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NIOSH HEALTH HAZARD EVALUATION REPORT: DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Disease Control and Prevention National Institute for Occupational Safety and Health HETA #2003-0114-2924 Felker Brothers Corporation Marshfield, Wisconsin January 2004 This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

HETA #2003-0114-2924 Felker Brothers Corporation ... · Felker Brothers Corporation Marshfield, Wisconsin ... fabricated piping systems at the two Felker Brothers Corporation facilities

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NIOSH HEALTH HAZARD EVALUATION REPORT:

DEPARTMENT OF HEALTH AND HUMAN SERVICESCenters for Disease Control and Prevention

National Institute for Occupational Safety and Health

HETA #2003-0114-2924Felker Brothers CorporationMarshfield, Wisconsin

January 2004

This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

This Health Hazard Evaluation (HHE) report and any recommendations made herein are for the specific facility evaluated and may not be universally applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

applicable. Any recommendations made are not to be considered as final statements of NIOSH policy or of any agency or individual involved. Additional HHE reports are available at http://www.cdc.gov/niosh/hhe/reports

ii

PREFACEThe Hazard Evaluations and Technical Assistance Branch (HETAB) of the National Institute forOccupational Safety and Health (NIOSH) conducts field investigations of possible health hazards in theworkplace. These investigations are conducted under the authority of Section 20(a)(6) of the OccupationalSafety and Health (OSHA) Act of 1970, 29 U.S.C. 669(a)(6) which authorizes the Secretary of Health andHuman Services, following a written request from any employer or authorized representative of employees,to determine whether any substance normally found in the place of employment has potentially toxic effectsin such concentrations as used or found.

HETAB also provides, upon request, technical and consultative assistance to Federal, State, and localagencies; labor; industry; and other groups or individuals to control occupational health hazards and toprevent related trauma and disease. Mention of company names or products does not constitute endorsementby NIOSH.

ACKNOWLEDGMENTS AND AVAILABILITY OF REPORTThis report was prepared by Ronald Hall, Daniel Rhodes, and Elena Page of HETAB, Division ofSurveillance, Hazard Evaluations and Field Studies (DSHEFS). Field assistance was provided by ChadDowell, Chandran Achutan, and Donald Booher. Analytical support was provided by Data ChemLaboratories. Desktop publishing was performed by Robin Smith. Review and preparation for printing wereperformed by Penny Arthur.

Copies of this report have been sent to employee and management representatives at Felker BrothersCorporation and the OSHA Regional Office. This report is not copyrighted and may be freely reproduced.Single copies of this report will be available for a period of three years from the date of this report. Toexpedite your request, include a self-addressed mailing label along with your written request to:

NIOSH Publications Office4676 Columbia ParkwayCincinnati, Ohio 45226

800-356-4674

After this time, copies may be purchased from the National Technical Information Service (NTIS) at5825 Port Royal Road, Springfield, Virginia 22161. Information regarding the NTIS stock number may beobtained from the NIOSH Publications Office at the Cincinnati address.

For the purpose of informing affected employees, copies of this report shall beposted by the employer in a prominent place accessible to the employees for a periodof 30 calendar days.

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Highlights of the NIOSH Health Hazard Evaluation

Evaluation of metal exposures at Felker Brothers CorporationOn December 23, 2002, the National Institute for Occupational Safety and Health (NIOSH) received a union requestfrom the International Brotherhood of Boilermakers regarding worker exposures to chromium and nickel compoundsduring the manufacturing of stainless steel products and fabricated piping systems at Felker Brothers Corporation inMarshfield, Wisconsin.

What NIOSH Did

# We collected air samples on workers during cutting,welding, grinding, and pickling operations.

# We talked to employees about health concerns inthe workplace.

# We looked at Illness and Injury reports for the past5 years.

What NIOSH Found

# Some workers may be exposed to nickel andhexavalent chromium above NIOSH criteria.

# Some workers may be exposed to manganese aboveAmerican Conference of Governmental IndustrialHygienist® criteria.

# Sampling results indicate highest concentrations fornickel, manganese, and hexavalent chromium occurwhen workers weld inside large stainless steel pipesor when welding fins on large pipes.

# Area air samples for ozone indicate concentrationsabove NIOSH criteria and the potential to exceedother occupational criteria if continuous welding isdone inside the pipes throughout the work shift.

# At the time of our evaluation, the types of cancers

linked to nickel and chromium compoundexposures have not been reported among current orformer workers.

# Welding fumes, acid vapors, ozone, general plantdust, and general plant ventilation could contributeto irritant symptoms reported by some workers.

What Felker Brothers Managers Can Do

# Put controls (i.e., local exhaust ventilation) in areaswhere sample results indicate exposures abovecriteria.

# Re-evaluate worker exposures after controls havebeen put in place.

# Do not allow eating, drinking, or smoking in workareas.

# Support communication between workerrepresentatives and management on the plant’ssafety/ergonomics team.

# Improve housekeeping practices by avoidingdry–sweeping and use wet clean–up methods (i.e.,mopping) or HEPA filter vacuums. [Don’t use wetmethods in areas where it could cause potentialelectrical or safety hazards.]

# Protect workers from potential fall hazards.

What the Felker Brothers Employees Can Do

# Use controls as instructed.

# Do not eat, drink, or smoke in work areas.

# Report health and safety concerns to management andsafety/ergonomics team.

# Follow plant safety and health guidelines.Highlights of the HHE Report

What To Do For More Information:We encourage you to read the full report. If you

would like a copy, either ask your health and safetyrepresentative to make you a copy or call

1-513/841-4252 and ask for HETA Report #2003-0114-2924

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Health Hazard Evaluation Report 2003-0114-2924Felker Brothers Corporation

Marshfield, WisconsinJanuary, 2004

Ronald M. Hall, MS, CIHDaniel Rhodes, MD, MPH

Elena Page, MD, MPH

SUMMARYOn December 23, 2002, the National Institute for Occupational Safety and Health (NIOSH) received arequest from the International Brotherhood of Boilermakers regarding worker exposures to chromium andnickel compounds during the manufacture of high-quality, corrosive-resistant stainless steel products andfabricated piping systems at the two Felker Brothers Corporation facilities in Marshfield, Wisconsin. Unionofficials also expressed concerns about potential carcinogenic effects of these exposures.

On February 5, 2003, NIOSH investigators made an initial site visit to gather information on stainless steelcutting, welding, grinding, and pickling processes. An in-depth industrial hygiene evaluation was conductedduring May 28-29, 2003. In addition, a NIOSH physician conducted private medical interviews with 23employees.

Personal breathing zone (PBZ) air sampling was conducted on employees during stainless steel cutting,welding, grinding, and pickling operations. PBZ air samples were collected for elements (various metalcompounds including nickel and chromium), total welding fumes, hexavalent chromium (CrVI), ozone,nitrogen dioxide, carbon monoxide, and inorganic acids. Carbon dioxide, temperature, and relative humiditywere also measured.

