Health Hazard Evaluation Report 2011-0102-3194 Page 1

Evaluation of respiratory concerns at a cream 

cheese manufacturing facility 

Report No. 2011-0102-3194

September 2013

Rachel L. Bailey, DO, MPH

Chris A. Piacitelli, MS, CIH

U.S. Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health
Page 2 Health Hazard Evaluation Report 2011-0102-3194

Contents

Highlights...............................................i

Abbreviations ..................................... iv

 Summary ............................................. 1

Introduction......................................... 1

Process Description............................. 2

Methods ............................................... 4

Results .................................................. 6

Updates Since Site Visits ..................... 9

Discussion .......................................... 10

Conclusion.......................................... 13

Recommendations............................. 13

References.......................................... 17

Tables.................................................. 20

Figures................................................ 23

Acknowledgements........................... 29

The employer is required to post a copy of this report for 30 days at or near the 

workplace(s) of affected employees. The employer must take steps to ensure 

that the posted report is not altered, defaced, or covered by other material.

The cover photo is a close-up image of sorbent tubes, which are used by the HHE

Program to measure airborne exposures. This photo is an artistic representation that may

not be related to this Health Hazard Evaluation.
Health Hazard Evaluation Report 2011-0102-3194 Page i

We evaluated the workplace 

for exposure to flavoring 

chemicals, cleaning products, 

and dust. While some controls 

were already in place to reduce 

exposures, we noted potential 

opportunities for exposure 

during our site visits. We 

recommended addressing the 

exposures through enhanced 

engineering controls and 

modified work practices. 

Highlights of this Evaluation

The Health Hazard Evaluation Program received a confidential request from employees to 

investigate respiratory concerns at a cream cheese manufacturing facility in New York.

What NIOSH Did

● We visited the cream cheese manufacturing facility in July and September 2011.

● We toured the plant and talked with employees and managers. 

● We conducted in-person, private interviews with 13 employees. 

● We collected flavorings, strawberry puree, and 

cardboard debris samples.

● We performed personal and area air sampling 

alongside the production and packaging of 

various cream cheese products and area air 

sampling during clean-in-place and clean-outof-place procedures.

● We provided recommendations to decrease 

exposures to flavorings and cardboard dust.

What NIOSH Found

● We observed airborne dust when cooks 

scooped and weighed powder ingredients for 

cream cheese batches.

● We observed no local exhaust ventilation at the cook stations.

● We noted that air from the ventilation supply vent above the whipped cook station 

created airborne dust while the cook scooped and weighed powdered ingredients.

● We identified diacetyl, 2,3-pentanedione, and acetoin in liquid dairy flavoring.

● We identified diacetyl and 2,3-pentanedione in liquid strawberry flavoring and a liquid 

smoke flavoring.

● We identified small amounts of diacetyl in a powder cheesecake flavoring, a powder 

cheese flavoring, a liquid blueberry flavoring, a liquid kosher strawberry flavoring, and 

strawberry puree.

● We identified diacetyl in air samples at levels above the National Institute for 

Occupational Safety and Health’s proposed recommended exposure limit in several

areas (free ingredients room, free cook room, cook room, 703 fill room) and jobs (703 

fill operator, free cook, condiment cook, soft cook).

● We identified 2,3-pentanedione and 2,3-hexanedione in air samples in the free 

ingredients room during clean-in-place and clean-out-of-place operations. 
Page ii Health Hazard Evaluation Report 2011-0102-3194

What the Employer Can Do

● Handle ingredients that contain these flavoring chemicals as respiratory hazards. 

● Install local exhaust ventilation at cooking kettles that use ingredients containing 

diacetyl, 2,3-pentanedione, 2,3-hexanedione, or other alpha-diketones (e.g., liquid dairy, 

strawberry, smoke, and blueberry flavorings; powder cheese and cheesecake flavorings; 

and strawberry puree). 

● Conduct additional air sampling after the addition of local exhaust ventilation.

● Install a new hood in the free ingredients room that pulls air to the rear of instead of 

overhead the barrels from which ingredients are being scooped and/or a semicircular 

hood that pulls air at the rear half of the barrel rim, and provide long-handled scoops. 

● Conduct additional air sampling during cleaning operations (clean-in-place and cleanout-of-place) using Occupational Safety and Health Administration’s Sampling Methods 

1012 for diacetyl and 1016 for 2,3-pentanedione. 

● Include local exhaust ventilation system (e.g., clean-out-of-place stations and measuring 

hood in free ingredients room) checks in the preventative maintenance schedule to 

ensure they continue to operate appropriately.

● Ensure workers use proper techniques when using ventilation hoods.

● Substitute vacuum cleaning with high-efficiency particulate air filters for cleaning 

with compressed air and brooms, wherever feasible. Those present during the use of 

compressed air should wear N-95 respirators.

● Encourage employees to report new or ongoing respiratory symptoms to their personal 

healthcare provider and, as instructed by their employer, to a designated individual at 

their workplace.

What Employees Can Do

● See a healthcare provider if you develop or have developed persistent or worsening 

respiratory or other health symptoms. 

● Use local exhaust ventilation systems as instructed by your employer.

● Follow your employer’s rules about mandatory use of respiratory protection and other 

personal protective equipment and clothing.

● Report new or ongoing respiratory symptoms to your personal healthcare provider and 

a designated individual at your workplace, as instructed by your employer.
Health Hazard Evaluation Report 2011-0102-3194 Page iii

This page left intentionally blank
Page iv Health Hazard Evaluation Report 2011-0102-3194

Abbreviations

ACGIH American Conference of Governmental Industrial Hygienists

ASHRAE American Society of Heating, Refrigerating, and Air-Conditioning Engineers 

CIP Clean-in-place

COP Clean-out-of-place

cfm Cubic feet per minute

CFR Code of Federal Regulations

cfu/g Colony forming units per gram 

GC-MS Gas chromatography and mass spectrometry 

LEV Local exhaust ventilation

mg/m3 Milligrams per cubic meter

NAICS North American Industry Classification System

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

PEL Permissible exposure limit

ppb Parts per billion

REL Recommended exposure limit

STEL Short-term exposure limit

TLV Threshold limit value

TWA Time-weighted average

VOC Volatile organic compounds
Health Hazard Evaluation Report 2011-0102-3194 Page v

The recommendations in this report are made on the basis of the findings at the workplace

evaluated and may not be applicable to other workplaces.

Mention of any company or product in this HHE does not constitute endorsement by the

National Institute for Occupational Safety and Health (NIOSH).

Citations to Web sites 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 Web sites. All Web addresses referenced in this document

were accessible as of the publication date.
Health Hazard Evaluation Report 2011-0102-3194 Page 1

Summary

In April 2011, the National Institute for Occupational Safety and Health received 

a confidential employees’ request for a health hazard evaluation at a cream cheese 

manufacturing plant. The employees submitted the request because of respiratory concerns 

related to exposures during the manufacturing and packaging processes. We visited the plant 

on two occasions. On our initial site visit, we toured the plant, talked with employees, and 

collected bulk samples of flavorings and cardboard debris. 

We analyzed the headspace air over each bulk sample we collected during our initial visit 

and identified the ketone chemical compounds diacetyl, 2,3-pentanedione, and acetoin in 

the headspace of a liquid dairy flavoring. We identified diacetyl and 2,3-pentanedione in 

the headspace of a liquid strawberry flavoring and liquid smoke flavoring. We found small 

amounts of diacetyl in the headspace of a powder cheesecake flavoring, a powder cheese 

flavoring, a liquid blueberry flavoring, and a liquid kosher strawberry flavoring. We also 

found a small amount of diacetyl in the headspace of a strawberry puree. 

On our follow-up industrial hygiene survey visit, we performed area and personal air 

sampling alongside the production and packaging of various cream cheese products. We 

identified diacetyl in air samples at levels above the NIOSH proposed recommended exposure 

limit in several areas (free ingredients room, free cook room, cook room, 703 fill room) and 

jobs (703 fill operator, free cook, condiment cook, soft cook). We identified 2,3-pentanedione 

and 2,3-hexanedione in air samples in the free ingredients room during clean-in-place and 

clean-out-of-place operations. 

