LABOR AND INDUSTRIES
[Filed June 17, 1997, 11:19 a.m.]
Preproposal statement of inquiry was filed as WSR 97-09-078 on April 22, 1997.
Title of Rule: Methylene chloride.
Purpose: methylene chloride: Chapter 296-62 WAC, General occupational health standards.
The Occupational Safety and Health Administration (OSHA) adopted a new methylene chloride standard on January 10, 1997. Methylene chloride is a highly volatile solvent used in a variety of industries including furniture refinishing, some labs in extraction procedures, in dip tanks, foam manufacturing, the printing industry, and others. This federal-final rule was published in the Federal Register Volume 62, Number 7, on January 10, 1997. The department is required by the OSHA/WISHA state plan agreement to adopt rules identical to or at-least-as-effective-as OSHA rules. The department is proposing to adopt a federal-identical standard. This standard (WAC 296-62-07470) will add additional compliance requirements since a standard did not exist previously. A summary of the rule follows:
The 8-hour permissible exposure limit will be lowered from the current WISHA PEL of 100 ppm to 25 ppm.
The short term exposure limit (STEL) will be lowered from 500 ppm to 125 ppm.
In addition, the new standard will require the following:
Exposure Monitoring. Initial and periodic air monitoring is required to determine employee exposure levels (unless already done in past year) if methylene chloride is used at workplace. Frequency of periodic monitoring depends on levels, but at least every six months if the "action limit" of 12.5 ppm is exceeded.
Methods of Compliance. Employers must use feasible engineering controls or work practices to lower or limit employee exposure to methylene chloride. Worker rotation is prohibited. Respirators are allowed, but can only be supplied-air type respirators.
Medical Surveillance. Medical surveillance is required for all employees exposed to levels of methylene chloride above the action limit (12.5 ppm) for more than thirty days a year or above the PEL for more than ten days a year.
Employee Information and Training. Employers must provide information and training to all employees who have the potential of being exposed to methylene chloride.
Statutory Authority for Adoption: Chapter 49.17 RCW.
Statute Being Implemented: RCW 49.17.040, [49.17].050, [49.17].060.
Summary: See Purpose above.
Name of Agency Personnel Responsible for Drafting: Tracy Spencer, 7273 Linderson Way, Tumwater, WA, (360) 902-5530; Implementation and Enforcement: Michael A. Silverstein, 7273 Linderson Way, Tumwater, WA, (360) 902-5495.
Name of Proponent: Department of Labor and Industries, governmental.
Rule is necessary because of federal law, Federal Register Volume 62, Number 7, dated January 10, 1997.
Explanation of Rule, its Purpose, and Anticipated Effects: See Purpose above.
Proposal does not change existing rules.
No small business economic impact statement has been prepared under chapter 19.85 RCW. Small business economic impact statements are not required because the rules are being proposed solely to comply with federal regulations (RCW 19.85.061). (Note: The federal standard, and therefore the state standard, gives small firms up to three times as long to meet some of the requirements of the standard compared to larger firms.)
Section 201, chapter 403, Laws of 1995, does not apply to this rule adoption. Significant rule-making criteria does not apply to these rule amendments because they meet the exempt criteria outlined in RCW 34.05.328 (5)(b)(iii). Significant rule-making criteria does not apply when adopting federal statutes or regulations without material change.
Hearing Location: Department of Labor and Industries Building, Auditorium, 7273 Linderson Way, Tumwater, WA, on July 22, 1997, at 9:30 a.m.
Assistance for Persons with Disabilities: Contact Linda Dausener by July 10, 1997, (360) 902-5516.
Submit Written Comments to: Tracy Spencer, Standards Manager, Division of Consultation and Compliance, P.O. Box 44620, Olympia, WA 98507-4620, by 5:00 p.m., July 29, 1997.
In addition to written comments, the department will accept comments submitted to FAX (360) 902-5529. Comments submitted by FAX must be ten pages or less.
Date of Intended Adoption: September 1, 1997.
June 17, 1997
WAC 296-62-07470 Methylene chloride. This occupational health standard establishes requirements for employers to control occupational exposure to methylene chloride (MC). Employees exposed to MC are at increased risk of developing cancer, adverse effects on the heart, central nervous system and liver, and skin or eye irritation. Exposure may occur through inhalation, by absorption through the skin, or through contact with the skin. MC is a solvent which is used in many different types of work activities, such as paint stripping, polyurethane foam manufacturing, and cleaning and degreasing. Under the requirements of subsection (4) of this section, each covered employer must make an initial determination of each employee's exposure to MC. If the employer determines that employees are exposed below the action level, the only other provisions of this section that apply are that a record must be made of the determination, the employees must receive information and training under subsection (12) of this section and, where appropriate, employees must be protected from contact with liquid MC under subsection (8) of this section.
The provisions of the MC standard are as follows:
(1) Scope and application. This section applies to all occupational exposures to methylene chloride (MC), Chemical Abstracts Service Registry Number 75-09-2, in general industry, construction and shipyard employment.
(2) Definitions. For the purposes of this section, the following definitions shall apply:
"Action level" means a concentration of airborne MC of 12.5 parts per million (ppm) calculated as an eight (8)-hour time-weighted average (TWA).
"Authorized person" means any person specifically authorized by the employer and required by work duties to be present in regulated areas, or any person entering such an area as a designated representative of employees for the purpose of exercising the right to observe monitoring and measuring procedures under subsection (4) of this section, or any other person authorized by the WISH Act or regulations issued under the act.
"Director" means the director of the department of labor and industries, or designee.
"Emergency" means any occurrence, such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment, which results, or is likely to result in an uncontrolled release of MC. If an incidental release of MC can be controlled by employees such as maintenance personnel at the time of release and in accordance with the leak/spill provisions required by subsection (6) of this section, it is not considered an emergency as defined by this standard.
"Employee exposure" means exposure to airborne MC which occurs or would occur if the employee were not using respiratory protection.
"Methylene chloride (MC)" means an organic compound with chemical formula, CH2Cl2. Its Chemical Abstracts Service Registry Number is 75-09-2. Its molecular weight is 84.9 g/mole.
"Physician or other licensed health care professional" is an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently provide or be delegated the responsibility to provide some or all of the health care services required by subsection (10) of this section.
"Regulated area" means an area, demarcated by the employer, where an employee's exposure to airborne concentrations of MC exceeds or can reasonably be expected to exceed either the 8-hour TWA PEL or the STEL.
"Symptom" means central nervous system effects such as headaches, disorientation, dizziness, fatigue, and decreased attention span; skin effects such as chapping, erythema, cracked skin, or skin burns; and cardiac effects such as chest pain or shortness of breath.
"This section" means this methylene chloride standard.
(3) Permissible exposure limits (PELs).
(a) Eight-hour time-weighted average (TWA) PEL. The employer shall ensure that no employee is exposed to an airborne concentration of MC in excess of twenty-five parts of MC per million parts of air (25 ppm) as an 8-hour TWA.
(b) Short-term exposure limit (STEL). The employer shall ensure that no employee is exposed to an airborne concentration of MC in excess of one hundred and twenty-five parts of MC per million parts of air (125 ppm) as determined over a sampling period of fifteen minutes.
(4) Exposure monitoring.
(a) Characterization of employee exposure.
(i) Where MC is present in the workplace, the employer shall determine each employee's exposure by either:
(A) Taking a personal breathing zone air sample of each employee's exposure; or
(B) Taking personal breathing zone air samples that are representative of each employee's exposure.
(ii) Representative samples. The employer may consider personal breathing zone air samples to be representative of employee exposures when they are taken as follows:
(A) 8-hour TWA PEL. The employer has taken one or more personal breathing zone air samples for at least one employee in each job classification in a work area during every work shift, and the employee sampled is expected to have the highest MC exposure.
(B) Short-term exposure limits. The employer has taken one or more personal breathing zone air samples which indicate the highest likely 15-minute exposures during such operations for at least one employee in each job classification in the work area during every work shift, and the employee sampled is expected to have the highest MC exposure.
(C) Exception. Personal breathing zone air samples taken during one work shift may be used to represent employee exposures on other work shifts where the employer can document that the tasks performed and conditions in the workplace are similar across shifts.
(iii) Accuracy of monitoring. The employer shall ensure that the methods used to perform exposure monitoring produce results that are accurate to a confidence level of 95 percent, and are:
(A) Within plus or minus 25 percent for airborne concentrations of MC above the 8-hour TWA PEL or the STEL; or
(B) Within plus or minus 35 percent for airborne concentrations of MC at or above the action level but at or below the 8-hour TWA PEL.
(b) Initial determination. Each employer whose employees are exposed to MC shall perform initial exposure monitoring to determine each affected employee's exposure, except under the following conditions:
(i) Where objective data demonstrate that MC cannot be released in the workplace in airborne concentrations at or above the action level or above the STEL. The objective data shall represent the highest MC exposures likely to occur under reasonably foreseeable conditions of processing, use, or handling. The employer shall document the objective data exemption as specified in subsection (13) of this section;
(ii) Where the employer has performed exposure monitoring within 12 months prior to December 1, and that exposure monitoring meets all other requirements of this section, and was conducted under conditions substantially equivalent to existing conditions; or
(iii) Where employees are exposed to MC on fewer than 30 days per year (e.g., on a construction site), and the employer has measurements by direct reading instruments which give immediate results (such as a detector tube) and which provide sufficient information regarding employee exposures to determine what control measures are necessary to reduce exposures to acceptable levels.