PBZ air samples indicated the potential for some workers to be exposed to nickel and CrVI concentrationsabove the NIOSH recommended exposure limit (REL) and to manganese above the American Conferenceof Governmental Industrial Hygienists’ (ACGIH®) Threshold Limit Value (TLV®). The highestconcentrations for nickel, manganese, and CrVI occurred during operations in which workers welded insidelarge stainless steel pipes or welded fins on a large stainless steel pipe. Two detector tube results for ozonealso indicated concentrations exceeding the NIOSH REL ceiling limit and the potential to exceed ACGIH,and the Occupational Safety and Health Administration (OSHA) occupational criteria (if continuous weldingoccurs throughout the work shift) during welding operations inside stainless steel pipes.

A total of 23 employees were interviewed. The average tenure at Felker Brothers was 24 years (range: 6months to 38 years). Seventeen of the 23 employees reported ever having work-related or work-aggravatedhealth problems, mainly upper respiratory/mucous membrane irritation or musculoskeletal injury. Seven ofthe 23 employees reported current upper respiratory or mucous membrane irritation. All reported that thesesymptoms were not severe enough to keep them from working. Welding fumes, acid vapors from the picklingtank, general plant dust, and general plant ventilation could contribute to these symptoms. Twelve (52%) ofthose interviewed were previous smokers, 6 (26%) had never smoked, and 5 (22%) were current smokers.There was no significant relationship between current mucous membrane irritation and smoking status.

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PBZ air samples indicated the potential for some workers to be exposed to nickel and CrVI concentrationsabove the NIOSH REL and to manganese above the ACGIH® TLV®. Although the potential for exposureto nickel and chromium exists, at the time of our evaluation, the types of cancers linked to exposure to thesesubstances have not been reported among current or former employees of Felker Brothers. Welding fumes,acid vapors from the pickling tank, general plant dust, and general plant ventilation could contribute to irritantsymptoms reported by some workers. Engineering controls (i.e., local exhaust ventilation) should be usedin areas where sample results indicated exposures exceeding applicable occupational criteria. Otherrecommendations to reduce worker exposures are provided in the report.

Keywords: SIC 3317 (Steel Pipe and Tubes). stainless steel, nickel, chromium, pipe, tube, fittings,pre-fabricated piping systems, cutting, welding, grinding, fabricating, pickling.

TABLE OF CONTENTSPreface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

Acknowledgments and Availability of Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

Highlights of the HHE Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

Introduction and Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Industrial Hygiene Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Total Welding Fumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Hexavalent Chromium (CrVI) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Ozone (O3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Nitrogen Dioxide (NO2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Carbon Monoxide (CO), Carbon Dioxide (CO2), Temperature, and Relative Humidity . . . . . . . 2Inorganic Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Medical Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Hexavalent Chromium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Nickel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Ozone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Manganese . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Industrial Hygiene Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Nickel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Chromium Compounds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Manganese . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Other Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Total Welding Fumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Hexavalent Chromium (CrVI) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Ozone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Carbon Monoxide, Nitrogen Dioxide, and Carbon Dioxide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Inorganic Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Local Exhaust Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Medical Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7OSHA 200/300 Logs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Discussion and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Health Hazard Evaluation Report No. 2003-0114-2924 Page 1

INTRODUCTION ANDBACKGROUND

On December 23, 2002, the National Institute forOccupational Safety and Health (NIOSH) receiveda request from the International Brotherhood ofBoiler makers regarding worker exposures tochromium and nickel compounds during themanufacturing of high quality, corrosive resistantstainless steel products and fabricated pipingsystems at the two Felker Brothers Corporationfacilities in Marshfield, Wisconsin. Unionofficials also expressed concerns about potentialcarcinogenic effects of these exposures, althoughthey reported being unaware of any current orformer employees having been diagnosed withcancer.

Felker Brothers Corporation is a manufacturer ofstainless steel commodity products (pipe, tube andfittings), and stainless steel custom products(pre-fabricated piping systems) withapproximately 114 employees working inproduction areas of the two facilities.Manufacturing processes at the facilities includecutting, welding, grinding, fabricating, andpickling.

On February 5, 2003, NIOSH investigators madean initial site visit to gather information onstainless steel cutting, welding, and grindingprocesses. The opening conference was attendedby management, union officials, and NIOSHrepresentatives. An in-depth industrial hygieneevaluation was conducted at the two facilities (i.e.,main and depot facilities) during May 28-29,2003. Air sampling was conducted throughout theplant during stainless steel cutting, welding, andgrinding operations. Air samples for inorganicacids were collected on workers involved inpickling and acid paste operations. In addition,temperature and humidity measurements were alsocollected.

A NIOSH physician interviewed 23 seriallyselected employees from approximately 114production workers within the two facilities.

Private medical interviews covered employeestenure and department, past medical history,smoking history, and current symptoms,complaints, and concerns. A closing conferencewas held on May 29, 2003, during whichpreliminary findings and recommendations werediscussed.

METHODS

Industrial Hygiene Evaluation

Personal breathing zone (PBZ) air sampling wasconducted on various employees within the mainand depot facilities during stainless steel cutting,welding, and grinding operations. PBZ and areaair samples were collected for elements (variousmetal compounds including nickel andchromium), total welding fumes, hexavalentchromium (CrVI), ozone (O3), nitrogendioxide(NO2), carbon monoxide(CO), carbondioxide (CO2), temperature, relative humidity, andinorganic acids.

Elements

PBZ air samples for elements were quantitativelyanalyzed for silver, aluminum, arsenic, beryllium,calcium, cadmium, cobalt, chromium, copper,iron, lithium, magnesium, manganese,molybdenum, sodium, nickel, phosphorus, lead,platinum, selenium, tellurium, thallium, titanium,vanadium, yttrium, zinc, and zirconium using aPerkin Elmer Optima 3000 DV inductivelycoupled plasma spectrometer according to NIOSHMethod 7300.1 These samples were collected on37–mm diameter (5–:m pore–size) polyvinylchloride (PVC) filters, using sampling pumpscalibrated at 2 liters per minute (Lpm).

Total Welding Fumes

PBZ air samples for total welding fumes werecollected on 37–mm diameter (5–:m pore–size)PVC filters, using sampling pumps calibrated at 2Lpm. Filters were gravimetrically analyzed (filterweight) according to NIOSH Method 0500.1

Page 2 Health Hazard Evaluation Report No. 2003-0114-2924

Hexavalent Chromium (CrVI)

PBZ air samples for CrVI were collected on37–mm diameter (5–:m pore–size) PVC filters,using sampling pumps calibrated at 2 Lpm. Thesesamples were analyzed by high performance liquidchromatography (HPLC) according to NIOSHmethod 7605.1

Ozone (O3)

Area monitoring for O3 was conducted withcolorimetric detector tubes (Draeger 0.05/b,#6733181 – range 0.05 to 0.7 parts per million[ppm] with 10 strokes on the pump) in thebreathing zone of workers during weldingactivities. The detector tubes are used by drawingair through the tube with a bellows–type pump.The resulting length of the stain in the tube(produced by a chemical reaction with the sorbent)is proportional to the concentration of the aircontaminant.