We have provided recommendations to decrease exposures to flavoring chemicals, cardboard 

dust, and cleaning chemicals. We recommended additional sampling for diacetyl and 

2,3-pentanedione during cleaning operations and after the additional of local exhaust systems. 

We also recommended that employees see a healthcare provider if they develop or have 

developed persistent or worsening respiratory or other symptoms. 

Introduction

The Health Hazard Evaluation Program of the National Institute for Occupational Safety 

and Health (NIOSH) received a confidential request from employees at a cream cheese 

manufacturing facility in New York. The requestors had concerns about health issues related 

to the manufacturing and packaging process. Their health concerns included breathing 

problems, coughing, bloody noses, and laryngitis. They also had concerns about dusty 

conditions, lack of ventilation, and cleaning procedures. We visited the plant on two occasions 

and provided an interim report with recommendations. 
Page 2 Health Hazard Evaluation Report 2011-0102-3194

Process Description

During our visits in July 2011 and September 2011, the plant employed approximately 318 

persons and produced cream cheese. We briefly describe the process at the time of our visits.

Initial Steps

Large refrigerated trucks delivered milk and cream into silos. The milk and cream were 

pasteurized and homogenized, and skim milk and cream enriched with milk fat were 

produced. A starter culture was added to the cream/milk fat mixture which was then sent to 

tanks to ferment. The cream cheese mix was then put through separators to collect curd and 

remove the whey. The remaining cheese mixture was piped to cook rooms and the chill room. 

In the chill room, chill rolls pressed the cheese and piped it to the rigid cream cheese fill 

room. Fill rooms and cook rooms are described below.

Powder Rooms

In the powder rooms, workers prepared powder ingredients for delivery to processing areas. 

Ingredients included locust bean gum, guar gum, xanthum gum, sorbic acid, salt, milk 

powder, and whey protein concentrate. These rooms were maintained below 58% relative 

humidity. 

Ingredients Cooler Room

Condiments (such as shredded salmon and strawberry puree) and powder and liquid 

flavorings including strawberry, blueberry, pineapple, honey nut, pumpkin, cheese, 

cheesecake, smoke, and others that required chilling were kept in the ingredients cooler room. 

Free Ingredients Room

Barrels of powder ingredients for free (as workers refer to fat-free products) cream cheese 

were stored in the free ingredients room under a ventilation hood. Working under the hood, 

a worker scooped ingredients from barrels, weighed them, and placed them into plastic 

bags for future use by cooks. Also in this room, a free condiment cook prepared and cooked 

condiments (such as strawberry puree) for free cream cheese blends. 

Free Cook Room

In the free cook room, free soft body cream cheese formulas were blended, condiments added, 

and product was brought to temperature specifications by the free cook. Several ingredients 

were weighed and added by hand. 

Cook Room

Soft body and whipped cream cheese formulas were blended, condiments added, and 

product was brought to cooking temperature. Cooks ran the machinery and weighed and 
Health Hazard Evaluation Report 2011-0102-3194 Page 3

added several ingredients by hand. A condiment cook also located in the room prepared 

condiments (such as salmon) for cream cheese blends; he also weighed and manually added 

the ingredients. When the condiment cook worked with allergens, such as salmon, a plastic 

sheet was placed around the condiment cook station. 

Fill Rooms 

Fill operators ran filling machines that placed cream cheese products into containers. These 

rooms were maintained near 30% relative humidity. 

Packaging Rooms (Large and Small Room)

Packaging machine operators ran packaging machines that placed containers coming by 

conveyor belts from the fill rooms into cardboard boxes. Filled cardboard boxes were then 

palletized. 

Warehouse and Coolers

Forklift operators transferred materials from the warehouse to the production areas. They also 

transferred product to the finished goods cooler. 

Quality Control Lab

Quality control technicians performed quality checks throughout the production process.

Other Areas

Other areas in the facility (such as the salvage room, maintenance shop, and boiler and 

compressor rooms) are not described.

Sanitation

Workers in the various production areas cleaned and sanitized equipment. Room floors, 

walls, and outer surfaces of equipment were sprayed with diluted cleaning chemicals onto the 

surfaces and then rinsed with water. Workers also used buckets and brushes to wash exteriors 

of equipment. The insides of cooking tanks were washed in a process called “clean-in-place” 

(CIP) that involved dilution of cleaning agents in hot water inside the cooking tank followed 

by water rinse. In the cook rooms, the cleaning solution and water rinse were emptied 

through a piped drain system or directly onto the cook room floor near floor drains. Some 

equipment parts were placed in large wash tanks for a similar type of cleaning that was called 

“clean-out-of-place” (COP). There were dedicated COP tanks to clean equipment that had 

been used to prepare condiments or make cream cheese blends that had potential allergens 

(such as salmon or honey nut). Material data safety sheets (MSDSs) indicated that many of 

the cleaning products contained inorganic acids (nitric, phosphoric, and sulfuric), sodium 

hydroxide, chlorine compounds, and/or quaternary ammonium compounds. Cardboard 

debris and dust were cleaned with compressed air (blowdown), vacuums, and brooms in the 

fill and packaging rooms. 
Page 4 Health Hazard Evaluation Report 2011-0102-3194

Personal Protective Equipment

Employees wore company-provided uniforms, hair coverings, beard covers (if applicable), 

hearing protection, safety glasses, and steel toe shoes in all production areas. Workers also 

wore goggles, a face shield, apron, and rubber gloves when dispensing undiluted chemicals, 

foam cleaning, or transporting cleaning products in an open container. When dispensing 

ready-to-use chemicals, bucket and brush cleaning, or transporting closed cleaning 

containers, workers wore goggles.

Company’s Respiratory Protection Plan (Dated 2011) 

The Respiratory Protection Plan indicated required use of organic vapor cartridge respirators 

for hydrogen peroxide by sanitation workers and self-contained breathing apparatus (SCBA) 

for ammonia by hazardous materials responders. The company provided voluntary-use 

respirators for paints and nuisance mists, dusts, and food ingredients. Without specifying the 

type of respirator, another section of the Respiratory Protection Plan listed the following as 

“respirator-required” activities: utility and refrigeration department maintenance of ammonia 

lines, pesticide spraying, and painting with inadequate ventilation or as called for by the 

manufacturer.

Methods

We made our initial site visit to the plant on July 6-7, 2011. We toured the plant, talked with 

employees, and collected bulk flavoring samples and cardboard debris samples. On our 

follow-up industrial hygiene survey visit on September 26-28, 2011, we performed air testing 

during cleaning procedures and alongside the production and packaging of various cream 

cheese products, including free plain soft cream cheese, free strawberry soft cream cheese, 

strawberry soft cream cheese, and salmon soft cream cheese. We chose to sample alongside 

these operations because the products used one or more of the powder cheese flavoring, 

liquid strawberry flavoring, or smoke flavoring, all of which were found during headspace 

analyses to contain ketone compounds. Other cream cheese products were being produced 

simultaneously with our air sampling with different ingredients from those in which we had 

measured ketone compounds. We also collected additional bulk flavoring and condiment 

samples.

Bulk process ingredient samples for headspace analyses 

We used 50-milliter sterile polypropylene centrifuge tube containers to collect approximately 

40-milliliter bulk samples of twelve flavorings in July 2011 and one flavoring (inadvertently 

duplicated a July sample) and one condiment in September 2011. In the laboratory, we used 

thermal desorption, gas chromatography, and mass spectrometry to analyze the headspace 

over the samples for volatile organic compounds (VOCs). This involved collecting a sample of 

the headspace at room temperature using a stainless steel thermal desorption tube and then 

desorbing it 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 
Health Hazard Evaluation Report 2011-0102-3194 Page 5

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.

