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September 4, 201 4 Mr. Bob Johnson ACME Printing Corporation, Inc. 100 Main Street Happy Valley, Washington 70001 SUBJECT: ANNUAL AIR SAMPLING SURVEY Dear Mr. Johnson : The subject report is attached and discusses the results of the air sampling survey that I conducted on July 23rd at the ACME Printing Corporation facility in Happy Valley , WS . The purpose of the survey was to evaluate personal exposure s to select components of commonly used chemicals associated with the ACME printing process . An additio nal sample was collected to assess ambient concentrations of ozone. A discussion of relevant exposure limits is included. If you have any comments or questions, call me at 720 /123 -4567 . Thank you. Signature Here Sam “IH” Sampler Industrial Hygienist 12 34 1 st Street Gilbert, WS 70002 720 /123 -4567 2012 ANNUAL AIR SAMPLING REPORT A CME Printing Corporation, Inc. September 4, 201 4 Sampling Conducted By: Sam “IH” Sampler Industrial Hygienist 1234 1 st Street Gilbert, WS 70002 720 /123 -4567 EXECUTIVE SUMMARY ACME Printing Corporation has had an active air -sampling program in place for several years. Air sampling was conducted to assess personal exposures to select components of commonly used chemicals associated with t he printing process . An additional sample was collected to assess ambient concentrations of ozone. A total of f ive personal samples were collected and analyzed for ink components; one are a sample w as collected and analyzed for ozone . Sampling was conducted in accordance with established procedures with results being compared to two relevant exposure limits. Personal samples ranged from 14.8 - 59.0 % of the calculated additive Permissible Exposure Limit (i.e. , n-propanol and n-propyl acetate combined). The re sults are in general agreement with samples taken in previous years. The area sample result for ozone was deemed insignificant after it was determined that the lamination process was non -operational the day of the study. Reco mmendations are made to share results with affected personnel, continue the annual sampling survey, and conduct another ozone study. BACKGROUND The printing industry uses a variety of inks, solvents , and adhesives that have chemical constituents deemed hazardous according to definition s established by the Occupational Safety and Health Administration (OSHA). Federal regulations require employers to evaluate employee exposures to select substance s and assure that airborne concentrations do not exceed eight -hour, time -weighted average s kn own as Permissible Exposure Limits (PELs). Employee exposures below PELs are not expected to cause adverse health effects in a majority of a healthy working population. To evaluate exposures, ACME Printing has been conducting air sampling on an annual bas is for several years. Previous year’s results have generally shown personal sampling results at or below 50 % of the applicable PEL. Are a samples in high traffic areas near production units have shown levels below P EL s. Additional process -specific studies h ave also been conducted and have shown localized areas where ambient concentrations exceed the applicable PEL. However, given the highly variable nature of work activities, workers do not occupy these areas for enough time to reach the PEL. Finally, air -sa mpling surveys have been conducted that characterize short -duration, potentially high -exposure activities . These studies showed ambient vapor concentrations near the associated OSHA short -term exposure limit but concluded that the infrequent nature of the activity and the “worst case” design used for the study resulted in low worker exposure potential. CHEMICAL HAZARDS & EXPOSURE POTENTIAL A review of current chemical usage shows that inks and adhesives are two of the most commonly used chemical material s across the plant. A review of the Safety Data Sheets (SDSs) for a typical ink and adhesive used shows two primary ingredients: n -propyl alcohol (n -propanol) and n - propyl acetate. A brief hazard review and exposure