Nitrogen Dioxide (NO2)

Area monitoring for NO2 was conducted withcolorimetric detector tubes (Draeger 0.05/c,#CH30001 – range 0.5 to 10 ppm with 5 strokeson the pump) in the breathing zone of workersduring welding.

Carbon Monoxide (CO), Carbon Dioxide(CO2), Temperature, and Relative Humidity

Area real-time CO, CO2, temperature, and relativehumidity spot measurements were taken using ahand-held, battery operated, TSI Q-Track™(Model 8554) indoor air quality (IAQ) monitor inthe breathing zone of workers during weldingoperations. This portable monitor uses an Electro-chemical sensor to measure CO in the range of 0-500 ppm. The monitor uses a non-dispersiveinfrared absorption (NDIR) sensor to measure CO2in the range of 0-5000 ppm. In addition, themonitor is capable of measuring temperature in therange of 32 to 122 degrees Fahrenheit, and is alsoable to measure relative humidity in the range of5 to 95%.

Inorganic Acids

PBZ air samples for inorganic acids (i.e.,hydrofluoric, hydrochloric, nitric, phosphoric,sulfuric, and hydrobromic acid) were collected onsolid sorbent tubes (washed silica gel, 400milligrams [mg]/200 mg with glass fiber plug)attached by tubing to sampling pumps calibratedat a flow rate of 0.2 Lpm. The samples wereanalyzed for fluoride, chloride, nitrate, phosphate,bromide, and sulfate ion concentrations by ionchromatography according to NIOSH samplingmethod 7903.1 The ion results were thenconverted to the respective acid.

Medical Evaluation

Twenty-five employees were serially selected forinterviews from approximately 114 productionemployees at both the main and depot facilities.Information regarding current or formeremployees with cancer was solicited from theseinterviews and from the union and management.The Illness and Injury reports (OccupationalSafety and Health Administration 200/300 logs)from the past five years were reviewed.

EVALUATION CRITERIAAs a guide to the evaluation of the hazards posedby workplace exposures, NIOSH field staffemploy environmental evaluation criteria for theassessment of a number of chemical and physicalagents. These criteria are intended to suggestlevels of exposure to which most workers may beexposed up to 10 hours per day, 40 hours per weekfor a working lifetime without experiencingadverse health effects. It is, however, important tonote that not all workers will be protected fromadverse health effects even though their exposuresare maintained below these levels. A smallpercentage may experience adverse health effectsbecause of individual susceptibility, a pre-existingmedical condition, and/or a hypersensitivity(allergy). In addition, some hazardous substancesmay act in combination with other workplaceexposures, the general environment, or withmedications or personal habits of the worker to

Health Hazard Evaluation Report No. 2003-0114-2924 Page 3

produce health effects even if the occupationalexposures are controlled at the level set by thecriterion. These combined effects are often notconsidered in the evaluation criteria. Also, somesubstances are absorbed by direct contact with theskin and mucous membranes, and thus potentiallyincreases the overall exposure. Finally, evaluationcriteria may change over the years as newinformation on the toxic effects of an agentbecome available.

The primary sources of environmental evaluationcriteria for the workplace are: (1) NIOSHRecommended Exposure Limits (RELs),2 (2) theAmerican Conference of Governmental IndustrialHygienists’ (ACGIH®) Threshold Limit Values(TLVs®),3 and (3) the U.S. Department of Labor,OSHA Permissible Exposure Limits (PELs).4

Employers are encouraged to follow the OSHAlimits, the NIOSH RELs, the ACGIH TLVs, orwhichever are the more protective criterion.

OSHA requires an employer to furnish employeesa place of employment that is free fromrecognized hazards that are causing or are likely tocause death or serious physical harm[Occupational Safety and Health Act of 1970,Public Law 91–596, sec. 5.(a)(1)]. Thus,employers should understand that not allhazardous chemicals have specific OSHAexposure limits such as PELs and short-termexposure limits (STELs). An employer is stillrequired by OSHA to protect their employeesfrom hazards, even in the absence of a specificOSHA PEL.

A time-weighted average (TWA) exposure refersto the average airborne concentration of asubstance during a normal workday. Somesubstances have recommended STEL or ceilingvalues which are intended to supplement the TWAwhere there are recognized toxic effects fromhigher exposures over the short-term.

Hexavalent Chromium

The toxicity and solubility of chromiumcompounds that contain chromium in the Cr2+,Cr3+, or CrVI valence state vary greatly, but those

that contain CrVI are of the greatest health concern.CrVI compounds include lead chromate and zincchromate pigments, chromic acid, and solublecompounds such as those used in chromiumplating. Some CrVI compounds are severe irritantsof the respiratory tract and skin, and some(including chromates) have been found to causelung cancer in exposed workers.5 Allergicdermatitis is one of the most common effects ofchromium toxicity among exposed workers.

NIOSH has identified CrVI as a potentialoccupational carcinogen. The NIOSH REL forCrVI, based on a designation as a potentialoccupational carcinogen, is 0.001 milligram percubic meter (mg/m3) full shift TWA.2 The OSHAPEL for CrVI is a ceiling limit of 0.1 mg/m3,6 andthe ACGIH TLV is 0.01 mg/m3 for insoluble CrVI

compounds and 0.05 mg/m3 for soluble CrVI

compounds.3 Nonoccupational sources ofexposure to chromium may include cigarettesmoke.