(c) Periodic monitoring. Where the initial determination shows
employee exposures at or above the action level or above the STEL, the
employer shall establish an exposure monitoring program for periodic
monitoring of employee exposure to MC in accordance with Table 1:
[Open Style:Columns Off]
Six Initial Determination Exposure Scenarios and Their
Associated Monitoring Frequencies
Exposure scenario Required monitoring activity
Below the action level and at or No 8-hour TWA or STEL monitoring required.
below the STEL.
Below the action level and above the No 8-hour TWA monitoring required; monitor STEL
STEL. exposures every three months.
At or above the action level, at or Monitor 8-hour TWA exposures every six months.
below the TWA, and at or below the STEL.
At or above the action level, at or Monitor 8-hour TWA exposures every six months
below the TWA, and above the STEL. and monitor STEL exposures every three months.
Above the TWA and at or below the Monitor 8-hour TWA exposures every three months.
Above the TWA and above the STEL. Monitor both 8-hour TWA exposures and STEL
exposures every three months.
[Open Style:Columns On]
(Note to subsection (3)(c) of this section: The employer may decrease the frequency of exposure monitoring to every six months when at least 2 consecutive measurements taken at least 7 days apart show exposures to be at or below the 8-hour TWA PEL. The employer may discontinue the periodic 8-hour TWA monitoring for employees where at least two consecutive measurements taken at least 7 days apart are below the action level. The employer may discontinue the periodic STEL monitoring for employees where at least two consecutive measurements taken at least 7 days apart are at or below the STEL.)
(d) Additional monitoring.
(i) The employer shall perform exposure monitoring when a change in workplace conditions indicates that employee exposure may have increased. Examples of situations that may require additional monitoring include changes in production, process, control equipment, or work practices, or a leak, rupture, or other breakdown.
(ii) Where exposure monitoring is performed due to a spill, leak, rupture or equipment breakdown, the employer shall clean up the MC and perform the appropriate repairs before monitoring.
(e) Employee notification of monitoring results.
(i) The employer shall, within 15 working days after the receipt of the results of any monitoring performed under this section, notify each affected employee of these results in writing, either individually or by posting of results in an appropriate location that is accessible to affected employees.
(ii) Whenever monitoring results indicate that employee exposure is above the 8-hour TWA PEL or the STEL, the employer shall describe in the written notification the corrective action being taken to reduce employee exposure to or below the 8-hour TWA PEL or STEL and the schedule for completion of this action.
(f) Observation of monitoring.
(i) Employee observation. The employer shall provide affected employees or their designated representatives an opportunity to observe any monitoring of employee exposure to MC conducted in accordance with this section.
(ii) Observation procedures. When observation of the monitoring of employee exposure to MC requires entry into an area where the use of protective clothing or equipment is required, the employer shall provide, at no cost to the observer(s), and the observer(s) shall be required to use such clothing and equipment and shall comply with all other applicable safety and health procedures.
(5) Regulated areas.
(a) The employer shall establish a regulated area wherever an employee's exposure to airborne concentrations of MC exceeds or can reasonably be expected to exceed either the 8-hour TWA PEL or the STEL.
(b) The employer shall limit access to regulated areas to authorized persons.
(c) The employer shall supply a respirator, selected in accordance with subsection (7)(c) of this section, to each person who enters a regulated area and shall require each affected employee to use that respirator whenever MC exposures are likely to exceed the 8-hour TWA PEL or STEL.
(Note to subsection (5)(c) of this section: An employer who has implemented all feasible engineering, work practice and administrative controls (as required in subsection (6) of this section), and who has established a regulated area (as required by subsection (5)(a) of this section) where MC exposure can be reliably predicted to exceed the 8-hour TWA PEL or the STEL only on certain days (for example, because of work or process schedule) would need to have affected employees use respirators in that regulated area only on those days.)
(d) The employer shall ensure that, within a regulated area, employees do not engage in nonwork activities which may increase dermal or oral MC exposure.
(e) The employer shall ensure that while employees are wearing respirators, they do not engage in activities (such as taking medication or chewing gum or tobacco) which interfere with respirator seal or performance.
(f) The employer shall demarcate regulated areas from the rest of the workplace in any manner that adequately establishes and alerts employees to the boundaries of the area and minimizes the number of authorized employees exposed to MC within the regulated area.
(g) An employer at a multi-employer worksite who establishes a regulated area shall communicate the access restrictions and locations of these areas to all other employers with work operations at that worksite.
(6) Methods of compliance.
(a) Engineering and work practice controls. The employer shall institute and maintain the effectiveness of engineering controls and work practices to reduce employee exposure to or below the PELs except to the extent that the employer can demonstrate that such controls are not feasible.
(b) Wherever the feasible engineering controls and work practices which can be instituted are not sufficient to reduce employee exposure to or below the 8-TWA PEL or STEL, the employer shall use them to reduce employee exposure to the lowest levels achievable by these controls and shall supplement them by the use of respiratory protection that complies with the requirements of subsection (7) of this section.
(c) Prohibition of rotation. The employer shall not implement a schedule of employee rotation as a means of compliance with the PELs.
(d) Leak and spill detection.
(i) The employer shall implement procedures to detect leaks of MC in the workplace. In work areas where spills may occur, the employer shall make provisions to contain any spills and to safely dispose of any MC-contaminated waste materials.
(ii) The employer shall ensure that all incidental leaks are repaired and that incidental spills are cleaned promptly by employees who use the appropriate personal protective equipment and are trained in proper methods of cleanup.
(Note to subsection (6)(d)(ii) of this section: See Appendix A of this section for examples of procedures that satisfy this requirement. Employers covered by this standard may also be subject to the hazardous waste and emergency response provisions contained in WAC 296-62-3112.)
(7) Respiratory protection.
(a) General requirements. The employer shall provide a respirator which complies with the requirement of this subsection, at no cost to each affected employee, and ensure that each affected employee uses such respirator where appropriate. Respirators shall be used in the following circumstances:
(i) Whenever an employee's exposure to MC exceeds or can reasonably be expected to exceed the 8-hour TWA PEL or the STEL (such as where an employee is using MC in a regulated area);
(ii) During the time interval necessary to install or implement feasible engineering and work practice controls;
(iii) In a few work operations, such as some maintenance operations and repair activities, for which the employer demonstrates that engineering and work practice controls are infeasible;
(iv) Where feasible engineering and work practice controls are not sufficient to reduce exposures to or below the PELs; or
(v) In emergencies.
(b) Medical evaluation. Before having any employee use a supplied-air respirator in the negative pressure mode, or a gas mask with organic vapor canister for emergency escape, the employer shall have a physician or other licensed health care professional ascertain each affected employee's ability to use such respiratory protection. The physician or other licensed health care professional shall provide his or her findings to the affected employee and the employer in a written opinion.
(Note to subsection (7)(b) of this section: See also WAC 296-62-07109(3) - Respiratory Protection for medical evaluation requirements for employees using respirators for purposes other than emergency escape.)
(c) Respirator selection. The appropriate atmosphere-supplying
respirators, as specified in Table 2, shall be selected from those
approved by the National Institute for Occupational Safety and Health
(NIOSH) under the provisions of 42 CFR Part 84, "Respiratory Protective
Devices." When employers elect to provide gas masks with organic vapor
canisters for use in emergency escape, the organic vapor canisters shall
bear the approval of NIOSH.
[Open Style:Columns Off]
Table 2.--Minimum Requirements for Respiratory
Protection for Airborne Methylene Chloride
Methylene chloride airborne
concentration (ppm) or condition of use Minimum respirator required1
Up to 625 ppm (25 X PEL) (1) Continuous flow supplied-air respirator,
hood or helmet.
Up to 1250 ppm (50 X 8 hr TWA PEL) (1) Full facepiece supplied-air respirator operated in
negative pressure (demand) mode.
(2) Full facepiece self-contained breathing apparatus
(SCBA) operated in negative pressure (demand)
Up to 5000 ppm (200 X 8-TWA PEL) (1) Continuous flow supplied-air respirator, full
(2) Pressure demand supplied-air respirator, full
(3) Positive pressure full facepiece SCBA.
Unknown concentration, or above 5000 ppm (1) Positive pressure full facepiece SCBA.
(Greater than 200 X 8-TWA PEL) (2) Full facepiece pressure demand supplied-air
respirator with an auxiliary self-contained air
Fire fighting Positive pressure full facepiece SCBA.
Emergency escape (1) Any continuous flow or pressure demand SCBA.
(2) Gas mask with organic vapor canister.
[Open Style:Columns On]
1 Respirators assigned for higher airborne concentrations may be used at
(d) Respirator program. Where respiratory protection is required by this section, the employer shall institute a respirator program in accordance with WAC 296-62-071.
(e) Permission to leave area. The employer shall permit employees who wear respirators to leave the regulated area to readjust the facepieces to their faces to achieve a proper fit, and to wash their faces and respirator facepieces as necessary in order to prevent skin irritation associated with respirator use.
(f) Filter respirators. Employers who provide gas masks with organic vapor canisters for the purpose of emergency escape shall replace those canisters after any emergency use before those gas masks are returned to service.
(g) Respirator fit testing.
(i) The employer shall ensure that each respirator issued to the employee is properly fitted and exhibits the least possible facepiece leakage from among the facepieces tested.