assessment is as follows: Chemical Nam e CAS# Primary Route(s) of Exposure Health Hazard Exposure Potential n-propyl alcohol 71 -23 -8 inhalation, dermal absorption irritation eyes, nose, throat; dry cracking skin; drowsiness, headache; ataxia, gastrointestinal pain; abdominal cramps, nausea, vo miting, diarrhea chemical used daily; inhalation is likely based on usage; skin contact is minimized via use of gloves n-propyl acetate 109 -60 -4 inhalation, dermal absorption irritation eyes, nose, throat; narcosis; dermatitis chemical used daily; inhalat ion is likely based on usage; skin contact is minimized via use of gloves Centers for Disease Control (2011) National Institute for Occupational Safety and Health (NIOSH) Pocket Guide . Retrieved f http://www.cdc .gov/niosh/npg To evaluate exposure potential, ACME Printing Corporation has been conducting air sampling on an annual basis for several years. Previous year’s results have generally shown personal sampling results at or below 50% of the applicable PEL. Several other exposure studies have been conducted on a process -specific basis and have also documented low worker exposure potential. However, given the variable nature of the business, ACME Printing Corporation has taken a prudent approach of documenting worker exposures on an annual basis. SAMPLING STRATEGY A sampling strategy was devised in consultation with the Plant Director . In addition to the organic constituents routinely included in past annual surveys, an area sample was collected for ozone. Ozone is a by -product of the lamination process and has been of interest to plant personnel recently. The following samples were collected for this year’s study: Personal Sample – Josh, W&H 3 - n-propanol, n -propyl acetate Personal Sample – Jake , W&H 2 - n-propanol, n -propyl acetate Personal Sample – Percy, Vision - n-propanol, n -propyl acetate Personal Sample – Mike, Pre -Press - n-propanol, n -propyl acetate Personal Sample – Ronnie, W&H 3 – n-propanol, n -propyl acetate Area Sample – Laminator Work Station - ozone SAMPLING METHOD OLOGY A total of five personal air samples and one area sample were collected. Air sampling was conducted using a sampling pump and appropriate charcoal tubes provided by the analytical lab contracted for the project . Pumps were ope rated for as close to a full shift as possible with a flow rate that ensured collection of the necessary air volume stated in the analytical method established by the National Institute for Occupational Safety and Health (NIOSH). All pumps were pre - and po st-calibrated to en sure accurate airflow rates. Personal samples were placed in the breathing zone of the employee with the sampling charcoal tube being attached to the lapel ; the area sample was placed in a location where employees are expected to spend most t heir time . Sampling media was sent for analysis to a laboratory accredited by the American Industrial Hygiene Association (AIHA). SAMPLING RESULTS Attachment A contains Table s 1-6 that summarize the sampling results . All personal monitoring results were compared to the applicable PEL. For n -propyl alcohol and n -propyl acetate , an additive formula method was used . Since both materials have similar potential adverse health effects (e.g. , both affect the central nervous system), it is acceptable to consider exposure to each in an additive fashion (see data tables for specific calculations). Table 1 shows personal air sampling results for Josh, W&H 2. This sample showed an ambient concentration of n -propanol of 47.0 parts per million (ppm) and 14.0 ppm of n -propyl acetate . The additive percentage of the PEL is 30.5 %. Table 2 shows personal air sampling results for Jake , W&H 2. This sample showed an ambient concentration of n-propanol of 64.0 parts per million (ppm) and 26.0 ppm of n -propyl acetate. The additi ve percentage of the PEL is 40 .0%. Table 3 shows personal air sampling results for Percy, Vision . This sample showed an ambient concentration of n-propanol of 23.0 parts per million (ppm) and 6.5 ppm of n -propyl acetate. The additive