Health Hazard Evaluation Report 2012-0222-3203 Page 1

Evaluation of Exposures and Health at a 

Specialty Chemicals Plant, West Virginia

Report No. 2012-0222-3203

February 2014

Anna-Binney McCague, MD

Jenna L. Armstrong, PhD

Kristin J. Cummings, MD, MPH

Ju-Hyeong Park, ScD, 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 2012-0222-3203

Contents

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

Abbreviations .......................................v

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

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

Background.......................................... 2

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

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

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

Discussion .......................................... 11

Conclusion.......................................... 14

Recommendations............................. 14

References.......................................... 18

Figures................................................ 21

Acknowledgements........................... 25

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 2012-0222-3203 Page i

We evaluated a specialty 

chemicals plant for skin and 

respiratory exposures leading to 

health problems. We found that 

eye and respiratory irritation are 

common among employees, 

who are generally concerned 

about their exposures. Two 

workers have sought care for 

illnesses they attributed to 

exposures at work: one was 

diagnosed with bronchiolitis 

obliterans while the other was 

diagnosed with occupational 

asthma and reactive airways 

dysfunction syndrome. Workers 

described apprehension 

about reporting accidents and 

unsafe conditions to superiors. 

We recommended that the 

company discuss such concerns 

with employees, invest further 

in the medical surveillance 

program, and modify the 

industrial hygiene program. 

Highlights of this Evaluation

The National Institute for Occupational Safety and Health (NIOSH) received a confidential 

request from employees at a specialty chemicals plant in West Virginia. The requestors had 

concerns about respiratory and skin exposures to multiple chemicals used at the plant. They 

felt that such exposures were causing respiratory disease and other illnesses. 

What NIOSH Did

● We interviewed employees, managers, and the 

company’s medical consultants by telephone.

● We reviewed documents, including air 

sampling reports and medical records.

● In February 2013, we visited the plant.

● During the visit, we met with company 

industrial hygienists and conducted private, 

in-person interviews with employees randomly 

selected from a variety of departments and 

shifts.

● We also took a tour of the plant and observed 

workers performing their tasks. 

● We provided an interim letter detailing 

recommendations for improvements.

● We held a conference call with the company 

several months later to review the changes that 

had been implemented. 

What NIOSH Found

● Management was cooperative and employees 

were willing to talk with us. 

● The plant uses and produces many chemicals 

with respiratory toxicity.

● One worker’s physician diagnosed him/her with 

bronchiolitis obliterans, an irreversible lung disease that this physician attributed to 

chemical exposures at the plant. 

● A second worker also became sick. This worker’s symptoms have been attributed to 

occupational asthma secondary to isocyanate exposure by a pulmonologist. Other 

physicians have felt these symptoms were consistent with asthma or reactive airways 

dysfunction syndrome. 
Page ii Health Hazard Evaluation Report 2012-0222-3203

● Employees seemed to know where to find out about personal protective equipment 

requirements and were knowledgeable about its proper use. 

● Workers were concerned about several issues: decreased local exhaust ventilation when 

many hoses were functioning simultaneously; delayed preventative maintenance leading 

to potentially catastrophic equipment failures; difficulty of wearing correct protective 

equipment in the summer months or when running multiple jobs; and understaffing at 

the plant impacting safety by requiring multi-tasking. 

● Workers felt that certain tasks were more likely to lead to exposures; these included filter 

cleaning, flushing of lines/kettles, and hand charging of kettles. 

● Some workers also expressed concern about reporting of unsafe conditions. They felt 

anonymous reporting mechanisms did not exist. Some expressed reluctance to submit 

reports for this reason. 

● The company has anonymous reporting mechanisms, including a phone line, but they 

may not be widely recognized.

● Some workers perceived that accidents led to retaliation.

● The company forbids retaliation for accidents, but says that employees may be punished 

for safety lapses that lead to accidents. These may be uncovered when the accident is 

investigated.

● The plant has an onsite clinic capable of conducting spirometry testing, but this testing 

has not been included in standard annual employee examinations for several years. 

● The plant conducts air monitoring to assess and manage workers’ exposures. 

Throughout the course of each year, approximately 300 personal air samples are 

collected. 

● Air monitoring is mainly focused on obtaining personal average exposures during tasks 

rather than during a full shift. 

● Workers frequently work 12 hour shifts plus mandatory overtime, leading to 40-80 hour 

work-weeks.

● Exposure limits are not adjusted to account for extended shifts.

What the Employer Can Do

● Communicate with employees about areas and tasks which concern operators, and 

investigate such concerns.

● Work with the union and health and safety committee to increase awareness of existing 

ways, or develop new ways for employees to anonymously report unsafe conditions.

● Invest in changing the perception of retaliation for accidents, so that incidents and near 

misses do not go unreported. 

● Include annual spirometry in the employee wellness exams. 
Health Hazard Evaluation Report 2012-0222-3203 Page iii

● Analyze spirometry results for excessive decline in lung function over time, and for 

clustering of abnormal results in certain departments. 

● Evaluate employees for bystander and intermittent high exposures, and include 

chemicals without a specific Threshold Limit Value-Ceiling or Short-Term Exposure 

Limit.

● Consider area monitoring with direct reading instruments to help guide peak or shortterm exposure sampling in areas of concern. 

● Conduct full shift sampling, and adjust regulatory limits for longer work days and work 

weeks.

● Develop a strategy to judge whether each group exposure profile is acceptable, 

unacceptable, or uncertain. 

What Employees Can Do

● Report conditions that appear to be unsafe either to a supervisor or using the 

anonymous reporting system.

● Check jobs for required personal protective equipment, and wear it as directed.

● Bring concerns about exposures to union or health and safety representatives.