Nickel

Metallic nickel compounds cause allergic contactdermatitis.5 NIOSH considers nickel a potentialoccupational carcinogen, as nickel refining hasbeen associated with an increased risk of nasal andlung cancer.6 Cigarette smoking may also be anonoccupational source of exposure to nickelcompounds.7 The NIOSH REL for nickel, basedon the designation as a potential occupationalcarcinogen, is 0.015 mg/m3.2 The ACGIH TLV forinsoluble compounds of nickel (i.e., nickeloxides8) is 0.2 mg/m3 (inhalable fraction), forsoluble nickel compounds (i.e., nickel compoundsthat include chloride, sulfate, and nitrate8) theTLV is 0.1 mg/m3 (inhalable fraction), and theTLV for elemental nickel is 1.5 mg/m3 (inhalablefraction).3 The OSHA PEL for nickel is 1 mg/m3.4

Ozone

Low concentrations of O3 (0.01 ppm to 0.05 ppm)may produce a sharp, irritating odor even duringbrief exposures.9 Symptoms of ozone exposureinclude irritation of the eyes, dryness of the noseand throat, and cough. At higher ozone

Page 4 Health Hazard Evaluation Report No. 2003-0114-2924

concentrations, more severe symptoms maydevelop. These symptoms may include headache,pain or tightness in the chest, and shortness ofbreath or tiredness.9 Short–term exposure (a fewhours) to O3 concentrations on the order of 0.1ppm has been shown to produce temporarydecreases in measured lung volumes in humans.10

The NIOSH REL for O3 is 0.1 ppm and is to bemeasured as a ceiling limit.2 A ceiling limit is apeak concentration that should not be exceeded atany time during the workday. NIOSH has alsorecommended an immediately dangerous to lifeand health (IDLH) limit of 5 ppm for O3.6 Thecurrent OSHA PEL for O3 is 0.1 ppm for an8–hour (40–hour work week) TWA.4 The currentACGIH TLV is based on the amount of physicalexertion or work load required for the job beingaccomplished and is to be average over an 8–hourperiod. The TLV is 0.1 ppm for jobs requiringlight physical exertion, 0.08 ppm for moderatephysical exertion, 0.05 ppm for heavy physicalexertion, and 0.2 ppm for heavy, moderate, orlight work loads less than or equal to 2 hours induration.3

Manganese

Manganese (Mn) is an abundant and ubiquitouselement present throughout the environmentincluding soil, water, air, vegetation, and fooditems. Manganese is an essential trace elementnecessary for the formation of connective tissueand bone as well as the metabolism ofcarbohydrates and lipids; for these reasons, adulthumans require 2 to 3 milligrams (mg) of dietaryMn per day.11 There are many importantindustrial uses for Mn; it is used in the metal alloyindustries, in ceramic and glass products, in rubberand wood preservatives; and in dry-cell batteries.5The health effects of excessive occupational Mnexposure are primarily neurological andrespiratory (including irritation, pneumonitis, andchronic bronchitis). Metal fume fever has alsobeen reported with exposure to Mn fume. Mostnotably, occupational exposure to Mn dust isknown to cause manganism, a Parkinsonian-likesyndrome. This condition has also been referredto as Mn poisoning and chronic Mn toxicity.

Chronic Mn toxicity has been found in workersexposed to Mn during operations in which highconcentrations of dust or fume were generated.Such operations have included mining, oreprocessing, purification processes, metallurgicaland manufacturing processes, and welding of Mnalloys or use of welding rods containing Mn.12

Inhalation is the primary route of occupationalexposure, but most inhaled Mn dust is mobilizedfrom the lungs and swallowed.13 Thus, thegastrointestinal tract may be an important route ofabsorption for inhaled as well as ingested Mn dust.

The NIOSH REL for Mn compounds is 1 mg/m3

(full shift TWA), with a STEL of 3.0 mg/m3 basedon central nervous system effects andpneumonitis.14,2 The OSHA PEL for manganeseis a ceiling criteria of 5.0 mg/m3.4 The ACGIHcurrent TLV for manganese is 0.2 mg/m3.3

RESULTS

Industrial Hygiene Evaluation

Elements

A total of 44 PBZ air samples for elements werecollected throughout the main and depot facilities.These samples were analyzed for silver,aluminum, arsenic, beryllium, calcium, cadmium,cobalt, chromium, copper, iron, lithium,magnesium, manganese, molybdenum, sodium,nickel, phosphorus, lead, platinum, selenium,tellurium, thallium, titanium, vanadium, yttrium,zinc, and zirconium.

Nickel

PBZ air samples with nickel concentrations equalto or above the NIOSH REL of 0.015 mg/m3 arelisted in Table 1. All other nickel samples (notlisted in Table 1) collected in the main and depotfacilities indicated nickel concentrations less thanoccupational criteria (NIOSH, ACGIH, andOSHA).

Four of the highest concentrations of nickel wereon workers in the main facility. Two of these

Health Hazard Evaluation Report No. 2003-0114-2924 Page 5

workers were performing welding/grindingoperations inside large stainless steel pipes(department 206). The PBZ samples collected onthese workers indicated nickel TWA exposures of0.12 mg/m3 and 0.15 mg/m3. One worker had anickel TWA exposure of 0.16 mg/m3 whilewelding fins on the outside of a large stainlesssteel pipe in department 206, and another workerhad a nickel TWA exposure of 0.16 mg/m3 whileperforming tasks as a fabricator in the mainfacility.

One PBZ sample collected on a worker in thedepot facility while performing weldingoperations on stainless steel indicated aconcentration of 0.0197 mg/m3, which is above theNIOSH REL. The worker that this sample wascollected on consistently smoked in the shopduring the work shift. Smoking may also be anonoccupational source of exposure to nickelcompounds.7 All other PBZ samples collected onworkers in the depot facility indicatedconcentrations of nickel below applicableoccupational criteria. All PBZ samples collectedand analyzed for nickel had concentrations belowthe OSHA PEL of 1 mg/m3.

Chromium Compounds

All PBZ air samples for chromium compoundshad concentrations below applicable occupationalexposure criteria (i.e., NIOSH REL of 0.5 mg/m3,ACGIH® TLV® of 0.5 mg/m3, and OSHA PEL of0.5 mg/m3). Chromium concentrations for thosesamples that had nickel concentrations above theREL are listed in Table 1. These samplesrepresent some of the more elevated chromiumconcentrations at the facility. Workers with thehighest reported TWA chromium exposures werelocated in department 206 where two of theseworkers were welding/grinding inside largestainless steel pipes (0.26 mg/m3 and 0.36 mg/m3),and one worker welded fins on a large stainlesssteel pipe (0.36 mg/m3). A worker performingtasks as a fabricator in the main facility had achromium compound TWA exposure of 0.24mg/m3.

Manganese

PBZ air sample results for three workers indepartment 206 indicated concentrationsexceeding the ACGIH TLV of 0.2 mg/m3 formanganese (see Table 1). Two of these workerswere welding/grinding inside large stainless steelpipes and had PBZ TWA manganeseconcentrations of 0.34 mg/m3 and 0.32 mg/m3.The manganese TWA concentration for anotherworker was 0.31 mg/m3 while welding/grindingfins on large stainless steel pipes. Theseconcentrations are below the NIOSH REL of 1mg/m3. All other manganese samples were belowapplicable occupational criteria.

Other Elements

Results of sampling for all other elementcompounds analyzed by NIOSH method 7300indicated concentrations below applicableoccupational exposure criteria.