(ii) The employer shall perform qualitative or quantitative fit tests at the time of initial fitting and at least annually thereafter for each employee wearing a negative pressure respirator, including those employees for whom emergency escape respirators are provided.
(Note to subsection (7)(g)(ii) of this section: The only supplied-air respirators to which this provision would apply are SCBA in negative pressure mode and full facepiece supplied-air respirators operated in negative pressure mode. The small business compliance guides will contain examples of protocols for qualitative and quantitative fit testing.)
(8) Protective work clothing and equipment.
(a) Where needed to prevent MC-induced skin or eye irritation, the employer shall provide clean protective clothing and equipment which is resistant to MC, at no cost to the employee, and shall ensure that each affected employee uses it. Eye and face protection shall meet the requirements of WAC 296-24-078, as applicable.
(b) The employer shall clean, launder, repair and replace all protective clothing and equipment required by this subsection as needed to maintain their effectiveness.
(c) The employer shall be responsible for the safe disposal of such clothing and equipment.
(Note to subsection (8)(c) of this section: See Appendix A for examples of disposal procedures that will satisfy this requirement.)
(9) Hygiene facilities.
(a) If it is reasonably foreseeable that employees' skin may contact solutions containing 0.1 percent or greater MC (for example, through splashes, spills or improper work practices), the employer shall provide conveniently located washing facilities capable of removing the MC, and shall ensure that affected employees use these facilities as needed.
(b) If it is reasonably foreseeable that an employee's eyes may contact solutions containing 0.1 percent or greater MC (for example through splashes, spills or improper work practices), the employer shall provide appropriate eyewash facilities within the immediate work area for emergency use, and shall ensure that affected employees use those facilities when necessary.
(10) Medical surveillance.
(a) Affected employees. The employer shall make medical surveillance available for employees who are or may be exposed to MC as follows:
(i) At or above the action level on 30 or more days per year, or above the 8-hour TWA PEL or the STEL on 10 or more days per year;
(ii) Above the 8-TWA PEL or STEL for any time period where an employee has been identified by a physician or other licensed health care professional as being at risk from cardiac disease or from some other serious MC-related health condition and such employee requests inclusion in the medical surveillance program;
(iii) During an emergency.
(b) Costs. The employer shall provide all required medical surveillance at no cost to affected employees, without loss of pay and at a reasonable time and place.
(c) Medical personnel. The employer shall ensure that all medical surveillance procedures are performed by a physician or other licensed health care professional, as defined in subsection (2) of this section.
(d) Frequency of medical surveillance. The employer shall make medical surveillance available to each affected employee as follows:
(i) Initial surveillance. The employer shall provide initial medical surveillance under the schedule provided by subsection (14)(b)(iii) of this section, or before the time of initial assignment of the employee, whichever is later. The employer need not provide the initial surveillance if medical records show that an affected employee has been provided with medical surveillance that complies with this section within 12 months before December 1.
(ii) Periodic medical surveillance. The employer shall update the medical and work history for each affected employee annually. The employer shall provide periodic physical examinations, including appropriate laboratory surveillance, as follows:
(A) For employees 45 years of age or older, within 12 months of the initial surveillance or any subsequent medical surveillance; and
(B) For employees younger than 45 years of age, within 36 months of the initial surveillance or any subsequent medical surveillance.
(iii) Termination of employment or reassignment. When an employee leaves the employer's workplace, or is reassigned to an area where exposure to MC is consistently at or below the action level and STEL, medical surveillance shall be made available if six months or more have elapsed since the last medical surveillance.
(iv) Additional surveillance. The employer shall provide additional medical surveillance at frequencies other than those listed above when recommended in the written medical opinion. (For example, the physician or other licensed health care professional may determine an examination is warranted in less than 36 months for employees younger than 45 years of age based upon evaluation of the results of the annual medical and work history.)
(e) Content of medical surveillance.
(i) Medical and work history. The comprehensive medical and work history shall emphasize neurological symptoms, skin conditions, history of hematologic or liver disease, signs or symptoms suggestive of heart disease (angina, coronary artery disease), risk factors for cardiac disease, MC exposures, and work practices and personal protective equipment used during such exposures.
(Note to subsection (10)(e)(i) of this section: See Appendix B of this section for an example of a medical and work history format that would satisfy this requirement.)
(ii) Physical examination. Where physical examinations are provided as required above, the physician or other licensed health care professional shall accord particular attention to the lungs, cardiovascular system (including blood pressure and pulse), liver, nervous system, and skin. The physician or other licensed health care professional shall determine the extent and nature of the physical examination based on the health status of the employee and analysis of the medical and work history.
(iii) Laboratory surveillance. The physician or other licensed health care professional shall determine the extent of any required laboratory surveillance based on the employee's observed health status and the medical and work history.
(Note to subsection (10)(e)(iii) of this section: See Appendix B of this section for information regarding medical tests. Laboratory surveillance may include before-and after-shift carboxyhemoglobin determinations, resting ECG, hematocrit, liver function tests and cholesterol levels.)
(iv) Other information or reports. The medical surveillance shall also include any other information or reports the physician or other licensed health care professional determines are necessary to assess the employee's health in relation to MC exposure.
(f) Content of emergency medical surveillance. The employer shall ensure that medical surveillance made available when an employee has been exposed to MC in emergency situations includes, at a minimum:
(i) Appropriate emergency treatment and decontamination of the exposed employee;
(ii) Comprehensive physical examination with special emphasis on the nervous system, cardiovascular system, lungs, liver and skin, including blood pressure and pulse;
(iii) Updated medical and work history, as appropriate for the medical condition of the employee; and
(iv) Laboratory surveillance, as indicated by the employee's health status.
(Note to subsection (10)(f)(iv) of this section: See Appendix B for examples of tests which may be appropriate.)
(g) Additional examinations and referrals. Where the physician or other licensed health care professional determines it is necessary, the scope of the medical examination shall be expanded and the appropriate additional medical surveillance, such as referrals for consultation or examination, shall be provided.
(h) Information provided to the physician or other licensed health care professional. The employer shall provide the following information to a physician or other licensed health care professional who is involved in the diagnosis of MC-induced health effects:
(i) A copy of this section including its applicable appendices;
(ii) A description of the affected employee's past, current and anticipated future duties as they relate to the employee's MC exposure;
(iii) The employee's former or current exposure levels or, for employees not yet occupationally exposed to MC, the employee's anticipated exposure levels and the frequency and exposure levels anticipated to be associated with emergencies;
(iv) A description of any personal protective equipment, such as respirators, used or to be used; and
(v) Information from previous employment-related medical surveillance of the affected employee which is not otherwise available to the physician or other licensed health care professional.
(i) Written medical opinions.
(i) For each physical examination required by this section, the employer shall ensure that the physician or other licensed health care professional provides to the employer and to the affected employee a written opinion regarding the results of that examination within 15 days of completion of the evaluation of medical and laboratory findings, but not more than 30 days after the examination. The written medical opinion shall be limited to the following information:
(A) The physician's or other licensed health care professional's opinion concerning whether the employee has any detected medical condition(s) which would place the employee's health at increased risk of material impairment from exposure to MC;
(B) Any recommended limitations upon the employee's exposure to MC or upon the employee's use of protective clothing or equipment and respirators;
(C) A statement that the employee has been informed by the physician or other licensed health care professional that MC is a potential occupational carcinogen, of risk factors for heart disease, and the potential for exacerbation of underlying heart disease by exposure to MC through its metabolism to carbon monoxide; and
(D) A statement that the employee has been informed by the physician or other licensed health care professional of the results of the medical examination and any medical conditions resulting from MC exposure which require further explanation or treatment.
(ii) The employer shall instruct the physician or other licensed health care professional not to reveal to the employer, orally or in the written opinion, any specific records, findings, and diagnoses that have no bearing on occupational exposure to MC.
(Note to subsection (10)(h)(ii) of this section: The written medical opinion may also include information and opinions generated to comply with other OSHA health standards.)
(11) Hazard communication. The employer shall communicate the following hazards associated with MC on labels and in material safety data sheets in accordance with the requirements of the hazard communication standard, WAC 296-62-054: cancer, cardiac effects (including elevation of carboxyhemoglobin), central nervous system effects, liver effects, and skin and eye irritation.
(12) Employee information and training.
(a) The employer shall provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to MC.
(b) The employer shall ensure that information and training is presented in a manner that is understandable to the employees.
(c) In addition to the information required under the hazard communication standard at WAC 296-62-054:
(i) The employer shall inform each affected employee of the requirements of this section and information available in its appendices, as well as how to access or obtain a copy of it in the workplace;
(ii) Wherever an employee's exposure to airborne concentrations of MC exceeds or can reasonably be expected to exceed the action level, the employer shall inform each affected employee of the quantity, location, manner of use, release, and storage of MC and the specific operations in the workplace that could result in exposure to MC, particularly noting where exposures may be above the 8-hour TWA PEL or STEL;
(d) The employer shall train each affected employee as required under the hazard communication standard at WAC 296-62-054, as appropriate.
(e) The employer shall re-train each affected employee as necessary to ensure that each employee exposed above the action level or the STEL maintains the requisite understanding of the principles of safe use and handling of MC in the workplace.