● Report accidents, incidents, and near-misses to the appropriate person so that 

procedures can be improved in the future. 
Page iv Health Hazard Evaluation Report 2012-0222-3203

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Health Hazard Evaluation Report 2012-0222-3203 Page v

Abbreviations

μm Micrometer

ACGIH® American Conference of Governmental Industrial Hygienists

AIHA American Industrial Hygiene Association

CFR Code of Federal Regulations

EHS Environmental health and safety

HazCom Hazard communication

HEG Homogenous exposure group

JSA Job safety analysis

LOD Limit of detection

mg/m3 Milligrams per cubic meter

mL Milliliter

MSDS Material safety data sheet

NAICS North American Industry Classification System

NIOSH National Institute for Occupational Safety and Health

OEL Occupational exposure limit

OP Operating procedure

OSHA Occupational Safety and Health Administration

PEL Permissible exposure limit

PPE Personal protective equipment

ppm Parts per million

REL Recommended exposure limit

SEG Similar exposure group

SOP Standard operating procedure

STEL Short-term exposure limit

TLV® Threshold limit value

TWA Time-weighted average

UCR Unsafe Condition Report

VPP Voluntary Protection Program
Health Hazard Evaluation Report 2012-0222-3203 Page 1

Summary

In September 2012, the National Institute for Occupational Safety and Health (NIOSH) 

received a confidential health hazard evaluation request from employees at a specialty 

chemicals plant. They were concerned about skin and respiratory exposures to chemicals used 

at the plant. They felt that workers were at risk for lung disease, rashes, and cancer, among 

other illnesses. In February 2013, NIOSH visited the plant. During the visit, we confidentially 

interviewed a variety of employees, talked to company officials (local and corporate), met 

with the union president, and toured the plant. We also reviewed documents provided by 

the company, including a list of some chemicals used at the plant, results of recent industrial 

hygiene sampling, injury and illness logs, and information about how unsafe conditions are 

reported. We found that the plant uses and produces many chemicals with respiratory toxicity, 

and two employees have sought medical attention for respiratory illnesses. One employee’s 

physician diagnosed him/her with bronchiolitis obliterans, which is an irreversible lung 

disease that the physician attributed to chemical exposures at the plant. Another employee 

was diagnosed with occupational asthma and reactive airways dysfunction syndrome. In 

conversations with employees, we found that many had concerns about the effect of workrelated exposures on their health, though most did not have symptoms they specifically 

attributed to the plant. Workers expressed concern about mechanisms for reporting of safety 

concerns, feeling that filing a complaint led to a “black mark” on their record, instead of being 

recognized as a proactive safety initiative. Some workers reported concerns about accidents as 

well, saying people who were involved in accidents were eventually fired or disciplined, and 

stated that they would hesitate to report an accident. The plant does not allow retaliation for 

accidents, but notes that workers can be disciplined for failing to follow safety procedures. 

During the tour we noticed that the plant had a variety of chemical odors in different areas, 

and although workers were careful about required personal protective equipment and local 

ventilation, bystanders in similar areas were not required to adhere to the same protection 

standards. The industrial hygiene sampling plan focused on measuring task-based exposure 

and workers with the highest exposure potential. Sampling was not performed on bystanders; 

neither did the plan account for simultaneous exposures to multiple chemicals during 

an eight-hour shift or the extended shifts worked by many employees. We made several 

recommendations in an interim letter in May 2013. Since that time, the company has begun 

to implement some changes. These include adding spirometry to annual medical exams 

and planning for changes in the industrial hygiene monitoring protocol for 2014. Given the 

potential exposure to recognized respiratory toxins, the occurrence of respiratory illness in 

the workforce, and employees’ concerns about exposure and health, we recommend that 

the company use an improved comprehensive exposure assessment strategy and medical 

monitoring to guide preventive interventions. 

Introduction

In October 2012, the National Institute for Occupational Safety and Health (NIOSH) received 

a confidential health hazard evaluation request from employees of a specialty chemical plant. 

The requestors were concerned about respiratory and skin exposures to the various chemicals 
Page 2 Health Hazard Evaluation Report 2012-0222-3203

used at the plant, and several potential health effects. From February 25 to 27, 2013, four 

NIOSH employees visited the plant, met with employees and management, and toured the 

plant. In May 2013, we sent an interim letter to the company with recommendations. The 

company replied in a formal letter in July 2013, and we followed up by phone in September 

2013. 

Background

The plant is located on 60 developed acres of a 1300-acre tract in a rural area. It has been in 

operation since 1955 and currently employs about 400 people, including over 200 chemical 

union members (International Chemical Workers, Local 698) who are hourly employees. 

Work shifts are typically 8 or 12 hours. The plant produces a range of specialty chemicals 

for a wide variety of industrial customers. The three main business lines are specialty fluids 

(e.g., defoamers, lubricants, cosmetics, and softeners), urethane additives (precursors for 

polyurethane foam applications), and silanes (e.g. adhesives, insulating material, wires, and 

rubber applications). The large plant is organized around four production departments 

referred to as Polymers I (or Specialties West), Polymers II, New Product Development 

(or Specialties East), and Silanes. The production departments are further supported by 

Warehouse and Distribution, Research and Development, a Quality Control Laboratory, and 

Environmental Protection Units. 

Process Description

Thousands of raw ingredients are used at the plant for a large number of batch recipes that are 

made according to customer orders. The batch orders change often and the work is variable. 

Some chemical classes include acid anhydrides, acrylates, amines, isocyanates, chlorides, 

silanes, and volatile organic solvents. Platinum salts may also be used as a catalyst. Most of the 

volatile organic solvents are routinely used in batches and for cleaning of equipment between 

batches. Nitrogen gas is also used often to purge empty kettles, storage tanks, and drums 

before filling in order to reduce flammability. 

Departments typically have one or more control rooms outfitted with computers and multiple 

monitors to control operations. The control room is located in a different room or building 

than the production floor. Operators follow company operating procedures (“OPs,” a term 

used by the company that is comparable to the widely used standard operating procedures 

[SOPs]), which are designed by engineers to include recipes and instructions for reacting raw 

or intermediate ingredients in a kettle. The special combination of raw ingredients is called a 

“batch”. Kettles range in size from 30 to 9,000 gallons. On the production floor, an operator

“charges” a kettle by adding solid (powdered) and liquid ingredients manually (i.e., “hand 

charges”) or automatically. Manual charging occurs through the “manhole”, which is a small 

bolted door at the top of the kettle. This is done by directly pouring the hand charge into the 

kettle or by using a funnel. Operators also use local exhaust to ventilate when the manhole 

is open. Automated charging occurs via hoses or pipes tied to tanks equipped with pumps 

or directly from drums and trailers. During the production process, certain chemicals may 
Health Hazard Evaluation Report 2012-0222-3203 Page 3

be removed (i.e., “stripped”) from the mixture through distillation and transferred to a strip 

tank. Depending on the circumstances, the stripped chemical can be the final product or an 

impurity. Most kettles have an agitator device that mixes ingredients inside. Samples are taken 

by operators at multiple stages of the process. Operators will collect samples from the kettles 

from inline valves into a 4-ounce glass jar. Samples are sent to the Quality Control Laboratory 

for analysis. 