Total Welding Fumes

A total of 44 PBZ air samples were collected andgravimetrically analyzed for total welding fumeson workers throughout the main and depotfacilities. These samples were also analyzed forelements to get a breakdown of the differentelemental compounds and concentrations. OnePBZ sample indicated a total welding fumeconcentration of 5.2 mg/m3 which exceeds theACGIH TLV of 5 mg/m3. However, this samplewas collected on a worker who performedgrinding operations in addition to operationswhere he may have been exposed to weldingfumes. Therefore, this sample is representative ofboth grinding dust and welding fumes. Theelement results for this sample indicated thatconcentrations of the various metal compoundswere below applicable occupational exposurecriteria, with the exception of nickel, which waspresent at a concentration of 0.04 mg/m3 (abovethe NIOSH REL of 0.015 mg/m3). All other PBZair samples for total welding fumes were belowthe ACGIH TLV (5 mg/m3 for total weldingfume).

Hexavalent Chromium (CrVI)

Page 6 Health Hazard Evaluation Report No. 2003-0114-2924

A total of 46 CrVI PBZ air samples were collectedin the main and depot facilities. Table 2 list CrVI

PBZ air sample results exceeding the NIOSH RELof 0.001 mg/m3. All other CrVI PBZ air samplescollected at both facilities (not listed on Table 2)indicated concentrations below applicableoccupational exposure criteria.

The two highest PBZ air sampling results weretaken on workers in department 206. PBZsamples for a worker who performed work taskssuch as welding/grinding inside large stainlesssteel pipes and another worker who welded fins onlarge stainless steel pipes both indicated CrVI

concentrations of 0.02 mg/m3, which exceeds theACGIH TLV (0.01 mg/m3) for insoluble CrVI

compounds.

Ozone

O3 samples were collected in the breathing zone ofworkers during welding operations.Concentrations of 0.13 ppm and 0.59 ppm weredetected near a worker welding inside largestainless steel pipes in department 206. Theseresults exceed the NIOSH REL (Ceiling limit of0.1 ppm), and indicate a potential to exceed theACGIH TLVs (8-hour TWA of 0.1 ppm for lightwork, 0.08 ppm for moderate work, 0.05 ppm forheavy work, and 0.2 ppm for heavy, moderate, orlight work loads less than or equal to 2 hours induration) and OSHA PEL (8-hour TWA of 0.1ppm) if continuous welding is done inside the pipethroughout the work shift. All other O3 samplescollected throughout the main and depot facilitieshad concentrations below applicable occupationalexposure criteria.

Carbon Monoxide, Nitrogen Dioxide, andCarbon Dioxide

Instantaneous real-time samples collected for CO,NO2, and CO2 near the breathing zone of workerswhile performing welding operations, indicatedconcentrations well below applicable occupationalexposure criteria.

Inorganic Acids

Inorganic acid samples were collected in thebreathing zone of workers during picklingoperations in the main facility at the pickling tank,and pickle paste operations in both the main anddepot facilities. Nitric acid concentrations were inthe range of 0.008 to 0.094 ppm, hydrochloric acidconcentrations in the range of 0.0045 to 0.026ppm, sulfuric acid concentrations in the range of0.0002 to 0.002 ppm, and hydrofluoric acidconcentrations in the range of 0.1 to 0.87 ppm.These results indicate that inorganic acidconcentrations were below applicableoccupational exposure criteria. Hydrobromic andphosphoric acids were not detected on oursamples.

Local Exhaust Assessment

The big plasma cutting table was not equippedwith a local exhaust ventilation (LEV) systemduring the time of our evaluation. This table waslocated in an area of the main facility near one ofthe two fixed dilution ventilation systems in theshop. The dilution ventilation systems in the shopprovided approximately 20% outside air and 80%recirculated air from the shop. They maintainedthe shop under positive pressure and wereequipped with filters that filtered the air before re-supplying it back into the shop.

The facility had LEV for plasma cuttingoperations on the cybermation table and elbowcut-off station. The ventilation measurementscollected on the downdraft ventilation system atthe cybermation table indicated a velocity of 76feet per minute (fpm) at the face and 55 fpm atapproximately 6-8 inches above the face. Thearea of the cybermation table was approximately53 square feet (ft2) and the volume of air moved(based upon the area and our face velocitymeasurements) was 4028 cubic feet per minute(ft3/min). Observations during work activities andsmoke powder test indicated that fume generatedfrom cutting operations on this table may escapethe capture of the hood. During our survey,considerable amounts of slag material from thecutting operations was located in the bottom of the

Health Hazard Evaluation Report No. 2003-0114-2924 Page 7

downdraft hood and may have resulted in reducedair flow through the system.

The elbow cut-off station had two hoods locatednear the elbow cutting operation. The ventilationduct located directly under the cutting operationhad an area of 0.11 ft2 and an average facevelocity of 209 fpm, which produces a calculatedvolumetric air flow of 23 ft3/min. The rectangularhood located off to the side of the cuttingoperation had an area of 0.125 ft2 and a facevelocity of 780 fpm, which produces a calculatedvolumetric air flow of 97.5 ft3/min. Observationsduring normal work activities and smoke powdertesting indicated that the elbow cut-off ventilationsystem effectively controlled fume emissions.

A ventilation system located inside the grindingbooth was also evaluated during our survey. Thissystem consisted of flexible duct attached to twosmall hoods. The flexible duct was connected toa fan mounted on top of a 55-gallon drum insidethe grinding booth. The system appeared to bedesigned to capture the large metal particlesgenerated during grinding activities. However,our observations and smoke test indicated thatsmall aerosols captured by the system were blownout the top of the drum and into the work area.Therefore, this system did not appear to beeffective.

Medical Evaluation

Interviews

Twenty-five employees were serially selected forinterviews from approximately 114 productionemployees at both the 4th street (main facility) anddepot street facilities. One of those selected wasoff work on the days of the interviews and twodeclined to be interviewed. One of those whodeclined was replaced, therefore a total of 23employees were interviewed. Nineteen (83%)were from the 4th street facility and four (17%)were from the depot street facility. The majorityof employees (about 70%) work at the 4th Streetfacility and the processes and exposures are

similar at both sites. The average age of thoseinterviewed was 52 years (range: 30 to 62 years).The average length of time these employees hadworked at Felker Brothers was 24 years (range: 6months to 38 years). Five were described asmachine operators, five as utility, four asfabrication/fitter, three as welder, three assemiskilled, and three as either maintenance,patternmaker, or tool builder. Seventeen of the 23employees reported ever having work-related orwork-aggravated health problems, mainly upperrespiratory/mucous membrane irritation ormusculoskeletal injury. Seven of the 23employees reported current upper respiratory ormucous membrane irritation. All reported thatthese symptoms were not severe enough to keepthem from working. Twelve (52%) of thoseinterviewed were previous smokers, six (26%) hadnever smoked, and five (22%) were currentsmokers. There was no significant relationshipbetween current mucous membrane irritation andsmoking status. Interviewed employees were notaware of current or former employees with cancer.Union officials reported that nine retirees mayhave had cancer, but were unable to providedetails about the type of cancer, time of diagnosis,or job history.