(f) Whenever there are workplace changes, such as modifications of tasks or procedures or the institution of new tasks or procedures, which increase employee exposure, and where those exposures exceed or can reasonably be expected to exceed the action level, the employer shall update the training as necessary to ensure that each affected employee has the requisite proficiency.
(g) An employer whose employees are exposed to MC at a multi-employer worksite shall notify the other employers with work operations at that site in accordance with the requirements of the hazard communication standard, WAC 296-62-054, as appropriate.
(h) The employer shall provide to the director, upon request, all available materials relating to employee information and training.
(a) Objective data.
(i) Where an employer seeks to demonstrate that initial monitoring is unnecessary through reasonable reliance on objective data showing that any materials in the workplace containing MC will not release MC at levels which exceed the action level or the STEL under foreseeable conditions of exposure, the employer shall establish and maintain an accurate record of the objective data relied upon in support of the exemption.
(ii) This record shall include at least the following information:
(A) The MC-containing material in question;
(B) The source of the objective data;
(C) The testing protocol, results of testing, and/or analysis of the material for the release of MC;
(D) A description of the operation exempted under subsection (4)(b)(i) of this section and how the data support the exemption; and
(E) Other data relevant to the operations, materials, processing, or employee exposures covered by the exemption.
(iii) The employer shall maintain this record for the duration of the employer's reliance upon such objective data.
(b) Exposure measurements.
(i) The employer shall establish and keep an accurate record of all measurements taken to monitor employee exposure to MC as prescribed in subsection (4) of this section.
(ii) Where the employer has 20 or more employees, this record shall include at least the following information:
(A) The date of measurement for each sample taken;
(B) The operation involving exposure to MC which is being monitored;
(C) Sampling and analytical methods used and evidence of their accuracy;
(D) Number, duration, and results of samples taken;
(E) Type of personal protective equipment, such as respiratory protective devices, worn, if any; and
(F) Name, Social Security number, job classification and exposure of all of the employees represented by monitoring, indicating which employees were actually monitored.
(iii) Where the employer has fewer than 20 employees, the record shall include at least the following information:
(A) The date of measurement for each sample taken;
(B) Number, duration, and results of samples taken; and
(C) Name, Social Security number, job classification and exposure of all of the employees represented by monitoring, indicating which employees were actually monitored.
(iv) The employer shall maintain this record for at least thirty (30) years, in accordance with WAC 296-62-052.
(c) Medical surveillance.
(i) The employer shall establish and maintain an accurate record for each employee subject to medical surveillance under subsection (10) of this section.
(ii) The record shall include at least the following information:
(A) The name, Social Security number and description of the duties of the employee;
(B) Written medical opinions; and
(C) Any employee medical conditions related to exposure to MC.
(iii) The employer shall ensure that this record is maintained for the duration of employment plus thirty (30) years, in accordance with WAC 296-62-052.
(i) The employer, upon written request, shall make all records required to be maintained by this section available to the director for examination and copying in accordance with WAC 296-62-052.
(Note to subsection (13)(d)(i) of this section: All records required to be maintained by this section may be kept in the most administratively convenient form (for example, electronic or computer records would satisfy this requirement).)
(ii) The employer, upon request, shall make any employee exposure and objective data records required by this section available for examination and copying by affected employees, former employees, and designated representatives in accordance with WAC 296-62-052.
(iii) The employer, upon request, shall make employee medical records required to be kept by this section available for examination and copying by the subject employee and by anyone having the specific written consent of the subject employee in accordance with WAC 296-62-052.
(e) Transfer of records. The employer shall comply with the requirements concerning transfer of records set forth in WAC 296-62-05215.
(a) Effective date. This section shall become effective December 1, 1997.
(b) Start-up dates.
(i) Initial monitoring required by subsection (4)(b) of this section shall be completed according to the following schedule:
(A) For employers with fewer than 20 employees, no later than February 4, 1998.
(B) Immediately for all other employers.
(ii) Engineering controls required under subsection (6)(a) of this section shall be implemented according to the following schedule:
(A) For employers with fewer than 20 employees, no later than April 10, 2000.
(B) For polyurethane foam manufacturers with 20 to 99 employees, no later than April 10, 1999.
(C) For all other employers, no later than April 10, 1998.
(iii) All other requirements of this section shall be complied with according to the following schedule:
(A) For employers with fewer than 20 employees, no later than April 10, 1998.
(B) For polyurethane foam manufacturers with 20 to 99 employees, no later than January 5, 1998.
(C) For all other employers, on the effective date.
(c) Transitional dates. The exposure limits for MC specified in WAC 296-62-07515 Table 1, shall remain in effect until the start-up dates for the exposure limits specified in subsection (14) of this section, or if the exposure limits in this section are stayed or vacated.
(15) Appendices. The information contained in the appendices does
not, by itself, create any additional obligations not otherwise imposed
or detract from any existing obligation.
WAC 296-62-07473 Appendix A. Substance Safety Data Sheet and Technical Guidelines for Methylene Chloride
I. Substance Identification
A. Substance: Methylene chloride (CH2Cl2).
B. Synonyms: MC, Dichloromethane (DCM); Methylene dichloride; Methylene bichloride; Methane dichloride; CAS: 75-09-2; NCI-C50102.
C. Physical data:
1. Molecular weight: 84.9.
2. Boiling point (760 mm Hg): 39.8 deg.C (104 deg.F).
3. Specific gravity (water=1): 1.3.
4. Vapor density (air=1 at boiling point): 2.9.
5. Vapor pressure at 20 deg. C (68 deg. F): 350 mm Hg.
6. Solubility in water, g/100 g water at 20 deg. C (68 deg. F)=1.32.
7. Appearance and odor: colorless liquid with a chloroform-like odor.
D. Uses: MC is used as a solvent, especially where high volatility is required. It is a good solvent for oils, fats, waxes, resins, bitumen, rubber and cellulose acetate and is a useful paint stripper and degreaser. It is used in paint removers, in propellant mixtures for aerosol containers, as a solvent for plastics, as a degreasing agent, as an extracting agent in the pharmaceutical industry and as a blowing agent in polyurethane foams. Its solvent property is sometimes increased by mixing with methanol, petroleum naphtha or tetrachloroethylene.
E. Appearance and odor: MC is a clear colorless liquid with a chloroform-like odor. It is slightly soluble in water and completely miscible with most organic solvents.
F. Permissible exposure: Exposure may not exceed 25 parts MC per million parts of air (25 ppm) as an eight-hour time-weighted average (8-hour TWA PEL) or 125 parts of MC per million parts of air (125 ppm) averaged over a 15-minute period (STEL).
II. Health Hazard Data
A. MC can affect the body if it is inhaled or if the liquid comes in contact with the eyes or skin. It can also affect the body if it is swallowed.
B. Effects of overexposure:
1. Short-term Exposure: MC is an anesthetic. Inhaling the vapor may cause mental confusion, light-headedness, nausea, vomiting, and headache. Continued exposure may cause increased light-headedness, staggering, unconsciousness, and even death. High vapor concentrations may also cause irritation of the eyes and respiratory tract. Exposure to MC may make the symptoms of angina (chest pains) worse. Skin exposure to liquid MC may cause irritation. If liquid MC remains on the skin, it may cause skin burns. Splashes of the liquid into the eyes may cause irritation.
2. Long-term (chronic) exposure: The best evidence that MC causes cancer is from laboratory studies in which rats, mice and hamsters inhaled MC 6 hours per day, 5 days per week for 2 years. MC exposure produced lung and liver tumors in mice and mammary tumors in rats. No carcinogenic effects of MC were found in hamsters. There are also some human epidemiological studies which show an association between occupational exposure to MC and increases in biliary (bile duct) cancer and a type of brain cancer. Other epidemiological studies have not observed a relationship between MC exposure and cancer. WISHA interprets these results to mean that there is suggestive (but not absolute) evidence that MC is a human carcinogen.
C. Reporting signs and symptoms: You should inform your employer if you develop any signs or symptoms and suspect that they are caused by exposure to MC.
D. Warning Properties:
1. Odor Threshold: Different authors have reported varying odor thresholds for MC. Kirk-Othmer and Sax both reported 25 to 50 ppm; Summer and May both reported 150 ppm; Spector reports 320 ppm. Patty, however, states that since one can become adapted to the odor, MC should not be considered to have adequate warning properties.
2. Eye Irritation Level: Kirk-Othmer reports that "MC vapor is seriously damaging to the eyes." Sax agrees with Kirk-Othmer's statement. The ACGIH Documentation of TLVs states that irritation of the eyes has been observed in workers exposed to concentrations up to 5000 ppm.
3. Evaluation of Warning Properties: Since a wide range of MC odor thresholds are reported (25-320 ppm), and human adaptation to the odor occurs, MC is considered to be a material with poor warning properties.
III. Emergency First Aid Procedures
In the event of emergency, institute first aid procedures and send for first aid or medical assistance.
A. Eye and Skin Exposures: If there is a potential for liquid MC to come in contact with eye or skin, face shields and skin protective equipment must be provided and used. If liquid MC comes in contact with the eye, get medical attention. Contact lenses should not be worn when working with this chemical.
B. Breathing: If a person breathes in large amounts of MC, move the exposed person to fresh air at once. If breathing has stopped, perform cardiopulmonary resuscitation. Keep the affected person warm and at rest. Get medical attention as soon as possible.