The product may be filtered when the reaction is complete or during agitation. This is done 

directly to the finished product or after being piped to a larger tank. The filtering may occur 

with bags or open frames containing filtering plates. Frames in the older filtering system are 

open, whereas bags and frames in newer systems are enclosed. In the older filtering system, 

the operators must attach filter paper to the plates, while the newer, enclosed system has 

built-in filters. A filtering aid, such as diatomaceous earth or activated charcoal, is added to 

the product in slurry to facilitate the removal of impurities. After contact with the filter, the 

impurities collect on the plates and bags, allowing a cleaner product to pass through.

After a product run is complete, the older plate frame filter system is cleaned by manually 

scraping off the slurry and filter paper material with a large spatula or scraper and shaking it 

into a pit located below the filter. The kettle and/or filter may be stripped with solvents like 

toluene, isopropyl alcohol, ethanol, methanol, or xylene. The stripping process is enclosed, 

as the solvent is piped into the kettle and blown into a waste solvent tank. Waste solvent is 

transferred to a portable tank, or dumpster, to be treated. This waste is managed onsite at 

a private wastewater treatment plant, a rotary kiln incinerator for solvents and solids, or 

by being transferred to an onsite landfill. Hazardous wastes are treated with neutralizing 

compounds (e.g., lime) to bring pH back to neutral and run through primary clarifiers. Some 

waste water is transported to an offsite commercial treatment facility. 

Finished products are packaged into drums in the production area in some areas and piped 

to storage tanks and held until transferred to a drum filling station in others. At this station, 

distribution transfer operators weigh and fill drums through a pipe opening or drum dip tube 

under local exhaust ventilation. Intermediate products that will be used at the plant to make 

final products are transferred to drums or centralized storage tanks where they are held until 

needed. All final products are transferred into drums or large shipment tanks for transport. 

Emergency Response

The plant operates a fire brigade and hazardous materials response team that is on call at all 

times. Brigade members receive hands-on training in fighting chemical fires at an annual 

course held in South Carolina. The fire brigade responds to fires, vapor clouds (which may 

occur due to leaks or pipe ruptures), leaks, spills, and the formation of a potentially explosive 

“hydrolysate ball” in the production of silanes. The ball is formed on pipes when a leak is 

present. The employer estimates that the fire brigade responds to about 10 calls per year. 
Page 4 Health Hazard Evaluation Report 2012-0222-3203

Personal Protective Equipment and Respiratory Protection Program

Required personal protective equipment (PPE) in production areas includes hard hats, safety 

glasses, steel toe shoes, and flame retardant clothing. Depending on the type of chemicals 

required for a batch recipe, operators may also wear gloves, rain suits, and respiratory 

protection. Respiratory protection consists of disposable filtering facepiece respirators, full 

facepiece respirators with cartridges, and tight-fitting full facepiece masks used with a selfcontained breathing apparatus or supplied air. The type of respiratory protection varies 

depending on the chemical ingredients in a batch recipe. Multiple information resources are 

provided to operators, allowing them to determine what type of respirator is required. These 

include a Job Safety Analysis (JSA) document, the OPs, the Lab Information Management 

System for labeling (LIMS), and the material safety data sheets (MSDSs). All workers have 

access to the JSA system and MSDSs from computers located in the control rooms. Employees 

in the respiratory protection program undergo annual medical evaluation (questionnaire and 

physical examination) followed by quantitative fit testing with a TSI PortaCount® respirator fit 

tester. Spirometry was not routinely conducted at the time of our evaluation.

Methods

Prior to Site Visit

Prior to our visit to the plant, we had several phone conversations with the plant industrial 

hygienist, the Environmental Health and Safety (EHS) manager, and the corporate industrial 

hygienist. We also talked with the medical team, including the plant nurse, the corporate 

physician, and the plant physician in order to learn more about the medical programs at 

the plant. Lastly, we interviewed the requestors and other workers from the plant over the 

phone, in order to understand health concerns, safety practices, and potential exposures at the 

workplace. 

The company industrial hygiene and EHS team described the plant’s operations and safety 

programs to us and provided the documentation that we requested. These documents 

included: Occupational Safety and Health Administration (OSHA) 300 logs of illness and 

injury, the hazard communication (HazCom) manual, the management of change plan, the 

written respiratory protection plan, and the OSHA Voluntary Protection Program (VPP) site 

review report. Additionally they provided the Superfund Amendment and Reauthorization 

Act Tier 2 chemical report from 2011, industrial hygiene monitoring data for the past 5 years, 

a list of chemicals within certain families used at the site, and a brief description of their 

homogenous exposure group (HEG) strategy. In preparation for the visit, they also sent us an 

employee roster. We reviewed all this information carefully, and asked for clarifications and 

other information where necessary. We also reviewed existing medical and industrial hygiene 

literature about known health effects from the chemicals used at the plant. 

Site Visit 

Upon arrival at the site, we had an opening conference, attended by local and corporate 

management, industrial hygienists, the corporate physician, supervisors and team leads 
Health Hazard Evaluation Report 2012-0222-3203 Page 5

from around the plant, and a union representative from the International Chemical Worker’s 

Union, Local 698c. During this meeting, we viewed a slide show about the plant’s history and 

manufacturing, and we discussed our plan for the visit. Afterwards, we watched a safety video 

about the plant. 

That afternoon, we toured the facility to improve our understanding of the plant processes. 

We observed workers performing their tasks. We took photographs of equipment and safety 

provisions, and also learned about how the need for PPE is determined. 

Subsequently, the two industrial hygienists on our team explored the plant in more depth. 

They revisited some areas, including New Product Development and Distribution Transfer, 

examined PPE use and OPs, and observed employees performing tasks (e.g., hand charging 

kettles, drum-filling, and laboratory experiments). Additionally, they spoke in depth about 

the plant’s current exposure assessment strategy and historical exposures with the plant and 

corporate industrial hygienists, as well as the union representative from the plant.

The two physicians on the team spent time interviewing workers from all over the plant. These 

confidential interviews were intended to better understand individual safety practices and 

PPE use, and to address any health and safety concerns that might exist in the workforce. We 

provided copies of an informational handout regarding our visit, and had available pamphlets 

on the NIOSH health hazard evaluation program [NIOSH 2009]. Lastly, we reviewed medical 

records and discussed health and safety issues and medical surveillance procedures and 

capabilities with medical personnel. 

