 25 randomly selected 

employees, and observed sanitation activities. We collected 

air samples during production and sanitation activities and 

collected bulk samples of seasonings for analysis of volatile organic 

compounds. We also collected additional documents, including 

records pertaining to the respiratory protection program. 

We found that the facility uses multiple substances that are 

respiratory irritants and/or allergens and that previous air sampling 

demonstrated the presence of the butter flavoring chemical diacetyl 

and diacetyl substitutes. One worker developed an uncommon 

immune-mediated lung disease, hypersensitivity pneumonitis, 

during employment that treating physicians concluded was caused 

by exposures to organic materials at the facility. During our site 

visit, we noted opportunities for potential respiratory exposure 

to organic materials from sources including corn and potatoes, 

seasonings, cardboard, sludge from a clarifying tank, and a catalyst. 

We detected diacetyl in three air samples at levels that were too 

low to quantify and found trace amounts of diacetyl in four bulk 

samples of seasonings. We detected sodium hydroxide in one air 

sample at a level that was too low to quantify.

Until more is known about the safety of diacetyl substitutes, we 

recommend that seasonings that contain these substitutes be 

handled as respiratory hazards. We recommend reducing the 

potential for respiratory exposures to organic materials through 

a combination of enhanced engineering controls, modified work 

practices, and mandatory use of respiratory protection. Results 

of industrial hygiene evaluations should be interpreted with the 

A case of an uncommon 

immune-mediated lung 

disease occurred in the 

workforce of a snack food 

production facility where 

multiple respiratory irritants 

and/or allergens are used. 

We noted opportunities 

for potential exposure to 

airborne organic materials 

that pose a risk of immunemediated lung disease. We 

recommend a combination 

of enhanced engineering 

controls, modified work 

practices, and mandatory 

use of respiratory protection 

to reduce risk.

Summary
Page 8 Health Hazard Evaluation Report 2011-0037-3172

Summary (continued)

knowledge that permissible exposure limits for dust or specific 

chemicals (where they exist) may not be protective for an immunemediated health outcome. Employees should be encouraged to 

report new or persistent respiratory symptoms to the facility’s 

nurse. The occurrence of such symptoms in the workforce should 

prompt consideration of work-related lung disease, re-evaluation of 

the potential for exposure to respiratory hazards, and lowering of 

such exposures. 

Keywords: NAICS 311919 (Other Snack Food Manufacturing), 

hypersensitivity pneumonitis, respiratory symptoms, occupational 

lung disease, flavorings, diacetyl, organic dust, bioaerosols, 

seasonings, sanitation, engineering controls, personal protective 

equipment.

Introduction In December 2010, the National Institute for Occupational Safety 

and Health (NIOSH) received a confidential employee request 

for a health hazard evaluation (HHE) at a snack food production 

facility in New York. The employees submitted the HHE request 

because of concerns about exposures to flavoring chemicals, 

seasonings, and materials encountered during cleaning activities, 

and concerns about breathing problems and lung disease. The 

employees indicated that they were not aware of investigations of 

the facility by the New York State Department of Health and the 

Occupational Safety and Health Administration (OSHA) done in 

2010. We provided the requesting employees with the reports from 

these previous evaluations, which were focused on exposures to 

butter flavoring chemicals. After reviewing these reports, in May 

2011 the employees reiterated their request for the HHE. 
Health Hazard Evaluation Report 2011-0037-3172 Page 9

The plant employs approximately 500 persons and produces 

multiple corn, potato, and grain-based snacks. Production 

activities include receiving, storing, washing, processing, cooking, 

frying, and packaging. The plant is divided into distinct processing 

areas, which feed into the packaging area. The processing areas 

include potato chips, corn chips, tortilla chips, and potato crisps.

Production

Potato chip processing: Potatoes directly from the field are 

delivered to the processing facility via tractor-trailer trucks several 

times a day. The potatoes are unloaded onto a conveyor system. 

An inspection process removes dirt, pebbles, and undesirable 

potatoes, which are put in a plastic bin. The satisfactory potatoes 

enter the production process where they are peeled, washed, sliced, 

and washed again. The process water is treated with a sanitizer to 

enable re-use. The potato slices enter the fryer. Upon exiting the 

fryer, unsatisfactory chips are removed and deposited into a bin. 

The rest of the chips are sorted onto conveyors and seasoned as 

they move through seasoning tumblers. The potato chips are then 

conveyed to the packaging area.

Corn chip and tortilla chip processing: There are some differences 

in production of corn and tortilla chips, but in general corn is 

delivered via railcars and stored in silos. Corn from the silos is 

fed into two hoppers in the corn sorting room where it is sorted 

and sent to the processing area. The corn is processed, which may 

include soaking and washing. The corn is then ground into meal 

and cut into the product shape. Tortilla chips are sent through 

an oven. As with potato chips, the corn chips and tortilla chips 

are fried and seasoned as they move through seasoning tumblers. 

In the processing of corn, a catalyst is also added using a metered 

dispensing system. 

Potato crisp processing: This product is made from a blend of 

potatoes, corn, and grain. The crisps are fed into a fryer and 

seasoned with salt in a tumbler prior to packaging. 

At each processing line in the facility, bags of powdered seasoning 

are manually emptied into a hopper that feeds the tumbler system. 

Empty seasoning bags are placed in a bin adjacent to the hopper; 

each bin is covered with a plastic sheet. The bags are subsequently 

baled at another location in the plant. In 2003, local ventilation 

systems with high-efficiency particulate air (HEPA) filters that 

Process Description
Page 10 Health Hazard Evaluation Report 2011-0037-3172

Process Description (continued)

discharge the filtered air back into the room were installed at the 

feed areas of the hoppers. Tortilla chip production lines 1 and 2 

were also equipped with a local ventilation system in 2005 that 

includes end caps on the tumblers as well as a seasoning control 

system serving both tumblers that contains a water bath through 

which air from the tumblers passes to remove dust particles before 

the air is sent back into the room. This system was installed for 

these lines in order to more effectively manage the more frequently 

used seasonings. Each fryer is equipped with a stack that exhausts 

hot fryer oil emissions outside through the roof via the chimney 

effect. Those that are heated with gas also have a gas combustion 

exhaust stack. The corn chip fryer is insulated, and the insulation 

is inspected periodically.

Packaging: Loose chips enter the packaging area on conveyor belts 

and are weighed. The weighing machines are separated by clear 

plastic curtains. The chips are then packaged into individual 

bags and then into cardboard boxes for shipping. The packaging 

machines are operated by packaging machine operators. One of 

the packaging machines has a vacuum installed to remove broken 

chips before packaging. Packers fill the cardboard boxes that come 

from the box drop area. Incoming boxes are sorted and categorized 

for use in an area adjacent to packaging. 

Sanitation

The sanitation process is routinely conducted by trained sanitation 

personnel who follow a standard process of equipment cleaning 

and sanitizing. All products used during cleaning and sanitation 

are stored in color-coded bulk containers in a central location. 

Members of the sanitation team use a dispensing system for 

preparation of proper dilutions of product. Cleaning products 

used include bleach, detergent, sodium hydroxide, nitric acid, and 

phosphoric acid.

Corn sorting room: The corn sorting room undergoes routine 

dry sweeping by operators. On a periodic basis, a more extensive 

cleaning is conducted that includes use of compressed air. 

