Health Hazard Evaluation Report 2012-0028-3190 Page 1

Evaluation of Chemical Exposures during Fire 

Fighter Training Exercises Involving Smoke 

Simulant

HETA 2012-0028-3190

July 2013

Kenneth W. Fent, PhD, CIH

Kristin Musolin, DO, MS

Mark Methner, PhD, 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 2012-0028-3190

Contents

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

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

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

Methods ............................................... 3

Results ................................................ 11

Discussion .......................................... 21

Conclusions........................................ 24

Recommendations............................. 25

Appendix A ........................................ 28

Appendix B......................................... 30

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

Acknowledgements........................... 39

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 2012-0028-3190 Page i

We evaluated fire fighter 

trainers’ chemical exposures 

and health effects during 

training exercises involving 

smoke simulant. Trainers could 

be overexposed to mineral 

oil mist, diethylene glycol, 

and thermal decomposition 

products. Wearing appropriate 

and fit-tested respiratory 

protection during training 

exercises should prevent eye 

and respiratory irritation and 

more serious acute respiratory 

effects. 

Highlights of this Evaluation

The Health Hazard Evaluation Program received a request from a fire department in Texas. 

The employer was concerned about respiratory health effects from exposures to smoke 

simulants used during training exercises. 

What We Did

● We sampled the air for components of two types of smoke simulant during training 

exercises in January 2012 and July 2012.

● We observed training exercises and interviewed 

five trainers to obtain an understanding of their 

work practices and work-related safety and 

health concerns. 

● We reviewed the fire department’s fire fighter 

training logs of work-related injuries and illnesses 

for the years 2005–2012.

● We reviewed medical records concerning 

a trainer’s exposure to an oil-based smoke 

simulant resulting in acute respiratory injury 

and hospitalization.

What We Found

● Levels of mineral oil mist in air were above 

exposure limits. These measurements were taken 

during training exercises involving only oil-based 

smoke simulant.

● Levels of diethylene glycol in air were above the 

exposure limit. Levels of formaldehyde in air were about half the exposure limit. These 

measurements were taken during a training exercise that involved only glycol-based 

smoke simulant.

● Levels of mineral oil mist, diethylene glycol, formaldehyde, and acrolein in air were 

above exposure limits. These measurements were made during training exercises that 

involved smoke simulants, heat, and fire.

● Levels of these compounds in air could exceed exposure limits outside the training 

room when a trainer opens the door to look inside.

● The mineral oil mist and diethylene glycol aerosols were small enough to penetrate 

deeply into the lungs. 

● Brief exposures to the compounds we measured could irritate the eyes and lungs or 

cause more serious lung damage.

● Levels of mineral oil on trainers’ turnout gear and surfaces in the training room after 

training exercises were mostly non-detectable.
Page ii Health Hazard Evaluation Report 2012-0028-3190

What We Found (continued)

● From our interviews, the most commonly reported symptom was cough.

● Our medical record review confirmed a respiratory illness due to prolonged exposure to 

mineral oil mist. 

What the Employer Can Do

● Rotate training officer duties throughout a full day of training exercises.

● Ensure that trainers do not re-enter the training tower without wearing appropriate 

respirators until the tower is visibly clear of smoke simulant.

● Require trainers to wear self-contained breathing apparatus inside the training tower even 

if they are outside the training room during training exercises that involve heat or fire.

● Require trainers to wear self-contained breathing apparatus or full-facepiece air 

purifying respirators with cartridges or canisters that are effective against oil-based 

aerosol and formaldehyde during training exercises that involve only smoke simulants. 

Trainers should wear these respirators inside the training tower even if they are outside 

the training room. Respirators should also be worn during maintenance and adjustment 

activities if smoke simulant release is expected.

● Maintain all respirators and make sure they fit and function properly.

● Create a schedule for changing out respirator cartridges and canisters.

● Fit test the trainers for each of the respirators that they are to wear.

● Encourage trainers to report any health concerns or symptoms associated with work 

tasks to a supervisor. 

What Employees Can Do

● Report health concerns or symptoms that could be work-related to a supervisor.

● Follow all procedures including work rotations, personal protective clothing, and 

respirator use.

● Make sure you are fit-tested for each respirator you wear.
Health Hazard Evaluation Report 2012-0028-3190 Page iii

Mention of any company or product does not constitute endorsement by NIOSH. In 

addition, citations to websites external to NIOSH do not constitute NIOSH endorsement 

of the sponsoring organizations or their programs or products. Furthermore, NIOSH is not 

responsible for the content of these websites. All web addresses referenced in this document 

were accessible as of the publication date of this report.
Page iv Health Hazard Evaluation Report 2012-0028-3190

Abbreviations

°F Degrees Fahrenheit

μm Micrometer

ACGIH® American Conference of Governmental Industrial Hygienists

AIHA American Industrial Hygiene Association

CFR Code of Federal Regulations

DNPH 2,4-Dinitrophenylhydrazine

EPA Environmental Protection Agency

GC/MS Gas chromatography/mass spectrometry

Lpm Liters per minute

mL Milliliter

mm Millimeter

NIOSH National Institute for Occupational Safety and Health

OEL Occupational exposure limit

OSHA Occupational Safety and Health Administration

PAH Polycyclic aromatic hydrocarbon

PTFE Polytetrafluoroethylene

SCBA Self-contained breathing apparatus

STEL Short-term exposure limit

TLV® Threshold limit value

VOC Volatile organic compounds
Health Hazard Evaluation Report 2012-0028-3190 Page 1

Introduction 

The Health Hazard Evaluation Program received a request from fire department managers. 

The request concerned exposures and potential health effects to fire fighter trainers from a 

mineral oil-based smoke simulant used during training exercises.

The fire department consisted of approximately 255 full-time fire fighters and 5 full-time fire 

fighter trainers. The number of fire fighter trainers on-site varied from two to five a day. Fire 

fighters at this fire department worked 24 hours on and 48 hours off. The fire fighter trainers 

worked about 40 hours a week and conducted almost 100 training exercises every year in a 

cinder-block three-story training tower built in 2007. 

In October 2011, three fire fighter trainers reported respiratory symptoms after being exposed 

to a dense cloud of oil-based smoke simulant for at least 30 minutes during preparations for a 

training exercise. None of the trainers involved were wearing respiratory protection. Symptoms 

subsided for two of the trainers, but symptoms persisted and worsened for the other trainer. The 

medical records for this trainer indicated that symptoms started after exposure to the oil-based 

smoke simulant. His condition was severe enough to warrant a weeklong hospital admission. 

He was diagnosed and treated for work-related pneumonitis/lipoid pneumonia; his symptoms 

improved over the next few months. 

Exercises involving smoke 

simulant are conducted to 

train fire fighters on proper 

fire-attack and victim-rescue 

techniques in low visibility 

conditions inside the training 

tower (Figure 1). Figure 2 

provides a schematic of the 

first floor of the training 

tower. The other two floors 

were similar to this floor. The 

training rooms on each floor 

had different obstacles, all 

made of steel. The first floor 

training room had a stove, the 

second floor training room 

had a bed, and the third floor 

training room had a desk. 

A built-in MDG Fog Generator System generated the oil-based smoke simulant. This 

system was controlled remotely from a nearby classroom. MDG Neutral Fluid was heated 

(maximum of 140 degrees fahrenheit [°F]) in an external reservoir and pressurized (50 

pounds per square inch). It was then transported along with pressurized nitrogen sheath 

Figure 1. Cinder-block tower during a training exercise. 
Page 2 Health Hazard Evaluation Report 2012-0028-3190

gas (50 pounds per square 

inch) to the training rooms 

on each floor. The gas and 

fluid terminated at the nozzle 

in each room to produce 

airborne oil-based aerosol 

with a reported particle size of 

0.5 to 0.7 micrometers (μm) 

(Figure 3) [MDG 2003].

In addition to the oil-based 

smoke simulant, the fire 

department occasionally used a 

glycol-based smoke simulant. 

Portable fog machines (High 

End FQ-100) generated the 

glycol-based smoke simulant. 

Glycol-based fluid was poured 

into the machine, heated, and 

aerosolized into the training 

room. The portable fog 

machines are less expensive 

to operate than the built-in 

oil-based fogging system; 

however, the portable units 

require longer periods to 

reach a smoke saturation 

point necessary for training 

exercises. 