C. Rescue: Move the affected person from the hazardous exposure immediately. If the exposed person has been overcome, notify someone else and put into effect the established emergency rescue procedures. Understand the facility's emergency rescue procedures and know the locations of rescue equipment before the need arises. Do not become a casualty yourself.
IV. Respirators, Protective Clothing, and Eye Protection
A. Respirators: Good industrial hygiene practices recommend that engineering controls be used to reduce environmental concentrations to the permissible exposure level. However, there are some exceptions where respirators may be used to control exposure. Respirators may be used when engineering and work practice controls are not feasible, when such controls are in the process of being installed, or when these controls fail and need to be supplemented. Respirators may also be used for operations which require entry into tanks or closed vessels, and in emergency situations. If the use of respirators is necessary, the only respirators permitted are those that have been approved by the National Institute for Occupational Safety and Health (NIOSH). Supplied-air respirators are required because air-purifying respirators do not provide adequate respiratory protection against MC. In addition to respirator selection, a complete written respiratory protection program should be instituted which includes regular training, maintenance, inspection, cleaning, and evaluation. If you can smell MC while wearing a respirator, proceed immediately to fresh air. If you experience difficulty in breathing while wearing a respirator, tell your employer.
B. Protective Clothing: Employees must be provided with and required to use impervious clothing, gloves, face shields (eight-inch minimum), and other appropriate protective clothing necessary to prevent repeated or prolonged skin contact with liquid MC or contact with vessels containing liquid MC. Any clothing which becomes wet with liquid MC should be removed immediately and not reworn until the employer has ensured that the protective clothing is fit for reuse. Contaminated protective clothing should be placed in a regulated area designated by the employer for removal of MC before the clothing is laundered or disposed of. Clothing and equipment should remain in the regulated area until all of the MC contamination has evaporated; clothing and equipment should then be laundered or disposed of as appropriate.
C. Eye Protection: Employees should be provided with and required to use splash-proof safety goggles where liquid MC may contact the eyes.
V. Housekeeping and Hygiene Facilities
For purposes of complying with WAC 296-24-120, the following items should be emphasized:
A. The workplace should be kept clean, orderly, and in a sanitary condition. The employer should institute a leak and spill detection program for operations involving liquid MC in order to detect sources of fugitive MC emissions.
B. Emergency drench showers and eyewash facilities are recommended. These should be maintained in a sanitary condition. Suitable cleansing agents should also be provided to assure the effective removal of MC from the skin.
C. Because of the hazardous nature of MC, contaminated protective clothing should be placed in a regulated area designated by the employer for removal of MC before the clothing is laundered or disposed of.
VI. Precautions for Safe Use, Handling, and Storage
A. Fire and Explosion Hazards: MC has no flash point in a conventional closed tester, but it forms flammable vapor-air mixtures at approximately 100 deg.C (212 deg.F), or higher. It has a lower explosion limit of 12%, and an upper explosion limit of 19% in air. It has an autoignition temperature of 556.1 deg.C (1033 deg.F), and a boiling point of 39.8 deg.C (104 deg.F). It is heavier than water with a specific gravity of 1.3. It is slightly soluble in water.
B. Reactivity Hazards: Conditions contributing to the instability of MC are heat and moisture. Contact with strong oxidizers, caustics, and chemically active metals such as aluminum or magnesium powder, sodium and potassium may cause fires and explosions. Special precautions: Liquid MC will attack some forms of plastics, rubber, and coatings.
C. Toxicity: Liquid MC is painful and irritating if splashed in the eyes or if confined on the skin by gloves, clothing, or shoes. Vapors in high concentrations may cause narcosis and death. Prolonged exposure to vapors may cause cancer or exacerbate cardiac disease.
D. Storage: Protect against physical damage. Because of its corrosive properties, and its high vapor pressure, MC should be stored in plain, galvanized or lead lined, mild steel containers in a cool, dry, well ventilated area away from direct sunlight, heat source and acute fire hazards.
E. Piping Material: All piping and valves at the loading or unloading station should be of material that is resistant to MC and should be carefully inspected prior to connection to the transport vehicle and periodically during the operation.
F. Usual Shipping Containers: Glass bottles, 5- and 55-gallon steel drums, tank cars, and tank trucks.
Note: This section addresses MC exposure in marine terminal and longshore employment only where leaking or broken packages allow MC exposure that is not addressed through compliance with WAC 296-56.
G. Electrical Equipment: Electrical installations in Class I hazardous locations as defined in Article 500 of the National Electrical Code, should be installed according to Article 501 of the code; and electrical equipment should be suitable for use in atmospheres containing MC vapors. See Flammable and Combustible Liquids Code (NFPA No. 325M), Chemical Safety Data Sheet SD-86 (Manufacturing Chemists' Association, Inc.).
H. Fire Fighting: When involved in fire, MC emits highly toxic and irritating fumes such as phosgene, hydrogen chloride and carbon monoxide. Wear breathing apparatus and use water spray to keep fire-exposed containers cool. Water spray may be used to flush spills away from exposures. Extinguishing media are dry chemical, carbon dioxide, foam. For purposes of compliance with WAC 296-24-956, locations classified as hazardous due to the presence of MC shall be Class I.
I. Spills and Leaks: Persons not wearing protective equipment and clothing should be restricted from areas of spills or leaks until cleanup has been completed. If MC has spilled or leaked, the following steps should be taken:
1. Remove all ignition sources.
2. Ventilate area of spill or leak.
3. Collect for reclamation or absorb in vermiculite, dry sand, earth, or a similar material.
J. Methods of Waste Disposal: Small spills should be absorbed onto sand and taken to a safe area for atmospheric evaporation. Incineration is the preferred method for disposal of large quantities by mixing with a combustible solvent and spraying into an incinerator equipped with acid scrubbers to remove hydrogen chloride gases formed. Complete combustion will convert carbon monoxide to carbon dioxide. Care should be taken for the presence of phosgene.
K. You should not keep food, beverage, or smoking materials, or eat or smoke in regulated areas where MC concentrations are above the permissible exposure limits.
L. Portable heating units should not be used in confined areas where MC is used.
M. Ask your supervisor where MC is used in your work area and for any additional plant safety and health rules.
VII. Medical Requirements
Your employer is required to offer you the opportunity to participate in a medical surveillance program if you are exposed to MC at concentrations at or above the action level (12.5 ppm 8-hour TWA) for more than 30 days a year or at concentrations exceeding the PELs (25 ppm 8-hour TWA or 125 ppm 15-minute STEL) for more than 10 days a year. If you are exposed to MC at concentrations over either of the PELs, your employer will also be required to have a physician or other licensed health care professional ensure that you are able to wear the respirator that you are assigned. Your employer must provide all medical examinations relating to your MC exposure at a reasonable time and place and at no cost to you.
VIII. Monitoring and Measurement Procedures
A. Exposure above the Permissible Exposure Limit:
1. Eight-hour exposure evaluation: Measurements taken for the purpose of determining employee exposure under this section are best taken with consecutive samples covering the full shift. Air samples must be taken in the employee's breathing zone.
2. Monitoring techniques: The sampling and analysis under this section may be performed by collection of the MC vapor on two charcoal adsorption tubes in series or other composition adsorption tubes, with subsequent chemical analysis. Sampling and analysis may also be performed by instruments such as real-time continuous monitoring systems, portable direct reading instruments, or passive dosimeters as long as measurements taken using these methods accurately evaluate the concentration of MC in employees' breathing zones. OSHA method 80 is an example of a validated method of sampling and analysis of MC. Copies of this method are available from OSHA or can be downloaded from the Internet at http://www.osha.gov. The employer has the obligation of selecting a monitoring method which meets the accuracy and precision requirements of the standard under his or her unique field conditions. The standard requires that the method of monitoring must be accurate, to a 95 percent confidence level, to plus or minus 25 percent for concentrations of MC at or above 25 ppm, and to plus or minus 35 percent for concentrations at or below 25 ppm. In addition to OSHA method 80, there are numerous other methods available for monitoring for MC in the workplace.
B. Since many of the duties relating to employee exposure are dependent on the results of measurement procedures, employers must assure that the evaluation of employee exposure is performed by a technically qualified person.
IX. Observation of Monitoring
Your employer is required to perform measurements that are representative of your exposure to MC and you or your designated representative are entitled to observe the monitoring procedure. You are entitled to observe the steps taken in the measurement procedure, and to record the results obtained. When the monitoring procedure is taking place in an area where respirators or personal protective clothing and equipment are required to be worn, you or your representative must also be provided with, and must wear, protective clothing and equipment.
Access To Information
A. Your employer is required to inform you of the information contained in this Appendix. In addition, your employer must instruct you in the proper work practices for using MC, emergency procedures, and the correct use of protective equipment.
B. Your employer is required to determine whether you are being exposed to MC. You or your representative has the right to observe employee measurements and to record the results obtained. Your employer is required to inform you of your exposure. If your employer determines that you are being over exposed, he or she is required to inform you of the actions which are being taken to reduce your exposure to within permissible exposure limits.
C. Your employer is required to keep records of your exposures and medical examinations. These records must be kept by the employer for at least thirty (30) years.
D. Your employer is required to release your exposure and medical records to you or your representative upon your request.
E. Your employer is required to provide labels and material safety
data sheets (MSDS) for all materials, mixtures or solutions composed of
greater than 0.1 percent MC. An example of a label that would satisfy
these requirements would be:
Danger Contains Methylene Chloride
Potential Cancer Hazard
May worsen heart disease because methylene chloride is converted to
carbon monoxide in the body.