Processing Lines: Detergent and water mixture is added to fill 

tanks under the potato peeler and slicers and circulated and then 

drained. Water is then added to rinse out the cleaning chemicals 

and then a sanitizer is added and run throughout the system. The 

equipment within processing is rinsed using a combination of 
Health Hazard Evaluation Report 2011-0037-3172 Page 11

Process Description (continued)

low pressure cool water and high pressure hot water (minimum 

140° F). After being thoroughly rinsed, a strong alkaline solution 

is introduced through a foaming process. After proper resident 

time, the chemical is subsequently removed through high pressure 

hot water rinse. The frying equipment within processing is also 

rinsed using a combination of low pressure cool water and high 

pressure hot water. After being thoroughly rinsed, chemical is 

introduced to the fryer and mixed with water and then brought up 

to temperature to “boil out.” After boiling out for adequate time, 

the fryer is drained of the chemical/water mixture and then rinsed 

thoroughly and the pH checked. 

The exterior of the fryer is cleaned using the same process 

described above. During sanitation, a plastic curtain is drawn 

around the processing line being cleaned. The building ventilation 

is changed during the process to maintain the area being cleaned 

at negative pressure with respect to surrounding areas and keep air 

from escaping from the enclosed area. 

Catalyst system: The metered dispensing system and the storage 

containers for the catalyst are periodically cleaned. 

Packaging: The packaging equipment is cleaned routinely by 

hand using a combination of cleaning towels, scrapers, and a mild 

detergent. The areas are first wiped/scraped free of residual snack 

crumbs. Once minimal residual remains, hard to reach areas may 

be cleaned using high pressure compressed air, followed by the 

application of mild detergent. This step is followed by a water 

rinse to remove any detergent residue and finally, the area is wiped 

dry to ensure it is clean and sanitized. 

Carton baler: The carton baler is manually cleaned periodically. 

Clarifying tank: Waste water from production processes is 

collected in an outdoor clarifying tank. Over the course of several 

hours, solid matter is allowed to settle out before the water enters 

the municipal treatment system. The solid matter is removed by 

an automated system. The clarifying tank is cleaned on an annual 

basis by two sanitation personnel. The tank is drained and cleaned 

using high pressure water. This task takes several hours.

Box drop area: This area is routinely swept and a shop vacuum 

used.

A pest control operator periodically checks pest traps and insect 
Page 12 Health Hazard Evaluation Report 2011-0037-3172

Process Description (continued)

lights, occasionally applies pesticides, and routinely aerates 

incoming railcars when the corn they are carrying has been treated 

with phosphine.

Personal Protective Equipment (PPE)

Employees are required to follow Good Manufacturing Practices in 

all production areas, which includes specific attention to personal 

hygiene, hair covering, and work practices to prevent product 

contamination. 

Employees in the production areas wear company-provided 

uniforms and are required to wear steel toe shoes with non-skid 

soles, hearing protection, and safety glasses/goggles. Employees 

must go through a Clean Room area where they put on hair covers 

and beard nets (if applicable), use adhesive rollers on their clothing 

to remove hair or other debris, and wash their hands with warm 

water and antimicrobial soap. Finally, employees pass through an 

air shower to remove any remaining hair and debris before entry to 

the production area. Jewelry is not allowed in the production area. 

Workers handling the catalyst at dispensers are required to wear 

nitrile gloves. 

In the production areas, some employees are required to wear 

rubber, heat resistant, or steel mesh gloves. During the application 

and rinsing of cleaning/sanitizing chemicals, sanitation personnel 

are required to wear “full PPE” consisting of waterproof boots, 

chemical resistant suits made of nylon with a polyurethane film, 

green rubber gloves, and face shields, in addition to the safety 

glasses/goggles and hairnets. 

The Respiratory Protection Program 

The facility has a written respiratory protection program. 

Disposable N-95 filtering facepiece respirators are required in 

the corn sorting room during periodic extensive cleaning using 

compressed air, but not for routine sweeping. Disposable N-95 

filtering facepiece respirators are recommended 1) for corn cooks, 

2) when cleaning the carton baler, and 3) in the seasoning areas. 

Maintenance personnel are required to wear half- or full-facepiece 

respirators with particulate filters when installing or removing 

insulation at the corn fryers. Pest control operators are required 

to wear full-facepiece respirators with organic vapor cartridges 

and particulate filters when applying pesticides and full-facepiece 

respirators with fumigant cartridges when testing for phosphine 
Health Hazard Evaluation Report 2011-0037-3172 Page 13

Process Description (continued)

gas in the train cars. Half- or full-facepiece respirators are 

recommended for sanitation personnel who use caustic or acidic 

cleaning chemicals. 

Workers who are required to wear respirators receive annual 

training, medical evaluation, and qualitative fit-testing. Other 

workers who choose to use respirators on a voluntary basis receive 

annual training and review and sign Appendix D (Information 

for Employees Using Respirators When Not Required under the 

Standard) of the OSHA Respiratory Protection Standard, 29 Code 

of Federal Regulations (CFR) 1910.134. 

Assessment Prior to the site visit, we interviewed employees, managers, 

treating physicians, the facility’s nurse, and the company’s medical 

consultant by telephone. We also reviewed documents provided 

to NIOSH, including reports of prior environmental evaluations 

by other government agencies and by consultants hired by the 

company, medical records and workers’ compensation records, 

material safety data sheets (MSDSs) for ingredients and cleaning 

products, the facility’s OSHA Logs of Work-related Injuries and 

Illnesses for 2006-2011, a facility map, and an employee roster 

including departments and job titles.

From May 14-16, 2012, we visited the facility. We held an opening 

meeting with employer and employee representatives. We toured 

the facility to understand processes, job tasks, controls in place to 

reduce exposures, and the use of PPE. We interviewed managers, 

the facility’s nurse, and the respiratory protection program 

administrator. We conducted private interviews about work 

history and health concerns with 25 employees whom we had 

randomly selected from the facility’s roster to represent a crosssection of the workforce. We collected additional documents, 

including records pertaining to the respiratory protection program, 

the hazard communication program, the company’s industrial 

hygiene strategy, PPE requirements, job safety analyses, precautions 

for handling the sanitizer and the catalyst, and the facility’s 

response to recommendations made by its medical consultant.

We collected air samples for volatile organic compounds (VOCs) 

during nacho cheese tortilla chip production. Five personal 

breathing zone (PBZ) and three area air samples were collected 

using evacuated canisters. The 450-milliliter canisters were 
Page 14 Health Hazard Evaluation Report 2011-0037-3172

Assessment (continued)

equipped with either instantaneous grab sampling attachments 

(n = 3) or capillary-based flow controllers (n = 5). The air 

samples were analyzed for VOCs using a pre-concentrator/gas 

chromatograph/mass spectrometer system pursuant to a recently 

published method validation study [LeBouf et al. 2012] with the 

following modifications: the pre-concentrator was a Model 7150 

(Entech Instruments, Inc., Simi Valley, California); three additional 

analyte compounds, the alpha-diketones 2,3-butanedione (diacetyl), 

2,3-pentanedione, and 2,3-hexanedione, were included; and 

qualitatively-identified compounds were compared to National 

Institute of Standards and Technology 2008 Mass Spectral Library 

and included in the analytical report if the quality factor was 

greater than 75%. At present, this canister method is partially 

validated and is in the process of being reviewed for incorporation 

into the NIOSH Manual of Analytical Methods. 

We also collected bulk samples of seven seasonings that were being 

used at the time of our air sampling or had ingredients listed in 

their MSDSs that might contain butter flavoring compounds for 

headspace analyses using thermal desorption, gas chromatography, 

and mass spectrometry. Approximately 40 milliters of each 

seasoning were placed in 50-milliliter sterile polypropylene 

centrifuge tubes. At the laboratory, a sample of the headspace 

above each sample was collected at room temperature using a 

thermal desorption tube and desorbed at 300° C for 10 minutes 

in a Unity/Ultra automatic thermal desorption system (Markes 

International, Inc., Cincinnati, Ohio) with an internal focusing 

trap packed with graphitized carbon sorbents. The thermal unit 

was interfaced directly to an HP6890A gas chromatograph (Agilent 

Technologies, Inc., Santa Clara, California) with an HP5973 mass 

selective detector using a 30-meter HP-1MS fused silica capillary 

column. 