At the end of the visit, we had a closing meeting, during which we discussed our findings, 

preliminary recommendations, and the future course of the investigation. We requested, 

and have received from the plant, a list of photos designated as trade secret, 2 sample 

JSAs, a sample unsafe condition report (UCR) form, a HazCom label, and the preventative 

maintenance procedures for the plant.

After the Site Visit

We prepared an interim letter summarizing our findings and interim recommendations. This 

was sent to the company, confidential requestors, OSHA, and the state health department in 

May 2013. The company reports that they posted the letter for 30 days as requested. In July 

2013, they composed and mailed a response letter, which detailed their implementation of our 

recommendations and the changes at the plant subsequent to our visit. It also included some 

information in response to our observations. We followed up with a phone call in September 

2013. During this phone call, we clarified questions and statements from the plant’s response 

letter. We also asked about further changes since the time of the letter. We offered to review 

the quality of spirometry and their amendments to industrial hygiene sampling strategy. 
Page 6 Health Hazard Evaluation Report 2012-0222-3203

Results

Document Review

During conversations prior to our visit, the management team disclosed information about 

2 workers with respiratory illness. The first had been diagnosed with bronchiolitis obliterans 

(also called obliterative bronchiolitis). Obliterative bronchiolitis is a severe lung disease, 

previously reported to be associated with chemical exposures in a variety of industries [Kreiss 

2013]. The lung function decline is irreversible and may result in the need for lung transplant. 

The second worker had been diagnosed with occupational asthma and reactive airways 

dysfunction syndrome. At least one physician related these symptoms to the worker’s 

reported prior isocyanate exposure at this plant. This worker had been potentially exposed 

to isocyanates during a spill response prior to the onset of symptoms. Some isocyanates are 

associated with asthma, asthma-like symptoms, and other obstructive lung disease [Pala et al 

2011; Pronk et al 2009]. Chemical sensitivity has also been described in the literature; it has 

been associated with several chemicals used at the plant, including di-isocyanates [Mapp et al 

1988]. 

Our review of the chemicals used at the plant revealed that many are skin and/or eye irritants. 

Additionally, others have been associated previously with respiratory injury and irritation. 

There is some literature available that certain exposures through the skin may lead to 

respiratory sensitization and thus irritation on subsequent exposure [Kimber and Dearman 

2002]. Additionally, solvent exposure has been linked to toxic encephalopathy (nervous 

system damage) as well as other health effects [Beningus et al 2009]. 

In our review of the OSHA VPP program application and assessment, we noted that OSHA 

had recommended a review of the conversation record. This is a record generated when the 

company investigates a UCR which has been turned in by an employee. These become part 

of the employee’s file and are widely perceived by employees to have a negative impact. The 

report stated that OSHA did not find evidence these were misused, though workers reported 

concerns about this process and the union felt it was disciplinary. When we asked the 

managers about this process prior to and during our visit, they stated that the conversation 

record remained largely unchanged, but they were discussing how to alter its perception 

among workers. 

From our review of the industrial hygiene documents, we learned that the plant applies 

a Similar Exposure Grouping (SEG) and HEG strategy to assess and manage workers’ 

exposures. There are two SEGs (hourly and salaried employees) and 39 HEGs, which are 

called similar exposure groups by the American Industrial Hygiene Association (AIHA). 

In this document we use the company’s terminology and will refer to them as HEGs. We 

analyzed the industrial hygiene monitoring data from 2008 to 2012 that the company 

provided. According to the defined working nature of each specific HEG, the company’s 

industrial hygienist monitored for specific airborne exposures to a range of chemicals. 

Over the course of 5 years, there were 126 combinations of HEGs and chemicals monitored 
Health Hazard Evaluation Report 2012-0222-3203 Page 7

(obtained from 35 HEGs and 44 chemicals monitored), for a total of 1,031 airborne 

measurements. Among those HEGs, Maintenance Welders were most frequently monitored 

(21% of the total number of measurements), followed by Distribution Transfer Operators 

(13%). Several HEGs, including Maintenance Welders, Distribution Transfer Operators, 

and other Operators in the production departments, were monitored for potential airborne 

exposures to more than 5 chemicals. Among all 44 chemicals, toluene was the most frequently 

monitored chemical, with over 19% of the total measurements (from 24 HEGs), followed by 

acrylonitrile (8% from 9 HEGs), acrolein (6% from 5 HEGs), and allyl chloride (4% from 6 

HEGs) [Figures 1 and 2 at the end of the report].

Employee Interviews

Everyone at the plant was friendly, welcoming, and generally willing to talk to us and answer 

questions. Overall, most employees felt that safety and the work environment at the plant 

had improved over the past several decades. Many mentioned a decrease in large scale 

incidents and emergencies such as vapor clouds and fires. They also commented that the plant 

responded to incidents with new safety regulations when appropriate. 

Many employees felt that there were additional steps that plant management could take in 

order to provide a safe working environment. Many workers stated that accidents frequently 

go unreported due to a fear of reprisal. Workers generally agreed that they would avoid 

reporting an accident if possible. Additionally, many employees acknowledged that the design 

of the UCRs was good in theory, but felt that they did not work as intended. In the past, 

employees were positively recognized for drawing attention to potential health and safety 

issues (by being entered into a drawing for a free gift). Workers stated that currently the UCR 

forms are used to follow back with employees about whether the problem has been fixed, in 

the process creating a “conversation record”. This record is viewed negatively by workers, who 

feel it is used solely as a disciplinary tool.

In terms of health, few employees reported symptoms that they attributed to the workplace, 

but many seemed to feel that working at the plant would ultimately negatively impact their 

health. The most frequent symptoms reported were eye burning or stinging during the filter 

stripping process or when using solvents. A number of people reported chronic cough or 

shortness of breath, though these were rarely attributed to work. 

Nonetheless, workers had concerns about possible exposures. Some specific concerns 

included: a) insufficient local exhaust ventilation when many of them within the same 

work area were operating simultaneously; b) delayed preventative maintenance and repairs, 

potentially leading to catastrophic equipment failure; c) difficulty in wearing correct PPE 

during the warmer months and while running multiple jobs requiring different PPE; and 

d) the current understaffing of the plant, leading to additional responsibilities and extended 

work shifts. 