Sorbent tubes for ketones in production and packaging areas 

During the September 2011 survey visit, we collected personal and general area air samples 

in sets of two silica gel sorbent tubes in series. These were analyzed for diacetyl and acetoin 

by gas chromatography with electron capture detection (GC-ECD) in accordance with OSHA 

Sampling Method 1012 [OSHA 2008]. When production was using flavorings that contained 

2,3-pentanedione, we placed an identical set of tubes alongside those tubes and analyzed them 

for 2,3-pentanedione using OSHA Sampling Method 1016 [OSHA 2010], which utilizes gas 

chromatography with flame ionization detection (GC-FID). We collected parallel samples at 

a small subset of the area locations using o-phenylenediamine-treated silica gel sorbent tubes, 

which were analyzed for 2,3-pentanedione with NIOSH Draft Sampling Procedure SMP2 

using gas chromatography with nitrogen phosphorus detection. 

Canisters and sorbent tubes for alongside cleaning

During the September visit, we used evacuated canisters near cleaning activities to collect 

area air samples for VOCs, including diacetyl, 2,3-pentanedione, and 2,3-hexanedione. The 

450-milliliter canisters were equipped with either instantaneous grab sampling attachments 

or restricted flow controllers which allow for calculation of a time-weighted average (TWA) 

concentration. The air samples were analyzed for VOCs using a pre-concentrator-gas 

chromatograph-mass spectrometer (GC-MS) 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.); three additional analyte compounds, 

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 used silica gel sorbent tubes to collect area air samples near cleaning activities 

to measure inorganic acids using ion chromatography according to NIOSH Sampling Method 

7903 [NIOSH 1994]. 

Real-time Monitoring

To evaluate some process tasks during the September visit, we used direct-reading monitors 

to obtain real-time continuous relative levels of dust or total VOCs. For dust, we used a 

personalDataRAM pDR-1000AN monitor (Thermo Scientific Corporation, Franklin, MA), 

an instrument that is optimized for detection of particles in the size range of 0.1 to 10 

micrometer, or approximately respirable. For total VOCs, we used a photoionization detector 

(ToxiRAE PGM-30, Rae Systems, Inc., San Jose, CA). The instruments were set to record 

data at 5-second averaging periods and were either strapped to the chest of the worker being 
Page 6 Health Hazard Evaluation Report 2011-0102-3194

evaluated or held close to the worker by a NIOSH investigator shadowing them as they 

worked. To record events that might be associated with any observed peaks in real-time 

readings, we utilized video cameras during those measurements.

Cardboard debris samples

During the July visit, we collected two cardboard debris samples – one under a conveyor on 

the mezzanine level in the large packaging room and the other on and around the conveyor 

for packaging line 9. The material consisted of a mix of cardboard remnants, ranging from 

small slivers from the cut edges of boxes to fine dust, and was identified as the material that 

compressed air was used to remove during cleaning. The samples were cultured for fungi on 

malt extract agar and for bacteria on tryptic soy agar. 

Results

Summary of prior industrial hygiene evaluations

The company provided the following exposure assessment records (all assessments included 

less than five samples):

2004 – Air sampling results indicated no concentrations in the salt & gum room and powder 

room above the OSHA permissible exposure limits (PEL) of 5 milligrams per cubic meter of 

air (mg/m3) for respirable dust or 15 mg/m3 for total dust [29 CFR 1910.1000]. 

2006 – Consultant determined that welding operations and cleaning operations with strong 

caustics and alkalis were exempt from the OSHA hexavalent chromium standard because air 

sampling results revealed concentrations less than 0.5 mg/m3. 

2008 - Air sampling results showed that the TWA of two samples collected on an employee 

(one while he was working in the packaging room and the other while in the free ingredients 

room) did not exceed the 8-hour OSHA PEL for titanium dioxide (PEL=15 mg/m3) or total 

dust (PEL=15 mg/m3), but that the total dust concentration during the time in the free 

ingredients room was 21 mg/m3 . 

March 2010 - Personal air sampling results indicated no respirable or total dust overexposures 

during manipulation of raw cardboard into packaging boxes at a packaging line. 

September 2010 - Personal air sampling results showed no exposures over OSHA PELs or 

American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit values 

(TLV) to 11 amine, 6 aldehyde, or 10 organic acid compounds during typical heat shrink wrap 

operations at a packaging line. 
Health Hazard Evaluation Report 2011-0102-3194 Page 7

Company OSHA injury logs

Company OSHA injury logs for 2009-2011 showed two reports of respiratory illness: March 

2009 asthma attack (attributed to milk powder) and February 2010 breathing difficulties 

(attributed to cardboard dust and plastic fumes). 

NIOSH site visits

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 personal protective 

equipment including hearing protection, eye protection, and steel-toe shoes with non-skid 

soles. 

In many rooms, including the free cook room and cook room, we observed alcohol hand 

cleaner and foot wash stations. There was extensive use of cleaning products in many areas 

of the plant for cleaning room floors, walls, and outer surfaces of equipment by spraying the 

diluted cleaning chemical onto the surfaces and rinsing with water. We observed several CIP 

and COP operations in progress. During one CIP, the hot cleaning solution was released onto 

the floor and flowed rapidly to the floor drain where it formed a large slowly draining puddle 

(Figure 1). 

Health Concerns

During informal interviews of 13 employees during the July visit, some workers reported 

they or others complained of upper respiratory symptoms (such as dry throat and sneezing) 

or lower respiratory symptoms when working with powder ingredients. Others reported 

symptoms included rash on arms while working in the condiment area, laryngitis while 

working on the packing line around the ink, or asthma symptoms (wheezing and shortness 

of breath) when working with cleaning products or around cardboard dust in the packaging 

area. We were told during our walk-through of complaints that cardboard dust was generated 

from handling of boxes in the packaging area and when it was cleaned from equipment with 

compressed air (blowdown).

Headspace analyses

We identified diacetyl, 2,3-pentanedione, and acetoin in the headspace of a liquid dairy 

flavoring. We identified diacetyl and 2,3-pentanedione in the headspace of a liquid 

strawberry flavoring and a liquid smoke flavoring. We found small amounts of diacetyl in the 

headspace of a powder cheesecake flavoring, a powder cheese flavoring, a liquid blueberry 

flavoring, a liquid kosher strawberry flavoring, and a strawberry puree. 

Sorbent tubes for ketones in production and packaging areas 

Table 1 shows area (n=15 near full-shift) and personal (n=14 near full-shift and n=6 shortterm) air sampling results for flavoring compounds in production areas using sorbent tubes, 

by type, date, shift, job title, work area, product, and sampling time. Diacetyl was measured 

above sampling analysis detection limits for all samples inside the building. Inside area 

concentrations ranged from 0.3 parts diacetyl per billion parts air (ppb) to 13.8 ppb. The four 
Page 8 Health Hazard Evaluation Report 2011-0102-3194

highest concentrations were greater than 11 ppb; three of these were collected near the cook 

room soft-body condiments area, and the other was collected in the 703 fill room. Near fullshift personal samples ranged from 0.4 ppb to 8.3 ppb, while short-term samples collected 

during the task of adding ingredients to cook kettles and another from a product fill room 

ranged from 4.4 ppb to 15.1 ppb. For comparison purposes, the NIOSH draft recommended 

exposure limit (REL) for diacetyl is 5 ppb for an 8-hour TWA, with a recommended shortterm exposure limit (STEL) of 25 ppb for 15 minutes [NIOSH 2011]. The 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]. Acetoin concentrations ranged from 1.2 ppb to 39.4 ppb for near full-shift samples and 

up to 85.1 ppb for 15-minute samples. Occupational exposure limits have not been established 

for acetoin. 2,3-pentanedione concentrations were less than the limit of detection for all 

samples, including two of the three analyzed using the more sensitive SMP2 method. The 

only detectable concentration was 0.9 ppb while processing salmon cream cheese at the cook 

room soft condiments area. For comparison, the NIOSH draft REL for 2,3-pentanedione is 

9.3 ppb, with a STEL of 31 ppb for 15 minutes. The liquid smoke flavoring was added along 

with shredded salmon to batches of salmon cream cheese. We did not collect a sample of the 

shredded salmon for headspace analysis, but we noted that natural smoke flavor was listed as 

an ingredient on its container label. 