We qualitatively assessed the local exhaust ventilation of a 

seasoning hopper, using smoke tubes to observe air movement 

around the seasoning hopper feed area when the door was 

open during loading of seasonings and when the door was 

closed. Additionally, we used real-time instruments: a toxiRAE 

photoionization detector (Model PGM-30, RAE Systems, San Jose, 

California) to measure total VOCs, and a particulate monitor 

(pDR-1000AN personal DataRAM, Thermo Scientific Corp., 

Franklin, Massachusetts) to measure airborne dust, approximately 

respirable in size.

We observed two sanitation workers cleaning the potato crisp 
Health Hazard Evaluation Report 2011-0037-3172 Page 15

Assessment (continued)

line with a sodium hydroxide cleaner using a foaming process 

and collected five personal air samples for sodium hydroxide 

during their sanitation activities. The samples were collected 

on 37-millimeter diameter, 0.8-micrometer pore size cellulose 

ester membrane filters in two-piece cassettes at a nominal flow 

rate of 3 liters per minute (Lpm). The samples were analyzed 

for sodium using inductively coupled plasma atomic emission 

spectroscopy according to NIOSH Method 7303 [NIOSH 2003]. 

Sodium hydroxide results were then calculated from the sodium 

results assuming all sodium detected was in the form of sodium 

hydroxide.

At the end of our visit, we held a closing meeting with employer 

and employee representatives to share our observations and 

preliminary recommendations. 

Results SUMMARY OF PRIOR INDUSTRIAL HYGIENE 

EVALUATIONS

The company provided us with reports from nine industrial 

hygiene consultant investigations at the plant from March 1998 

through January 2012. Sampling was conducted for: 

● Calcium hydroxide during three investigations and acetic 

acid and hydrogen peroxide twice in processing areas, 

● Sodium hydroxide six times and nitric and phosphoric acids 

five times during cleaning of equipment,

● Particulates five times on the production lines,

● Diacetyl four times, acetoin and 2,3-hexanedione two times, 

and 2,3-pentanedione once near application of seasonings, 

● Hexavalent chromium three times during stainless steel 

welding, 

● Phosphine once on the pest control operator at the railcars, 

● Carbon monoxide three times on forklifts, and 

● Noise during five evaluations.

No air concentrations were found to exceed OSHA permissible 

exposure limits (PELs), American Conference of Governmental 

Industrial Hygienists (ACGIH®) Threshold Limit Values (TLVs), 

or NIOSH recommended exposure limits (RELs) [CFR 2012; 
Page 16 Health Hazard Evaluation Report 2011-0037-3172

Results (continued)

ACGIH 2012; NIOSH 2005]. Consultant reports noted noise 

exposures above the OSHA action level of 85 decibels but below 

the OSHA PEL of 90 dBA on the A-weighted scale (dBA) in some 

job classifications. The facility has a hearing conservation program, 

and employees are required to wear hearing production in all 

production areas. 

We noticed in a November 2008 consultant report a discrepancy 

between the laboratory-reported air sample volume (33.8 liters [L]) 

and the volume calculated using the reported sampling time and 

rate (50 minutes x 0.1 Lpm = 5 L) for nitric acid air sampling. It 

is possible that the reported 5.9 milligrams per cubic meter of 

air (mg/m3) was instead nearly 40 mg/m3 – well over the shortterm exposure limit (STEL) of 10 mg/m3

 for nitric acid. During 

this same investigation, the consultant surveyed the laboratory 

hood ventilation system. The consultant measured an acceptable 

air flow at only one of the two sash height demarcations and 

recommended removal of the other demarcation. 

In an April 2010 industrial hygiene report, the consultant collected 

four PBZ air samples for particulates not otherwise regulated on 

employees who empty bags of seasoning into hoppers. Eight-hour 

time-weighted average (TWA) concentrations ranged from 0.23 

mg/m3 to 3.11 mg/m3, which were below the OSHA PEL of 15 

mg/m3. The consultant noted that manually compacting the 

empty bags in bins near the hoppers created visible dust, and he 

suggested work practice changes to minimize exposure. He also 

collected a 4.4-hour air sample for diacetyl above a bin for empty 

seasoning bags between hoppers supplying the nacho cheese and 

spicy sweet chili lines. He reported 0.57 parts per billion (ppb) of 

diacetyl. The proposed NIOSH REL for diacetyl is 5 ppb (8-hour 

TWA) and the proposed 15-minute STEL for diacetyl is 25 ppb 

[NIOSH 2011]. ACGIH has adopted a TLV for diacetyl of 10 ppb 

as an 8-hour TWA and 20 ppb as a 15-minute STEL [ACGIH 

2012]. 

In May 2010, OSHA visited the facility after a complaint was 

filed by a local occupational medicine physician about employees 

“experiencing breathing difficulties following exposure to 

flavorings and seasonings used in manufacturing, and cleaning 

chemicals used during sanitation process.” OSHA and an 

industrial hygiene consultant hired by the facility collected 

concurrent air samples. On PBZ samples from a tortilla chip line 

operator, the consultant detected 3.02 ppb of diacetyl, 3.98 ppb 
Health Hazard Evaluation Report 2011-0037-3172 Page 17

Results (continued)

of acetoin, and 234 ppb (subsequently recalculated as 159 ppb) of 

2,3-hexanedione, while OSHA detected 1.7 ppb of diacetyl and no 

acetoin or 2,3-hexanedione. There are no occupational exposure 

guidelines for acetoin or 2,3-hexanedione. Concurrent PBZ air 

samples for sodium hydroxide, phosphoric acid, and nitric acid 

on workers cleaning equipment such as fryers and ovens found air 

concentrations below the established occupational exposure limits 

of OSHA and ACGIH.

In July 2010, the New York State Department of Health collected 

samples for flavoring compounds at the facility and requested 

technical assistance from NIOSH to provide air sampling 

equipment and analytical laboratory services. Industrial hygienists 

from the health department collected bulk samples and area 

and PBZ air samples at the facility. Headspace analyses detected 

diacetyl, 2,3-pentanedione, 2,3-hexanedione, and acetoin in two 

bulk samples of ingredients. When the area and PBZ air samples 

were tested for diacetyl, 2,3-pentanedione, 2,3-hexanedione, 

and 2,3-heptanedione, none of these flavoring compounds were 

detected in the area air sample collected at a tortilla chip line 

seasoning hopper or PBZ air sample collected on a worker at the 

tortilla chip line whose job included emptying seasonings into the 

hopper. The minimum detectable concentrations ranged from 

2 to 3 ppb for the samples. The NIOSH proposed REL for 2,3-

pentanedione is 9.3 ppb TWA with a proposed STEL of 31 ppb 

[NIOSH 2011]. Occupational exposure guidelines do not exist 

for 2,3-heptanedione. Two other air samples were also collected 

for total VOC screening using thermal desorption tubes; however, 

these samples may have been mislabeled or contaminated, and 

therefore were uninterpretable. The consultant again collected 

concurrent samples in addition to a PBZ air sample on a worker 

who cleaned conveyors in the packaging area. Concentrations of 

diacetyl, acetoin, and 2,3-hexanedione were below the analytical 

laboratory’s limit of detection for these three air samples. The 

minimum detectable concentrations ranged from 3.5 ppb to 6.1 

ppb for diacetyl; 3.4 ppb to 6.0 ppb for acetoin; and 530 ppb to 

930 ppb for 2,3-hexanedione. 