May cause dizziness, headache, irritation of the throat and lungs, loss
of consciousness and death at high concentrations (for example, if used
in a poorly ventilated room).
Avoid Skin Contact. Contact with liquid causes skin and eye irritation.
X. Common Operations and Controls
The following list includes some common operations in which exposure
to MC may occur and control methods which may be effective in each case:
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Use as solvent in paint and varnish removers General dilution ventilation; local; manufacture of aerosols;
cold cleaning and ultrasonic cleaning, and cold cleaning exhaust ventilation; personal
as a solvent in furniture stripping. protective equipment; substitution.
Use as solvent in vapor degreasing. Process enclosure; local exhaust ventilation; chilling
Use as a secondary refrigerant in air General dilution ventilation; local conditioning and
scientific testing. exhaust ventilation; personal protective equipment.
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WAC 296-62-07475 Appendix B. Medical Surveillance for Methylene Chloride
I. Primary Route of Entry Inhalation.
Methylene Chloride (MC) is primarily an inhalation hazard. The principal acute hazardous effects are the depressant action on the central nervous system, possible cardiac toxicity and possible liver toxicity. The range of CNS effects are from decreased eye/hand coordination and decreased performance in vigilance tasks to narcosis and even death of individuals exposed at very high doses. Cardiac toxicity is due to the metabolism of MC to carbon monoxide, and the effects of carbon monoxide on heart tissue. Carbon monoxide displaces oxygen in the blood, decreases the oxygen available to heart tissue, increasing the risk of damage to the heart, which may result in heart attacks in susceptible individuals. Susceptible individuals include persons with heart disease and those with risk factors for heart disease. Elevated liver enzymes and irritation to the respiratory passages and eyes have also been reported for both humans and experimental animals exposed to MC vapors.
MC is metabolized to carbon monoxide and carbon dioxide via two separate pathways. Through the first pathway, MC is metabolized to carbon monoxide as an end-product via the P-450 mixed function oxidase pathway located in the microsomal fraction of the cell. This biotransformation of MC to carbon monoxide occurs through the process of microsomal oxidative dechlorination which takes place primarily in the liver. The amount of conversion to carbon monoxide is significant as measured by the concentration of carboxyhemoglobin, up to 12% measured in the blood following occupational exposure of up to 610 ppm. Through the second pathway, MC is metabolized to carbon dioxide as an end product (with formaldehyde and formic acid as metabolic intermediates) via the glutathione dependent enzyme found in the cytosolic fraction of the liver cell. Metabolites along this pathway are believed to be associated with the carcinogenic activity of MC.
MC has been tested for carcinogenicity in several laboratory rodents. These rodent studies indicate that there is clear evidence that MC is carcinogenic to male and female mice and female rats. Based on epidemiologic studies, OSHA has concluded that there is suggestive evidence of increased cancer risk in MC-related worker populations. The epidemiological evidence is consistent with the finding of excess cancer in the experimental animal studies. NIOSH regards MC as a potential occupational carcinogen and the International Agency for Research Cancer (IARC) classifies MC as an animal carcinogen. OSHA considers MC as a suspected human carcinogen.
III. Medical Signs and Symptoms of Acute Exposure
Skin exposure to liquid MC may cause irritation or skin burns. Liquid MC can also be irritating to the eyes. MC is also absorbed through the skin and may contribute to the MC exposure by inhalation. At high concentrations in air, MC may cause nausea, vomiting, light-headedness, numbness of the extremities, changes in blood enzyme levels, and breathing problems, leading to bronchitis and pulmonary edema, unconsciousness and even death.
At lower concentrations in air, MC may cause irritation to the skin, eye, and respiratory tract and occasionally headache and nausea. Perhaps the greatest problem from exposure to low concentrations of MC is the CNS effects on coordination and alertness that may cause unsafe operations of machinery and equipment, leading to self-injury or accidents. Low levels and short duration exposures do not seem to produce permanent disability, but chronic exposures to MC have been demonstrated to produce liver toxicity in animals, and therefore, the evidence is suggestive for liver toxicity in humans after chronic exposure. Chronic exposure to MC may also cause cancer.
IV. Surveillance and Preventive Considerations
As discussed above, MC is classified as a suspect or potential human carcinogen. It is a central nervous system (CNS) depressant and a skin, eye and respiratory tract irritant. At extremely high concentrations, MC has caused liver damage in animals. MC principally affects the CNS, where it acts as a narcotic. The observation of the symptoms characteristic of CNS depression, along with a physical examination, provides the best detection of early neurological disorders. Since exposure to MC also increases the carboxyhemoglobin level in the blood, ambient carbon monoxide levels would have an additive effect on that carboxyhemoglobin level. Based on such information, a periodic post- shift carboxyhemoglobin test as an index of the presence of carbon monoxide in the blood is recommended, but not required, for medical surveillance.
Based on the animal evidence and three epidemiologic studies previously mentioned, OSHA concludes that MC is a suspect human carcinogen. The medical surveillance program is designed to observe exposed workers on a regular basis. While the medical surveillance program cannot detect MC-induced cancer at a preneoplastic stage, OSHA anticipates that, as in the past, early detection and treatments of cancers leading to enhanced survival rates will continue to evolve.
A. Medical and Occupational History:
The medical and occupational work history plays an important role in the initial evaluation of workers exposed to MC. It is therefore extremely important for the examining physician or other licensed health care professional to evaluate the MC-exposed worker carefully and completely and to focus the examination on MC's potentially associated health hazards. The medical evaluation must include an annual detailed work and medical history with special emphasis on cardiac history and neurological symptoms.
An important goal of the medical history is to elicit information from the worker regarding potential signs or symptoms associated with increased levels of carboxyhemoglobin due to the presence of carbon monoxide in the blood. Physicians or other licensed health care professionals should ensure that the smoking history of all MC exposed employees is known. Exposure to MC may cause a significant increase in carboxyhemoglobin level in all exposed persons. However, smokers as well as workers with anemia or heart disease and those concurrently exposed to carbon monoxide are at especially high risk of toxic effects because of an already reduced oxygen carrying capacity of the blood.
A comprehensive or interim medical and work history should also include occurrence of headache, dizziness, fatigue, chest pain, shortness of breath, pain in the limbs, and irritation of the skin and eyes. In addition, it is important for the physician or other licensed health care professional to become familiar with the operating conditions in which exposure to MC is likely to occur. The physician or other licensed health care professional also must become familiar with the signs and symptoms that may indicate that a worker is receiving otherwise unrecognized and exceptionally high exposure levels of MC.
An example of a medical and work history that would satisfy the requirement for a comprehensive or interim work history is represented by the following:
The following is a list of recommended questions and issues for the
self-administered questionnaire for methylene chloride exposure.
Questionnaire For Methylene Chloride Exposure
I. Demographic Information
2. Social Security Number
4. Date of Birth
6. Present occupation
II. Occupational History
1. Have you ever worked with methylene chloride, dichloromethane, methylene dichloride, or CH2Cl2 (all are different names for the same chemical)? Please list which on the occupational history form if you have not already.
2. If you have worked in any of the following industries and have not listed them on the occupational history form, please do so.
Polyurethane foam manufacturing
Chemical manufacturing or formulation
Any industry in which you used solvents to clean and degrease equipment or parts
Construction, especially painting and refinishing
Any industry in which you used aerosol adhesives
3. If you have not listed hobbies or household projects on the occupational history form, especially furniture refinishing, spray painting, or paint stripping, please do so.
III. Medical History
1. Do you consider yourself to be in good health? If no, state reason(s).
2. Do you or have you ever had:
a. Persistent thirst
b. Frequent urination (three times or more at night)
c. Dermatitis or irritated skin
d. Nonhealing wounds
3. What prescription or nonprescription medications do you take, and for what reasons?
4. Are you allergic to any medications, and what type of reaction do you have?
1. Do you have or have you ever had any chest illnesses or diseases? Explain.
2. Do you have or have you ever had any of the following:
c. Shortness of breath
3. Have you ever had an abnormal chest X-ray? If so, when, where, and what were the findings?
4. Have you ever had difficulty using a respirator or breathing apparatus? Explain.
5. Do any chest or lung diseases run in your family? Explain.
6. Have you ever smoked cigarettes, cigars, or a pipe? Age started:
7. Do you now smoke?
8. If you have stopped smoking completely, how old were you when you stopped?
9. On the average of the entire time you smoked, how many packs of cigarettes, cigars, or bowls of tobacco did you smoke per day?
1. Have you ever been diagnosed with any of the following:
Which of the following apply to you now or did apply to you at some time in the past, even if the problem is controlled by medication? Please explain any yes answers (i.e., when problem was diagnosed, length of time on medication).
a. High cholesterol or triglyceride level
b. Hypertension (high blood pressure)
d. Family history of heart attack, stroke, or blocked arteries
2. Have you ever had chest pain? If so, answer the next five questions.
a. What was the quality of the pain (i.e., crushing, stabbing, squeezing)?
b. Did the pain go anywhere (i.e., into jaw, left arm)?
c. What brought the pain out?
d. How long did it last?
e. What made the pain go away?
3. Have you ever had heart disease, a heart attack, stroke, aneurysm, or blocked arteries anywhere in your body? Explain (when, treatment).