After generating oil-based 

smoke simulant, glycolbased smoke simulant, or 

both, the fire department 

also occasionally (35%–40% 

of the time) used propane 

burners and heaters to 

generate rollover fire 

conditions inside the training 

room (Figure 4). This process 

was controlled remotely from the nearby classroom. Exercises involving heat and fire 

were intended to mimic conditions that a fire fighter may encounter in the field, including 

temperatures above 400°F.

Figure 3. Mineral oil-based smoke simulant exiting the supply 

nozzle in the corner of the first floor training room. 

Figure 2. Overhead schematic of the first floor of the 

training tower. 
Health Hazard Evaluation Report 2012-0028-3190 Page 3

The trainers’ activities before 

initiating smoke simulant 

or propane-generated heat 

and fire included refilling 

the fog machine reservoirs 

(usually without wearing 

gloves), orienting the crew, 

assigning a trainer to the 

control room, inspecting the 

building, checking hose lines, 

opening valves, checking oil 

and glycol fluid levels, and 

turning on the built-in fogging 

system and/or portable fog 

machines. For the exercises 

involving propane-generated 

heat and fire, the trainers also 

preheated the building to 

400oF–425oF. The oil-based 

smoke simulant and propane burners and heaters operated for 10 minutes (timer-controlled). 

After the exercises, the trainers inside the tower opened doors, windows, and turned off 

equipment while an exhaust system in the tower was activated remotely to clear the building 

of smoke simulant and heat. 

National Fire Protection Association-compliant structural fire-fighting ensembles, including 

self-contained breathing apparatus (SCBA), were mandatory for the training exercises 

involving propane-generated heat and fire. At the time of our visit, the trainers were also 

required to wear structural fire-fighting ensembles during the exercises involving only 

smoke simulant. Prior to the incident in October 2011, it was not uncommon for trainers to 

wear station uniforms and National Institute for Occupational Safety and Health (NIOSH)-

approved N95 respirators during these exercises. We were informed that trainers would also 

occasionally open training rooms without wearing SCBA or other appropriate respiratory 

protection to check progress during exercises involving heat and fire. It was less common for 

the trainers not to wear respirators (as was the case during the October 2011 incident) when 

they were checking the generation of the oil-based smoke simulant. All the trainers received 

a medical clearance examination every 3 years and a respirator fit test for SCBA every year. 

Methods

Prior to our initial visit, we held telephone conferences with the fire department’s 

battalionchief and a trainer. We requested a roster of the current trainers and copies of the 

fire department’s fire fighter training logs of work-related injuries and illnesses. The fire 

department provided statements from the trainers involved in the October 2011 incident and 

Figure 4. Training exercise containing oil-based smoke simulant and 

propane-generated heat and fire. 
Page 4 Health Hazard Evaluation Report 2012-0028-3190

an MDG Neutral Fluid sample analysis report, which showed that this fluid was composed of 

> 98% petroleum-based mineral oil (i.e., highly refined mineral oil). 

We first visited the facility in January 2012. During this visit, we held confidential, voluntary 

medical interviews with four trainers on-site and one former trainer via telephone. All 

trainers were asked about their work responsibilities; work practices before, during, and after 

a training exercise; use of personal protective equipment; and work-related health concerns. 

There were no selection criteria as all trainers were interviewed. We also discussed the 

October 2011 incident. In addition, we assessed exposure during two exercises involving 

only oil-based smoke simulant (Exercises 1A and 1B). One trainer was assigned to a room 

on each of the three floors during these exercises. Each exercise lasted approximately 15 

minutes and included 10 minutes of smoke simulant generation. 

We visited the facility again in July 2012, to further assess exposure during training 

exercises. Only the first floor training room was used for these exercises. One trainer was 

assigned to this room for each exercise. Each exercise lasted approximately 15 minutes with 

10 minutes of smoke simulant and heat generation (if applicable). Table 1 describes the 

sampling plans, Table 2 summarizes the air sampling methods, and Table 3 summarizes the 

surface and bulk sampling methods. Figure 5 shows an example of how we set up the area air 

samples. We used turnout gear jackets and Nomex® hoods to shield the sampling equipment 

from the radiant heat load produced by the propane burners.
Health Hazard Evaluation Report 2012-0028-3190 Page 5

Table 1. Sampling plans for training exercises

Exercise Description Area air sampling Personal air 

sampling‡

Other sampling

Inside room* Outside room†

1A and 1B Oil-based smoke 

simulant, training 

rooms on all 3 

floors,

1 trainer on each 

floor

Mineral oil mist§

Size distribution 

of oil mist 

aerosol (1st floor 

only)§ 

Mineral oil mist Mineral oil mist Mineral oil mist 

deposition on 

surfaces** and 

clothing††, bulk 

sampling of oil fluid 

(from reservoir), 

collection of 

oil condensate 

(Exercise 1A, 1st 

floor only)

2 Glycol-based 

smoke simulant, 

training room on 

first floor,

1 trainer

Diethylene glycol

Aldehydes

PAHs

VOCs

Size distribution 

of glycol aerosol

Diethylene glycol Diethylene 

glycol

Bulk sampling of 

glycol fluid (from 

reservoir)

3 Oil-based smoke 

simulant, propanegenerated heat 

and fire, training 

room on first floor, 

1 trainer

Mineral oil mist

Aldehydes

PAHs

VOCs

Mineral oil mist

Aldehydes

PAHs

VOCs

Carbonaceous 

particles

Mineral oil mist

Aldehydes

PAHs

None

4 Glycol-based 

smoke simulant, 

propane-generated 

heat and fire, 

training room on 

first floor, 1 trainer

Diethylene glycol

Aldehydes

PAHs

VOCs

Diethylene glycol

Aldehydes

PAHs

VOCs

Carbonaceous 

particles

Diethylene 

glycol

Aldehydes

PAHs

None

5 Oil-based and 

glycol-based 

smoke simulant, 

propane-generated 

heat and fire, 

training room on 

first floor, 1 trainer

Mineral oil mist¶

Diethylene 

glycol¶

Aldehydes¶

PAHs¶

VOCs¶

Carbonaceous 

particles

Mineral oil mist

Diethylene glycol

Aldehydes

PAHs

VOCs

Carbonaceous 

particles

Mineral oil mist

Diethylene 

glycol

Aldehydes

PAHs

None

PAH = polycyclic aromatic hydrocarbon

VOCs = volatile organic compounds

*Collected 1–3 feet above the floor in the middle of the training room(s) unless otherwise noted. 

†Collected 5 feet above the floor just outside one of the doors. We documented whether the doors were opened 

or closed. All other doors were closed.

‡Collected outside and just below each trainer’s SCBA mask. 

§Additional sample collected near the supply nozzle to examine spatial variability. 

¶Additional sample collected 5 feet above the floor to examine spatial variability.

**Filters to measure deposition of oil mist were placed 3 feet above the floor in the middle of each room. 

††Patch samples were placed on the sleeve, front, back, and pant leg of two trainers per exercise.
Page 6 Health Hazard Evaluation Report 2012-0028-3190

Table 2. Summary of air sampling methods

Analyte Sampling media/

equipment

Flow 

rate 

(Lpm)

Method No. of 

area air 

samples

No. of 

personal air 

samples

No. of 

background 

samples

Mineral oil mist 37-mm, 2-μm 

pore size PTFE 

filter, open-face 

cassette

1 NIOSH 

5026*

25 9 NA

Size 

distribution of 

oil mist aerosol

8-stage high flow 

cascade impactor 

with 75-mm PTFE 

filters‡

100 NIOSH 

5026*

4 NA NA

Diethylene 

glycol 

XAD-7 OSHA 

versatile sampler 

1 NIOSH 

5523*

7 3 NA

Size 

distribution of 

glycol aerosol

8-stage high flow 

cascade impactor 

with 75-mm PTFE 

filters‡

100 NIOSH 

5523*

1 NA NA

Aldehydes DNPHimpregnated silica 

gel tube

1 EPA

TO-11A†

7 3 2

PAHs XAD-7 OSHA 

versatile sampler

1 NIOSH 

5528*

7 3 2

VOCs 1- or 6-liter 

evacuated 

canisters

0.07 or 

0.4

EPA

TO-15†

7 NA 1

Characteristics 

of 

carbonaceous 

particles

37-mm, 0.8-

μm pore size 

polycarbonate 

filter, open-face 

cassette

1 Scanning 

electron 

microscopy

4 NA 1

DNPH = 2,4-dinitrophenylhydrazine

EPA = Environmental Protection Agency

Lpm = liters per minute 

mm = millimeters

NA = not applicable 

PTFE = polytetrafluoroethylene

*NIOSH Manual of Analytical Methods [NIOSH 2010].