Three tasks routinely mentioned by employees as potential sources of exposure were cleaning 

of filters, flushing of the lines and kettles, and hand charging of materials into the kettle. 
Page 8 Health Hazard Evaluation Report 2012-0222-3203

According to workers, filter cleaning often involves the use of solvents and may be performed 

manually in sinks or at the filter station. Although the sinks are ventilated, workers were 

concerned because the filters continue to emit chemical odors while drying. Similarly, piping 

and tanks must be routinely cleaned with solvents or other solutions. Though harsher solvents 

are piped to a hazardous waste collection area, many cleaning solutions can be emptied 

directly into drains in the buildings, which could result in exposure to the remnants of 

whatever was in the tank prior to cleaning. 

On-site interviews with health professionals

We interviewed the plant nurse, plant physician, and corporate physician. During these 

discussions, we learned about the medical team’s interest in health promotion among 

employees. Employees get a yearly physical exam, part of which involves filling out a 

respiratory questionnaire. Responses to the respiratory questions may prompt spirometry 

testing in the clinic. Through our discussion with the nurse, and review of records, we found 

that fewer than 30 employees underwent spirometry testing each year, and these results 

tended to be normal. Previously, the plant periodically conducted surveillance spirometry, 

but this was no longer the case at the time of our visit. Attempts to review records from 

surveillance spirometry were hampered by the age and condition of the records, making 

examination difficult. We were able to review two spirometry reports from employees who 

required further testing based on their respiratory questionnaire. These two spirometry tests 

appeared to be of acceptable quality. 

On-site interview with Industrial Hygienists

We also interviewed both plant and corporate industrial hygiene personnel during the 

site visit. From the interview, we learned that every year a chemical monitoring strategy is 

developed by adapting and modifying the previous year’s plan. The chemical monitoring 

strategy was originally designed using a primarily observational, qualitative approach. This 

involves using job characteristics, chemical toxicity, frequency of chemical usage, and worker 

input to determine sampling goals. Throughout the course of each year, approximately 300 

samples are collected from various HEGs. 

The plant has historical industrial hygiene monitoring data collected over more than two 

decades, and we commended the efforts by the plant’s industrial hygienist to collect such 

information. However, this abundance of data has not been used to more effectively manage 

workers’ exposures by confirming or adjusting the grouping of HEGs or the number of 

samples collected for each HEG. From the interview, we also found that the plant does not 

have a strategy to judge whether each HEG exposure profile is acceptable, unacceptable, or 

uncertain. Rather, the plant has been adapting a traditional method in evaluating workers’ 

exposure by comparing the highest exposure worker’s result to occupational exposure limits 

(OEL) such as the American Conference of Governmental Industrial Hygienists’ (ACGIH) 

threshold limit values (TLVs) and OSHA permissible exposure limits (PELs). In addition, 

most samples were taken only during job-specific tasks (rather than full-shift sampling) 

though results were compared to 8-hour TWA (time-weighted average) limits.
Health Hazard Evaluation Report 2012-0222-3203 Page 9

Field Observations

During the site visit, our industrial hygiene personnel learned that potential exposures to 

workers performing tasks such as hand and drum charges are monitored routinely. We 

observed close adherence to PPE guidelines and safety protocols for workers interacting with 

chemicals during batch processes. Local exhaust ventilation was used when tasks involved 

direct contact with chemicals, opening kettles, or during distribution and transfer into drums 

and other containers. However, bystanders adjacent to active work areas were not monitored, 

even for confirmation of low or absent exposures. In addition, we learned that throughout the 

course of a single work-shift, workers may be working with several different chemical agents 

resulting in potential multiple chemical exposures and that work shifts may be up to 12-hours 

a day. With the addition of mandatory overtime, many workers are working 40-80 hours per 

week. 

After the Site Visit: Company Response and Updates 

The company was concerned that employees stated accidents go unreported due to fear of 

reprisal. They described their process for investigating accidents and unsafe conditions. They 

felt strongly that workers are not punished for accidents, but stated that the investigations can 

reveal that an employee was not following safety standards, therefore resulting in disciplinary 

action. Additionally, all events, including accidents, incidents such as fires and explosions, 

near misses for incidents or accidents, and spills or leaks are investigated by a team. The team 

may consist of only the area manager and operator, or may involve the entire EHS group. They 

keep track of such incidents in a database. They informed us that there are about 350-400 per 

year, all of which are investigated. 

We had suggested that the company discuss the negative perception of their UCRs, and 

consider anonymous reporting. The company maintains that anonymous reporting avenues 

already exist. They have an anonymous phone line to an organizational ombudsman that 

employees can call with their concerns. This phone line was not mentioned by workers during 

our interviews, and it is unclear how much of the workforce is aware of this option. The 

company also stated that Union Safety Representatives can bring anonymous concerns to the 

committee, and they plan to improve this option in the future. 

We had reported that employees felt that there was not enough attention paid to routine 

maintenance and that the equipment (in some cases) was at risk for catastrophic failure. 

Several instances were described by a variety of employees. The company provided us with 

information about preventative maintenance for pipes and tanks. They also informed us 

that regular preventative maintenance is performed depending on the age of the equipment, 

manufacturer recommendations, and history of usage. The company stated that they have not 

had any overdue critical safety preventative maintenance work orders in the last 5 years, and 

that they performed over 1400 critical safety preventative maintenance work orders in the last 

year alone. 

The regular medical exam that employees receive includes a hearing evaluation and 

respiratory questionnaire. As of July 2013, the company restarted annual spirometry as we 
Page 10 Health Hazard Evaluation Report 2012-0222-3203

recommended. Secondary to our recommendations in the interim letter, their medical team 

is considering ways to look at the spirometry data longitudinally by plant area to check for 

excessive decline over time and correlations with employee jobs. We suggested SPIROLA 

software as a potential tool, but the company believes their current software has the ability to 

do similar analyses. They are currently entering information into this database and plan to 

examine it in concert with industrial hygiene information based on area sampling and HEG 

results.

Likewise, the company is looking into the concerns voiced by employees about over 

reliance on PPE. Because workers are aware of the existing engineering controls, they often 

inquire about the need for PPE. The company states that it requires PPE in some cases to 

protect against potential equipment failures that could result in exposure. They plan to add 

information about existing controls into their annual posting series, which educates workers 

about different aspects of the job at the plant.

The plant is examining specific areas and tasks that employees felt were potentially hazardous, 

such as New Product Development, Polymers I and II, and filter cleaning. They informed us 

that these were going to be “priority areas” for some of the changes they are implementing 

based on our recommendations. In addition, these areas will be built into the 2014 industrial 

hygiene sampling plan, with guidance from the AIHA’s manual on assessment and managing 

occupational exposures [AIHA 2006]. 