percentage of the PEL is 14.8% . Table 4 shows personal air sampling results for Mike, Pre -Press. This sample showed an ambient concentration of n -propanol of 32.0 parts per million (ppm) and 10.0 ppm of n -propyl acetate. The additive percentage of the PEL is 21.0%. Table 5 s hows personal air sampling results for Ronnie, W&H 3. This sample showed an ambient concentration of n -propanol of 91.0 parts per million (ppm) and 27.0 ppm of n -propyl acetate. The additive percentage of the PEL is 59.0%. Table 6 shows area sampling for the sample taken at the laminator work station. This sample showed an ambient concentration of ozone of <0.013 ppm which is 2.5% of the PEL. DISCUSSION & RECOMMENDATIONS All personal samples are below their respective PELs and in general agreement with the range of personal exposures measured in previous years. Although ACME Printing continues to be in compliance with OSHA regulations, it is a best management practice to keep employee exposures below 50% of the relevant PEL. Accordingly, A CME Printing sh ould continue to conduct annual sampling and periodically assess any trends associated with exposures (i.e. , are exposures regularly exceeding 50% of the PEL). Recommendations are as follows: 1) Share sampling information with employees. ACME Printing has a strong record of sharing monitoring results with affected employees. Employees are well versed in the meaning of sampling and employee exposure results. 2) Continue the annual air -sampling program. Day to day operations can change and may impact exposure pot ential to employees. It is prudent to conduct regular air sampling even though ACME Printing is full compliance with OSHA regulations. 3) Conduct a separate study to evaluate ozone concentrations . It is unfortunate that the lamination unit did not end up run ning on the day of sampling. A separate study should be conducted to fully evaluate ambient ozone concentrations. ATTACHMENT A PERSONAL & AREA SAMPLE DATA TABLES 1 -6 TABLE 1 - PERSONAL AIR SAMPLING RESULTS Josh W&H 2 ACME Pri nting Corporation, Inc. Sampling Date: July 23, 201 4 Sampling Conducted by: Sam “IH” Sampler NOTES: 1) Abbreviations : ppm = part of analyte per million parts of air OSHA = Occupational Safety & Health Administration PEL = Permissible Exposure Limit % PEL = what percent the measured concentration is of the PEL 2) Definitions : PEL - legally enfor ceable, 8 -hour, time -weighted average concentrations allowed during a work shift; concentrations below OSHA PEL are not expected to cause adverse health effects in the majority of workers. 3) Additive Formula Calculation: “*” = % PEL calculated using OSH A additive formula: (concentration of contaminant 1 divided by OSHA PEL for contaminant 1) + (concentration of contaminant 2 divided by OSHA PEL for contaminant 2): (n -propanol: 47.0/200) + (n -propyl acetate: 14.0/200) = 23.5 + 7.0 = 30.5 LOCATION SAMPLE TYPE ANALYTE RESULT (ppm) OSHA PEL (ppm) (% PEL)* >PEL? Josh W&H 2 Personal n-Propanol 47.0 200 (30.5) No n-Propyl Acetate 14.0 200 TABLE 2 - PE RSONAL AIR SAMPLING RESULTS Jake W&H 2 ACME Printing Corporation, Inc. Sampling Date: July 23, 2014 Sampling Conducted by: Sam “IH” Sampler NOTES: 1) Abbreviations : ppm = part of analyte per million parts of air OSHA = Occupational Safety & Health Administration PEL = Permissible Exposure Limit % PEL = what percent the measured concentration is of the PEL 2) Definitions : PEL - legally enforceable, 8 -hour, time -weighted average concentrations allowed during a work shift; concentrations below OSHA PEL are not expected to cause adverse health effects in the majority of workers. 