†EPA Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air 

[EPA 1999a,b]. 

‡MSP® Corp. Model 130. The last stage held a 90-mm, 2-μm pore PTFE filter.
Health Hazard Evaluation Report 2012-0028-3190 Page 7

Table 3. Summary of surface and bulk sampling methods

Analyte Sampling media/equipment Volume collected

(mL)

Method No. of 

samples 

Mineral oil mist 

deposition

90-mm glass fiber filter 

patches in paperboard 

holder with 75-mm opening

NA NIOSH 

5026*

16

90-mm PTFE filters in petridishes placed face-up on 

surfaces

NA NIOSH 

5026*

6

Purity of mineral 

oil fluid

20-mL glass vial 5

(from oil reservoir)

GC/MS 1

20-mL glass vial Condensate

(from supply nozzle)†

GC/MS 1

Glycol 

identification

20-mL glass vial 5

(from glycol reservoir)

NIOSH 

5523*

1

GC/MS = gas chromatography/mass spectrometry

mL = milliliter

*NIOSH Manual of Analytical Methods [NIOSH 2010] 

†Condensate was collected by opening the vial and placing near the supply nozzle for 1 minute.

For the exercises that 

involved propane-generated 

heat and fire, we focused 

on characterizing possible 

thermal decomposition 

products of mineral oil and 

glycol, such as aldehydes, 

PAHs, and VOCs [Teschke 

et al. 2005]. The method we 

used to analyze for aldehydes 

on air samples included 

10 aldehyde analytes [EPA 

1999a]; samples were also 

analyzed for acrolein. The 

method we used to analyze 

for PAHs on air samples 

included 16 PAH analytes 

[NIOSH 2010]. The method we used to analyze for VOCs on air samples included 65 VOC 

analytes [EPA 1999b]; samples were also analyzed for 20 tentatively identified compounds, 

including acrolein. Air samples were also collected during these exercises for scanning 

electron microscopy to determine if carbonaceous particles were being produced and, if 

so, their physical characteristics (i.e., particle size, shape, and agglomeration). We had not 

considered thermal decomposition products when we assessed exposures during Exercises 

Figure 5. Area air sampling set-up for Exercise 5. 
Page 8 Health Hazard Evaluation Report 2012-0028-3190

1A and 1B, which is why aldehydes, PAHs, and VOCs were not measured. These exercises 

also did not involve propane-generated heat and fire. Without heat and fire, we expected low 

concentrations of aldehydes, PAHs, and VOCs. This is why we did not collect personal air 

samples for aldehydes and PAHs during Exercise 2. Personal air sampling for VOCs could 

not be done because of the large size of the sampling media.

Area air samples were collected outside the training rooms because we were informed that 

trainers occasionally opened the doors to look inside the room without wearing respiratory 

protection. We documented whether these doors were opened or closed during the exercises. 

Filters were placed on the trainer’s turnout gear and face-up inside the training rooms to 

measure the deposition of oil mist because the fire department expressed concern about 

surface contamination. A bulk sample of the oil fluid and a sample of the oil condensate 

(from the supply nozzle during Exercise 1A) were collected to determine the fluid’s initial 

purity and whether its purity changed at the point of aerosol generation. A bulk sample of the 

glycol fluid was collected to determine the predominant type of glycol composing the fluid. 

For most of the analytes, background samples were collected inside and outside the training 

room in the morning before exercises began. For VOCs one background sample was 

collected inside the training room and for carbonaceous particles one background sample was 

collected outside the training room. We were not aware of any outside environmental sources 

of mineral oil mist or diethylene glycol near the fire department. Therefore, we did not collect 

background samples for these compounds. Furthermore, we did not sample the air for these 

compounds unless they were being aerosolized for the training exercises. 

In addition to the area air samples collected 1–3 feet above the floor in the middle of the 

room(s), we collected area air samples 1–3 feet above the floor near the supply nozzles in 

each room for measuring mineral oil mist and aerosol size distribution (Exercises 1A and 

1B). We also collected area air samples 5 feet above the floor in the middle of the room 

for measuring mineral oil mist, diethylene glycol, aldehydes, PAHs, and VOCs (Exercise 

5). These samples were collected to examine spatial variability. More information on the 

sampling and analytical methods is provided in Appendix A.

Data Analysis

The smoke simulation portion of the training exercises lasted 10 minutes, and the trainers 

typically remained in the structure for another 5 minutes to open windows and doors and 

turn off equipment. Therefore, all air concentrations were calculated using 15 minutes of 

sampling time unless the pumps malfunctioned. Four of the five pumps that malfunctioned 

ran for 5–9 minutes during the exercises, which we assumed was a sufficient duration to 

obtain an accurate sample of the air. Therefore, only one air sample was excluded from the 

results because the sampling pump malfunctioned immediately after the exercise began. Two 

other air samples were excluded from the results because the tubing between the filter and the 

pump became disconnected. 
Health Hazard Evaluation Report 2012-0028-3190 Page 9

The sampling pumps we used have isothermal flow control systems that are supposed to 

maintain the set flow rate at varying temperatures and pressure with an accuracy of ±5%. 

The operating temperature range of the sampling pumps is 32°F–113°F. According to the fire 

department, when propane burners and heaters were used, air temperatures inside the training 

room were about 400°F at 5-foot height and about 250°F near the floor, and air temperatures 

outside the training room were about 150°F at 5-foot height. Because the performance 

of the sampling pumps at these elevated temperatures is unknown (i.e., flow rates could 

increase, decrease, or stay the same), the air concentrations were not adjusted for the higher 

temperatures. Air collected by evacuated canisters, on the other hand, occupies less volume 

as it cools. Therefore, we adjusted the air concentrations measured using an evacuated 

canister (expressed in mass per volume) according to the ideal gas law by the ratio of the 

absolute air temperature in the lab during analysis to the absolute air temperature during 

collection. 

The air concentrations we measured are most appropriately compared to short-term 

occupational exposure limits (OELs). The short-term OELs for the most prevalent 

compounds in air are provided in Table 4. A short-term exposure limit (STEL) is a 15-minute 

time-weighted average exposure that should not be exceeded at any time during a workday. 

A ceiling limit is an exposure that should not be exceeded at any time. Both the American 

Conference of Governmental Industrial Hygienists (ACGIH®) and the American Industrial 

Hygiene Association (AIHA) have excursion limits for compounds that do not have STELs 

or ceiling limits, but otherwise have work-shift (8-hour) time-weighted average OELs. These 

excursion limits are determined by multiplying the organizations’ work-shift time-weighted 

average OELs by five [AIHA 2011; ACGIH 2013]. These excursion limits are similar to 

ceiling limits and should not be exceeded at any time. In the absence of instantaneous 

exposure data, comparing 15-minute time-weighted average air concentrations to ceiling and 

excursion limits is appropriate. 

Table 4 also gives the minimum detectable and quantifiable concentrations for each analyte. 

These are the lowest concentrations of an analyte that can be detected or quantified in air 

with the sampling method. The minimum detectable and quantifiable concentrations were 

calculated by dividing the detection and quantitation limits by the average volume of air 

sampled for each analyte. Air concentrations below their minimum detectable concentrations 

were assigned values by dividing the minimum detectable concentration by the square root 

of two. Total PAHs were calculated by summing the air concentrations of individual PAHs 

after assigning levels below the minimum detectable concentrations. All minimum detectable 

concentrations were well below the most protective short-term OELs; therefore, nondetectable air concentrations should be considered well below the applicable short-term OELs.
Page 10 Health Hazard Evaluation Report 2012-0028-3190

Table 4. Short-term OELs for the most prevalent compounds measured in air

Agency/ 

organization*

Type of 

short-term 

OEL

OEL

(μg/m3

)

Minimum 

detectable 

concentration 

(μg/m3)

Minimum 

quantifiable 

concentration 

(μg/m3)

Aldehydes:

Crotonaldehyde ACGIH Ceiling limit 860 2 160

Formaldehyde NIOSH Ceiling limit 120 1 4.6

ACGIH STEL 370

OSHA STEL 2,500

Acrolein ACGIH Ceiling limit 230 1†–1.4‡ 4.0†–4.8‡

NIOSH STEL 800

Total PAHs ACGIH Excursion 1,000§ 30¶ NA**

Mineral oil mist ACGIH Excursion 25,000†† 400 1,300

Diethylene glycol AIHA Excursion 50,000 2,000 6,700

VOCs:

1,3-Butadiene OSHA STEL 11,000 1 4.7

ACGIH Excursion 22,000

Benzene NIOSH STEL 3,200 2 6.6

ACGIH STEL 8,000

OSHA STEL 16,000

OSHA = Occupational Safety and Health Administration 

*ACGIH Threshold Limit Values (TLVs®) [ACGIH 2013], NIOSH recommended exposure limits and 

OSHA permissible exposure limits [NIOSH 2010], AIHA workplace environmental exposure levels 

[AIHA 2011]

†For EPA TO-11A method

‡For EPA TO-15 method for air collected at 150°F

§For coal tar pitch volatiles 

¶Calculated using the sum of the LODs for all 16 PAH analytes. 

