Occupational & Environmental Medicine for Clinicians & Public Health Professionals

“Both OSHA and BP misinterpret their air sampling to mean that the air in the Gulf is safe for all workers, everywhere, at all times.”

“Life and death decisions, including whether or not cleanup workers get respirators, are being made on the basis of air sampling in the Gulf spill. Therefore, we must hold OSHA and BP sampling to the standards laid out by NIOSH on July 2 in Chemical Exposure Assessment Considerations for Use in Evaluating Deepwater Horizon Response Workers and Volunteers.”

Eileen Senn, MS
July 15, 2010
 
OSHA and BP continue their steady stream of sweeping reassurances that the air in the Gulf poses no health hazard to Gulf cleanup workers. Their reassurances are based in large part on their measurements of workers’ personal exposures to chemicals. I find both OSHA’s and BP’s worker chemical exposure air sampling data to be incomplete, unrepresentative, poorly documented, untimely, and misinterpreted.

Potential chemical exposure sources in the Gulf include 1.5 to 2.5 million gallons of fresh crude each day, over 150 million gallons of crude in various stages of weathering, 22,000 gallons of fresh dispersant each day, 2 million gallons of dispersant used cumulatively, combustion products from burning 10 million gallons of crude, engine and vehicle fuel and exhaust, and detergents and cleaning products. OSHA and BP have not evaluated anticipated offshore worker personal exposures to respirable particulates, heavy metals, toxic gases, sulfur compounds, aldehydes, and Polycyclic Aromatic Hydrocarbons (PAHs).

OSHA Sampling Far From Spill

OSHA is air sampling onshore and nearshore for sixteen cleanup tasks with high potential for dermal exposure but low potential for airborne exposure. Fourteen of these tasks were designated for no respiratory protection from the outset. Sampling far from the spill, OSHA has found only a handful of workers with detectable personal exposures. Ninety-nine percent of OSHA’s reported sampling has been below detection limits.

Note: Personal air sampling evaluates the air near a worker’s nose and mouth. It is distinct from area air sampling, which is a screening tool. Dermal exposure is best evaluated not by air sampling but by visual observation of workers for activities that may cause chemicals to contact their eyes, skin, hair, gloves, shoes, or clothing.

Too Few Chemicals Sampled

In their summaries covering April 27 to June 1, 2010, BP reported sampling results for two specific chemicals – benzene and 2-butoxy ethanol, plus total hydrocarbons as a group. In July, BP reported personal sampling results for June for three additional specific chemicals –ethyl benzene, toluene, and xylene. This doesn’t come close to being a complete list of chemicals in the Gulf. The vast majority of OSHA sampling has been for the same chemicals as BP plus cyclohexane and trimethybenzene.

Too Few Locations and Workers Sampled

OSHA has collected about 1,000 personal samples and BP about 7,000. BP’s data does not provide locations, dates, or times for samples so we don’t know how many specific locations or workers they have sampled. Until May 30, BP reported only offshore data. They now report offshore, nearshore, and onshore/beach data.

OSHA has reported personal sampling in about thirty locations onshore and nearshore on about ten days between May 27 and June 22.  We can’t easily tell how many workers have worn OSHA personal samplers from the way the data is presented, but I estimate about 100.

By comparison, there are 46,000 workers operating 121 aircraft and 6,850 vessels, including 2,710 Vessels of Opportunity, 530 barges, 580 skimmers, and 3,020 other vessels involved in the response Workers, vessels, and aircraft are on the move in an area one-third the size of Texas and on approximately 484 miles of Gulf Coast shoreline that is currently oiled—approximately 287 miles in Louisiana, 71 miles in Mississippi, 62 miles in Alabama, and 86 miles in Florida.

In addition, no two days in the Gulf thus far are likely to have been identical in terms of exposure variables, necessitating many samples every day.