The January 2012 industrial hygiene survey included PBZ 

sampling for diacetyl and 2,3-pentanedione on workers using 

nacho cheese seasoning during tortilla chip production. Diacetyl 

concentrations were less than 1.7 ppb and 2.4 ppb for the 3-hour 

and 2-hour sampling periods, respectively, while 2,3-pentanedione 

concentrations were less than 5.7 ppb and 8.3 ppb. 
Page 18 Health Hazard Evaluation Report 2011-0037-3172

Results (continued) SUMMARY OF PRIOR MEDICAL CONSULTANT 

EVALUATION

In 2011, the company requested that a pulmonary physician review 

information pertaining to employee occupational respiratory 

health. The consultant recommended that the facility 1) develop 

processes to ensure engineering controls were functionally effective, 

2) fine-tune work practices to minimize exposure to airborne 

seasonings, and 3) train employees on the types of adverse health 

effects that are associated with materials used in the facility and 

how to minimize such exposures. In response, the facility reported 

that it 1) developed process control sheets that are filled daily by 

operators, 2) had the air handling units inspected to ensure they 

met and exceeded state regulations, 3) developed an employee 

input protocol for optimal ventilation during cleaning activities, 

4) provided training to workers on numerous occasions, and 5) 

encouraged employees to report work-related concerns to the 

facility’s safety and occupational health coordinator. 

NIOSH EVALUATION

Workplace Observations and Employees’ Reports

We found the facility clean and organized. We observed employees 

in the production area wearing facility uniforms, hair covers, 

beard nets (if applicable) and PPE such as hearing protection, eye 

protection, and steel-toe shoes with non-skid soles. N95 filtering 

facepiece respirators were available for use and “recommended,” 

though not “required,” for some areas or tasks. 

We noted opportunities for potential respiratory exposure to 

organic particles. In production, we noted that manually emptying 

bags of powdered seasonings into a hopper that feeds the tumbler 

system may generate dust. We observed workers using different 

handling techniques, from very gentle to aggressive, when cutting 

and emptying seasoning bags into seasoning hoppers and disposing 

of seasoning bags in the waste bag bins. Some of these techniques 

generated plumes of dust in the worker’s breathing zone. Each 

waste bin had a plastic cover. 

Local exhaust ventilation was installed on the seasoning hoppers 

to reduce operators’ exposure to dust while loading the hoppers. 

However, employees described attempting to clean clogged filters by 

removing the filters from the ventilation units and shaking them in 

the open or hitting them against the hoppers. This activity would 

be expected to generate airborne dust. In addition, employees 
Health Hazard Evaluation Report 2011-0037-3172 Page 19

Results (continued)

indicated that filling the seasoning bag baler with the used bags 

was a dusty task. Formal industrial hygiene evaluation of this task 

had not been conducted prior to the NIOSH visit. 

We noted that compressed air is used for cleaning in many areas 

of the facility during sanitation. This practice has the potential 

to create exposures to irritating or sensitizing ingredients found 

in settled dust. In addition, routine cleaning of the corn sorting 

room involves sweeping, which may generate organic dust. Formal 

industrial hygiene evaluation of this task had not been conducted 

prior to the NIOSH survey. Furthermore, the periodic cleaning 

of the carton baler was described by employees as a dusty task. 

Formal industrial hygiene evaluation of this task had not been 

conducted prior to the NIOSH survey. Another task that could 

aerosolize organic material, including microbial antigens, is the 

cleaning of the clarifying tank.

We observed two instances of employees who were not wearing 

the jacket component of the chemical suit while using pressurized 

water to rinse chemicals from equipment. The PPE matrix 

provided by the company indicated that the jacket component was 

required for this task. The employees’ exposed skin (arms and 

face) became extremely wet from splashing, which may present an 

opportunity for dermal exposure to cleaning chemicals. 

MSDS Review

We reviewed 45 unique MSDSs for materials used at the facility, 

including 30 seasonings, 10 cleaning products, four other 

ingredients, and the sanitizer added to the process water to enable 

its re-use. The cleaning products contained a variety of agents, 

including bleach (sodium hypochlorite), acids, and sodium 

hydroxide. All of the MSDSs that we reviewed indicated that the 

material posed both skin and eye irritant hazards. In addition, 

43 MSDSs indicated that the material posed a respiratory irritant 

hazard. Eleven MSDSs, including those for 10 different seasonings 

and the one for the catalyst, indicated that the material posed an 

allergic hazard. Although none of the MSDSs for the cleaning 

products mentioned an allergic hazard, we noted that two of the 

cleaning products contained quaternary ammonium compounds, 

which have been described as sensitizers [Quirce and Barranco 

2010]. Several of the seasoning MSDSs commented on the ability 

of steam or hot water used during cleaning to increase vapor 

concentrations. The MSDSs recommended keeping all heated 

processes at the lowest necessary temperature to minimize emission 
Page 20 Health Hazard Evaluation Report 2011-0037-3172

Results (continued)

of volatile chemicals into the air. In addition, in the section on 

Stability and Reactivity, some seasoning MSDSs recommended 

avoiding contact with strong acids, alkali, or oxidizing agents. 

Finally, some seasoning MSDSs recommended the use of chemicalresistant gloves while handling the seasoning.

Health Concerns

Interviewed employees noted concerns about respiratory irritation 

from certain spicy seasonings, exposure to cardboard dust, dust 

generated when shaking out filters from the seasoning hopper, 

dust generation during baling of seasoning bags, skin irritation 

from sweating, excessive heat in the facility during the summer 

months, and ergonomic issues for some tasks that involve heavy 

lifting. They were generally aware of the availability of disposable 

respirators for voluntary use, although few reported using these 

respirators. 

We found that a facility employee developed an uncommon 

lung disease, hypersensitivity pneumonitis, during employment. 

This condition occurs when a person’s immune system becomes 

sensitized and reacts to something that a person repeatedly 

breathes into the lungs from his or her environment. Typically 

the sensitizing material comes from plants, animals, bacteria, or 

fungi. The immune reaction causes inflammation in the lungs and 

symptoms such as shortness of breath, cough, fever, and fatigue. 

The symptoms may improve when the person is away from the 

sensitizing material. Over time, if the person continues to breathe 

in the sensitizing material, irreversible scarring of the lungs can 

occur, leading to permanent disability or death. Additional details 

about this case follow, with the employee’s written permission. 

Case report: A 32-year-old man without a history of respiratory 

illness or smoking began working at the facility in 1998. A 

spirometry test at hire showed forced vital capacity (FVC) of 5.81 

L (92% of predicted), forced expiratory volume in 1 second (FEV1) 

of 4.09 L (80% of predicted), and FEV1/FVC ratio of 70%. He 

worked in the sanitation department from 1998 to 2003 and 

moved to the packaging department in 2003. In 2008, he returned 

to the sanitation department, with tasks as described in the section 

of this report entitled Process Description, Sanitation. 

In early 2009, he noted onset of watery eyes, nasal congestion, 

sneezing, and cough that he initially attributed to a cold. His 

symptoms progressed, and he began to experience shortness of 
Health Hazard Evaluation Report 2011-0037-3172 Page 21

Results (continued)

breath, particularly on exertion, and chest tightness, accompanied 

by fatigue, intermittent chills and fevers, and weight loss. His 

worsening cough was generally dry. Tasks at work that exacerbated 

his symptoms included cleaning processing lines and fryers using 

chemical cleaners and high pressure water, cleaning in packaging 

using compressed air, baling used seasoning bags, cleaning the 

carton baler, handling the sanitizer, cleaning the clarifying tank, 

and cleaning the metered dispensing system and the storage 

containers for the catalyst. He did not use respiratory protection 

for any tasks. In mid-2009, he transferred back to packaging due to 

his declining health, but his symptoms continued to worsen. He 

noticed that he developed blisters on the palms of his hands after 

dry-wiping spicy seasonings off packaging machines. 