**Could not be calculated because the lab was unable to determine using NIOSH criteria the LOQs 

for benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, dibenzo(a,h)anthracene, and 

indeno(1,2,3-c,d)pyrene.

††Inhalable particulate matter
Health Hazard Evaluation Report 2012-0028-3190 Page 11

Results

Work-Related Injuries and Illnesses

We reviewed the fire department’s fire fighter training logs of work-related injuries and 

illnesses (such as strain/sprain, fracture, wound, exhaustion, respiratory illness, and chest 

pain) for the years 2005–2012. The fire department appropriately reported the respiratory 

illness that occurred in the October 2011 incident. 

Employee Interviews and Symptoms

The interviewees included four males and one female. Their average age was 43 years (age 

range: 36–47 years) and their average years working as a trainer was 6 years (range: 1–13 

years). Fire fighter trainers worked 40 hours a week (five 8-hour shifts). The trainers were 

typically stationed at the training tower where they conducted training exercises. 

Work-related health symptoms reported by trainers are listed in Figure 6. The most 

commonly reported symptom was cough. Chest pain and dry, itching, or tearing eyes 

were each reported by one trainer. Some trainers reported that they experienced similar 

symptoms when hauling hay in a dusty environment. We asked trainers about a wide variety 

of respiratory conditions. The most commonly reported health problem was pneumonia; the 

presence of asthma in one of these individuals may have been a predisposing factor. Two 

trainers reported having a history of physician-diagnosed asthma. Regarding other physiciandiagnosed medical conditions, three trainers reported hay fever and one trainer reported 

chronic bronchitis. 

Figure 6. Self-reported work-related health symptoms (n = 5). 
Page 12 Health Hazard Evaluation Report 2012-0028-3190

The adequacy of personal protective equipment during training exercises (specifically 

respiratory protection) was a general concern among the trainers. Long-term effects from 

exposure to the oil-based and glycol-based smoke simulant were additional concerns. The 

employer also mentioned dermal exposure as a concern. The trainers wore shorts and t-shirts 

during the incident in October 2011; they reported feeling an oily residue on their skin, but 

did not report developing rashes or acne. 

Medical Record Review

We reviewed the medical records for the hospitalized trainer and agreed with the stated 

physician diagnosis of work-related acute pneumonitis/lipoid pneumonia, likely developed 

after inhaling a heavy mineral oil mist over a 30-minute period. 

Chemical Exposures during Training Exercises

Our analysis of the bulk samples confirmed that the oil-based fluid was composed of high 

molecular weight hydrocarbons characteristic of mineral oil. The glycol-based fluid was 

composed of a 34% aqueous solution of diethylene glycol. The mineral oil mist condensate 

collected from the supply nozzle during Exercise 1A had the same composition and purity as 

the oil-based fluid. Therefore, alteration of the composition or thermal decomposition of the 

mineral oil fluid did not appear to occur within the fogging system.

Of the VOCs and aldehydes measured in air, we only report the results of benzene, 

1,3-butadiene, crotonaldehyde, formaldehyde, and acrolein. The air concentrations of these 

compounds were above or within one tenth of their applicable short-term OELs. All other 

VOC and aldehyde air concentrations were less than one twentieth of their applicable shortterm OELs. The area air concentrations of acrolein measured using EPA TO-15 and EPA 

TO-11A methods [EPA 1999a,b] are reported together. The scanning electron microscopy 

analysis of the air samples for carbonaceous particles was problematic. Only four samples 

were analyzed because volatiles on the samples contaminated the sample chamber. Most of 

these samples were collected outside the training room. One of these samples was collected 

inside the training room during Exercise 5. Material collected on these samples did not 

vary from the field blanks. Therefore, the lab determined that these samples did not collect 

nonvolatile carbonaceous particulate (i.e., soot) originating from the training atmosphere.

Exercise 1: Oil-Based Smoke Simulant 

Figure 7 presents the average air concentrations of mineral oil mist measured during 

Exercises 1A and 1B. The ACGIH excursion limit for mineral oil mist of 25,000 μg/m3

is also provided in this figure as a horizontal line [ACGIH 2013]. It is only appropriate 

to compare area air concentrations to OELs if they are representative of exposures in an 

employee’s personal breathing zone. The trainer who suffered acute respiratory injury in 

October 2011, spent several minutes near the supply nozzle while the oil-based smoke 

simulant was being generated. Therefore, comparing area air concentrations measured near 

the supply nozzle during Exercises 1A and 1B is meaningful. All other area air concentrations 

for Exercises 1A, 1B, and the other exercises were measured in locations and at heights that 

were intended to be representative of a trainer’s breathing zone during normal operations. For 
Health Hazard Evaluation Report 2012-0028-3190 Page 13

example, most area air samples inside the training room were collected in the middle of the 

room at 1–3-foot height, which is representative of a trainer’s breathing zone while kneeling 

or crouching; area air samples outside the training room were collected just outside the door 

at 5-foot height, which is representative of a trainer’s breathing zone while standing.

All the personal and area air concentrations of mineral oil mist inside the room exceeded the 

ACGIH excursion limit for mineral oil mist. The area air concentrations of mineral oil mist 

outside the room, on average, also exceeded this excursion limit. One personal air sample 

from Exercise 1A and one personal air sample from Exercise 1B were excluded from the 

results because the tubing was disconnected from the sampling pump. One area air sample 

collected inside the room during Exercise 1B was excluded from the results because the 

sampling pump malfunctioned early in the exercise. 

Table 5 shows the area air concentrations of mineral oil mist inside and outside the training 

room stratified by location in the room and how much the door to the room was opened. Both 

factors appear to explain some of the variability in the area air concentrations. For example, 

the highest levels inside each room were measured near the supply nozzle, and highest levels 

outside the room were measured when the door was mostly opened. Air concentrations 

of mineral oil mist outside the training room were well below the ACGIH excursion limit 

[ACGIH 2013] when the door was mostly closed.

Figure 7. Average air concentrations of mineral oil mist measured during Exercises 1A and 1B (error bars 

represent the minimum and maximum measurements). 
Page 14 Health Hazard Evaluation Report 2012-0028-3190

Table 5. Area air concentrations measured inside and outside the training room stratified by location 

and door opening

No. of 

samples

Air concentration (μg/m3)

Mean Minimum Maximum

Area air samples (inside the room)

Near supply nozzle 5* 320,000 230,000 450,000

Middle of room 6 250,000 150,000 300,000

Area air samples (outside the room)

Door mostly opened 2 150,000 84,000 220,000

Door partially opened 2 33,000 9,100 57,000

Door mostly closed 2 1,100 920 1,200

*One sample was excluded due to sampling pump malfunction.

Figures 8 and 9 present the air concentrations of the mineral oil mist aerosol by aerodynamic 

diameter measured inside the training room during Exercises 1A and 1B. The impactor filters 

collecting aerosol between 0.77 μm and 0.25 μm were oversaturated for each sample location 

and exercise. Therefore, the actual concentrations of these particles were greater than what 

we report. For Exercise 1B, we neglected to include the post filter for particles < 0.25 μm. 

Nevertheless, on a mass basis, most airborne particles were < 0.77 μm in aerodynamic 

diameter, and higher levels were generally measured near the supply nozzle than in the 

middle of the room.

Figure 8. Area air concentrations of mineral oil mist aerosol by aerodynamic diameter 

during Exercise 1A. 
Health Hazard Evaluation Report 2012-0028-3190 Page 15

Figure 9. Area air concentrations of mineral oil mist aerosol by aerodynamic diameter during Exercise 1B. 

All the filters used to collect the deposition of mineral oil mist onto surfaces (n = 6) were 

below the detection limit of 0.8 μg/m2

. All but two of the patches used to collect the 

deposition of mineral oil mist onto the trainers’ clothing (n = 16) were below the detection 

limit of 0.5 μg/m2

, and all were below the quantitation limit of 1.6 μg/m3. 
Page 16 Health Hazard Evaluation Report 2012-0028-3190

Figure 10. Air concentrations of diethylene glycol and its thermal decomposition products (including 

background levels) during Exercise 2. Average concentrations and error bars representing the minimum and 

maximum measurements are provided if more than one sample was collected. If no measurements were 

collected, then nothing is reported. 