We had raised concerns about bystander exposures and the lack of area monitoring. The 

company reported that they plan to use qualitative measures as a screening tool to determine 

the need for area monitoring. They informed us that they will prioritize the areas where 

operators are concerned. Since there are a variety of potential exposures at the plant, the realtime or near real-time area monitoring will allow the industrial hygienist to identify where 

and when personal sampling for short-term or bystander exposure should be performed. In 

addition, the company has added a new task to each HEG called “bystander”, which will allow 

these workers to be analyzed as a new group. 

The plant is currently evaluating how to take into account longer work shifts and extended 

work weeks. They stated that exposures will be assessed against PELs and TLVs which will 

be adjusted for longer work periods in the future. In addition to the simple Brief and Scala 

[1986] method that we recommended for the adjustment, they are looking at utilizing 

pharmacokinetic modeling. Furthermore, the plant industrial hygienist checked with the 

analytical laboratory and was informed that they are able to analyze multiple chemicals 

(certain combinations of solvents, excluding methanol) with a single sample, which will 

make it easier for the plant industrial hygienist to evaluate workers’ simultaneous exposure to 

multiple chemicals. 

The plant industrial hygienist has signed up for continuing education. She has taken the 

AIHA course for exposure assessments and statistics. Additionally, she attended the 2013 

virtual AIHA conference.
Health Hazard Evaluation Report 2012-0222-3203 Page 11

Discussion

Health Effects

Employees at the plant were concerned about potential exposures while at work. They 

complained of eye and respiratory irritation when exposed to certain chemicals. Several 

people reported chronic cough or shortness of breath, but they did not attribute these 

symptoms to work. 

Several of the chemicals used at the plant have been identified as respiratory toxins. For 

example, isocyanates, epoxy resins, and methyl methacrylate have been reported to cause or 

aggravate asthma [NIOSH 2004, Hannu et al 2009, Borak et al 2011]. Isocyanates have been 

studied extensively in the literature, and in addition to asthma, have been associated with 

hypersensitivity pneumonitis, obstructive lung disease, non-asthmatic neutrophilic bronchitis, 

and contact dermatitis [NIOSH 2004, Pronk et al 2009, Pala et al 2011]. In particular, a single 

over-exposure to isocyanates can lead to triggering of a respiratory reaction upon future 

exposures, even if these are well below regulatory limits [NIOSH 2004]. Such exposures 

have been reported in a wide variety of industries, including polyurethane foam, reinforced 

plastics, spray painting, foam packaging, iron foundries, and aircraft assembly [NIOSH 2004]. 

One of the facility’s employees was diagnosed with obliterative bronchiolitis, a disease in 

which the lung’s smallest airways are irreversibly scarred, leading to cough and shortness of 

breath. Obliterative bronchiolitis cannot be excluded by normal spirometry, as individuals 

may have obstructive, restrictive, mixed, or no abnormalities on the test [King et al 2011]. 

Definitive diagnosis involves lung biopsy [Kreiss 2013]. As a result of its non-specific 

symptoms, variable spirometric findings, and relative rarity compared to more common 

airways diseases such as asthma and emphysema, obliterative bronchiolitis is frequently 

misdiagnosed. There is no specific therapy for the disease; advanced cases may require oxygen 

therapy and lung transplantation. 

Obliterative bronchiolitis is associated with inhalational exposures to gases or vapors 

including chlorine, dimethyl disulfide, hydrochloric acid, sulfur mustard, hydrogen sulfide, 

nitrogen oxides, diacetyl, ammonia, and household cleaners [Seaton 2008, Kreiss 2013]. 

Cases have also been described in relation to other types of inhalational exposures, such 

as iron oxide, fly ash, and World Trade Center dust [Seaton 2008, Kreiss 2013]. The classic 

description was of chronic impairment following acute illness after a massive exposure 

(such as from an act of war or an accidental release), but more recent information points 

to the indolent evolution of impairment without antecedent overwhelming exposure or 

acute illness [Kreiss 2013]. For instance, obliterative bronchiolitis has occurred in flavoring 

chemical-exposed workers without unusual over-exposure events or acute illness [Kreiss et 

al 2002, CDC 2007]. Thus, this disease is often insidious at onset, but can rapidly progress to 

significant disability and the need for lung transplant. 

The work-relatedness of occupational obliterative bronchiolitis may go unrecognized 

because declines in lung function secondary to work-related lung disease are not always 
Page 12 Health Hazard Evaluation Report 2012-0222-3203

clinically apparent, and many people do not associate their symptoms with work [Kreiss 

2007a, Kreiss 2013]. Furthermore, identifying the specific cause of a particular case can 

be challenging, especially in the setting of multiple chemical exposures. The first cases of 

obliterative bronchiolitis in flavoring manufacturing workers were reported in 1986, but 

hundreds of flavoring chemicals were in use, obscuring the cause [Kreiss 2007b]. It was not 

until a cluster of disease was noted in microwave popcorn workers using only butter flavoring 

chemicals that a link to diacetyl was made [Kreiss et al 2002, Kreiss 2007b]. Thus an absence 

of prior literature linking obliterative bronchiolitis to a particular chemical does not mean 

that the chemical does not cause this disease. Indeed, it has been argued that “obliterative 

bronchiolitis may be regarded as a possible consequence of exposure to any gas, fume, or 

fine soluble dust with potential to damage airways either on account of its strongly acidic or 

alkaline pH or because of its ability to release toxic free radicals” [Seaton 2008]. 

Additionally, many of the chemicals have effects outside the respiratory system. Many are 

classified as skin and eye irritants, and some have adverse reproductive effects, while others 

may be carcinogens [NIOSH 2010]. For example, aromatic amines have been linked to 

bladder cancer [Ward et al 1996] while solvent inhalation has been linked to neurotoxicity 

[Beningus et al 2007].

At this time, it is unknown whether exposures at this plant pose a risk of disease to the 

workers. Literature, employee concerns, and reports of two sick employees suggest that such a 

link is plausible. The company has appropriate resources to investigate possible work-related 

illness, and medical surveillance over time may help to answer this question.

Industrial Hygiene Monitoring

Compliance monitoring at the facility simply focuses on the employees with the highest 

exposure potential with the assumption that the rest of the workers’ exposures are below 

occupational exposure limits. In contrast, comprehensive exposure assessment (based on 

SEGs in the literature, or HEGs in the plant’s terminology) is the state-of-the-art approach to 

help an organization better understand and manage the risks associated with the exposures. 