In late 2009, he sought medical care for his symptoms, first with 

primary care and later with pulmonary and occupational medicine 

specialists. Spirometry showed FVC of 3.39 L (57% of predicted), 

FEV1of 2.67 L (57% of predicted), and FEV1/FVC ratio of 79%. 

There was no significant response to bronchodilator. Total lung 

capacity by plethysmography was 6.96 L (90% of predicted) and 

residual volume was 3.20 L (152% of predicted), indicating air 

trapping. His diffusing capacity was 29.15 milliliter per minute 

per millimeter of mercury (77% of predicted). High-resolution 

computed tomography (HRCT) of the chest with contrast 

showed diffuse centrilobular ground-glass opacities and mosaic 

attenuation, but no evidence of thromboemboli. The HRCT also 

showed enlargement of the main pulmonary artery consistent with 

pulmonary hypertension. Oxygen saturation on room air was 87% 

at rest and 83% with ambulation. He was started on supplemental 

oxygen, which he used when he was not at work. His symptoms 

did not improve with a one-week trial of an oral corticosteroid 

medication (prednisone). He began to experience difficulty getting 

to his vehicle at the end of a shift due to severe shortness of breath 

and fits of cough productive of bloody sputum (hemoptysis). He 

also noted blurry vision, dizziness, and nausea that was brought on 

by smells at work. He did not respond to a combination inhaler 

containing a bronchodilator and a corticosteroid (Advair) or to 

another one-week trial of prednisone. He left work in March 2010, 

at which point he had lost 70 pounds. He was short of breath at 

rest and remained hypoxic, with an oxygen saturation of 90-94% at 

rest with supplemental oxygen at 4 Lpm. 

He ultimately underwent thoracoscopic lung biopsy that revealed 

mild, cellular chronic interstitial pneumonia consistent with 
Page 22 Health Hazard Evaluation Report 2011-0037-3172

Results (continued)

chronic hypersensitivity pneumonitis. It was accentuated around 

the bronchioles and characterized by a lymphoplasmacytic infiltrate 

within alveolar septae. There were scattered lymphoid follicles 

with germinal centers and scattered multinucleated giant cells and 

loose non-necrotizing granulomas, especially in peribronchiolar 

interstitium. An extensive search did not identify a specific cause. 

Erythrocyte sedimentation rate was normal. Serum rheumatoid 

factor was elevated at 31, but other serologies (anti-CCP, antiSSA, anti-SSB, anti-SCL70, ANA profile, ANA pattern and titer) 

were normal. Serum immunoglobulin (Ig)G was elevated and 

serum IgA and IgM were normal. Serum precipitins to grain dust 

and, since he was known to keep a pet lovebird in his home, to 

parakeet droppings, parrot droppings, lovebird serum, and lovebird 

droppings, were analyzed, and all were negative. 

Away from work, he noted improvement in his symptoms. He 

experienced prompt resolution of the eye and nasal symptoms, 

the hemoptysis, and the fever and chills. Over time, his cough 

gradually improved, and he began to gain back some of the 

weight he had lost. One year after leaving the workplace, his 

cough had nearly resolved, and his breathlessness had improved 

somewhat, though he remained short of breath at rest and on 

exertion. Spirometry showed FVC of 4.79 L (84% of predicted), 

FEV1 of 3.60 L (80% of predicted), and FEV1/FVC ratio of 75%. 

Diffusing capacity was 37.6 ml/mmHg/min (91% of predicted). 

Four months later, there was evidence of further improvement in 

lung function. Spirometry in August 2011 showed FVC of 5.14 L 

(90% of predicted), FEV1 of 3.96 L (85% of predicted), and FEV1/

FVC ratio of 77%. Diffusing capacity was 38.2 ml/mmHg/min 

(117% of predicted). At rest on room air, oxygen saturation was 

94% but fell to 91% during a short walk on supplemental oxygen 

at 2 Lpm. He remained on supplemental oxygen at night and as 

needed. In late 2011, exercise tolerance testing on room air showed 

reduced exercise tolerance (66% of predicted workload and 59% 

of predicted oxygen consumption). Arterial blood gas analysis on 

room air showed a low partial pressure of oxygen of 59 mm Hg, 

corresponding to an oxygen saturation of 90%. Total lung capacity 

was 8.6 L (110% of predicted), and residual volume was 3.44 L 

(181% of predicted), demonstrating persistent air trapping. 

On the basis of the clinical, radiological, and histopathological 

findings, he was diagnosed with hypersensitivity pneumonitis. 

Multiple consulting physicians concluded that his disease was 

caused by workplace exposures at the facility. They cited the 
Health Hazard Evaluation Report 2011-0037-3172 Page 23

Results (continued)

likely exposure to airborne organic materials in the workplace, the 

substantial improvement in his clinical status following removal 

from the workplace, the absence of findings of autoimmune 

disease, the absence of immune response to the lovebird in his 

home, and the improvement despite the persistence of the lovebird 

in his environment. 

Our review of the OSHA Logs of Work-related Injuries and 

Illnesses for 2006-2011, in-person interviews with 25 employees, 

and outreach to area pulmonologists did not reveal additional cases 

of hypersensitivity pneumonitis or other lung disease in employees 

of this facility as of mid-2012. 

NIOSH Air Sampling

Diacetyl, 2,3-pentanedione, and 2,3-hexanedione were not detected 

in the five PBZ canister samples from the processing line operators 

during nacho cheese tortilla chip production, as shown in Table 

1. The detection limits ranged from 2.8 to 6.0 ppb for diacetyl, 

3.4 to 7.2 ppb for 2,3-pentanedione, and 3.2 to 6.8 ppb for 2,3-

hexanedione. Although diacetyl was detected in three area samples 

collected instantaneously near the seasoning hopper, it was not 

quantifiable. Because it was detected between the detectable level 

of 1.3 ppb and the quantifiable level of 4.3 ppb, the reported 

concentrations of 1.4 to 1.7 ppb are considered estimates. The 

area samples did not detect 2,3-pentanedione or 2,3-hexanedione 

(detection limits of 1.5 and 1.6 ppb, respectively). The detection 

limit for one of the PBZ samples (6.0 ppb) was higher than the 

NIOSH proposed REL for diacetyl of 5 ppb; all other limits of 

detection and estimated concentrations were below any proposed 

or established occupational exposure guideline values. Ethanol, 

acetone, and isopropyl alcohol were detected in the canister 

samples at concentrations less than 1 part per million and well 

below any occupational exposure guidelines.

Table 2 shows the headspace analyses of bulk samples of 

seasonings. Trace amounts of diacetyl, but no other alpha-diketone 

compounds, were found in four of the seven samples: barbeque, 

honey barbeque, cheddar sour cream, and chili cheese. 

In our qualitative ventilation assessment of the seasoning hopper’s 

local exhaust ventilation at tortilla chip line 2, smoke was drawn 

into the hopper from all points in the feed zone where bags of 

seasoning are loaded with the door open. With the door closed, 

air flow was neutral at the door seams. Using the real-time 
Page 24 Health Hazard Evaluation Report 2011-0037-3172

Results (continued)

particulate and VOC monitors at the rear filter exhaust of the 

seasoning hopper, we found no change in the concentrations 

of 1.1 parts per million total VOCs and 0.4 mg/m3 particulate 

immediately before and while loading seasoning from a bag.