Exercise 2: Glycol-Based Smoke Simulant

Figure 10 presents the air sampling results for diethylene glycol and its thermal 

decomposition products during Exercise 2. The background sampling results and the most 

protective short-term OELs for these compounds (as horizontal lines) are also provided in 

this figure. All personal and area air concentrations of diethylene glycol were well above 

background levels and exceeded the AIHA excursion limit [AIHA 2011]. The door to 

the training room was fully opened during this exercise, which could explain why the air 

concentrations of diethylene glycol outside the room were similar to those inside the room. 

The area air concentration of formaldehyde inside the room was nearly 10 times background 

levels and > 40% of the NIOSH ceiling limit [NIOSH 2010]. All other air sampling results 

were near the background levels and well below their short-term OELs. 
Health Hazard Evaluation Report 2012-0028-3190 Page 17

Figure 11 presents the air concentrations of the diethylene glycol aerosol by aerodynamic 

diameter measured inside the training room during Exercise 2. We neglected to include 

the impactor filter for aerosol 0.25–0.44 μm in aerodynamic diameter. The majority of the 

aerosol was < 0.44 μm. However, this may not accurately characterize the size distribution 

because diethylene glycol is semivolatile (vapor pressure = 0.07 millimeters of mercury 

[mmHg] at 68°F) and, therefore, the airflow through the cascade impactor could have caused 

some of the collected material to evaporate especially under elevated temperatures.

Figure 11. Area air concentrations of diethylene glycol aerosol by aerodynamic diameter inside the 

training room during Exercise 2. 
Page 18 Health Hazard Evaluation Report 2012-0028-3190

Exercise 3: Oil-Based Smoke Simulant and Propane-Generated Heat and Fire 

Figure 12 presents the air sampling results for mineral oil mist and its thermal decomposition 

products during Exercise 3. The most protective short-term OELs for these compounds are 

also provided in this figure as horizontal lines. Personal air concentrations of formaldehyde, 

acrolein, and mineral oil mist exceeded the most protective short-term OELs [NIOSH 2010; 

ACGIH 2013]. Area air concentrations of formaldehyde outside the room exceeded the 

NIOSH ceiling limit [NIOSH 2010] despite the fact that the training room door was mostly 

closed during the exercise. 

Figure 12. Air concentrations of mineral oil mist and its thermal decomposition products during Exercise 3. 

Average concentrations and error bars representing the minimum and maximum measurements are provided if more than one sample was collected. If no measurements were collected, then nothing is reported. 
Health Hazard Evaluation Report 2012-0028-3190 Page 19

Exercise 4: Glycol-Based Smoke Simulant and Propane-Generated Heat and Fire

Figure 13 presents the air sampling results for diethylene glycol and its thermal 

decomposition products during Exercise 4. The most protective short-term OELs for these 

compounds are also provided in this figure as horizontal lines. The personal and area air 

concentrations of formaldehyde inside the room exceeded the NIOSH ceiling limit [NIOSH 

2010]. The personal air concentration of diethylene glycol inside the room was > 50% of the 

AIHA excursion limit [AIHA 2011]. The area air concentrations outside the room were an 

order of magnitude below the most protective short-term OELs; the training room door was 

one fourth opened during this exercise.

Figure 13. Air concentrations of diethylene glycol and its thermal decomposition products during 

Exercise 4. Average concentrations and error bars representing the minimum and maximum measurements are provided if more than one sample was collected. If no measurements were collected, then 

nothing is reported. 
Page 20 Health Hazard Evaluation Report 2012-0028-3190

Exercise 5: Oil-Based Smoke Simulant, Glycol-Based Smoke Simulant, and PropaneGenerated Heat and Fire 

Figure 14 presents the air sampling results for mineral oil mist, diethylene glycol, and their 

thermal decomposition products during Exercise 5. The most protective short-term OELs 

for these compounds are also provided in this figure as horizontal lines. The personal air 

concentrations inside the room for formaldehyde, mineral oil mist, and diethylene glycol 

exceeded the most protective short-term OELs [NIOSH 2010; AIHA 2011; ACGIH 2013]. The 

area air concentrations of these compounds varied by measurement height inside the room. The 

area air samples inside the room were collected at two heights (2-foot and 5-foot) because the 

trainers told us that they occasionally stand or kneel during the exercises and the heat inside the 

room forced much of the smoke towards the ground (below about 3-foot height). The area air 

concentration of formaldehyde outside the room exceeded the NIOSH ceiling limit [NIOSH 

2010]; the training room door was one fourth opened during this exercise. 

Figure 14. Air concentrations of mineral oil mist, diethylene glycol, and their thermal decomposition 

products during Exercise 5. Average concentrations and error bars representing the minimum and 

maximum measurements are provided if more than one sample was collected. If no measurements were 

collected, then nothing is reported. 
Health Hazard Evaluation Report 2012-0028-3190 Page 21

Discussion 

We faced some challenges during this evaluation. First, we did not sample all possible 

contaminants. Training exercises involving propane-generated heat and fire can produce 

thermal decomposition products beyond those we sampled. For example, oxides of nitrogen 

are produced during the combustion of propane [Arashidani et al. 1996]. Second, the 

potential for sampling errors increases with elevated ambient temperatures. In particular, 

the sampling pumps used have a maximum operating temperature of 113°F [SKC 2001]. 

This maximum temperature was probably exceeded at all sampling locations during the 

training exercises that contained propane-generated heat and fire. The ability of the pumps 

to accurately draw air at temperatures > 113°F (especially > 400°F) is unknown. The 

development of sampling pumps specially designed for these extreme temperatures is 

needed. Third, the two methods we used to measure acrolein in air have limitations. The EPA 

TO-11A method has been shown to underestimate the actual concentrations [EPA 1999a], 

while the EPA TO-15 method has been shown to overestimate the actual concentrations [EPA 

2010]. Fourth, not all the polycarbonate filter samples could be analyzed by scanning electron 

microscopy because volatile compounds on the samples contaminated the sample chamber. 

Despite these potential limitations, we believe the results provide reasonable estimates of 

exposure and other valuable information. For example, mineral oil mist has a boiling point 

(590°F) well above the maximum ambient temperatures inside the training room and thus 

should not evaporate or decompose as readily as diethylene glycol. The similarity between 

the air concentrations of mineral oil mist measured during training exercises with and without 

heat and fire suggests that the pumps performed as designed even in the high heat conditions. 

In addition, we obtained similar acrolein measurements from both the EPA TO-11A and 

EPA TO-15 methods. Finally, the absence of soot on the polycarbonate filter samples that 

were analyzed suggests that the thermal decomposition products formed during the training 

exercises were mostly volatile or semivolatile compounds.

We compared the 15-minute time-weighted average air concentrations to the most protective 

short-term OELs. Most of these OELs were ceiling or excursion limits that should not be 

exceeded at any time. Air concentrations can vary substantially over a 15-minute sampling 

period. In addition, 15-minute time-weighted average air concentrations can vary from one 

sampling period to the next. Therefore, overexposures are possible even if the 15-minute 

time-weighted average air concentration is below the short-term OEL. To account for this 

variability, action levels or some fraction of the OEL are sometimes used. Although we focus 

much of our discussion on the air concentrations above OELs; those within about 50% of the 

OELs may also represent potential overexposures. 

In general, the magnitude of the air concentrations followed this pattern: area air 

concentrations inside the room were at or above personal air concentrations, which were at or 

above area air concentrations outside the room. The magnitude of the area air concentrations 

outside the room depended on how much the door to the room was opened. Differences 

between the area air concentrations inside the room and the personal air concentrations were 
Page 22 Health Hazard Evaluation Report 2012-0028-3190

generally small (within a factor of 2) and may be explained by whether or not the trainers 

took measures to reduce their exposures, such as standing above the smoke layer. 

For Exercises 1A, 1B, and 2 that involved only the oil-based or glycol-based smoke simulant, 

the personal and area air sampling results collected inside the room are relevant because the 

trainers did not always wear the appropriate respiratory protection during these exercises. 