Sampling Poorly Documented

BP and OSHA provide inadequate supporting information on sampled workers although OSHA does a better job than BP. Missing information includes cleanup tasks being performed, equipment and machinery being used, worker locations relative to sources of chemicals, and duration of hours in the exposure environment, either worked or off duty, for example, such as sleeping onboard a vessel.  BP and OSHA both fail to provide relevant weather variables. BP fails to provide sampling and analytical methods.

Worst Exposures Not Sampled

BP and OSHA don’t provide enough information to show that the worst worker exposures have been sampled, or even typical exposures. BP and OSHA don’t make that claim or give any indication of how representative their sampling is of worker exposures. I suspect OSHA doesn’t know and BP doesn’t want to say.

Data Untimely

BP and OSHA both have a week or two gap between sample collection and reporting. BP has only provided five summaries in three months and they have become less and less frequent: May 20, 24, and 30, June 9, and July 6.

Data Misinterpreted

Both OSHA and BP misinterpret their air sampling to mean that the air in the Gulf is safe for all workers, everywhere, at all times.

Neither BP nor OSHA provides a narrative explanation and interpretation of their own sampling results, leaving stakeholders to try to figure it out for themselves. BP reports ambiguous ranges of results which often encompass levels both above and below exposure limits. BP invites misinterpretation of its data as a “Clean Bill of Health” by failing to make comparisons with the most protective occupational exposure limits. BP also fails to calculate and present additive exposures to chemicals when comparing sampling results with exposure limits.

BP Data Shows Potentially Dangerous Exposures

Despite its shortcomings, BP’s data for April 27 to June 29, 2010 shows:

· 10 benzene samples above the NIOSH REL of 0.1 ppm, potentially 5 times above

· Up to 210 2-butoxy ethanol samples potentially 2 times above the NIOSH REL of 5 ppm

· Up to 267 ethyl benzene samples potentially 5 times above the proposed ACGIH TLV of 20 ppm

· Up to 463 toluene samples potentially 5 times above the ACGIH TLV of 20 ppm

BP has removed 179 2-butoxy ethanol samples from the July 6 summary, compared to the June 9 BP summary, which showed 43 samples on beaches – potentially double the NIOSH REL of 5 ppm.

Total Hydrocarbon Evaluation Criteria Bogus

One key to the success of the BP air sampling in misinterpreting data and keeping the use of respirators to a minimum is the lenient criteria used to evaluate measurements of total hydrocarbons. BP attempts to justify their 100 ppm total hydrocarbon action level in their July sampling summary:

Fresh crude oil and weathered crude oil are comprised of a wide range of hydrocarbons including aliphatic and aromatic hydrocarbons. These combinations of hydrocarbons when sampled together are referred to as “total hydrocarbons”. When monitored in combination in this manner, this analysis provides an indication of whether one or more particular hydrocarbon constituents may be elevated. If the total hydrocarbon analytical result is sufficiently low, that provides assurance that the individual constituents are also present at only low levels. Although there is no official occupational exposure limit for total hydrocarbons, BP has adopted its own internal guideline of 100 ppm as a limit which is generally considered to be a conservative level by the industrial hygiene community.

No basis for this last claim of conservatism is given. For total hydrocarbons as a group there can be no valid evaluation criteria because the identity of individual hydrocarbons present is unknown and there is no limit applicable to all the possible compounds combined. The only legitimate use of total hydrocarbon data would be to track trends over time.

Other Shortcomings

BP and OSHA both fail to provide limits of detection. I have not examined other possible technical problems with the accuracy of their data such as improper calibration, interferences, methodological errors, or invalid sampling and analytical techniques.

OSHA and BP Must Do Better

Life and death decisions, including whether or not cleanup workers get respirators, are being made on the basis of air sampling in the Gulf spill. Therefore, we must hold OSHA and BP sampling to the standards laid out by NIOSH on July 2 in Chemical Exposure Assessment Considerations for Use in Evaluating Deepwater Horizon Response Workers and Volunteers.

OSHA must provide a narrative making it clear just how limited their sampling is and likely reasons they haven’t found airborne contaminants.