3) Additive Formu la Calculation: “*” = % PEL calculated using OSHA additive formula: (concentration of contaminant 1 divided by OSHA PEL for contaminant 1) + (concentration of contaminant 2 divided by OSHA PEL for contaminant 2): (n -propanol: 64.0/200) + (n -propyl acetat e: 16.0/200) = 32.0 + 8.0 = 40.0 LOCATION SAMPLE TYPE ANALYTE RESULT (ppm) OSHA PEL (ppm) (% PEL)* >PEL? Jake W&H 2 Personal n-Propanol 64.0 200 (40.0) No n-Propyl Acetate 16.0 200 TABLE 3 - PERSONAL AIR SAMPLING RESULTS Percy Vision ACME Printing Corporation, Inc. Sampling Date: July 2 3, 201 4 Sampling Conducted by: Sam “IH” Sampler NOTES: 1) Abbreviations : ppm = part of analyte per million parts of air OSHA = Occupational Safety & Health Administration PEL = Permissible Exposure Limit % PEL = what percent the measured concentration is of the PEL 2) Definitions : PEL - legally enforceable, 8 -hour, time -weighted average concentrations allowed during a work shift; concentrations below OSHA PEL are not expected to cause adverse health eff ects in the majority of workers. 3) Additive Formula Calculation: “*” = % PEL calculated using OSHA additive formula: (concentration of contaminant 1 divided by OSHA PEL for contaminant 1) + (concentration of contaminant 2 divided by OSHA PEL for contami nant 2): (n -propanol: 23.0/200) + (n -propyl acetate: 6.5/200) = 11.5 + 3.3 = 35.7 LOCATION SAMPLE TYPE ANALYTE RESULT (ppm) OSHA PEL (ppm) (% PEL)* >PEL? Percy Vision Personal n-Propanol 23.0 200 (35.7) No n-Propyl Acetate 6.5 200 TABLE 4 - PERSONAL AIR SAMPLING RESULTS Mike Pre -Press ACME Printing Corpora tion, Inc. Sampling Dates: July 2 3, 201 4 Sampling Conducted by: Sam “IH” Sampler NOTES: 1) Abbreviations : ppm = part of analyte per million parts of air OSHA = Occupational Safety & Health Administration PEL = Permissible Exposure Limit % PEL = what percent the measured concentration is of the PEL 2) Definitions : PEL - legally enforceable, 8 -hour, time -weighted average concentrations allowed during a work shift; concentrations belo w OSHA PEL are not expected to cause adverse health effects in the majority of workers. 3) Additive Formula Calculation: “*” = % PEL calculated using OSHA additive formula: (concentration of contaminant 1 divided by OSHA PEL for contaminant 1) + (concent ration of contaminant 2 divided by OSHA PEL for contaminant 2): (n -propanol: 32.0/200) + (n -propyl acetate: 10.0/200) = 16.0 + 5.0 = 21.0 LOCATIO N SAMPLE TYPE ANALYTE RESULT (ppm) OSHA PEL (ppm) (% PEL)* >PEL? Mike Pre -Press Personal n-Propanol 32.0 200 (21.0) No n-Propyl Acetate 10.0 200 TABLE 5 - PERSONAL AIR SAMPLING RESULTS Ronnie W&H 3 ACME Printing C orporation, Inc. Sampling Date: July 23, 20 14 Sampling Conducted by: Sam “IH” Sampler NOTES: 1) Abbreviations : ppm = part of analyte per million parts of air OSHA = Occupational Safety & Health Administration PEL = Permissible Exposure Limit % PEL = what percent the measured concentration is of the PEL 2) Definitions : PEL - legally enforceable, 8 -hour, time -weighted average concentra tions allowed during a work shift; concentrations below OSHA PEL are not expected to cause adverse health effects in the majority of workers. 3) Additive Formula Calculation: “*” = % PEL calculated using OSHA additive formula: (concentration of contamin ant 1 divided by OSHA PEL for contaminant 1) + (concentration of contaminant 2 divided by OSHA PEL for contaminant 2): (n -propanol: 91.0/200) + (n -propyl acetate: 27.0/200) = 45.5 + 13.5 = 59.0 LOCATION SAMPLE TYPE ANALYTE RESULT (ppm) OSHA PEL (ppm) (% PEL)* >PEL? Ronnie W&H 3 Personal n-Propanol 91.0 200 (59.0) Yes n-Propyl Acetate 27.0 200 TABLE 6 - AREA SAMPLING RESULTS Area Sample Laminator Wor k Station ACME Printing Corporation, Inc. Sampling Date: July 2 3, 201 4 Sampling Conducted by: Sam “IH” Sampler NOTES : 1) Abbreviations : ppm = part of analyte per million parts of air OSHA = Occupational Safety & Health Administration PEL = Permissible Exposure Limit % PEL = what percent the measured concentration is of the PEL 2) Definitions : PEL - legally enforcea ble, 8 -hour, time -weighted average concentrations allowed during a work shift; OSHA PEL are not expected to cause adverse health effects in the majority of workers. 3) NOTE : It was determined after sampling that the laminator unit was not operational on t he day of sampling. Accordingly, the above data is of no significance from an exposure perspective. LOCATION SAMPLE TYPE ANALYTE RESULT (ppm) OSHA PEL (ppm) (% PEL) >PEL? Laminator Work Station Area Ozone <0.013 0.1 (<1.25) No