We measured air concentrations of the parent compounds that were well above the shortterm OELs. The thermal decomposition of diethylene glycol was probably the main source 

of formaldehyde in Exercise 2 (where the air concentration was > 40% of the NIOSH ceiling 

limit) and likely took place inside the portable fogging machine. According to the user guide 

for the FQ-100 Fog Generator, Atmospheres Fog Fluid is supposed to be used with the 

portable fog machine [High End Systems 2010]. This fog fluid is composed of triethylene 

glycol, propylene glycol, and deionized water [High End Systems 2007]. Propylene glycol 

has an ACGIH excursion limit of 50,000 μg/m3 (same as the AIHA excursion limit for 

diethylene glycol) [ACGIH 2013]. Although these glycols are structurally different than 

diethylene glycol, similar thermal decomposition products may be expected.

For Exercises 3–5, the propane-generated heat and fire caused thermal decomposition of 

oil-based and glycol-based smoke simulant. The propane-generated fire forced the smoke 

simulant down toward the floor (Figure 4). This smoke-simulant boundary layer (about 3-foot 

height) could explain why the air concentrations varied between 2-foot and 5-foot sampling 

heights (Figure 14). The area air samples outside the room were always collected at 5-foot 

height because trainers typically stand when looking into the training room. This task, if done 

without appropriate respiratory protection, presents the potential for inhalation exposure. 

Personal and area air concentrations of many compounds measured inside the training room 

during these exercises exceeded short-term OELs. Therefore, trainers have the potential 

to be overexposed to certain chemicals any time they look inside the training room during 

an exercise. Our air sampling results suggest that air concentrations of formaldehyde, in 

particular, are likely to exceed short-term OELs outside the training rooms during exercises 

involving one or both of the smoke simulants and heat and fire. 

On a mass basis, most of the mineral oil mist aerosol was measured in the size range of 0.25–

0.77 μm in aerodynamic diameter, while the diethylene glycol aerosol was < 0.44 μm. The 

technical manual for the MDG Fog Generator System (mineral oil-based smoke simulant) 

reported a particle size range of 0.5–0.7 μm [MDG 2003], which agrees with our findings. 

However, the user guide for the FQ-100 Fog Generator (glycol-based smoke simulant) did 

not report a particle size range [High End Systems 2010]. Because diethylene glycol is 

semivolatile, some of the collected aerosol could evaporate during sampling. Therefore, the 

actual aerosol size distribution likely varies from our results. Despite this, it is likely that 

most of the glycol aerosols are < 1 μm in aerodynamic diameter. Aerosols in this range are 

able to penetrate deeply into the lungs where they are more difficult to clear [Hinds 1999].

The small size of the aerosols may also explain why we did not detect much mineral oil on 

the patch samples on the trainers’ turnout gear and on the deposition filters in the middle of 

the training rooms during Exercises 1A and 1B. Aerosols < 1 μm have slow settling velocities 
Health Hazard Evaluation Report 2012-0028-3190 Page 23

(estimated at < 0.006 feet per minute) and can remain airborne for long periods of time. It is 

plausible, therefore, that much of the mist was carried outdoors during the forced ventilation 

after the training exercises before it could deposit onto surfaces or coat surfaces by other 

mechanisms. The surface of the skin is different than the surface of the sampling media or 

turnout gear. Mineral oil mist could have a greater affinity for skin. Lipids in the skin could 

enhance the dermal absorption of the mineral oil mist. We did not investigate the surface 

contamination with glycol-based smoke simulant. However, because diethylene glycol is 

semivolatile, any surface contamination would likely evaporate over time. 

Dermal exposure to poorly or mildly refined mineral oil can cause skin irritation such as 

dermatitis, oil acne, and lipid granuloma, but it is unclear whether dermal exposure to highly 

refined mineral oil could also cause skin irritation [ACGIH 2010]. Diethylene glycol does not 

significantly irritate the skin and is slowly absorbed through the skin [Cavender and Sowinski 

1994]. Although three of the trainers reported feeling an oily residue on their skin following 

training exercises, none of the trainers reported experiencing rashes, acne, or other skin problems. 

The primary route of exposure to the compounds we measured is inhalation. Because 

exposures are of short duration, acute health effects are most relevant. However, chronic 

health effects are also possible if trainers are exposed repeatedly without proper respiratory 

protection. The trainer, who suffered the acute respiratory injury in October 2011, was 

exposed to mineral oil mist. Short-term inhalation exposures to mineral oil mist can cause 

lipoid pneumonia or chemical pneumonitis [Spickard and Hirschmann 1994; IPCS 2006]. 

Lipoid pneumonia is an uncommon condition resulting from aspirating or inhaling lipid 

soluble substances, such as mineral oils [Spickard and Hirschmann 1994]. Other health 

effects from exposure to mineral oil mists may include eye, skin, and upper respiratory 

tract infection, central nervous effects, and respiratory distress associated with a chemical 

pneumonitis [NIOSH 1978]. However, many of these effects have been attributed to the 

poorly and mildly refined mineral oils used in industrial applications, but not necessarily 

the highly refined mineral oil used in the MDG Neutral Fluid [MDG 2003]. The safety data 

sheet for the MDG Neutral Fluid specifically states that “no acute or chronic health effects 

are known to occur when used in the MDG Fog Generator.” However, the safety data sheet 

recommends that fire fighters (or trainers) wear protective equipment and SCBA [MDG 

2003]. The findings from this evaluation support the physician’s diagnosis of work-related 

pneumonitis/lipoid pneumonia for the trainer who suffered the acute respiratory injury. 

Depending on the type of training exercise, trainers can also be exposed to diethylene 

glycol and thermal decomposition products of mineral oil and diethylene glycol. Short-term 

exposures to diethylene glycol can cause adverse effects to the blood, kidney, liver, and 

central nervous system; the generation of mists should be avoided if possible [IPCS 2007]. 

Short-term exposures to crotonaldehyde, formaldehyde, and acrolein can irritate the skin, 

respiratory tract, and eyes. Inhalation exposures to high concentrations of these aldehydes 

can cause pulmonary edema [IPCS 2001, 2003b, 2004]. Of these compounds, acrolein is the 

most potent irritant [IPCS 2001]. Short-term exposures to PAHs can irritate the eyes, skin, 

and respiratory tract [IPCS 2002]. Short-term exposures to 1,3-butadiene can irritate the eyes 

and respiratory tract and cause adverse effects on the central nervous system [IPCS 2000]. 
Page 24 Health Hazard Evaluation Report 2012-0028-3190

Short-term exposures to benzene can irritate the eyes, skin, and respiratory tract and cause 

adverse effects on the central nervous system [IPCS 2003a]. Many of the short-term OELs 

are based on the acute effects to the eyes and respiratory tract (Appendix B). Therefore, the 

ACGIH additive mixture formula could be used for these compounds because the health 

effect (irritation) and target organs (eyes and respiratory system) are the same [ACGIH 

2013]. We did not do this analysis because it would not change our main conclusions and 

recommendations. Nevertheless, eye and respiratory tract irritation are likely during training 

exercises if the trainers are not adequately protected.

Most other studies investigating exposures to oil-based or glycol-based smoke simulants 

were performed in the theatrical industry. Investigators in these studies found average workshift (about 4 hours) exposures to glycols ranging up to 7,000 μg/m3

, while average workshift (about 4 hours) exposures to mineral oils ranged up to 60,000 μg/m3

; both levels are 

well below the short-term levels we measured [NIOSH 1994; Moline et al. 2000; Teschke 

et al. 2005]. Investigators in one of these studies also found detectable levels of aldehydes and 

PAHs [Teschke et al. 2005]. Acute and chronic respiratory health effects have been associated 

with exposures to theatrical smoke [Varughese et al. 2005]. 

The study that is most comparable to this evaluation investigated pilots’ exposures to glycolbased smoke simulant during aviation emergency training [Wieslander et al. 2001]. In that 

study, short-term (1-minute) air concentrations of propylene glycol averaged 310,000 μg/m3, 

which is similar to the short-term air concentrations of diethylene glycol we measured. The 

pilots did not wear respiratory protection. Following this brief exposure, self-reported eye 

and throat irritation and trouble breathing (dyspnea) increased. In addition, tear film stability 

increased and the ratio of forced expiratory volume in 1 second to forced vital capacity was 

slightly reduced [Wieslander et al. 2001]. 