BP must provide a much more detailed public summary of their air sampling results, including dates, times, specific worker locations and tasks, and sampling and analytical methods. BP must present trends in their data over time. BP must compare their data with the most protective occupational exposure limits and present additive exposures to chemicals when comparing sampling results with exposure limits. BP must stop using 100 ppm as the criterion for evaluating VOC levels. They must explain why 2-butoxy ethanol samples have been removed from summaries and when and if they will be returned.

OSHA and BP must both provide:

· Narrative qualitative exposure assessments for the Gulf spill cleanup, laying the basis for their air sampling plans.

· Narrative explanations of why they have sampled for specific contaminants in specific tasks and locations.

Above all, BP and OSHA must both stop proclaiming the Gulf air safe based on dangerously deficient data.

References

BP Sampling Data

BP Respirator Policy

OSHA Personal Protective Equipment Sampling Matrix

OSHA Initial Sampling Strategy

OSHA Laboratory Analysis Results by Site

OSHA Direct Reading Results by Site

OSHA Sampling Map

NIOSH Chemical Exposure Document

NIOSH/OSHA Respirator Recommendations

Table of NIOSH/OSHA Respirator Recommendations

Deepwater Horizon Response and Operations Summaries

Eileen Senn, MS
Independent Industrial Hygiene Consultant
1 Highgate Drive, Apt. 204
Ewing, NJ 08618
609-323-7237
cell 609-638-3370
eileensenn@gmail.com

U.S. Chamber of Commerce & Deceit in Mold Litigation

TRUTH OUT Sharon Kramer Letter To Andrew Saxon MOLD ISSUE

National Apartment Association Tells Its Members MOLD CAUSES DEATH; Tells Courts It Doesn’t With The Help of US Chamber and UCLA

Thank You National Apartment Association. I will do my best to get this very important information out ASAP to numerous owners, investors, huge property management companies (e.g., Riverstone Residential), attorneys, and judges, AND, of course, to the MANY people who are currently living in MOLD-INFESTED APARTMENT COMPLEXES right now! katy

FEMA Using US Chamber Fraud in Katrina Trailer Litigation; EPA, GAO & Both Isle$ of Congre$$ Turn Blind Eye$

Political Action Committee – National Apartment Association (NAA) files Amicus Brief in mold case (two infant deaths in mold filled apt – Wasatch Prop Mgmt) citing US Chamber/ACOEM ‘litigation defense report’ to disclaim health effects of indoor mold & limit financial risk for industry

New Action Committee – ACHEMMIC- Urges Transparency in EPA Policy Over Mold & Microbial Contaminants

Truth About Mold – the most up to date, accurate, and reliable information on Toxic Mold

Sociological Issues Relating to Mold: The Mold Wars

“Changes in construction methods have caused US buildings to become perfect petri dishes for mold and bacteria to flourish when water is added. Instead of warning the public and teaching physicians that the buildings were causing illness; in 2003 the US Chamber of Commerce Institute for Legal Reform, a think-tank, and a workers comp physician trade organization mass marketed an unscientific nonsequitor to the courts to disclaim the adverse health effects to stave off liability for financial stakeholders of moldy buildings. Although publicly exposed many times over the years, the deceit lingers in US courts to this very day.” Sharon Noonan Kramer

Information about Riverstone Residential, the Louisiana Housing Finance Agency, and the owners of Jefferson Lakes Apartments in Baton Rouge, Louisiana allowing tenants to be exposed to extreme amounts of toxins from molds by intentionally concealing evidence

Irrefutable evidence indicates that Riverstone Residential, Guarantee Service Team of Professionals, & plaintiffs’ attorney, J Arthur Smith III, must have agreed to exclude evidence that would have shown the owners of Jefferson Lakes Apartments & Riverstone Residential had knowledge of the severe MOLD INFESTATION at the complex before we moved in

Riverstone Residential Litigation

Mold Inspection Reports

Photos of Mold in Apartment

Attorney Malpractice

Links to Riverstone Residential Mold and Illegal Business Practice Complaints and More!