4. Have you ever had bypass surgery for blocked arteries in your heart or anywhere else? Explain.
5. Have you ever had any other procedures done to open up a blocked artery (balloon angioplasty, carotid endarterectomy, clot-dissolving drug)?
6. Do you have or have you ever had (explain each):
a. Heart murmur
b. Irregular heartbeat
c. Shortness of breath while lying flat
d. Congestive heart failure
e. Ankle swelling
f. Recurrent pain anywhere below the waist while walking
7. Have you ever had an electrocardiogram (EKG)? When?
8. Have you ever had an abnormal EKG? If so, when, where, and what were the findings?
9. Do any heart diseases, high blood pressure, diabetes, high cholesterol, or high triglycerides run in your family? Explain.
D. Hepatobiliary and Pancreas
1. Do you now or have you ever drunk alcoholic beverages? Age started: Age stopped: .
2. Average numbers per week:
a. Beers: , ounces in usual container: b. Glasses of wine: , ounces per glass: c. Drinks: , ounces in usual container:
3. Do you have or have you ever had (explain each):
a. Hepatitis (infectious, autoimmune, drug-induced, or chemical)
c. Elevated liver enzymes or elevated bilirubin
d. Liver disease or cancer
E. Central Nervous System
1. Do you or have you ever had (explain each):
d. Loss of consciousness
e. Garbled speech
f. Lack of balance
g. Mental/psychiatric illness
1. Do you have, or have you ever had (explain each):
b. Sickle cell disease or trait
c. Glucose-6-phosphate dehydrogenase deficiency
d. Bleeding tendency disorder
2. If not already mentioned previously, have you ever had a reaction to sulfa drugs or to drugs used to prevent or treat malaria? What was the drug? Describe the reaction.
B. Physical Examination
The complete physical examination, when coupled with the medical and occupational history, assists the physician or other licensed health care professional in detecting pre-existing conditions that might place the employee at increased risk, and establishes a baseline for future health monitoring. These examinations should include:
1. Clinical impressions of the nervous system, cardiovascular function and pulmonary function, with additional tests conducted where indicated or determined by the examining physician or other licensed health care professional to be necessary.
2. An evaluation of the advisability of the worker using a respirator, because the use of certain respirators places an additional burden on the cardiopulmonary system. It is necessary for the attending physician or other licensed health care professional to evaluate the cardiopulmonary function of these workers, in order to inform the employer in a written medical opinion of the worker's ability or fitness to work in an area requiring the use of certain types of respiratory protective equipment. The presence of facial hair or scars that might interfere with the worker's ability to wear certain types of respirators should also be noted during the examination and in the written medical opinion.
Because of the importance of lung function to workers required to wear certain types of respirators to protect themselves from MC exposure, these workers must receive an assessment of pulmonary function before they begin to wear a negative pressure respirator and at least annually thereafter. The recommended pulmonary function tests include measurement of the employee's forced vital capacity (FVC), forced expiratory volume at one second (FEV1), as well as calculation of the ratios of FEV1 to FVC, and the ratios of measured FVC and measured FEV1 to expected respective values corrected for variation due to age, sex, race, and height. Pulmonary function evaluation must be conducted by a physician or other licensed health care professional experienced in pulmonary function tests.
The following is a summary of the elements of a physical exam which would fulfill the requirements under the MC standard:
I. Skin and appendages
1. Irritated or broken skin 2. Jaundice 3. Clubbing cyanosis, edema 4. Capillary refill time 5. Pallor
1. Facial deformities 2. Scars 3. Hair growth
1. Scleral icterus 2. Corneal arcus 3. Pupillary size and response 4. Fundoscopic exam
1. Standard exam
1. Standard exam 2. Jugular vein distension 3. Peripheral pulses
1. Liver span
VII. Nervous System
1. Complete standard neurologic exam
1. Hemoglobin and hematocrit 2. Alanine aminotransferase (ALT, SGPT) 3. Post-shift carboxyhemoglobin
1. Pulmonary function testing
An evaluation of the oxygen carrying capacity of the blood of employees (for example by measured red blood cell volume) is considered useful, especially for workers acutely exposed to MC. It is also recommended, but not required, that end of shift carboxyhemoglobin levels be determined periodically, and any level above 3% for nonsmokers and above 10% for smokers should prompt an investigation of the worker and his workplace. This test is recommended because MC is metabolized to CO, which combines strongly with hemoglobin, resulting in a reduced capacity of the blood to transport oxygen in the body. This is of particular concern for cigarette smokers because they already have a diminished hemoglobin capacity due to the presence of CO in cigarette smoke.
C. Additional Examinations and Referrals
1. Examination by a Specialist
When a worker examination reveals unexplained symptoms or signs (i.e. in the physical examination or in the laboratory tests), follow-up medical examinations are necessary to assure that MC exposure is not adversely affecting the worker's health. When the examining physician or other licensed health care professional finds it necessary, additional tests should be included to determine the nature of the medical problem and the underlying cause. Where relevant, the worker should be sent to a specialist for further testing and treatment as deemed necessary. The final rule requires additional investigations to be covered and it also permits physicians or other licensed health care professionals to add appropriate or necessary tests to improve the diagnosis of disease should such tests become available in the future.
The examination of workers exposed to MC in an emergency should be directed at the organ systems most likely to be affected. If the worker has received a severe acute exposure, hospitalization may be required to assure proper medical intervention. It is not possible to precisely define "severe," but the physician or other licensed health care professional's judgment should not merely rest on hospitalization. If the worker has suffered significant conjunctival, oral, or nasal irritation, respiratory distress, or discomfort, the physician or other licensed health care professional should instigate appropriate follow-up procedures. These include attention to the eyes, lungs and the neurological system. The frequency of follow-up examinations should be determined by the attending physician or other licensed health care professional. This testing permits the early identification essential to proper medical management of such workers.
D. Employer Obligations
The employer is required to provide the responsible physician or other licensed health care professional and any specialists involved in a diagnosis with the following information: a copy of the MC standard including relevant appendices, a description of the affected employee's duties as they relate to his or her exposure to MC; an estimate of the employee's exposure including duration (e.g., 15hr/wk, three 8-hour shifts/wk, full time); a description of any personal protective equipment used by the employee, including respirators; and the results of any previous medical determinations for the affected employee related to MC exposure to the extent that this information is within the employer's control.
E. Physicians' or Other Licensed Health Care Professionals' Obligations
The standard requires the employer to ensure that the physician or other licensed health care professional provides a written statement to the employee and the employer. This statement should contain the physician's or licensed health care professional's opinion as to whether the employee has any medical condition placing him or her at increased risk of impaired health from exposure to MC or use of respirators, as appropriate. The physician or other licensed health care professional should also state his or her opinion regarding any restrictions that should be placed on the employee's exposure to MC or upon the use of protective clothing or equipment such as respirators. If the employee wears a respirator as a result of his or her exposure to MC, the physician or other licensed health care professional's opinion should also contain a statement regarding the suitability of the employee to wear the type of respirator assigned.
Furthermore, the employee should be informed by the physician or other licensed health care professional about the cancer risk of MC and about risk factors for heart disease, and the potential for exacerbation of underlying heart disease by exposure to MC through its metabolism to carbon monoxide. Finally, the physician or other licensed health care professional should inform the employer that the employee has been told the results of the medical examination and of any medical conditions which require further explanation or treatment. This written opinion must not contain any information on specific findings or diagnosis unrelated to employee's occupational exposures.
The purpose in requiring the examining physician or other licensed
health care professional to supply the employer with a written opinion
is to provide the employer with a medical basis to assist the employer
in placing employees initially, in assuring that their health is not
being impaired by exposure to MC, and to assess the employee's ability
to use any required protective equipment.
WAC 296-62-07477 Appendix C.
Questions and Answers
Methylene Chloride Control in Furniture Stripping
(Adapted from NIOSH publication No. 93-133)
This appendix answers commonly asked questions about the hazards from
exposure to methylene chloride. It also describes approaches to
controlling methylene chloride exposure during the most common furniture
stripping processes. Although these approaches were developed and field
tested by the National Institute of Occupational Safety and Health, each
setting requires custom installation because of the different air flow
interferences at each site.
1. What is the Stripping Solution Base?
The most common active ingredient in paint removers is a chemical called
methylene chloride. Methylene chloride is present in the paint remover
to penetrate, blister, and finally lift the old finish. Other chemicals
in paint removers work to accelerate the stripping process, to retard
evaporation, and to act as thickening agents. These other ingredients
may include: methanol, toluene, acetone, or paraffin.1
2. Is Methylene Chloride Bad for Me?
Exposure to methylene chloride may cause short-term health effects or
long-term health effects.
Short-Term (Acute) Health Effects
Exposure to high levels of paint removers over short periods of time can
cause irritation to the skin, eyes, mucous membranes, and respiratory
tracts. Other symptoms of high exposure are dizziness, headache, and
lack of coordination. The occurrence of any of these symptoms indicates
that you are being exposed to high levels of methylene chloride. At the
onset of any of these symptoms, you should leave the work area, get some
fresh air, and determine why the levels were high.
A portion of inhaled methylene chloride is converted by the body to
carbon monoxide, which can lower the blood's ability to carry oxygen.