Conclusions 

Prior to the incident where a trainer suffered acute respiratory injury after being exposed 

to the oil-based smoke simulant, many of the trainers were under the assumption that the 

oil-based and glycol-based smoke simulants were not hazardous. However, the results of 

this evaluation indicate that air concentrations of mineral oil mist and diethylene glycol 

can exceed short-term OELs during training exercises involving oil-based smoke simulant, 

glycol-based smoke simulant, or both. If propane-generated heat and fire are added to 

the training exercises, thermal decomposition products can be produced, and the air 

concentrations of these products could also exceed short-term OELs. Overexposures are also 

possible if trainers open the training room and look inside without respiratory protection 

for even just a short time. If trainers are not adequately protected, these chemical exposures 

could cause eye and respiratory irritation or more serious acute respiratory effects.
Health Hazard Evaluation Report 2012-0028-3190 Page 25

Recommendations 

On the basis of our findings, we recommend the actions listed below. We encourage the fire 

department to use a labor-management health and safety committee or working group to 

discuss the recommendations in this report and develop an action plan. Those involved in the 

work can best set priorities and assess the feasibility of our recommendations for the specific 

situation at the fire department. 

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

(Appendix B). 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. 

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. Use the training tower’s exhaust ventilation system immediately after completing a 

training exercise. Do not re-enter the tower without appropriate respiratory protection 

until all smoke simulant has visibly dissipated.

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. Rotate training duties throughout a full day of training exercises. This will lessen each 

trainer’s chemical exposures. Although not a focus of our evaluation, this would also 

lessen the physiological strain associated with repeated training exercises, particularly 

those involving heat, fire, and use of SCBA.

2. Encourage trainers to report health concerns or symptoms associated with work tasks 

to a supervisor. Irritation to the eyes or respiratory system may be the most common 

immediate symptom a trainer could experience if he/she is not adequately protected 

during the training exercises.
Page 26 Health Hazard Evaluation Report 2012-0028-3190

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. Wear full-structural fire-fighting ensembles (including SCBA) inside the training tower 

at all times during or when preparing for the training exercises involving propanegenerated heat and fire. The ensembles (including SCBA) should be worn even if the 

trainer is outside the training room and only looks in the room briefly. This is because 

the SCBA provides optimal respiratory protection to the compounds we measured 

in addition to those we did not measure but could be present in air from thermal 

decomposition of the oil-based or glycol-based smoke simulant or the incomplete 

combustion of propane. In addition, the ensembles provide protection from heat, 

which would be especially important if an emergency were to occur that required the 

trainer to provide assistance inside the training room. SCBA could also be used for the 

other training exercises that do not involve heat and fire. However, the added weight of 

the SCBA increases the physical burden on the trainers. Therefore, we provide another 

respirator option below for the training exercises that do not involve heat and fire. 

2. Wear NIOSH-approved full-facepiece air purifying respirators with NIOSH-approved 

cartridge/canisters that are effective against oil-based aerosol (i.e., P100 cartridge) and 

formaldehyde (i.e., formaldehyde cartridge) during or when preparing for the training 

exercises that involve oil-based or glycol-based smoke simulant or both (but not heat 

and fire). This type of respirator should also be worn inside the training tower during 

these exercises even if the trainer is outside the training room. Full-facepiece air 

purifying respirators have a NIOSH assigned protection factor of 50 [NIOSH 2004]. 

This means that they can be used for atmospheres not immediately dangerous to life 

and health when air concentrations are < 50 times the applicable OELs provided that 

the appropriate cartridge/canister is used and that they are fitted, worn, and maintained 

properly. All the air concentrations we measured were well below 50 times the mostprotective short-term OELs. Full-facepiece respirators also protect the eyes from 

chemical irritants or other hazards that may be present during these training exercises. 

Cartridges/canisters that are effective against oil-based aerosol and formaldehyde 

may be available for use with existing respirators. Ensure that trainers are cleanshaven and that they check the seal of the tight-fitting respirators before using them. 

This is especially important for negative-pressure air-purifying respirators because an 

improper seal around the face will result in an increase of inward leakage of air and 

thereby an increase in inhalation of contaminants.
Health Hazard Evaluation Report 2012-0028-3190 Page 27

3. Conduct fit testing for the full-facepiece air purifying respirators under the 

configuration that they will be used as mandated in the OSHA comprehensive 

respiratory protection program standard [29 CFR 1910.134].

4. Determine a cartridge/canister change-out schedule based on the service life of 

the cartridge/canister under the conditions of use. The change-out schedule can be 

determined by using the information in this report along with the assistance of the 

respirator manufacturer (software or other tools) or by conducting service life tests.

5. Wear nitrile gloves when refilling the fog machine reservoirs with oil-based or glycolbased fluids.

6. Wash hands after each training exercise and shower at the end of a series of training 

exercises to rinse possible chemical contamination off the skin. 
Page 28 Health Hazard Evaluation Report 2012-0028-3190

Appendix A: Additional Sampling and Analytical 

Information

Mineral Oil, Diethylene Glycol, Aldehydes, and Polycyclic 

Aromatic Hydrocarbons 

Calibrated SKC Airchek 2000 pumps were used to draw 1 Lpm of air through media used for 

sampling mineral oil mist, diethylene glycol, aldehydes, and PAHs. The aldehyde media was 

stored in a −20°C freezer before and after sampling. These samples were analyzed using the 

published NIOSH or EPA methods (Table 2 on page 6).

Bulk samples of the mineral oil-based fluid and the diethylene glycol-based fluid were 

collected using 25-mL glass pipets to draw a 5-mL sample of each fluid from its reservoir. 

The fluid was then expelled into 20-mL glass vials. A sample of mineral oil condensate 

was collected by placing an open 20-mL vial near the built-in fog generator supply nozzle 

for 1 minute during Exercise 1A. The samples of the mineral oil fluid and condensate were 

prepared by dissolving in methylene chloride and analyzed using GC/MS. The sample of the 

diethylene glycol fluid was analyzed using NIOSH Method 5523 [NIOSH 2013] modified for 

the aqueous matrix.

Samples of mineral oil mist deposition were collected by placing the media into open petri 

dishes and positioning the open petri dishes on surfaces in the middle of each training room 

(during Exercises 1A and 1B). Patch samples to measure the levels of mineral oil mist on 

clothing during these exercises were made by placing the media inside paperboard holders 

with 75-mm openings. The patch samples were attached to the trainers’ turnout gear with 

alligator clips. After the training exercises, the samples were collected. The patch samples 

were placed into 100-mm petri dishes. The petri dishes were closed and sealed with parafilm. 

These samples were analyzed using NIOSH Method 5523 [NIOSH 2013].

Volatile Organic Compounds

The evacuated canisters for sampling VOCs in air were equipped with orifices set to run for 

15 minutes. The sampling port on the evacuated canisters were opened just prior to the start 

of each training exercise and closed just after the end of each training exercise. The samples 

were analyzed using EPA Method TO-15 [EPA 1999b]. Each canister was analyzed for 65 

target compounds and the top 20 tentatively identified compounds by GC/MS.

Carbonaceous Particles (Scanning Electron Microscopy)

Calibrated SKC Airchek 2000 pumps were used to pull 1 Lpm of air through the 

polycarbonate filters. The samples were analyzed by scanning electron microscopy using 

NIOSH Method 7404 [NIOSH 2013] with modifications. These modifications included 

affixing the filters to aluminum stubs with colloidal silver to avoid adding carbon to the 

samples and using energy dispersive X-ray analysis. In addition, no quantitation was 
Health Hazard Evaluation Report 2012-0028-3190 Page 29

performed. The samples were analyzed at magnifications ranging from 1,000 to 12,000 times. 

Images were obtained using the backscatter electron detector at an accelerating voltage of 20,000.

Aerosol Size Distribution

The cascade impactor plates were prepared with media using forceps and assembled in order. 

Thomas VTE vacuum pumps were used for pulling 100 Lpm through the cascade impactors. 

A Magnehelic® pressure gauge was used to set the inlet flow rate through the impactors at 

100 Lpm. After sampling, the impactors were disassembled. Using forceps, the media was 

placed inside 100-mm petri dishes and sealed with parafilm. The samples were analyzed 

using NIOSH Method 5026 [NIOSH 2013]. 
Page 30 Health Hazard Evaluation Report 2012-0028-3190

Appendix B: Occupational Exposure Limits and 

Health Effects

NIOSH investigators refer to mandatory (legally enforceable) and recommended OELs for 

chemical, physical, and biological agents when evaluating workplace hazards. OELs have 

been developed by federal agencies and safety and health organizations to prevent adverse 

health effects from workplace exposures. Generally, OELs suggest levels of exposure that 

most employees may be exposed to for up to 10 hours per day, 40 hours per week, for a 

working lifetime, without experiencing adverse health effects. However, not all employees 

will be protected if their exposures are maintained below these levels. Some may have 

adverse health effects because of individual susceptibility, a pre-existing medical condition, 

or a hypersensitivity (allergy). In addition, some hazardous substances act in combination 

with other exposures, with the general environment, or with medications or personal habits of 

the employee to produce adverse health effects. Most OELs address airborne exposures, but 

some substances can be absorbed directly through the skin and mucous membranes.