Among each day’s samples clustered by cream cheese product, the area samples in the cook 

rooms were the highest or next-to-highest for diacetyl, with four of five above the NIOSH 

draft REL (Table 1). The near-full-shift personal samples for cooks showed a similar pattern, 

with four of five above the draft REL. None of the short-term samples were above the draft 

STEL for diacetyl. Packaging room area samples and personal samples for packagers were the 

lowest in each grouping for diacetyl; all were below the draft REL.

Real-time monitoring

Real-time total VOC measurements collected by a NIOSH investigator shadowing a cook 

at the condiment cooking station are shown in Figure 2. The figure provides a graph of the 

continuous measurements of concentration by the real-time instrument. Also included are 

time frame bars of the events that occurred during measurement. These were produced by 

examination of the video camera recording that was obtained simultaneously. The worker was 

loading shredded salmon from 5-gallon pails into the cooking tank inside an area enclosed 

with a plastic sheet curtain that was used when allergenic ingredients were used. Entering and 

exiting the enclosure coincided with increases and decreases, respectively, in concentration. 

Tasks within the enclosure that coincided with increased concentrations included opening 

pails of salmon, adding the salmon to the cooking tank, and adding liquid smoke into the 

tank. Outside the enclosure, the concentration rose when the worker poured liquid smoke 

at the scale in preparation for the next addition of the ingredient to the tank. Note: These 

measurements indicate the amount of total VOCs in the air, and they do not provide the 

concentrations of any ketone compounds that may be included.

Figure 3 provides dust measurements collected by a real-time monitor worn on the cook at 

the whip cooking station. Several sharp increases and decreases in concentration coincided 

with weighing powder ingredients, which involved scooping them from totes, pails, and 
Health Hazard Evaluation Report 2011-0102-3194 Page 9

bags into smaller pails on a scale. Visible clouds of dust were seen during several of these 

peak measurements. Another task that produced visible dust (see Figure 4) and peak 

concentrations (no graph shown) in the breathing zone of a worker was the compacting by 

hand during disposal of empty bags of milk powder into waste cans.

Canisters for VOCs alongside cleaning 

The evacuated canister area samplers that were placed alongside cleaning operations (Table 

2) measured diacetyl, but the presence of an interfering compound (2-methylpentane) made 

these results unreliable by introducing the possibility of overestimation. Of the six samples, 

only the free ingredients room sample had measurable results: 2,3-pentanedione at 6.2 ppb 

and 2,3-hexanedione at 9.0 ppb. This sample was obtained during CIP and COP procedures 

of equipment containing remnants of free strawberry cream cheese ingredients from a 

previous shift; no cream cheese was being made in the free cook room at the time of sampling; 

strawberry cream cheese was being made in the cook room. Based on the detection limits, 

all of the other in-plant canister samples were below 2.9 ppb for 2,3-pentanedione and 3.6 

ppb for 2,3-hexanedione. All of the canisters, including the sample taken outside the facility, 

measured ethyl alcohol, isopropyl alcohol, and acetone, and all in-plant samples detected 

hexane and trichloromethane; every level was very low, as none of these compounds were at a 

concentration greater than 1/50 of its NIOSH REL [NIOSH 2005].

Sorbent tubes for inorganic acids alongside cleaning 

Table 3 shows the results of area sorbent tube air sampling near cleaning operations for 

inorganic acids. Nitric acid was the only inorganic acid detected, and most measurements 

were below detection limits. The two measurable longer-term concentrations, both about 0.01 

mg/m3, were well below the NIOSH 8-hour REL of 5 mg/m3. The shorter-term 17-minute 

measurement of 0.04 mg/m3 was also well below the NIOSH STEL of 10 mg/m3.

Cardboard debris samples 

Table 4 shows microbial agents cultured from cardboard debris samples collected from 

underneath a packaging conveyor system on the mezzanine level and around the conveyor 

system on the ground level on packaging line 9 in the main packaging room. In the two 

samples, total fungi ranged from 3,300 colony forming units per gram (cfu/g) on the 

ground level to 13,000 cfu/g on the mezzanine level. Total bacteria ranged from 700 cfu/g 

on the mezzanine level to 6,100 cfu/g on the ground level. Currently, there are no accepted 

quantitation levels for health effects for microorganisms in dust. During our sampling in the 

large packaging room, the temperature ranged from 74 to 79 degrees Fahrenheit while the 

relative humidity ranged from 31 to 45 percent.

Updates Since Site Visits

After our site visits, we provided recommendations to the company regarding evaluation of 

existing and installation of additional local exhaust ventilation (LEV). We also recommended 

air sampling after new LEV is installed and during cleaning operations, training on proper 

use of LEV when weighing powders, and using N-95 respirators during compressed air 
Page 10 Health Hazard Evaluation Report 2011-0102-3194

cleaning or eliminating the practice of cleaning with compressed air. We recommended that 

employees see a healthcare provider if they develop or have developed persistent or worsening 

respiratory or other health symptoms.

The company has since reported that they increased the amount of fresh air introduced into 

the cook rooms. Products made with salmon and other allergens are now cooked in a new 

isolated room with dedicated ventilation rather than within a plastic sheet curtain enclosure 

inside the main cooking room as was done during our visits. The company has verified the 

proper performance of local exhaust systems and included these checks in their preventative 

maintenance schedule. Workers have been trained on proper techniques when using the 

ventilation hood in the free ingredients room; the training has been included in the company’s 

safety training. The free ingredients room is currently being reconfigured. The company is 

working at replacing blowing dust (with compressed air) out of areas with vacuuming. The 

cleaning is still done during production times. N-95 respirators are available for voluntary use 

for workers performing or adjacent to compressed air cleaning. Employees see a healthcare 

provider if they develop symptoms that may be work-related. Individualized plans (such as 

moving an affected employee to a different work area or location) are utilized when needed.

Discussion

Flavorings (alpha-diketones)

Results from the NIOSH industrial hygiene survey conducted in September 2011, indicated 

that diacetyl was present at levels above the NIOSH proposed REL in several areas and jobs. 

Unfortunately, for the set of samples analyzed for 2,3-pentanedione with OSHA Sampling 

Method 1016, the limit of detection achieved during analysis was not low enough to assess 

whether exposures exceeded the NIOSH draft REL for that compound. However, when we 

had simultaneous measurement with NIOSH Draft Sampling Procedure SMP2, results were 

well below the OSHA Method 1016 detection limit and the draft REL. A canister sample 

did measure 2,3-pentanedione in the free ingredients room during CIP and COP activities 

at a concentration (6.2 ppb) closer to the draft REL of 9.3 ppb. Our sample was collected 

over 2.6 hours, so direct comparison to the proposed 8-hour REL is not possible. No other 

activities took place in the room that day, so if the concentration was zero for the remaining 

5.4 hours, the 8-hour TWA diacetyl concentration would be 2 ppb [(6.2 x 2.6)/8], well below 

the proposed REL of 9.3 ppb. The actual 8-hour TWA 2,3-pentanedione concentration on that 

day in the free ingredients room was likely somewhere between 2.0 ppb and 6.2 ppb. Diacetyl 

and 2,3-pentanedione likely share the same mechanism of toxicity. Although the draft REL for 

2,3-pentanedione is above that of diacetyl (5 ppb), 2,3-pentanedione has recently been shown 

to be as hazardous as diacetyl [Hubbs et al. 2012; Morgan et al. 2012]. The NIOSH draft REL 

is higher for 2,3-pentanedione than for diacetyl largely because analytic measures are not 

available in a validated OSHA method to detect 2,3-pentanedione at lower levels. The canister 

measurement is more sensitive than the validated OSHA method. There is no draft REL for 

2,3-hexanedione, as its toxicity has not been studied. However, the active chemical structure 

that is believed to be responsible for the butter smell and taste is consistent among diacetyl 
Health Hazard Evaluation Report 2011-0102-3194 Page 11

(also known as 2,3-butanedione), 2,3-pentanedione, and 2,3-hexanedione. 2,3-hexanedione 

may have comparable toxicity to the respiratory epithelial (surface) cells in the smallest 

airways of the lung. Accordingly, the canister measurement of 9.0 ppb for 2,3-hexanedione 

in the free ingredients room is concerning from a health point of view, despite there being 

no recommended guidance. The measurable concentrations of these compounds during 

cleaning processes demonstrate the ongoing potential for exposure even after a product 

has left the immediate production area for packaging. Using evacuated canisters, we were 

not able to obtain reliable measurements of diacetyl at cleaning operations because of an 

interfering chemical compound, so it would be reasonable to conduct additional sampling for 

diacetyl during cleaning operations using OSHA Sampling Method 1012. With simultaneous 

analysis for 2,3-pentanedione and 2,3-hexanedione during this sampling, a more complete 

understanding of potential exposures during these operations would be gained. 