OSHA 200/300 Logs

The OSHA logs from January 1998 throughDecember 2002 were reviewed. There were 71,47, 30, 24, and 29 recorded injury or illnessentries for the years 1998 through 2002,respectively. These totals are for both facilities.The majority of entries were for strains,contusions, lacerations, and foreign body to eye.There was only one entry for mucous membraneirritation; it occurred in 1998.

DISCUSSION ANDCONCLUSIONS

PBZ air samples collected during our evaluationindicated the potential for some workers to beexposed to nickel and CrVI at concentrations abovethe NIOSH REL (see Tables 1 and 2), and to Mn

Page 8 Health Hazard Evaluation Report No. 2003-0114-2924

above the ACGIH TLV (see Table 1). The PBZresults indicated that the highest concentrations ofnickel, Mn, and CrVI occurred during operations indepartment 206 where workers welded insidelarge stainless steel pipes or welded fins on a largestainless steel pipe. Two detector tube results forO3 also indicated concentrations exceeding theNIOSH REL ceiling limit and the potential toexceed ACGIH and OSHA occupational criteria(if consistent welding is accomplished throughoutthe work shift) during welding operations insidestainless steel pipes in department 206.

Engineering controls (i.e.,LEV) should be used inareas where sample results indicatedconcentrations exceeding applicable occupationalcriteria. Portable air cleaning systems arecommercially available for the collection andfiltration of welding fumes. However, thesesystems require stringent maintenance to ensurethat they are operating at manufacturerspecifications to effectively remove the aerosolsgenerated during cutting or welding operations. Ifthese systems are not maintained properly or arenot performing to manufacturer’s specificationsthey may release welding aerosols back into thework environment. The ACGIH ventilationmanual recommends avoiding recirculatingfiltered air from welding hoods back into occupiedspaces unless the welding is low hazard andproduces low quantities of contaminants.15

Because nickel and CrVI compounds areconsidered potential occupational carcinogens theuse of systems that re-circulate filtered air backinto work areas is not recommended.

The filters on the dilution ventilation systems inthe main facility may not be effective forremoving fumes generated during weldingactivities inside the shop without the use of highefficiency particulate air filters (HEPA) andappropriate seals. Also, these systems are noteffective for reducing emissions at the source ofthe welding operations in the shop.

LEV is the best way to remove fumes at the sourceof the operation. A welding ventilation movableexhaust hood system could be used to capture thecontaminants generated during welding

operations. The local exhaust ventilation systemshould be designed to have a capture velocity(minimum hood-induced air velocity necessary tocapture and convey the contaminant into the hood)of approximately 100 - 170 fpm with the highervalues used for poor conditions such as high cross-draft velocities and with higher hazard levels.15 The system should also have a minimum ductvelocity of approximately 3000 fpm (weldingventilation movable exhaust hoods Figure VS-90-02, ACGIH Ventilation Manual).15 The hood ofthe local exhaust ventilation system should beplaced as close as possible to the source ofcontaminant generation. However, it should benoted that capture velocities above 100–200 fpmmay disturb shield gas.15 Anytime LEV is used ina facility, sufficient clean make-up air must beprovided to the shop for the systems to operateeffectively. Depending on the climate, thetemperature of the make-up air supplied to theshop may need to be considered.

Additional methods that could be used to controlworker exposures in areas where sample resultsindicate concentrations exceeding applicableexposure criteria consist of administrative controlsand personal protective equipment (PPE) (i.e.,respirators). Administrative controls and PPE aredesigned to protect workers from airborneexposures while engineering controls are beingimplemented or when engineering controls are notfeasible or effective in reducing air contaminantsto acceptable levels. For respirators to be worn byemployees, an appropriate respiratory protectionprogram must be utilized by the company and bein accordance with OSHA regulation 29 CFR1910.134.16 Under the NIOSH respirator usepolicy for protection against carcinogens, NIOSHrecommends respirators based on the followingselection criterion:

Assigned protection factor (APF) > (workplaceairborne concentration/NIOSH REL)

This selection criteria only applies to respiratorsused in a proper respirator program under thesupervision of a properly trained respiratorprogram administrator. Respirators used without

Health Hazard Evaluation Report No. 2003-0114-2924 Page 9

such a program with all its essential elements cannot be relied upon to protect workers.17

Each worker required to wear a respirator must bemedically evaluated and cleared by a physician towear the specific respirator before performingassigned tasks. For respirators to be effective andprotect workers from harmful exposures they mustbe selected, inspected, and maintained properly.Respirators should be inspected by the workerprior to and after each use for any defects.Respiratory protective equipment should also becleaned and disinfected after each use.Respiratory protective devices should never beworn when a satisfactory face seal can not beobtained. Many conditions may prevent a goodseal between the worker's face and the respirator.Some of these conditions include facial hair,glasses, or an unusually structured face. Allworkers required to wear a respirator must beproperly trained on the selection, use, limitations,and maintenance of the respirator and also befit–tested to assure a proper seal between theworkers face and the respirator prior to performingwork tasks in a contaminated area. A recentarticle [Campbell, D.L. et al. 2001], recommendsto purchase only respirators with good fittingcharacteristics (h $ 0.95) and then carefullyconduct fit-test on individual workers.18 Allworkers should receive annual fit–testing with aquantitative testing device. When not in use,respirators must be stored in a clean environmentlocated away from any source of contamination.

During our evaluation, we observed workerseating, drinking, and smoking in the productionareas of the plant. These activities should berestricted to designated areas away fromcontaminants in the shop to reduce potentialsecondary exposures. Additionally, workersshould also change out of contaminated clothingand wash thoroughly to remove any contaminantsprior to eating, drinking, smoking, or leaving work(to prevent any possible contamination of vehiclesor homes). Housekeeping practices could also beimproved to reduce secondary exposures tocontaminants. Dry–sweeping in the facilitiesshould be prohibited to prevent dust frombecoming airborne which would increase workers'

exposures. Only wet clean–up methods (i.e.,mopping) or vacuuming with an approved HEPAfilter vacuum should be used during clean–upactivities. Wet clean–up methods should not beused in any area where they may cause a potentialelectrical or safety hazard.

The plant currently has a safety/ergonomics teamwhich consist of management and workerrepresentatives. This team has scheduled meetingsto address health and safety issues within theworkplace. We encourage the exchange ofconcerns and communication betweenmanagement officials and worker representativeson this team. Employees should be made aware ofworkplace health and safety concerns anddecisions made by facility managers to addressthose concerns. Any employees with work-relatedhealth concerns should be encouraged to reportthese concerns to the safety/ergonomics teamrepresentatives.