Most OELs are expressed as a time-weighted average exposure. A time-weighted average 

refers to the average exposure during a normal 8- to 10-hour workday. Some chemical 

substances and physical agents have recommended STEL or ceiling values. Unless otherwise 

noted, the STEL is a 15-minute time-weighted average exposure. It should not be exceeded at 

any time during a workday. The ceiling limit should not be exceeded at any time.

In the United States, OELs have been established by federal agencies, professional 

organizations, state and local governments, and other entities. Some OELs are legally 

enforceable limits; others are recommendations. 

● The U.S. Department of Labor OSHA permissible exposure limits (29 CFR 1910 

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

industry]) are legal limits. These limits are enforceable in workplaces covered under the 

Occupational Safety and Health Act of 1970. 

● NIOSH recommended exposure limits are recommendations based on a critical review 

of the scientific and technical information and the adequacy of methods to identify 

and control the hazard. NIOSH recommended exposure limits are published in the 

NIOSH Pocket Guide to Chemical Hazards [NIOSH 2010]. NIOSH also recommends 

risk management practices (e.g., engineering controls, safe work practices, employee 

education/training, personal protective equipment, and exposure and medical 

monitoring) to minimize the risk of exposure and adverse health effects.

● Other OELs commonly used and cited in the United States include the TLVs, which 

are recommended by ACGIH, a professional organization, and the workplace 

environmental exposure levels, which are recommended by the American Industrial 

Hygiene Association, another professional organization. The TLVs and workplace 

environmental exposure levels are developed by committee members of these 

associations from a review of the published, peer-reviewed literature. These OELs are 
Health Hazard Evaluation Report 2012-0028-3190 Page 31

not consensus standards. TLVs are considered voluntary exposure guidelines for use 

by industrial hygienists and others trained in this discipline “to assist in the control of 

health hazards” [ACGIH 2013]. Workplace environmental exposure levels have been 

established for some chemicals “when no other legal or authoritative limits exist” 

[AIHA 2011].

Outside the United States, OELs have been established by various agencies and organizations 

and include legal and recommended limits. The Institut für Arbeitsschutz der Deutschen 

Gesetzlichen Unfallversicherung (Institute for Occupational Safety and Health of the German 

Social Accident Insurance) maintains a database of international OELs from European Union 

member states, Canada (Québec), Japan, Switzerland, and the United States. The database, 

available at http://www.dguv.de/ifa/en/gestis/limit_values/index.jsp, contains international 

limits for more than 1,500 hazardous substances and is updated periodically. 

OSHA requires an employer to furnish employees a place of employment free from 

recognized hazards that cause or are likely to cause death or serious physical harm 

[Occupational Safety and Health Act of 1970 (Public Law 91–596, sec. 5(a)(1))]. This is 

true in the absence of a specific OEL. It also is important to keep in mind that OELs may not 

reflect current health-based information.

When multiple OELs exist for a substance or agent, NIOSH investigators generally 

encourage employers to use the lowest OEL when making risk assessment and risk 

management decisions. NIOSH investigators also encourage use of the hierarchy of controls 

approach to eliminate or minimize workplace hazards. This includes, in order of preference, 

the use of (1) substitution or elimination of the hazardous agent, (2) engineering controls 

(e.g., local exhaust ventilation, process enclosure, dilution ventilation), (3) administrative 

controls (e.g., limiting time of exposure, employee training, work practice changes, medical 

surveillance), and (4) personal protective equipment (e.g., respiratory protection, gloves, 

eye protection, hearing protection). Control banding, a qualitative risk assessment and risk 

management tool, is a complementary approach to protecting employee health. Control 

banding focuses on how broad categories of risk should be managed. Information on control 

banding is available at http://www.cdc.gov/niosh/topics/ctrlbanding/. This approach can be 

applied in situations where OELs have not been established or can be used to supplement 

existing OELs.

Criteria for the Short-Term Occupational Exposure Limits 

Referenced in this Report

Of the short-term OELs referenced in this report (Table 4 on page 10), ACGIH TLV 

documentation exists for crotonaldehyde, formaldehyde, acrolein, and benzene; NIOSH 

criteria documentation exists for formaldehyde and benzene. The ACGIH TLV ceiling 

for crotonaldehyde is intended to minimize the potential for rapidly acting irritation of 

the eyes and upper respiratory tract [ACGIH 2001e]. Likewise, the ACGIH TLV STEL 

for formaldehyde is intended to minimize the potential for eye and upper respiratory tract 

irritation [ACGIH 2001f]. The NIOSH ceiling limit for formaldehyde was set in 1988 
Page 32 Health Hazard Evaluation Report 2012-0028-3190

according to the NIOSH carcinogen policy at that time (i.e., lowest reliably quantifiable 

concentration) [NIOSH 1988]. Since then, sampling methods have become more sensitive 

and the quantity and quality of data for performing a risk assessment on formaldehyde 

has increased. NIOSH is currently in the process of evaluating and possibly revising this 

ceiling limit. The ACGIH TLV ceiling for acrolein is intended to minimize the potential for 

intense irritation of the eyes, mucous membranes, and respiratory tract and the development 

of pulmonary edema [ACGIH 2001b]. The ACGIH TLV STEL for benzene is intended to 

protect against the excess risk of leukemia due to the dose rate-dependent hematopoietic 

toxicity of benzene [ACGIH 2001c]. The NIOSH STEL for benzene is also intended to 

prevent leukemia from repeated exposures; however, this STEL was based on the analytical 

detection limits at the time it was set in 1974 [NIOSH 1974].

The basis for excursion limits is the variability in air concentrations throughout a workday. 

Air concentrations that are five times the work-shift OEL represent poorly controlled 

occupational environments [ACGIH 2013]. Although work-shift OELs are typically based on 

chronic health effects, maintaining exposures below excursion limits should also minimize 

acute health effects when such health effects are possible. Most the compounds we measured 

are capable of producing acute health effects from short-term exposures (pages 23–24 have 

an overview of these health effects). Maintaining intermittent exposures below excursion 

limits should also minimize chronic health effects. This is relevant for the trainers because 

repeated exposure to the smoke simulants and their thermal decomposition products are 

possible throughout the year. The ACGIH work-shift TLV for coal tar pitch volatiles (criteria 

we used for total PAHs) is intended to minimize the potential for an increase incidence of 

lung and other tumors [ACGIH 2001d]. The ACGIH work-shift TLV for mineral oil mist 

(pure, highly refined) is intended to prevent respiratory symptoms and pulmonary function 

changes and is mainly based on theatrical smoke exposures in the entertainment industry 

[ACGIH 2010]. The ACGIH work-shift TLV for 1,3-butadiene is intended to minimize the 

potential for cancer [ACGIH 2001a]. 
Health Hazard Evaluation Report 2012-0028-3190 Page 33

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Page 38 Health Hazard Evaluation Report 2012-0028-3190

Keywords: North American Industry Classification System 922160 (Fire Protection), simulated smoke, smoke simulant, fire fighter training, training exercises, theatrical smoke, 

fog, fogging machine, mineral oil, diethylene glycol, thermal decomposition
Health Hazard Evaluation Report 2012-0028-3190 Page 39

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). The Health Hazard Evaluation Program also 

provides, upon request, technical assistance to federal, state, and local agencies to control 

occupational health hazards and to prevent occupational illness 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: Joseph Fernback, Jennifer Roberts, and Bureau Veritas North America 

Desktop Publisher: Mary Winfree 

Editor: Ellen Galloway 

Health Communicator: Stefanie Brown 

Logistics: Donnie Booher and Karl Feldmann

Availability of Report

Copies of this report have been sent to the employer and employees at the installation. 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/2012-0028-3190.pdf.

Recommended citation for this report:

NIOSH [2013]. Health hazard evaluation report: evaluation of chemical 

exposures during fire fighter training exercises involving smoke 

simulant. By Fent KW, Musolin K, Methner M. Cincinnati, OH: U.S. 

Department of Health and Human Services, Centers for Disease Control 

and Prevention, National Institute for Occupational Safety and Health, 

NIOSH HETA Report No. 2012-0028-3190.
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