The risk assessment underlying the NIOSH draft recommended standards is based on 

preventing lung abnormalities after a 45-year working life. Thus, the presence of these 

chemicals, even at a low level, is potentially hazardous. The hazard potential may increase 

when these chemicals occur in combination with each other or with other flavoring 

ingredients. For example, many flavorings contain butyric acid in combination with diacetyl, 

and butyric acid may impair the metabolism of diacetyl [Morris and Hubbs 2009], resulting in 

higher possible levels of exposure in the airways. Having exposure to three chemicals with the 

same functional alpha-diketone group may result in additive effects. 

In summary, we did not measure chemical concentrations that violate existing regulations. 

However, the facility has some concentrations of flavoring ingredients that would be prudent 

to reduce or to protect against with respiratory protection. The sampling results suggest 

that there may be increased potential for exposure associated with the process of cooking in 

the plant, which seems reasonable given that this process involves mixing of the individual 

ingredients as well as heating of the mixture, which increases vaporization of VOCs into 

the air. Targeting cooking in any implementation of controls would be a sensible approach. 

Installation of local exhaust at cooking kettles that use flavorings or condiments with alphadiketones (such as diacetyl, 2,3-pentanedione, or 2,3-hexanedione) is one way to reduce 

exposure. Another is to adjust the supply ventilation above the whip cook’s station so it does 

not blow in the direction of the weighing station. In the free ingredients room, the overhead 

ventilation hood arrangement may potentially result in contaminated air being pulled through 

a worker’s breathing zone when a worker places his head over an open barrel while scooping 

powdered material from it. One worker who frequently measures the ingredients in the free 

ingredients room was aware of this fact. He described how he intentionally moves barrels 

to the edge of the hood and scoops while standing outside the hood to ensure emissions are 

pulled away from him into the hood. This is a good practice with the available arrangement 

as long as all workers practice it. However the effectiveness of the practice decreases as the 

material in the barrel is depleted, and the worker is forced to bend over more into the barrel 

to scoop. Effective alternatives would include a hood that pulls air to the rear of the barrel 

instead of overhead and/or a semicircular hood that pulls air at the rear half of the barrel rim. 

Long-handled scoops could supplement ventilation control so the worker does not need to 

bend into the barrel while scooping. Real-time air monitoring for VOCs during our survey 
Page 12 Health Hazard Evaluation Report 2011-0102-3194

indicated tasks that present potential for exposure while producing salmon cream cheese. The 

company has since made an effort to minimize exposure by moving cooking operations with 

salmon and other allergens into a new isolated room with dedicated ventilation rather than 

within a plastic sheet curtain enclosure inside the main cooking room as was done during our 

visits. Real-time dust monitoring indicated certain tasks that produced airborne dust, some 

of which could irritate or exacerbate respiratory conditions. Dusty conditions could also be 

produced with powder flavorings.

Cardboard debris/dust

Regarding the cardboard dust with potential for microbial contamination, there are no 

standards for what level or what species of molds constitute a health risk. We measured them 

because of concern for asthma and knowledge that microbially-contaminated cardboard 

(and contaminated heating-cooling ventilation units containing open water spray chambers) 

had been found in another factory with multiple cases of immune-mediated lung disease 

[Woodard et al. 1988]. All molds have the potential to be allergenic, but there is a lack of 

knowledge on the antigens or allergens found in the vast majority of molds. General good 

housekeeping, and maintenance of heating and air conditioning equipment, is important 

for controlling microbial contaminants. The American Society of Heating, Refrigerating, 

and Air-Conditioning Engineers (ASHRAE) recommends for sorting, packaging, and 

light assembly areas, at least 7.5 cubic feet per minute (cfm) of outside air per person (cfm/

person) and an additional 0.12 cfm of air for every square foot of occupied floor space [ANSI/

ASHRAE 2010A]. ASHRAE also recommends that relative humidity be maintained at or 

below 65% [ANSI/ASHRAE 2010B]. The U.S. Environmental Protection Agency recommends 

maintaining indoor relative humidity below 60%, ideally between 30-50% because excessive 

humidity can promote the excessive growth of microorganisms [EPA 2008]. Our relative 

humidity measurements were within these guidelines. 

Cleaning products

Cleaning products have been identified as an occupational risk for asthma and asthma-like 

symptoms [Ng et al. 1994; Kogevinas et al. 1999; Medina-Ramon et al. 2003; Zock et al. 

2001; Le Moual et al. 2004; 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]. Rosenman et al. [2003] evaluated data from the California, Massachusetts, 

Michigan, and New Jersey state-based surveillance systems from 1993 to 1997. These 

states conducted surveillance for work-related asthma as part of NIOSH’s Sentinel Event 

Notification System for Occupational Risks (SENSOR) Program. Of the confirmed cases of 

work-related asthma identified by these states, 12% were associated with cleaning products. 

Of the cases, 80% had new-onset asthma while 20% had aggravation of pre-existing asthma. 

For many individuals, cleaning often was not the usual primary task; however, based on the 

California data, janitors and cleaners were the most common occupations reported. Nurses, 

nurse aides, and clerical staff were the next most common occupations. Often the specific 

cleaning agents were not identified during the interviews of individuals with work-related 

asthma; however, of the cleaning agents identified, the most common were irritants (such 
Health Hazard Evaluation Report 2011-0102-3194 Page 13

as acids, ammonia, or bleach) and disinfectants (such as formaldehyde, glutaraldehyde, and 

quaternary ammonium compounds). Our air sampling near cleaning operations found nitric 

acid at concentrations well below occupational exposure guidelines.

The company requires two different levels of personal protective equipment depending on the 

type of cleaning. In the cook room, we observed employees not involved with the cleaning 

walking through hot cleaning solution that had been emptied from the bottom of a cooking 

kettle to flow across the floor to open drains. Wet floors can result in slipping, tripping, 

and falling. Also hot cleaning solution on the floor may result in vaporization of cleaning 

chemicals into the air. Skin irritation and burns are also possible.

Ergonomic Issues

At one cook station, we observed repetitive lifting and emptying of 50-pound bags of 

ingredients; the lifting procedures often involved twisting of the worker’s trunk which 

may lead to musculosketal problems such as back pain. Workstations can be designed to 

accommodate the individual worker’s height and reach. This may involve adjustable platforms, 

scales, or work tables. Employees may have useful ideas on how to adjust their workstations to 

make them more user friendly and decrease workplace risk factors. 

Conclusions

While some controls were already in place to reduce exposures to airborne flavorings 

chemicals, cleaning chemicals, and cardboard dust, we noted potential opportunities for 

exposure during our site visits that can be addressed through enhanced engineering controls 

and modified work practices. 

Recommendations

Our recommendations are based on an approach known as the hierarchy of controls. This 

approach groups actions by their likely effectiveness in reducing or removing hazards. In 

most cases, the preferred approach is to eliminate hazardous materials or processes and 

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 personal protective 

equipment may be needed. 