Comprehensive exposure assessment aims to characterize all exposures for all workers on 

all days based on the monitoring of worker groups having similar exposures. The goal is 

to understand each worker’s exposure, and hopefully, the risks that such exposures entail. 

This approach emphasizes the importance of day-to-day and between-worker variations in 

evaluating a given group’s exposure profile. We commend the industrial hygiene team at the 

company for taking on such efforts.

The assumption that workers’ exposures are low or negligible in the absence of monitoring 

data may be incorrect. Some employees were also worried about chemical odors that drifted 

from adjacent work areas, and we also noticed odors during the plant tour. Although one 

worker might be required to wear respiratory protection while working with specific agents, 

other workers (e.g., a supervisor) in the area or the nearby adjacent area may not be wearing 

equivalent protection. The significance and severity of this exposure is unknown because 

workers are not routinely sampled for bystander exposures. As with bystander exposure, there 
Health Hazard Evaluation Report 2012-0222-3203 Page 13

may be exposures that precede or follow specific job tasks. The assumption of low or absent 

exposure outside these measurement times may be false, as most samples are taken only 

during job specific tasks and yet results are compared OELs-TWA and PELs for an 8-hour full 

shift during a 40-hour week. Therefore, taking some full-shift samples is important to fully 

understand workers’ exposure during an entire period of work. This is particularly useful if 

the samples can be analyzed for multiple contaminants (e.g., solvents).

From our conversations during the site visit, we learned that understanding peak exposures of 

workers is particularly critical in this plant, considering the consistent potential risks of leak 

and periodic manual batch processes. Appropriate use of direct-reading instruments can help 

industrial hygienists identify targeted sampling for peak or short-term exposures and reduce 

the number of samples that are below the limit of detection. Although there are two real time 

monitors currently located in the laboratory and laboratory storage area to measure airborne 

levels of isocyanates, there were no real time air monitors for isocyanates or other chemicals 

in production areas. 

TLVs, RELs (NIOSH recommended exposure limits), and PELs normally refer to exposures 

over an 8-hour shift during a 40-hour week; adjusted standards for workers with longer shifts 

and longer work weeks should be lower than the 8-hour standards. Thus, exposure assessment 

for those workers requires modification to account for longer exposure periods [AIHA 

2011]. Additionally, exposure to multiple chemicals during the work shift may produce 

interactions among chemicals, resulting in additive, synergistic, or antagonistic health effects; 

particularly for respiratory (e.g., asthma) and skin sensitizers [Brodeur et al 2001]. Therefore, 

it is important to investigate the potential of multiple exposures stemming from mixtures and 

potential interactions of multiple chemicals even though no individual chemical is over an 

OEL. 

Other

Many workers felt that current preventative safety maintenance was not sufficient to prevent 

all catastrophic equipment failures, and that engineering controls could be used more often 

throughout the plant. Additionally, several employees had concerns regarding the reporting 

of unsafe conditions, the plant’s method for dealing with accidents, and the use of the 

conversation record as a disciplinary tool. 

Conversations with employees suggested a lack of awareness of anonymous reporting options. 

OSHA requires that companies provide a mechanism for employees to report concerns and 

suggests that there be multiple paths [OSHA 2013]. Ensuring that employees are aware of 

these options, including anonymous reporting routes, is important.

The negative perception of UCRs, conversation records, and accident retaliation is 

concerning. Regardless of the realities of retaliation and frequency of safety maintenance, 

such concerns among workers may lead to real problems. For example, if workers feel that 

preventative maintenance is not dealt with appropriately, they may be less likely to report 

things that need attention because they perceive that repairs may not happen in a timely 
Page 14 Health Hazard Evaluation Report 2012-0222-3203

fashion. Though the company maintains that conversation records can be good or bad, the 

general perception among workers is that conversation records are a negative tool. Thus, they 

may avoid reporting concerns in an effort to avoid this perceived undesirable outcome.

Conclusions

This HHE was requested secondary to worker concerns about exposures at a chemical plant 

leading to a variety of health effects. During the investigation we reviewed the literature 

on some chemicals used at the plant, health effects at similar plants, information from the 

company’s industrial hygiene monitoring, and medical records. We found that the facility 

uses a large number of chemicals, some of which are known respiratory toxins, and that 

two workers developed respiratory problems that could be related to workplace exposures. 

While we cannot determine if the employees are at risk of health effects secondary to work 

exposures, we do feel that there is potential for exposures and secondary health effects due 

to the large number of chemicals used. Our recommendations for medical surveillance and 

changes to industrial hygiene monitoring strategies are intended to assist the company in 

identifying some problematic areas or workers who would benefit from enhanced protection 

from ongoing exposures. 

Recommendations

On the basis of our findings, we recommend the actions listed below. As the plant has a 

labor-management health and safety committee, we suggest that the group discuss our 

recommendations and develop an action plan. Those involved in the work can best set 

priorities and assess the feasibility of our recommendations for the specific situations at this 

plant. Though the plant has made some changes based on our interim letter as discussed 

above, we include these recommendations for completeness.

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 

additional controls in the future.

1. As mentioned in the discussion of this report, many of the chemicals used at this 

plant have known or suspected health effects. Yet effective substitutes may not be 
Health Hazard Evaluation Report 2012-0222-3203 Page 15

available for many of these substances, and those that do exist may also pose a risk of 

health problems. Thus, we focus our recommendations on ways to assess and control 

exposures from chemicals currently used. If safe and effective substitutes become 

available, we would recommend the use of these when possible. 

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. We understand that putting engineering controls into place is costly, especially in 

an older plant. Nevertheless, workers were concerned about over-reliance on PPE. 

We encourage the plant to assess engineering controls and changes to processes to 

minimize workers’ exposure during the decision making process for capital project 

improvements. 

Administrative Controls 

The term administrative controls 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. The potential for chemical exposures at the plant poses risks of occupational lung 

disease, especially from episodic or peak exposures. Some workers have concerns about 

these risks. Therefore, we recommend that the plant institute annual spirometry for all 

employees who regularly enter the production area or work with chemicals. 