During the sanitation activities at the potato crisp line, sodium 

hydroxide was detected on one sample collected for 289 minutes 

on a sanitation worker (Table 3). The estimated concentration of 

0.02 mg/m3 was between the detectable level of 0.01 mg/m3 and 

the quantifiable level of 0.04 mg/m3 for the sample. The other 

worker’s long-term sample was not at a detectable concentration, 

and the 16-minute samples collected on both workers were each 

less than their detectable concentration of 0.21 mg/m3. These 

measurements were well below the occupational exposure 

guidelines. The OSHA PEL for sodium hydroxide is an 8-hour 

time-weighted average of 2 mg/m3. The NIOSH REL and ACGIH 

TLV are ceiling limits of 2 mg/m3 that should not be exceeded at 

any time.

We responded to an HHE request from employees at a snack food 

production facility who expressed concerns about exposure to 

flavoring chemicals, seasonings, and materials encountered during 

cleaning activities, and respiratory health. 

Flavorings (alpha-diketones)

Air sampling results from prior evaluations conducted by 

government agencies and private consultants hired by the company 

indicated low concentrations of the butter flavoring chemical 

diacetyl and higher concentrations of a diacetyl substitute, 2,3-

hexanedione, for which toxicity has not been determined. Our 

air sampling also found low concentrations of diacetyl, while 

2,3-pentanedione and 2,3-hexanedione were not detected. 

Occupational exposure to diacetyl can cause bronchiolitis 

obliterans, a rare lung disease in which the lung’s small airways 

become scarred, leading to breathlessness [NIOSH 2011]. It is 

important to note that bronchiolitis obliterans is distinct from 

hypersensitivity pneumonitis, the lung disease diagnosed in one of 

this facility’s employees. Studies of laboratory animals exposed to 

the diacetyl substitute 2,3-pentanedione indicate that it is also toxic 

to the respiratory system [Morgan et al. 2012; Hubbs et al. 2012]. 

Little is known about the toxicity of other diacetyl substitutes 

including 2,3-hexanedione. 

Discussion
Health Hazard Evaluation Report 2011-0037-3172 Page 25

Discussion (continued)

Seasonings

We reviewed MSDSs for 30 seasonings used at the facility. All 

of these seasonings were noted by their manufacturers to be 

respiratory irritants and 10 were noted to be allergens. Seasonings 

are a diverse group of substances, many plant-derived, with 

potential respiratory health effects. Seasonings were implicated in 

a disabling case of bronchiolitis obliterans organizing pneumonia 

(BOOP) that occurred in a worker at another snack food 

production facility [Allenman and Darcey 2002]. In that case, the 

worker’s primary responsibility was to empty bags of seasoning into 

a hopper, a task he described as “very dusty.” Immune reactions 

to curry powder and ground pepper were associated with a fatal 

case of non-specific interstitial pneumonia (NSIP) in a curry sauce 

production facility [Ando et al. 2006]. Allergy to some seasonings 

(paprika, coriander, mace, garlic, onion, and chili pepper) has been 

associated with occupational asthma [Sastre et al. 1996; Añibarro 

et al. 1997; van der Walt et al. 2010]. In spice factory workers, 

immune response to spice dust was common (73%) and associated 

with respiratory symptoms of cough, chest tightness, and throat 

irritation [Zuskin et al. 1988]. 

Cleaning products

In our review of MSDSs for 10 cleaning products used at the 

facility and the sanitizer added to process water to enable its re-use, 

all but two were noted by their manufacturers to be respiratory 

irritants. The cleaning compounds included acidic and caustic 

agents. Two of the cleaning compounds contained quaternary 

ammonium compounds. Company consultant air sampling has 

always found cleaning compound components to be present only at 

levels below occupational exposure guidelines, as did our sampling 

for sodium hydroxide during a cleaning operation; however, the 

discrepancy in reported values for nitric acid during one company 

sampling event raised the possibility of an overexposure. Although 

nitric acid was found at acceptable levels on other occasions, it may 

be useful to investigate any apparent differences in the conditions 

that may have led to the possible higher exposure so that 

overexposures can be avoided in the future. Cleaning products 

(including bleach, sodium hydroxide, and quaternary ammonium 

compounds) pose a risk of asthma, which may occur through 

an irritant or allergic mechanism [Quirce and Barranco 2010; 

Labrecque 2012]. In addition, acute respiratory distress syndrome 

in relation to exposure to cleaning products has been reported 

[Mapp et al. 2000]. Furthermore, the health effects of combining 

cleaning products with seasonings during sanitation activities are 
Page 26 Health Hazard Evaluation Report 2011-0037-3172

Discussion (continued)

unknown, but some seasoning MSDSs suggested this may pose a 

hazard.

The facility-provided PPE matrix prescribes the use of a full 

chemical suit during application of chemicals as well as during 

rinsing of chemicals from equipment. The matrix does not require 

the use of a full chemical suit during rinsing activities not involving 

the use of chemicals. We observed employees rinsing chemicals 

without the chemical suit jacket. Because of the potential for 

splashing of chemicals during the rinsing process, we agree with the 

matrix that a full chemical suit should be utilized during rinsing 

activities.

Hypersensitivity pneumonitis

We found that an employee developed an uncommon immunemediated lung disease, hypersensitivity pneumonitis, that treating 

physicians concluded was related to exposures to sensitizing organic 

dusts at work. Hypersensitivity pneumonitis has been reported 

with exposure to a wide variety of antigens including from fungi, 

bacteria, animals, and insects [Selman et al. 2012]. Because this 

condition involves an immune response, sensitized individuals may 

react to a relatively small amount of an organic agent and PELs, 

if they exist, may not be protective [NIOSH 1998]. During our 

visit, we noted the following multiple opportunities for exposure 

to organic materials that could pose a risk of hypersensitivity 

pneumonitis:

Corn and Potatoes

It has long been recognized that whole kernel corn is 

commonly infected by fungal species [Bothast et al. 

1974; Greene et al. 1992] and that unpeeled and peeled 

raw potatoes are associated with multiple bacteria 

and fungi [Doan and Davidson 2000]. Corn dust 

contaminated by fungi and bacteria was implicated in 

a case of hypersensitivity pneumonitis in a farm worker 

who grew and stored corn [Moreno-Ancillo et al. 2004]. 

Immune reaction to fungal antigens was associated with 

hypersensitivity pneumonitis in an onion and potato 

sorter [Merget et al. 2008]. We noted that routine 

sweeping in the corn sorting room may generate airborne 

corn dust and that using compressed air for cleaning in 

production and packaging areas may generate airborne 

corn and potato dust that may contain fungal or bacterial 

materials. 
Health Hazard Evaluation Report 2011-0037-3172 Page 27

Discussion (continued)

Seasoning

The diagnosis of hypersensitivity pneumonitis can be 

challenging, as lung biopsy specimens do not always reveal 

the classic findings of granulomatous inflammation. 

Hypersensitivity pneumonitis may mimic BOOP or NSIP 

pathologically [Lacasse et al. 2012]. Thus, the occurrence 

of BOOP in a snack food worker who emptied bags of 

seasonings into a hopper [Allenman and Darcey 2002] 

and NSIP in a curry sauce worker [Ando et al. 2006] may 

actually reflect a risk of hypersensitivity pneumonitis 

with seasoning exposures. We found that although the 

company has been proactive in installing engineering 

controls to reduce seasoning exposures, some work 

practices may create opportunities for exposure to 

seasoning dust. These practices include attempts to clean 

clogged filters from the local exhaust ventilation on the 

seasoning hoppers, placing empty seasoning bags in bins, 

and filling the seasoning bag baler. Unfortunately, in 

the case of the clogged filters, the engineering control 

provided to prevent worker exposure to seasonings during 

the hopper loading is presenting a new source of potential 

exposure. The fact that workers need to unclog its filters 

suggests the current system for keeping the filters clear 

needs to be improved. 