Elimination and Substitution

Eliminating or substituting hazardous processes or materials reduces hazards and protects 

employees more effectively than other approaches. Prevention through design, considering 

elimination or substitution when designing or developing a project, reduces the need for 
Page 14 Health Hazard Evaluation Report 2011-0102-3194

additional controls in the future.

1. Until more is known about the safety of diacetyl and 2,3-pentanedione substitutes 

(e.g., 2,3-hexanedione and 2,3-heptanedione), handle ingredients that contain these 

flavoring chemicals as respiratory hazards. 

Engineering Controls 

Engineering controls reduce employees’ exposures by removing the hazard from the process 

or by placing a barrier between the hazard and the employee. Engineering controls protect 

employees effectively without placing primary responsibility of implementation on the 

employee. 

1. Install local exhaust ventilation at cooking kettles that use ingredients containing 

diacetyl, 2,3-pentanedione, or 2,3-hexanedione (e.g., liquid dairy, strawberry, smoke, 

and blueberry flavorings; powder cheese and cheesecake flavorings; and strawberry 

puree). Conduct additional air sampling after the addition of local exhaust ventilation.

2. Install a new hood in the free ingredients room that pulls air to the rear of instead of 

overhead the barrels from which ingredients are being scooped and/or a semicircular 

hood that pulls air at the rear half of the barrel rim. Provide long-handled scoops.

3. Evaluate cook stations for possible ergonomic changes. 

Administrative Controls 

The term administrative control refers to employer-dictated work practices and policies 

to reduce or prevent hazardous exposures. Their effectiveness depends on employer 

commitment and employee acceptance. Regular monitoring and reinforcement are necessary 

to ensure that policies and procedures are followed consistently.

1. Conduct additional air sampling during cleaning operations (CIP and COP) using 

OSHA Sampling Method 1012 for diacetyl and OSHA Sampling Method 1016 for 

2,3-pentanedione. 

2. Include local exhaust system (e.g., COP stations and measuring hood in free 

ingredients room) checks in the preventative maintenance schedule to ensure they 

continue to operate appropriately.

3. Ensure workers use proper techniques when using ventilation hoods.
Health Hazard Evaluation Report 2011-0102-3194 Page 15

4. Avoid the use of compressed air during cleaning in the packaging room. As an 

alternative, consider using vacuums with high-efficiency particulate air filters. If 

compressed air is used, it should be done during non-production times with minimal 

staff in the area. Those present during the use of compressed air should have N-95 

respirators available for use.

5. Avoid walking through cleaning solution or water on the floor that has drained from 

kettles after clean-in-place procedures. If feasible, install piping from kettles to the 

drainage system instead of allowing cleaning solution to drain onto cook room floor.

6. In the packaging rooms, follow ASHRAE recommended guidelines for indoor relative 

humidity and outside air flow rates.

7. Employees should report new, persistent, or worsening symptoms to their personal 

healthcare provider and, as instructed by their employer, to a designated individual at 

their workplace. An individualized management plan (such as assigning an affected 

employee to a different work location) is sometimes required, depending upon medical 

findings and recommendations of the individual’s physician.

Personal Protective Equipment 

Personal protective equipment is the least effective means for controlling hazardous 

exposures. Proper use of personal protective equipment requires a comprehensive program 

and a high level of employee involvement and commitment. The right personal protective 

equipment must be chosen for each hazard. Supporting programs such as training, changeout schedules, and medical assessment may be needed. Personal protective equipment should 

not be the sole method for controlling hazardous exposures. Rather, personal protective 

equipment should be used until effective engineering and administrative controls are in place.

1. Continue to provide N-95 respirators for voluntary use. Dusty tasks where workers 

may consider wearing them include the following: 

● weighing powder ingredients

● manual addition of powder ingredients into tanks/kettles

● emptying bags of ingredients into bins

● manual compaction of empty bags during disposal in waste cans 

● use of compressed air 

Ensure that each potential N-95 user receives a copy of Appendix D of the OSHA 

Respiratory Protection Standard (http://www.osha.gov/pls/oshaweb/owadisp.show_
Page 16 Health Hazard Evaluation Report 2011-0102-3194

document?p_table=standards&p_id=9784). A NIOSH document showing how to put 

on and take off a disposable respirator correctly can be obtained at http://www.cdc.gov/

niosh/docs/2010-133/pdfs/2010-133.pdf. Further information on respirators can be 

obtained at http://www.cdc.gov/niosh/npptl/topics/respirators/disp_part/RespSource.

html.

Please be aware that N-95s are not protective against alpha-diketones (diacetyl, 

2,3-pentanedione, and 2,3-hexanedione). In cases of dual exposure to dust and alphadiketones, NIOSH-certified organic vapor cartridges (for the alpha-diketones) and 

particulate cartridges/filters (for the dust) would be warranted.

2. Update the Respiratory Protection Plan to specify the type of respirator and cartridges/

filters to use during the following “respirator-required” activities: utility and 

refrigeration department maintenance of ammonia lines, pesticide spraying, and 

painting with inadequate ventilation or as called for by the manufacturer.
Health Hazard Evaluation Report 2011-0102-3194 Page 17

References

ACGIH [2012]. 2012 TLVs® and BEIs®: threshold limit values for chemical substances and 

physical agents and biological exposure indices. Cincinnati, OH: American Conference of 

Governmental Industrial Hygienists.

American National Standards Institute (ANSI)/American Society of Heating, Refrigerating, 

and Air-Conditioning Engineers (ASHRAE) [2010A]. Ventilation for acceptable indoor 

air quality, standard 62.1-2010. American Society of Heating, Refrigeration, and AirConditioning Engineers, Atlanta, GA.

American National Standards Institute (ANSI)/ American Society of Heating, Refrigerating, 

and Air-Conditioning Engineers (ASHRAE) [2010B]. Thermal environmental conditions for 

human occupancy, standard 55-2010. American Society of Heating, Refrigeration, and AirConditioning Engineers, Atlanta, GA. 

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

of the Federal Register.

Environmental Protection Agency (EPA) [2008]. Mold remediation in schools and 

commercial buildings. http://www.epa.gov/mold/mold_remediation.html. Date accessed: 

September 2013.

Hubbs AF, Cumpston AM, Goldsmith WT, Battelli LA, Kashon ML, Jackson MC, Frazer 

DG, Fedan JS, Goravanahally MP, Castranova V, Kreiss K, Willard PA, Friend S, SchweglerBerry D, Fluharty KL, Sriram K [2012]. Respiratory and olfactory cytotoxicity of inhaled 

2,3-pentanedione in Sprague-Dawley rats. Am J Pathol. Sep;181(3):829-44. 

Kogevinas M, Antó JM, Sunyer J, Tobias A, Kromhout H, Burney P [1999]. Occupational 

asthma in Europe and other industrialised areas: a population-based study. European 

Community Respiratory Health Survey Study Group. Lancet 353(9166):1750-1754.

Labrecque M [2012]. Irritant-induced asthma. Curr Opin Allergy Clin Immunol 12(2):140-

144.

LeBouf RF, Stefaniak AB, Virji MA [2012]. Validation of evacuated canisters for sampling 

volatile organic compounds in healthcare settings. J Environ Monit. Mar;14(3):977-83.

Le Moual N, Kennedy SM, Kauffmann F [2004]. Occupational exposures and asthma in 

14,000 adults from the general population. Am J Epidemiol 160:1108-1116.

Mapp CE, Pozzato V, Pavoni V, Gritti G [2000]. Severe asthma and ARDS triggered by acute 

short-term exposure to commonly used cleaning detergents. Eur Respir J 16(3):570-572.
Page 18 Health Hazard Evaluation Report 2011-0102-3194

Medina-Ramon M, Zock JP, Kogevinas M, Sunyer J, Anto JM [2003]. Asthma symptoms in 

women employed in domestic cleaning: A community based study. Thorax 58:950-954.

Morgan DL, Jokinen MP, Price HC, Gwinn WM, Palmer SM, Flake GP [2012].