2. We recommend that the medical staff analyze individual and group spirometry by 

looking at changes in function over time, which may allow early, pre-symptomatic, 

identification of workers suffering from lung disease. For a test interval of 1 year, a 

decline in the forced expiratory volume in one second (FEV1) of greater than 10% 

is considered excessive and should prompt referral to a lung specialist familiar with 

occupational lung disease [Wang et al 2006]. Additionally, looking at longitudinal 

spirometry data by area of the plant can help pinpoint areas of the plant that may 

be problematic. Such analysis can be done on-site using software that is currently 

available. NIOSH has designed a free tool called SPIROLA, available on the NIOSH 

website [NIOSH 2013] to facilitate this.

3. We suggest that the plant continue to discuss with the plant health and safety 

committee and union ways to change the perception of UCRs, including the possibility 

of anonymous reporting of problematic areas. This may include increasing awareness 

of existing anonymous reporting mechanisms. Additionally discuss with the committee 

ways to make sure accidents are perceived as opportunities to learn and improve, 

as opposed to mechanisms to punish people. Regardless of the reality of retaliation, 

employee perception of such retaliation influences reporting behaviors. The under-
Page 16 Health Hazard Evaluation Report 2012-0222-3203

reporting of accidents and unsafe conditions can lead to unrecognized hazards, and 

ultimately to exposure and accidents.

4. Workers were concerned that local exhaust ventilation was insufficient when many 

within the same work area were operating at the same time. We suggest you evaluate 

the systems when multiple exhaust ventilations are in operation. To check adequate 

airflow at the opening of the exhaust, the plant can use inexpensive smoke generation 

tubes or air velometers [ACGIH, 2004].

5. Bystander exposure is a concern, especially when people are performing different tasks 

in relatively close proximity. The precautionary approach would state that unless the 

exposure is demonstrated to be zero, “no exposure” should not be assumed. We suggest 

that the plant assess the possibility of bystander exposure with industrial hygiene 

sampling. The company has begun to examine ways to do this, and we encourage the 

continuation of this effort.

6. Area monitoring with direct-reading instruments may be used to collect data on 

background, variations, spikes, and changes in levels due to process or ventilation 

controls. Direct-reading instrument data can also be used to identify targeted sampling 

for peak or short-term exposures and reduce the number of samples below the limit of 

detection. 

7. For extended shift workers, the OEL-TWA can be adjusted by applying an OEL 

reduction factor [ACGIH 2013]. We suggest altering the sampling procedure by 

conducting full-shift sampling and then adjusting calculations to take this into account. 

An example calculation for a 12 hour shift is included [Brief and Scala 1986]:

OEL-TWA

For 12 hour-work shift, OEL-TWA 

It is also possible to apply a work-week correction factor for employees who work 

longer than 40-hour weeks. This calculation is delineated in the same resource, though 

other methods are available. 

8. Special consideration should be given to assessing exposures to a mixture of two or 

more chemicals with additive effects by summing the ratios of measured TWA to OELTWA [ACGIH 2013]. We are aware the company has begun looking at the combined 

effects of multiple solvents, and recommend that they expand this to other chemicals as 

feasible.

9. We suggest that the company develop an evaluation strategy which allows for 

characterization of the complete exposure profile for each of the HEGs. For detailed 

information on how to perform such a comprehensive exposure assessment, the 

following AIHA publication may be useful: Bullock WH and Ignacio JS 2006. 

10. The company stated that air sampling was limited by budgetary concerns. Since the 
Health Hazard Evaluation Report 2012-0222-3203 Page 17

plant is sampling on a fixed budget, we suggest increasing frequency of the sampling on 

areas of concern. Some of these areas include new product development and polymers 

I and II - particularly the filter presses and filter cleaning areas in these locations. 

Workers may be able to pinpoint other areas that they feel need attention. 

11. In addition to the current approach for sampling, we recommend that the plant 

incorporate some quantitative methods to define HEGs to optimize sampling 

strategy. Please note that reference materials will call these groupings SEGs. Some 

recommendations include:

a. Consider increased sampling on or investigating HEGs when there is large 

variability of measured exposures within the HEGs (large geometric standard 

deviation). Handle non-detectable (<LOD) samples in a uniform way 

[Hornung and Reed 1990]. 

b. If exposures are within 10% of the occupational exposure limit for a given 

compound, re-sampling (4-6 additional random measurements) within the 

HEG should take place to increase power of compliance testing.

c. In each HEG, continue to choose the subset of workers and sample days at 

random while aiming to cover some amount of seasonal variation. Samples 

should span over the course of 2 or more seasons. 

d. Continue to perform task-specific sampling (e.g. STEL) if the task is highexposure or if the task occurs infrequently. 

e. Continue to involve workers directly in the sampling procedure (performing 

self-monitoring with passive monitoring badges).

f. Analyze historical measurement data to evaluate if all HEGs are appropriately 

grouped.

12. We recommend that the company continue to support the plant industrial hygienist 

for continuing education, so that she can be up-to-date on comprehensive exposure 

assessment strategy and industrial hygiene statistics.

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 train employees on the need for PPE, and ensure that PPE is stored in 

clean, accessible areas. Employees should be able to voluntarily increase their level of 

protection (such as by choosing to wear a full face mask instead of a half mask).

2. Additionally, ensure that employees performing simultaneous tasks requiring different 

PPE have enough time to change PPE safely between tasks. 
Page 18 Health Hazard Evaluation Report 2012-0222-3203

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Figures
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Keywords: NAICS 325199 (All Other Basic Organic Chemical Manufacturing) and 325411 

(Medicinal and Botanical Manufacturing). 
Page 25

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

under the authority of the Occupational Safety and Health Act of 1970 (29 U.S.C. § 669(a)

(6)). 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 disease or injury. Regulations guiding the Program can be found in Title 42, Code 

of Federal Regulations, Part 85; Requests for Health Hazard Evaluations (42 CPR Part 85).

Disclaimer 

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 report does not constitute endorsement by the 

National Institute for Occupational Safety and Health (NIOSH).

Citations to Web sites external to NlOSH do not constitute NIOSH endorsement of the 

sponsoring organizations or their programs or products. 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.

Acknowledgments

Desktop Publisher: Tia McClelland

Availability of Report

Copies of this report have been sent to the employer, employees, and union at the 

facility. The state and local health department 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/2012-0222-3203.pdf.

NIOSH 2014. Health hazard evaluation report: Evaluation of 

Exposures and Health at a Specialty Chemicals Plant, West Virginia. 

By McCague A, Cummings K, Armstrong J, Park J. Morgantown, WV: 

U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety 

and Health, NIOSH HETA No. 2012-0222-3203.
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:

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