During our evaluation, NIOSH representativesobserved workers loading stainless steel pipes ona truck at a distance of approximately 10-14 feetoff the ground without fall protection. OSHAregulation 1910.23©)(1) states “every open-sidedfloor or platform 4 feet or more above adjacentfloor or ground level shall be guarded by astandard railing (or the equivalent as specified inparagraph (e)(3) of this section) on all open sidesexcept where there is entrance to a ramp, stairway,or fixed ladder.”19

Seven of 23 (30%) interviewed employeesreported current upper respiratory or mucousmembrane irritation related to work. Weldingfumes, acid vapors from the pickling tank, generalplant dust, and general plant ventilation couldcontribute to these symptoms.

While we did not receive any specific informationto suggest that there is an excess of cancer amongcurrent or former employees at Felker Brothers,some general information on cancer and how welook at cancer in workplaces is provided in thefollowing paragraphs.

Page 10 Health Hazard Evaluation Report No. 2003-0114-2924

Cancer is a group of different diseases thathave the same feature, the uncontrolledgrowth and spread of abnormal cells. Eachdifferent type of cancer may have its own setof causes. Cancer is common in the UnitedStates. One of every four deaths in the UnitedStates is from cancer. Among adults, canceris more frequent among men than women, andis more frequent with increasing age. Manyfactors play a role in the development ofcancer. The importance of these factors isdifferent for different types of cancer. Mostcancers are caused by a combination ofseveral factors. Some of the factors include:(a) personal characteristics such as age, sex,and race, (b) family history of cancer, ©) diet,(d) personal habits such as cigarette smokingand alcohol consumption, (e) the presence ofcertain medical conditions, (f) exposure tocancer-causing agents in the environment, and(g) exposure to cancer-causing agents in theworkplace. In many cases, these factors mayact together or in sequence to cause cancer.Although some causes of some types ofcancer are known, we don't know everythingabout the causes of cancer.

When cancer in a workplace is described, it isimportant to learn whether the type of canceris a primary cancer or a metastasis (spread ofthe primary cancer into other organs). Onlyprimary cancers are used to investigatecancers.

Because cancer is a common disease, cancercan be found among people at any workplace.In the United States, one in two men and onein three women will develop cancer over thecourse of their lifetimes. These figures showthe unfortunate reality that cancer occurs moreoften than many people realize. When severalcases of cancer occur in a workplace they maybe part of a true cluster when the number isgreater than we expect compared to othergroups of people similar with regard to age,sex, and race. Disease or tumor rates,however, are highly variable in smallpopulations and rarely match the overall ratefor a larger area, such as the state, so that for

any given time period some populations haverates above the overall rate and other haverates below the overall rate. So, even whenthere is an excess, this may be completelyconsistent with the expected randomvariability. In addition, calculations like thismake many assumptions, which may not beappropriate for every workplace. Comparingrates without adjusting for age, sex, or otherpopulation characteristics assumes that suchcharacteristics are the same in the workplaceas in the larger population, which may not betrue.

The relationship between some agents andcertain cancers has been well established. Forother agents and cancers, there is a suspicionbut the evidence is not definitive. When aknown or suspected cancer-causing agent ispresent and the types of cancer occurring havebeen linked with these exposures in othersettings, we are more likely to make theconnection between cancer and a workplaceexposure. Although the potential for exposureto nickel and chromium exists, at the time ofour evaluation the types of cancers linked toexposure to these substances (i.e., lung andnasal)20,21, have not been reported amongcurrent or former employees of FelkerBrothers.

The time between first exposure to acancer-causing agent and clinical recognitionof the disease is called the latency period.Latency periods vary by cancer type, butusually are 15 to 20 years, or longer. Forexample, it can take up to 30 years afterexposure to asbestos for mesothelioma todevelop. This means that past exposures,which can be very difficult to assess, are morerelevant to current cancer cases than arecurrent exposures.

RECOMMENDATIONS1. The highest exposures occurred during weldingoperations inside stainless steel pipes, and whenwelding fins on stainless steel pipes in department

Health Hazard Evaluation Report No. 2003-0114-2924 Page 11

1. NIOSH [1994]. Cassinelli, M.E. &O'Connor, P.F., Eds. NIOSH manual of analyticalmethods. 4th ed. U.S. Department of Health andHuman Services, Public Health Service, Centersfor Disease Control, National Institute forOccupational Safety and Health, DHHS (NIOSH)Publication No. 94–113.

2. NIOSH [1992]. Recommendations foroccupational safety and health: compendium ofpolicy documents and statements. Cincinnati, OH:U.S. Department of Health and Human Services,Public Health Service, Centers for Disease Controland Prevention, National Institute forOccupational Safety and Health, DHHS (NIOSH)Publication No. 92-100.

3. ACGIH [2003]. 2003 TLVs® and BEIs®:threshold limit values for chemical substances andphysical agents. Cincinnati, OH: AmericanConference of Governmental IndustrialHygienists.

4. CFR [1997]. 29 CFR 1910.1000. Code ofFederal Regulations. Washington, DC: U.S.Government Printing Office, Office of the FederalRegister.

5. Hathaway G et al, eds. [1991]. Proctor andHughes' chemical hazards of the workplace, 3rd

206. Local exhaust ventilation systems to controlworker exposures should be a priority for theseoperations. A welding ventilation movableexhaust hood system could be used to capture thecontaminants generated during weldingoperations.

Other recommendations for possible LEV systemsto control emissions from welding and cuttingoperations are provided in the ACGIH VentilationManual (pages 10-148 through 10-154).15 Anyventilation system must be designed to meet fire,safety, or environmental codes that apply to thisfacility and operations.

2. Frequent maintenance should be performed ona regular basis to remove material thataccumulates in the cybermation downdraft hood.Personal monitoring should be conducted tocharacterize worker exposures during themaintenance activities. Personnel performingthese maintenance operations should be providedwith appropriate controls or personal protectionequipment to protect them from exposures.

3. After engineering controls have been installed,worker exposures should be re-evaluated todetermine if controls are effectively reducingelement (e.g., CrVI, nickel, and manganese) andozone concentrations below occupationalevaluation criteria. Worker exposures should alsobe re-evaluated after any process changes in thefacilities to determine the level of exposures undernew conditions.

4. Eating, drinking, or smoking should not beallowed in work areas. Workers should alsochange out of contaminated clothing and washthoroughly to remove any contaminants prior toeating, drinking, smoking, or leaving work (toprevent any possible contamination of vehicles orhomes).

5. The plant’s safety/ergonomics team whichconsists of management and workerrepresentatives should continue scheduledmeetings to address health and safety issues withinthe workplace. Employees with work-relatedhealth concerns should be encouraged to report

these concerns to the safety/ergonomics teamrepresentatives.

6. Housekeeping practices should be improved toreduce secondary exposures to contaminants.Dry–sweeping in the facilities should beprohibited. Wet clean–up methods (i.e., mopping)or vacuuming with an approved HEPA filtervacuum should be utilized during clean–upactivities. Wet clean–up methods should not beused in any area where they may cause a potentialelectrical or safety hazard.