Bronchial and bronchiolar fibrosis in rats exposed to 2,3-pentanedione vapors: implications 

for bronchiolitis obliterans in humans. Toxicol Pathol. 2012 Apr;40(3):448-65. 

Morris JB, Hubbs AF [2009]. Inhalation dosimetry of diacetyl and butyric acid, two 

components of butter flavoring vapors. Toxicol Sci. Mar;108(1):173-83. 

NIOSH [1994]. Acids, inorganic: Method 7903. In: NIOSH manual of analytical methods 

(NMAM). 4th ed. 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 Number 94-113.

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. 

Available at www.cdc.gov/niosh/npg/. Date accessed: September 2013.

NIOSH [2011]. Draft criteria for a recommended standard: Occupational exposure to diacetyl 

and 2,3-pentanedione. Cincinnati, OH: U.S. Department of Health and Human Services, 

Centers for Disease Control and Prevention, NIOSH; external review draft; August 12, 2011. 

Available at: http://www.cdc.gov/niosh/docket/archive/docket245.html. Date accessed: 

September 2013.

Ng TP, Hong CY, Goh LG, Wong ML, Koh KT, Ling SL [1994]. Risks of asthma associated 

with occupations in a community-based case-control study. Am J Ind Med 25:709-718.

OSHA [2008]. Sampling and analytical methods: Method 1012 – Acetoin and diacetyl. 

Available at http://www.osha.gov/dts/sltc/methods/validated/1012/1012.html. Date accessed: 

September 2013.

OSHA [2010]. Sampling and analytical methods: Method 1016 – 2,3-Pentanedione. Available 

at http://www.osha.gov/dts/sltc/methods/validated/1016/1016.html. Date accessed: September 

2013.

Rosenman KD, Reilly MJ, Schill DP, Valiante D, Flattery J, Harrison R, Reinisch F, Pechter 

E, Davis L, Tumpowsky CM, Filios M [2003]. Cleaning products and work related asthma. J 

Occup Environ Med. 45(5):556-563.

Quirce S, Barranco P [2010]. Cleaning agents and asthma. J Investig Allergol Clin Immunol 

20(7):542-550.

Woodard ED, Friedlander B, Lesher RJ, Font W, Kinsey R, Hearne FT [1988]. Outbreak of 

hypersensitivity pneumonitis in an industrial setting. JAMA. Apr 1;259(13):1965-9.
Health Hazard Evaluation Report 2011-0102-3194 Page 19

Zock JP, Kogevinas M, Sunyer J, Almar E, Muniozguren N, Payo F, Sanchez JL, Anto JM 

[2001]. Asthma risk, cleaning activities and use of specific cleaning products among Spanish 

indoor cleaners. Scand J Work Environ Health 27:76-81.

 

 
Page 20 Health Hazard Evaluation Report 2011-0102-3194 Tables Table 1. Air sampling results for diacetyl, acetoin, and 2,3-pentanedione using sorbent tubes in production and packaging areas, NIOSH survey, Sept. 2011. Sample Type Date Shift Job Title Work Area Cream Cheese Product in Room Sampling Duration (minutes) Diacetyl Concentration (ppb) * Acetoin Concentration (ppb) † 2,3-Pentanedione Concentration (ppb)‡ Area 9/26 1 --- Free Cook Room Free Plain 369 4.6 11.0 Area 9/26 1 --- Line 10 Packaging Room Free Plain 369 0.8 2.3 Area 9/26 1 --- 703 Fill Room Free Plain 376 5.9 23.0 Area 9/26 2 --- Free Cook Room Free Strawberry 372 7.9 33.4 < 15.8 [ < 0.5 ] Area 9/26 2 --- Line 10 Packaging Room Free Strawberry 369 1.5 3.9 < 15.9 Area 9/26 2 --- 703 Fill Room Free Strawberry 354 11.4 22.1 < 16.6 Area 9/26 2 --- Free Ingredients Room Free Strawberry 375 6.7 12.6 < 15.6 Area 9/27 1 --- Cook Room-Soft (Cond.) Strawberry 366 13.8 39.4 [ < 0.5 ] Area 9/27 1 --- Line11 Fill Room Strawberry 358 3.6 13.2 Area 9/27 1 --- Line 7 Fill Room Strawberry 362 1.7 13.0 Area 9/27 1 --- Line 7 Packaging Room Strawberry 247 0.3 2.7 Area 9/28 1 --- Cook Room-Soft (Cond.) Salmon, Plain, C&O€ 364 13.0 23.3 < 16.1 [ 0.9 ] Area§ 9/28 1 --- Cook Room-Soft (Cond.) Salmon, Plain, C&O€ 370 11.4 18.7 < 15.8 Area 9/28 1 --- Line 11 Fill Room Salmon, Plain, C&O€ 368 3.4 11.9 < 15.9 Area 9/28 1 --- Line 11 Packaging Room Salmon, Plain, C&O€ 367 0.3 1.2 < 16.0 Area 9/27 1 --- Outside ---- 190 < 0.3 < 0.1 < 15.4 Personal 9/26 1 Packager Line 10 Packaging Room Free Plain 397 0.4 1.7 Personal 9/26 1 Fill operator 703 Fill Room Free Plain 379 5.2 21.8 Personal 9/26 1 Free cook Free Cook Room Free Plain 400 3.6 8.5 Personal 9/26 2 Free cook Free Cook Room Free Strawberry 361 8.3 34.3 < 16.2 Personal 9/26 2 Free condiment cook Free Ingredients Room Free Strawberry 362 6.7 19.6 < 16.2 Personal 9/26 2 Packager Line 10 Packaging Room Free Strawberry 361 0.9 3.2 < 16.2 Personal 9/26 2 Fill operator 703 Fill Room Free Strawberry 180 6.3 20.9 VOID Personal 9/27 1 Packager Line 7 Packaging Room Strawberry 386 1.0 4.2 Personal 9/27 1 Fill operator Line 7 Fill Room Strawberry 364 1.4 9.0 Personal 9/27 1 Fill operator Line 11 Fill Room Strawberry 390 3.3 12.9 Personal 9/27 1 Soft cook Cook Room-Soft Strawberry 370 8.3 23.5 Personal 9/28 1 Packager Line 11 Packaging Room Salmon, Plain, C&O€ 362 0.7 1.5 < 16.2 Personal 9/28 1 Fill operator Line 11 Fill Room Salmon, Plain, C&O€ 386 2.2 6.8 < 15.7 Personal 9/28 1 Soft cook Cook Room-Soft Salmon, Plain, C&O€ 391 5.5 12.2 < 15.0 Personal 9/26 1 Free cook Free Cook Room Free Plain 16 4.4 11.3 Personal 9/26 2 Free cook Free Cook Room Free Strawberry 15 15.1 85.1 < 48.8 Personal 9/26 2 Fill operator 703 Fill Room Free Strawberry 15 8.5 25.9 < 48.8 Personal 9/27 1 Condiment cook Cook Room-Soft (Cond.) Strawberry 16 10.7 28.6 Personalß 9/28 1 Condiment cook Cook Room-Soft (Cond.) Salmon, Plain, C&O€ 43 11.6 20.0 < 17.0 Personal 9/28 1 Condiment cook Cook Room-Soft (Cond.) Salmon, Plain, C&O€ 43 10.9 25.5 < 17.0 *OSHA Sampling Method 1012; NIOSH Draft Recommended Exposure Limit (REL) 5 ppb 8-hour time-weighted average (TWA) (above REL in BOLD); NIOSH Draft Short-Term 