When the solvent is used properly, however, the levels of carbon monoxide
should not be hazardous. Individuals with cardiovascular or pulmonary
health problems should check with their physician before using the paint
stripper. Individuals experiencing severe symptoms such as shortness of
breath or chest pains should obtain proper medical care immediately.1
Long-Term (Chronic) Health Effects
Methylene chloride has been shown to cause cancer in certain laboratory
animal tests. The available human studies do not provide the necessary
information to determine whether methylene chloride causes cancer in
humans. However, as a result of the animal studies, methylene chloride
is considered a potential occupational carcinogen. There is also
considerable indirect evidence to suggest that workers exposed to
methylene chloride may be at an increased risk of developing ischemic
heart disease. Therefore, it is prudent to minimize exposure to solvent
3. What does the Methylene Chloride Standard Require?
On January 10, 1997, the Occupational Safety and Health Administration
published a new regulation for methylene chloride. The standard
establishes an eight-hour time-weighted average exposure limit of 25
parts per million (ppm), as well as a short-term exposure limit of 125
ppm determined from a 15 minute sampling period. That is a reduction
from the current WISHA limit of 100 ppm. The standard also sets a 12.5
ppm action level (a level that would trigger periodic exposure monitoring
and medical surveillance provisions).2 WISHA adopted an identical
standard on [date].
The National Institute for Occupational Safety and Health recommends that
methylene chloride be regarded as a "potential occupational carcinogen."
NIOSH further recommends that occupational exposure to methylene chloride
be controlled to the lowest feasible limit. This recommendation was
based on the observation of cancers and tumors in both rats and mice
exposed to methylene chloride in air.5
4. How Can I Be Exposed to Methylene Chloride while Stripping Furniture?
Methylene chloride can be inhaled when vapors are in the air. Inhalation
of the methylene chloride vapors is generally the most important source
of exposure. Methylene chloride evaporates quicker than most chemicals.
The odor threshold of methylene chloride is 300 ppm.6 Therefore, once
you smell methylene chloride, you are being over-exposed. Pouring,
moving, or stirring the chemical will increase the rate of evaporation.
Methylene chloride can be absorbed through the skin either by directly
touching the chemical or through your gloves. Methylene chloride can be
swallowed if it gets on your hands, clothes, or beard, or if food or
drinks become contaminated.
5. How Can Breathing Exposures be Reduced?
Install a Local Exhaust Ventilation System
Local exhaust ventilation can be used to control exposures. Local
exhaust ventilation systems capture contaminated air from the source
before it spreads into the workers' breathing zone.7 If engineering
controls are not effective, only a self-contained breathing apparatus
equipped with a full face piece and operated in a positive-pressure mode
or a supplied-air respirator affords the level of protection. Air-purifying respirators such as gas masks with organic vapor canisters can
only be used for escape situations.8 These gas masks are not suitable for
normal work situations because methylene chloride is poorly absorbed by
the canister filtering material.
A local exhaust system consists of the following: a hood, a fan,
ductwork, and a replacement air system.9,10,11 Two processes are commonly
used in furniture stripping: flow-over and dip tanks. For flow-over
systems there are two common local exhaust controls for methylene
chloride - a slot hood and a down draft hood. A slot hood of different
design is most often used for dip tanks. (See Figures 1, 2, and 3.)
The hood is made of sheet metal and connected to the tank. All designs
require a centrifugal fan to exhaust the fumes, ductwork connecting the
hood and the fan, and a replacement air system to bring conditioned air
into the building to replace the air exhausted.
In constructing or designing a slot or down draft hood, use the following
Safe Work Practices
Workers can lower exposures by decreasing their access to the methylene
1) Turn on dip tank control system several minutes before entering the stripping area.
2) Avoid unnecessary transferring or moving of the stripping solution.
3) Keep face out of the air stream between the solution-covered furniture and the exhaust system.
4) Keep face out of vapor zone above the stripping solution and the dip tank.
5) Retrieve dropped items with a long handled tool.
6) Keep the solution-recycling system off when not in use. Cover reservoir for recycling system.
7) Cover dip tank when not in use.
8) Provide adequate ventilation for rinse area.
How Can Skin Exposures Be Reduced?
Skin exposures can be reduced by wearing gloves whenever you are in
contact with the stripping solution.13
1) Two gloves should be worn. The inner glove should be made from polyethylene/ethylene vinyl alcohol (e.g., Silver Shield®, or 4H®). This material, however, does not provide good physical resistance against tears, so an outer glove made from nitrile or neoprene should be worn.
2) Shoulder-length gloves will be more protective.
3) Change gloves before the break-through time occurs. Rotate several pairs of gloves throughout the day. Let the gloves dry in a warm well ventilated area at least over night before reuse.
4) Keep gloves clean by rinsing often. Keep gloves in good condition. Inspect the gloves before use for pin-holes, cracks, thin spots, and stiffer than normal or sticky surfaces.
5) Wear a face shield or goggles to protect face and eyes.
6. What Other Problems Can Occur?
Stripping Solution Temperature
Most manufacturers of stripping solution recommend controlling the
solution to a temperature of 70F. This temperature is required for the
wax in the solution to form a vapor barrier on top of the solution to
keep the solution from evaporating too quickly. If the temperature is
too high, the wax will not form the vapor barrier. If it is too cold,
the wax will solidify and separate from the solvent causing increased
evaporation. Use a belt heater to heat the solution to the correct
temperature. Call your solution manufacturer for the correct temperature
for your solution.14
Air will enter a building in an amount to equal the amount of air
exhausted whether or not provision is made for this replacement. If a
local exhaust system is added a make-up or replacement air system must
be added to replace the air removed. Without a replacement air system,
air will enter the building through cracks causing uncontrollable eddy
currents. If the building perimeter is tightly sealed, it will prevent
the air from entering and severely decrease the amount exhausted from the
ventilation system. This will cause the building to be under negative
pressure and decrease the performance of the exhaust system.15
With general or dilution ventilation, uncontaminated air is moved through
the workroom by means of fans or open windows, which dilutes the
pollutants in the air. Dilution ventilation does not provide effective
protection to other workers and does not confine the methylene chloride
vapors to one area.16
Phosgene Poisoning from Use of Kerosene Heaters
Do not use kerosene heaters or other open flame heaters while stripping
furniture. Use of kerosene heaters in connection with methylene chloride
can create lethal or dangerous concentrations of phosgene. Methylene
chloride vapor is mixed with the air used for the combustion of kerosene
in kerosene stoves. The vapor thus passes through the flames, coming
into close contact with carbon monoxide at high temperatures. Any
chlorine formed by decomposition may, under these conditions, react with
carbon monoxide and form phosgene.17
1Halogenated Solvents Industry Alliance and Consumer Product Safety Commission . Stripping Paint from Wood (Pamphlet for consumers on how to strip furniture and precautions to take). Washington DC: Consumer Product Safety Commission.
3NIOSH . NIOSH Testimony on Occupational Safety and Health Administration's proposed rule on occupational exposure to methylene chloride, September 21, 1992, OSHA Docket No. H-71. NIOSH policy statements. Cincinnati, OH: U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health.
456 Fed. Reg. 57036 . Occupational Safety and Health Administration: Proposed rule on occupational exposure to methylene chloride.
6Kirk, R.E. and P.F. Othmer, Eds. . Encyclopedia of Chemical Technology, 3rd Ed., Vol. 5:690. New York: John Wiley & Sons, Inc.
7ACGIH . Industrial Ventilation: A Manual of Recommended Practice. 20th Ed. Cincinnati, OH: American Conference of Governmental Industrial Hygienists.
9Fairfield, C.L. and A.A. Beasley . In-depth Survey Report at the Association for Retarded Citizens, Meadowlands, PA. The Control of Methylene Chloride During Furniture Stripping. Cincinnati, OH: U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health.
10Fairfield, C.L. . In-depth Survey Report at the J.M. Murray Center, Cortland, NY. The Control of Methylene Chloride During Furniture Stripping. Cincinnati, OH: U.S. Department of Health and Human Services, Publish Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health.
11Hall, R.M., K.F. Martinez, and P.A. Jensen . In-depth Survey Report at Tri-County Furniture Stripping and Refinishing, Cincinnati, OH. The Control of Methylene Chloride During Furniture Stripping. Cincinnati, OH: U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health.
12Fairfield, C.L. and A.A. Beasley . In-depth Survey Report at the Association for Retarded Citizens, Meadowlands, PA. The Control of Methylene Chloride During Furniture Stripping. Cincinnati, OH: U.S. Department of Health and Human Service, Centers for Disease Control, National Institute for Occupational Safety and Health.
13Roder, M. . Memorandum of March 11, 1991 from Michael Roder of the Division of Safety Research to Cheryl L. Fairfield of the Division of Physical Sciences and Engineering, National Institute for Occupational Safety and Health, Centers for Disease Control, Public Health Service, U.S. Department of Health and Human Services.
14Kwick Kleen Industrial Solvents, Inc., . Operations Manual, Kwick Kleen Industrial Solvents, Inc., Vincennes, IN.
17Gerritsen, W.B. and C.H. Buschmann . Phosgene Poisoning Caused by
the Use of Chemical Paint Removers containing Methylene Chloride in Ill-Ventilated Rooms Heated by Kerosene Stoves. British Journal of
Industrial Medicine 17:187.
Reviser's note: The brackets and enclosed material in the text of the above section occurred in the copy filed by the agency and appear in the Register pursuant to the requirements of RCW 34.08.040.