Cardboard

An investigation of an outbreak of hypersensitivity 

pneumonitis in an industrial setting demonstrated that 

corrugated cardboard dust (and heating-cooling ventilation 

units containing open spray chambers) contaminated 

with the fungus Aureobasidium pullulans was a source of 

exposure that contributed to disease [Woodard et al. 

1988]. In that outbreak, some affected workers required 

removal from exposure to corrugated cardboard to prevent 

symptoms. During our visit, we noted that activities 

associated with the area where incoming boxes are sorted 

and categorized for use could generate airborne cardboard 

dust. In particular, cleaning out the carton baler may 

result in exposure to cardboard dust that might contain 

fungal materials.

Clarifying Tank Contents

Hypersensitivity pneumonitis can occur with exposure 

to a variety of bioaerosols of rotting plant materials 
Page 28 Health Hazard Evaluation Report 2011-0037-3172

Discussion (continued)

(grains, sugarcane, mushrooms, compost, cork, wood) or 

contaminated water systems [Selman et al. 2012]. The 

clarifying tank serves as a holding tank for a mixture 

of water and solid plant materials that are undergoing 

decomposition, accounting for the accumulation of 

sludge on the surface of the tank. This mixture would 

be expected to contain multiple microbial antigens from 

both bacteria and fungi. The annual cleaning activities 

by sanitation personnel using high pressure water likely 

generate bioaerosol exposures, which could pose a risk for 

hypersensitivity pneumonitis. 

Catalyst

The catalyst used at the facility is noted by its 

manufacturer to cause allergic respiratory reactions. 

Given that similar catalysts have been associated with 

hypersensitivity pneumonitis [Selman et al. 2012], it is 

feasible that the catalyst used at the facility could pose 

a similar risk for this immune-mediated lung disease. 

Cleaning the metered dispensing system and the storage 

containers may create exposure opportunities.

Respiratory Protection

With the exception of periodic extensive cleaning of the 

corn sorting room using compressed air, the facility does 

not require mandatory respiratory protection for any of 

these potential exposures. The facility does indicate that 

respirators are “recommended” for some of these potential 

exposures. 

Conclusions The facility uses multiple substances that are respiratory 

irritants and/or allergens, and air sampling has demonstrated 

use of diacetyl and diacetyl substitutes. One worker developed 

hypersensitivity pneumonitis during employment and improved 

away from work, suggesting a workplace exposure was responsible. 

Reducing the risk of work-related immune-mediated lung disease 

in a facility with multiple potential causative agents is challenging. 

It requires a prudent approach that does not rely solely on PELs, 

which may not be protective for this type of health outcome. 

While many controls are already in place to reduce exposures to 

airborne organic materials, flavorings, and cleaning chemicals, we 
Health Hazard Evaluation Report 2011-0037-3172 Page 29

Conclusions

(continued) noted potential opportunities for exposure during our site visit that 

can be addressed through enhanced engineering controls, modified 

work practices, and mandatory use of respiratory protection. 

On the basis of our findings, we recommend the following actions 

to create a more healthful workplace. 

Elimination and Substitution

Elimination and substitution of a toxic/hazardous process material 

have traditionally been highly effective means for reducing hazards. 

However, these may not be feasible approaches in this facility, given 

the array of potential hazards that might be subject to elimination 

or substitution and the limited information on the toxicity of 

substitutes. Substitution for diacetyl is particularly challenging, 

as little is known about the health effects of substitute flavorings. 

Available information on the diacetyl substitute 2,3-pentanedione 

indicates that it has similar toxicity to diacetyl, which raises 

concerns that other substitutes with similar chemical structure may 

also be respiratory toxins. 

1. Until more is known about the safety of diacetyl substitutes, 

handle ingredients that contain these butter flavoring 

chemicals as respiratory toxins.

2. Given cautions in some seasoning MSDSs about avoiding 

contact with strong acids, alkali, or oxidizers, consult with 

seasoning suppliers and cleaning product suppliers about 

the compatibility of seasonings with cleaning agents and, if 

incompatibilities are identified, the need for elimination or 

substitution.

Engineering Controls

Engineering controls reduce exposures to employees by removing 

the hazard from the process or placing a barrier between the hazard 

and the employee. Engineering controls can be very effective at 

protecting employees without placing primary responsibility of 

implementation on the employee. 

1. Substitute vacuum cleaning with HEPA filters for 

compressed air cleaning and sweeping throughout the 

Recommendations
Page 30 Health Hazard Evaluation Report 2011-0037-3172

Recommendations

(continued) facility wherever feasible.

2. Investigate new engineering measures to prevent the 

clogging of the filters used for the local ventilation of the 

seasoning hoppers. Monitoring pressure differentials across 

the hopper may be useful in evaluating the effectiveness of 

controls. 

3. Explore engineering controls, such as local exhaust 

ventilation, to reduce dust generation during the handling 

of seasoning bags, particularly related to filling the seasoning 

bag baler.

4. If not already done, follow the recommendations of the 

previous consultant regarding the laboratory hood sash 

demarcation. 

Administrative Controls

Administrative controls are employer-dictated work practices and 

policies to reduce or prevent exposures to workplace hazards. 

The effectiveness of administrative changes in work practices 

for controlling workplace hazards is dependent on employer 

commitment and employee acceptance. Regular monitoring and 

reinforcement is necessary to ensure that control policies and 

procedures are not circumvented in the name of convenience or 

production efficiency.

1. Follow seasoning MSDS recommendations on keeping 

all heated processes (including sanitation processes using 

hot water) at the lowest necessary temperature in order to 

minimize emissions of volatile chemicals into the air.

2. Develop and disseminate clear guidelines for the 

maintenance and replacement of the filters from the local 

exhaust ventilation on the seasoning hoppers. Employees 

should be discouraged from attempting to openly shake or 

otherwise remove dust from clogged filters.

3. Continue to explore work practices to reduce dust 

generation during the handling of seasoning bags, 

particularly related to filling the seasoning bag baler. 

Continue to keep the bins for empty seasoning bags covered.

4. Encourage employees to report respiratory symptoms to 

the facility’s nurse. The occurrence of new or ongoing 

respiratory symptoms in the workforce should prompt 

consideration of work-related lung disease and re-evaluation 

of the potential for exposure to respiratory hazards.
Health Hazard Evaluation Report 2011-0037-3172 Page 31

Recommendations

(continued) Personal Protective Equipment (PPE)

PPE is the least effective means for controlling employee exposures. 

Proper use of PPE requires a comprehensive program, and calls 

for a high level of employer and employee involvement and 

commitment to be effective. 

Determining the need for respiratory protection in the face of 

an immune-mediated lung disease is challenging. In addition to 

traditional sources of information such as PELs and industrial 

hygiene sampling results, managers should consider the substance’s 

potential to stimulate the immune system, even at relatively low 

levels of exposure. 

1. Follow seasoning MSDS recommendations regarding the 

use of chemically resistant gloves.

2. Ensure the PPE matrix outlining personal protection 

requirements during chemical handling and cleaning 

processes is followed. 

3. Require mandatory use of a fit-tested full-facepiece respirator 

with particulate cartridges for cleaning the clarifying tank. 

Although this task is conducted relatively infrequently, 

the likelihood of microbial growth on the tank, the use 

of pressurized water, and the length of time the task takes 

suggest the potential for substantial bioaerosol exposure.