Exposure Limit (STEL) 25 ppb for 15 minutes. †OSHA Sampling Method 1012; no NIOSH Draft REL or STEL. ‡OSHA Sampling Method 1016, NIOSH Draft Sampling Procedure SMP2 [in brackets]; NIOSH Draft REL 9.3 ppb 8-hour TWA, NIOSH Draft STEL 31 ppb for 15 minutes. §Used shortly as personal sample and finished as area sample (adjacent to other area sample). ßNIOSH investigator carried sampler and shadowed condiment cook. €Plain and chive & onion (C&O) cream cheeses, which did not use alpha-diketone-containing ingredients, also being made in the room. VOID = sample results void because of sampling pump failure. Cond. = condiments area. ppb = parts contaminant per billion parts air. < = not detected; value is limit of detection.
Health Hazard Evaluation Report 2011-0102-3194 Page 21 Table 2. Air sampling results† for diacetyl, 2,3-pentanedione, and 2,3-hexanedione using evacuated canisters at cleaning operations, NIOSH survey, Sept. 2011. Sample Type Date Shift Job Title Work Area Cream Cheese Product Being Made in Room Sampling Duration (minutes) Diacetyl Concentration (ppb)* 2,3-Pentanedione Concentration (ppb) 2,3-Hexanedione Concentration (ppb) Area 9/26 1 --- Cook Room-at COP Plain‡§ Instant 20* < 1.2 < 1.5 Area 9/26 1 --- Cook Room-at COP Plain‡§ 279 25* < 2.1 < 2.6 Area 9/26 2 --- Cook Room-at COP Plain‡§ Instant 23* < 1.2 < 1.5 Area 9/26 2 --- Cook Room-at COP Plain‡§ 239 19* < 2.9 < 3.6 Area 9/27 1 --- Free Ingredients Room-at CIP/COP None (free strawberry)ß Instant 5.1* < 1.2 < 1.5 Area 9/27 1 --- Free Ingredients Room-at CIP/COP None (free strawberry)ß 155 4.8* 6.2 9.0 Area 9/27 1 --- Outside ---- 279 < 3.0* < 3.4 < 4.3 †No recovery correction was performed. *Reliable diacetyl results not available because of co-eluting interference with another compound (2-methylpentane); thus, measurement could be overestimation. ‡Plain cream cheese did not use alpha-diketone-containing ingredients. §Free plain cream cheese being made in adjacent free cook room during 1st shift; free strawberry cream cheese being made in adjacent free cook room during 2nd shift. ßNo product was being made in the room, but remnants of free strawberry cream cheese ingredients from previous shift were being cleaned from equipment, and strawberry cream cheese was being made in the cook room. COP = clean-out- of-place. CIP = clean-in-place. ppb = parts contaminant per billion parts air. < = not detected; value is limit of detection Table 3. Air sampling results for inorganic acids using sorbent tubes at cleaning operations, NIOSH survey, September 2011. Sample Type Date Shift Job Title Work Area Sampling Duration (minutes) Nitric Acid Concentration (mg/ m3)* Area 9/26 1 --- Cook Room-at COP 280 < 0.004 Area 9/26 1 --- Cook Room-at COP 142 < 0.003 Area 9/26 2 --- Cook Room-at COP 379 < 0.003 Area 9/27 1 --- Free Ingredients Room-at CIP/COP 155 0.007 Area 9/28 1 --- Cook Room-at COP (CIP)† 160 0.008 Area 9/26 2 --- Cook Room-at COP 19 < 0.021 Area 9/27 1 --- Free Ingredients Room-at CIP/COP 17 0.038 Area 9/28 1 --- Cook Room-at COP (CIP)† 15 < 0.027 *Nitric acid measured with NIOSH Sampling Method 7903; no other acids were detected. †A CIP also took place nearby in the room COP = clean-out-of-place. CIP = clean-in-place. mg/m3 = milligrams nitric acid per cubic meter air. < = not detected; value is limit of detection.
Page 22 Health Hazard Evaluation Report 2011-0102-3194

Table 4. Microbial agents cultured from cardboard dust mixture collected by NIOSH 

investigators, July 7, 2011.

Sample location Fungi Bacteria

Identification cfu/g† Identification cfu/g†

Under conveyor Cladosporium sphaerospermum 5,000 Bacillus 500

on mezzanine Mucor plumbeus 1,000 Gram negative rods 200

level in large Penicillium brevicompactum 3,000 Total bacteria 700

packaging room Penicillium chrysogenum 2,000

Penicillium glaborum 1,000 Thermophilic actinomycetes 0

Penicillium species 1,000

Total fungi 13,000

On and around Cladosporium sphaerospermum 1,400 Bacillus 2,200

conveyor on Mucor plumbeus 200 Gram negative rods 3,800

ground level of Penicillium brevicompactum 100 Gram positive cocci 100

packaging line 9 Penicillium crustosum 700 Total bacteria 6,100

in the large Penicillium glabrum 200

packaging room Penicillium species 600 Thermophilic actinomycetes 0

Yeast 100

Total fungi 3,300

†cfu/g = colony forming units per gram.
Health Hazard Evaluation Report 2011-0102-3194 Page 23

Figures

Figure 1. Puddle formed after release of cleaning solution onto floor during cleanin-place operation, NIOSH survey, Sept. 28, 2011.
Page 24 Health Hazard Evaluation Report 2011-0102-3194

Figure 2. Real-time total volatile organic compound measurements near worker at 

condiment cooking station, NIOSH survey, Sept. 28, 2011.

Note. VOCs: volatile organic compounds; ppm: parts per million.
Health Hazard Evaluation Report 2011-0102-3194 Page 25

Figure 3. Personal real-time dust measurements at whip cooking station, NIOSH 

survey, September 27, 2011.

Note. mg/m3: milligram per cubic meter.
Page 26 Health Hazard Evaluation Report 2011-0102-3194

Figure 4. Worker disposing of empty powder ingredient bag into waste can in free 

cook room, NIOSH survey, Sept. 26, 2011.
Health Hazard Evaluation Report 2011-0102-3194 Page 27

Keywords: NAICS 311513 (Cheese Manufacturing), flavorings, diacetyl, 2,3-pentanedione, respiratory symptoms, ventilation
Page 28 Health Hazard Evaluation Report 2011-0102-3194

This page left intentionally blank
Health Hazard Evaluation Report 2011-0102-3194 Page 29

NIOSH Health Hazard Evaluation Program 

Description 

The Health Hazard Evaluation Program investigates possible health hazards in the workplace 

under the authority of Section 20(a)(6) of the Occupational Safety and Health 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, U.S.C. 951(a)(11). The Health Hazard Evaluation Program also provides, upon request, 

technical assistance to federal, state, and local agencies to investigate occupational health 

hazards and to prevent occupational injury and disease. Regulations guiding the Program 

can be found in Title 42, Code of Federal Regulations, Part 85; Requests for Health Hazard 

Evaluations (42 CFR 85).

Acknowledgments

Analytical Support: Nicole Edwards

Desktop Publisher: Tia McClelland

Site Visit: Rachel Bailey, Mike Beaty, Randy Boylstein, Chris Piacitelli, and Christine Schuler. 

Availability of Report

Copies of this report have been sent to the employer and employee representative at the 

facility. The New York State Department of Health and the Occupational Safety and Health 

Administration Regional Office have also received a copy. This report is not copyrighted 

and may be freely reproduced. 

This report is available at http://www.cdc.gov/niosh/hhe/reports/pdfs/2011-0102-3194.pdf.

All other HHE Reports may be found at http://www2a.cdc.gov/hhe/search.asp

Recommended citation for this report:

NIOSH [2013]. Health hazard evaluation report: Evaluation of respiratory 

concerns at a cream cheese manufacturing facility—New York. By 

Bailey RL, Piacitelli CA. Morgantown, WV: U.S. Department of Health and 

Human Services, Centers for Disease Control and Prevention, National 

Institute for Occupational Safety and Health, NIOSH HHE Report No. 

2011-0102-3194.
To receive documents or other information about

occupational safety and health topics, contact NIOSH

Telephone: 1-800-CDC-INFO (1-800-232-4636)

TTY: 1-888-232-6348

email: cdcinfo@cdc.gov

or visit the NIOSH website at http://www.cdc.gov/niosh

Delivering on the Nation’s promise:

Safety and health at work for all people through research and prevention