7. OSHA regulations that pertain to fall protectionin this industry must be followed to protectworkers from potential fall hazards.

REFERENCES

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ed. New York, NY: Van Nostrand Reinhold.

6. NIOSH [1997]. NIOSH Pocket Guide toChemical Hazards, Cincinnati, OH: U.S.Department of Health and Human Services, PublicHealth Service, Centers for Disease Control andPrevention, National Institute for OccupationalSafety and Health, DHHS (NIOSH) PublicationNo. 97–140.

7. IARC [1985]. IARC Monographs on theevaluation of the carcinogenic risk of chemicals tohumans. Tobacco Smoking. Volume 38. Lyon:World Health Organization. [International Agencyfor research on Cancer.]

8. ACGIH [1991]. Nickel and InorganicCompounds. In: Documentation of the thresholdlimit values and biological exposure indices, Sixthed. Cincinnati, OH: American Conference ofGovernmental Industrial Hygienists, Inc, BEI–69.

9. NIOSH [1981]. Occupational healthguidelines for chemical hazards. Cincinnati, OH:U.S. Department of Health and Human Services,Public Health Service, Centers for DiseaseControl, National Institute for Occupational Safetyand Health, DHHS (NIOSH)/DOL (OSHA)Publication No. 81–123 and supplements 88–118,89–104.

10. Karen E. Stine and Thomas M. Brown.[1996]. Principles of Toxicology, LewisPublishers, CRC Press, Inc. Boca Raton, Florida.page 206.

11. WHO [1981]. Environmental Health Criteria17: Manganese. Geneva, Switzerland. WorldHealth Organization.

12. Tanaka S [1993]. Manganese and itscompounds. In: Zenz C, Dickerson OB, HorvathE (eds.). Occupational medicine: Principles andpractical applications, 3rd ed. Chicago: YearBook Medical Publishers, Inc.

13. Mena I, Horiuchi K, Burke K, Cotzias GC[1969]. Chronic manganese poisoning: individualsusceptibility and absorption of iron. Neurology19:1000-1006.

14. NIOSH [1988]. NIOSH testimony onOSHA's proposed rule on air contaminants.Compendium of policy documents and statements.Cincinnati, OH: U.S. Department of Health andHuman Services, Public Health Service, Centersfor Disease Control, National Institute forOccupational Safety and Health, NTIS No.PB-90-115-337.

15. ACGIH [2001]: Industrial Ventilation, AManual of Recommended Practice, 24th edition.Cincinnati, OH: American Conference ofGovernmental Industrial Hygienists.

16. CFR [1996]. 29 CFR 1910.134. Code ofFederal regulations. Washington, DC: U.S.Government Printing Office, Office of the FederalRegister.

17. NIOSH [1997]. NIOSH Respirator UsePolicy for Protection Against Carcinogens. U.S.Department of Health and Human Services, PublicHealth Service, Centers for Disease Control andPrevention, National Institute for OccupationalSafety and Health, RUP 1.0.

18. Campbell DL, Coffey CC, Lenhart SW[2001]. Respiratory Protection as a Function ofRespirator Fitting Characteristics and Fit-TestAccuracy. Am Ind Hyg Assoc J 62:36-44.

19. CFR [1996]. 29 CFR 1910.23. Walking-Working Surfaces. Code of Federalregulations. Washington, DC: U.S. GovernmentPrinting Office, Office of the Federal Register.

20. Sjogren B, Hansen KS, Kjuus H, Persson P[1994]. Exposure to stainless steel welding fumesand lung cancer; a meta-analysis. Occup EnvironMed 51:335-336.

21. Grimsrud TK, Berge SR, Haldorsen T,Andersen A [2002]. Exposure to Different Formsof Nickel and Risk of Lung Cancer. Am JEpidemiol 156:1123-1132.

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Page 14 Health Hazard Evaluation Report No. 2003-0114-2924

Table 1Personal Breathing Zone (PBZ) sample results for nickel, chromium, and manganese

HETA 2003-0144-2924 Felker Brothers Corporation

SampleNumber

Task/Location Nickel (mg/m3) Chromium (mg/m3)

Manganese(mg/m3)

SampleTime

(minutes)

343 &355

Burner operations TWA = 0.032 TWA = 0.072 TWA = 0.042 Total Time(n=2) 277

327 Depot Facility 0.0197 0.034 0.01 415

382 &378

Department 206Welding/Grindinginside pipe

TWA = 0.122 TWA = 0.26 TWA = 0.34 Total Time(n=2) 443

400&375

Department 206Welding/Grindinginside pipe

TWA = 0.15 TWA = 0.36 TWA= 0.32 Total Time(n=2) 439

389 &394

Department 206Welding/GrindingFins on pipe

TWA = 0.16 TWA = 0.36 TWA = 0.31 Total Time(n=2) 423

383 Machineoperator (anglerings)

0.015 0.03 0.009 432

371 Utility WorkerDepartment 108

0.017 0.032 0.007 407

381 Department 206cutting/welding/grinding

0.018 0.04 0.029 278

344 &334

Department 206cutting/welding/grinding

0.021 0.043 0.015 Total Time(n=2) 448

345 &372

Fabricator 0.052 0.087 0.042 Total Time(n=2) 415

342 &332

Fabricator 0.156 0.24 0.08 Total Time(n=2) 416

360 Grinding/Oven 0.045 0.066 0.013 287

TWA = Time Weighted Average (based on total sample time)mg/m3 = milligrams per cubic meter

Table 2Personal Breathing Zone (PBZ) sample results for Hexavalent Chromium(CrVI) exceeding

NIOSH REL HETA 2003-0144 -2924

Felker Brothers Corporation

SampleNumber

Worker Task/Location CrVI Concentration(mg/m3)

Sample Time(minutes)

HC26 &HC28

Department 206Welding/Grinding inside pipe

TWA = 0.005 Total Time = 443(n=2)

HC27 &HC29

Department 206Welding/Grinding inside pipe

TWA = 0.02 Total Time = 439(n=2)

HC38 &HC33

Department 206Welding/Grinding Fins onpipe

TWA = 0.02 Total Time = 423(n=2)

HC70 &HC68

Fabrication Fitter TWA = 0.008 Total Time = 416(n=2)

HC73 &HC64

Assembly/Tack Welder TWA = 0.001 Total Time = 424(n=2)

HC23 &HC66

Fabrication Fitter TWA = 0.004 Total Time = 415(n=2)

HC35 &HC67

Burner TWA = 0.003 Total Time = 277(n=2)

HC13 Fabrication Fitter 0.0016 408

HC36 Department 203Header Line Welding

0.002 421

HC22 Grinding/Oven 0.001 287

TWA = Time Weighted Average (based on total sample time) mg/m3 = milligrams per cubic meter

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