4. Require mandatory use of respiratory protection with 

HEPA/P100 filters (as per the product MSDS) for cleaning 

the metered dispensing system and storage containers for 

the catalyst, which is a recognized allergen and may be 

similar to other substances that have been known to cause 

immune-mediated lung disease. 

5. Consider requiring mandatory use of respiratory protection 

for tasks that have the potential to generate organic dust. 

These tasks include cleaning the carton baler, filling the 

seasoning bag baler, and sweeping the corn sorting room. 

If formal industrial hygiene evaluations are conducted to 

inform decisions about respiratory protection, consider 

that traditional PELs may not be protective for immunemediated lung disease.

6. Continue the hearing conservation program.
Page 32 Health Hazard Evaluation Report 2011-0037-3172

Recommendations

(continued)

On October 18, 2012, a team from OSHA visited the facility 

for a Voluntary Protection Program (VPP) evaluation. As 

part of the VPP evaluation, the VPP team leader met with the 

facility’s manager to discuss the HHE and the preliminary 

recommendations that we made during our site visit in May 2012. 

Our preliminary recommendations and the facility’s responses 

follow. 

1. Consider ways of incorporating vacuum cleaning in place of 

the use of compressed air throughout the plant.

Response: The manager reported that the facility had taken 

multiple steps to reduce the use of compressed air for cleaning. 

These steps included the introduction of vacuums into the 

packaging area and the development of new cleaning protocols in 

the production areas. 

2. Require mandatory use of a full-facepiece respirator for 

employees conducting cleaning of the clarifying tank.

Response: The manager reported that the company agreed with 

this recommendation and was in the process of identifying one to 

two employees for medical clearance and respirator fit testing, so 

that employees could use respiratory protection during cleaning of 

the clarifying tank in the future.

3. Conduct further assessment of the need for mandatory 

respiratory protection for tasks that may be dusty, including 

cleaning the box baler, filling the seasoning bag baler, and 

sweeping the corn sorting room.

Response: The manager reported that the company agreed to 

evaluate these tasks for respirator usage.

Other Issues

1. Investigate any apparent differences in the conditions 

that may have led to the possible higher exposure to nitric 

acid on one occasion in November 2008, so that future 

occurrences can be avoided. 

Update since Site Visit
Health Hazard Evaluation Report 2011-0037-3172 Page 33

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Health Hazard Evaluation Report 2011-0037-3172 Page 35 Tables Table 1. Air sampling results for diacetyl, 2,3-pentanedione, and 2,3-hexanedione (in parts per billion) using evacuated canisters, May 2012. Sample type Field blank Field blank Personal Personal Personal Personal Personal Area Area Area Job title or work area Tortilla chip 1 operator Tortilla chip 1 operator Tortilla chip 2 operator Tortilla chip 2 operator Tortilla chip 2 operator Tortilla chip 2 seasoning hopper - at front near worker while loading from bag Tortilla chip 2 seasoning hopper - at filter exhaust before loading from bag Tortilla chip 2 seasoning hopper - at filter exhaust while loading from bag Sampling time 8:52 - 11:23* 12:14 - 14:11 10:18 - 10:33 9:02 - 10:18, 10:33 - 12:17† 12:17 - 14:26 10:21 11:14 11:24 Duration (minutes) 151 117 15 180 129 Instant Instant Instant Canister ID 520 540 531 521 538 512 513 511 537 546 2,3-butanedione (diacetyl) < 0.9 < 0.9 < 6.0 < 4.5 < 3.0 < 2.8 < 3.7 [1.6] [1.4] [1.7] 2,3-pentanedione < 1.1 < 1.1 < 7.2 < 5.5 < 3.6 < 3.4 < 4.4 < 1.6 < 1.6 < 1.6 2,3-hexanedione < 1.0 < 1.0 < 6.8 < 5.2 < 3.4 < 3.2 < 4.2 < 1.5 < 1.5 < 1.5 *removed canister immediately after sampler tubing separated from canister †disengaged flow controller and removed canister from 10:18 to 10:33 while collecting a 15-minute sample in canister 538 < = not detected; value is limit of detection [ ] = detected but not quantifiable; value is estimated measurement between limit of detection and limit of quantification Note: Nacho cheese seasoning was used all day on tortilla chip line 2; operators for both tortilla chip lines 1 and 2 loaded bags for line 2, but it was primarily operated by the tortilla chip line 2 operator. Tortilla chip line 1 remained down all day for cleaning after a production run with sweet chili seasoning.
Page 36 Health Hazard Evaluation Report 2011-0037-3172

Tables (continued) Table 2. Alpha-diketone compounds detected in headspace analyses of bulk seasoning samples, May 2012. Sample ID Seasoning Collection site Alpha-diketone detected

1 Nacho cheese Tortilla chip line 2 None2 Ranch Tortilla chip line 1 None3 Barbeque Potato chip line Trace diacetyl4 Honey barbeque Corn chip line Trace diacetyl5 Cheddar sour cream Warehouse Trace diacetyl6 Spicy sweet chili Warehouse None7 Chili cheese Warehouse Trace diacetyl

Tables (continued)
Health Hazard Evaluation Report 2011-0037-3172 Page 37 Tables (continued) Table 3. Air sampling results for sodium hydroxide using filter cassettes via NIOSH Method 7303, May 2012. Sample type Person Job title Sample ID Flow (Lpm) Sampling times Sample duration (minutes) Sample mass (μg) Sample concentration (mg/m3) Consecutive sample duration (minutes) Consecutive sample concentration (mg/m3) 8-hr time- weighted average concentration† (mg/m3) Personal Worker A Sanitor - cleaning potato crisp production line with sodium hydroxide cleaner NE-01 3 9:13 - 12:22, 12:38 - 14:18 289 [18] [0.02] 289 [0.02] [0.01] NE-02 3 12:22 - 12:38 16 < 10 < 0.21 16 < 0.21 Personal Worker B Sanitor - cleaning potato crisp production line with sodium hydroxide cleaner NE-00 3 9:11 - 10:01* 50 < 10 < 0.07 291 < 0.02 < 0.01 NE-06 3 10:01 - 12:22, 12:38 - 14:18 241 < 10 < 0.01 NE-08 3 12:22 - 12:38 16 < 10 < 0.21 16 < 0.21 Field Blank NE-03 0 < 10 NE-05 0 < 10 *cassette fell off onto dry floor; replaced with sample NE-06 †entire cleaning task sampled, so zero exposure assumed for periods not sampled < = not detected; value is limit of detection [ ] = detected but not quantifiable; value is estimated measurement between limit of detection and limit of quantification μg = microgram mg/m3 = milligrams per cubic meter of air Lpm = liters per minute
Page 38 Health Hazard Evaluation Report 2011-0037-3172

Acknowledgments 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 disease. 

Mention of any company or product does not constitute 

endorsement by NIOSH. In addition, citations to websites 

external to NIOSH do no 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 Kristin J. Cummings, Chris Piacitelli, 

Marcia Stanton, and Rachel L. Bailey, of the Field Studies Branch, 

Division of Respiratory Disease Studies. Field support was provided 

by Randy Boylstein. Laboratory support was provided by Ryan 

LeBouf. Desktop publishing was performed by Tia McClelland. 

The authors thank Kathleen Fedan and Nicole Edwards for their 

thoughtful reviews. 

Copies of this report have been sent to employee and employer 

representatives, the 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 [2013]. Health Hazard Evaluation Report: Evaluation of respiratory 

concerns at a snack food production facility, New York. Morgantown, WV: U.S. 

Department of Health and Human Services, Public Health Service, Centers for 

Disease Control and Prevention, National Institute for Occupational Safety and 

Health, NIOSH HETA No. 2011-0037-3172

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