project no. 0069.1080.0 formaldehyde & phenol exposure...

1725 Victory Boulevard, Glendale, California 91201 / P 818 246-2707 / F 818 246-3145 www.citadelenvironmental.com

October 14, 2015

Michael Strong

Vice President of Administrative Services

SAN BERNARDINO COMMUNITY COLLEGE DISTRICT FOR CRAFTON HILLS COLLEGE

114 South Del Rosa Drive

San Bernardino, California 92408

Re: CITADEL Project No. 0069.1080.0

Formaldehyde & Phenol Exposure Monitoring Report

September 2015 Sample Event #1

Crafton Hills College, LADM Building

Anatomy Department Room 229/230

11711 Sand Canyon Road

Yucaipa, California 92399

Dear Mr. Strong:

Enclosed please find a copy of the Exposure Monitoring Report prepared by Citadel

Environmental Services, Inc. All work was conducted in accordance with Client-

established protocols.

If after your review you have any questions or require additional information, please

do not hesitate to telephone me at the Citadel Office in Glendale at (818) 246-2707.

Sincerely,

CITADEL ENVIRONMENTAL SERVICES, INC.

Nalinna Rasu, CAC, CDPH, CHMM, LEED AP

Director, Environmental Compliance

Enclosure

http://www.citadelenvironmental.com/

San Bernardino Community College District for Crafton Hills College 114 South Del Rosa Drive San Bernardino, California 92408

Formaldehyde & Phenol Exposure Monitoring Report September 2015 Sampling Event #1

October 14, 2015 Citadel Project Number 0069.1080.0 Crafton Hills College Anatomy Department Room 229/230 11711 Sand Canyon Road Yucaipa, California 92399

www.citadelenvironmental.com

CITADEL PROJECT NO. 0069.1080.P

FORMALDEHYDE & PHENOL EXPOSURE MONITORING REPORT

OCTOBER 2015 SAMPLING EVENT #1

SAN BERNARDINO COMMUNITY COLLEGE DISTRICT

CRAFTON HILLS COLLEGE

YUCAIPA, CALIFORNIA

OCTOBER 14, 2015

Table of Contents

1.0 BACKGROUND ........................................................................................................................................................ 1

2.0 SCOPE OF SERVICES .............................................................................................................................................. 1

3.0 METHODOLOGY ..................................................................................................................................................... 2

4.0 OBSERVATIONS, RESULTS, AND DISCUSSION .................................................................................................... 2

5.0 RECOMMENDATIONS ............................................................................................................................................ 5

6.0 DISCLAIMER AND LIMITATIONS .......................................................................................................................... 6

7.0 SIGNATURES .......................................................................................................................................................... 6

APPENDICES

Field Documentation .................................................................................................................................................................................. A

Laboratory Report ....................................................................................................................................................................................... B

CITADEL PROJECT NO. 0069.1080.0





YUCAIPA, CALIFORNIA

OCTOBER 14, 2015

0069-1080-0_CHC_Sept-2015_Formaldehyde&Phenol_Exposure_ Monitoring_Report 1

1.0 BACKGROUND

The Subject Site is a community college located at 11711 Sand Canyon Road in Yucaipa,

California. Citadel Environmental Services, Inc. (Citadel) was contacted by San Bernardino

Community College District (Client), C/O Crafton Hills College, to provide industrial hygiene air

monitoring services. Citadel understands that personal exposure monitoring for formaldehyde

and phenol is required for individuals (1-2 people at any one time) working with cadavers in the

Crafton Hills College (CHC) Anatomy Department to evaluate existing engineering, respiratory

and personal protective equipment needs. As such, Citadel was contacted by the Client to

conduct exposure monitoring in the Cadaver Room during work with embalming fluid

(containing formaldehyde and phenol).

2.0 SCOPE OF SERVICES

All work was conducted by a knowledgeable and qualified Industrial Hygienist. Citadel’s scope

of work included the following:

1) Conducting employee exposure monitoring for formaldehyde and phenol in

accordance with NIOSH Method 2016 and NIOSH Method 2546, respectively, and

applicable standard industry sampling practices. Samples were collected during

cadaver dissection activities. A total of four (4) air samples were taken: two (2) for

formaldehyde and two (2) for phenol. Additionally, a total of two (2) field blanks were

collected: one (1) for formaldehyde and one (1) for phenol.

2) Submitting the samples to an independent accredited laboratory for analysis.

3) Preparing an Exposure Monitoring Report to include all of Citadel’s observations,

sampling data and methodologies, results and conclusions, and any subsequent

recommendations.

The sampling and monitoring activities, as described above, were completed to determine the

degree of exposure for an instructor working with embalming fluid, containing formaldehyde

and phenol. Equipment and media appropriate to the specific sampling protocols were utilized

to obtain samples during activities involving use of the embalming fluid, to determine the 8-hour

time weighted average (TWA) exposures and short-term exposure limits (STEL) for the worker. The

monitoring results were compared with recognized occupational exposure limits (Permissible

Exposure Limits, Recommended Exposure Limits, Threshold Limit Values, etc.).






YUCAIPA, CALIFORNIA

OCTOBER 14, 2015


3.0 METHODOLOGY

Air sampling was performed by Citadel’s Project Industrial Hygienist, Ms. Jessica Small, during

cadaver dissection activities on September 24, 2015.

Air Sampling and Laboratory Analyses

All of the air samples were delivered via courier to L.A. Testing in Garden Grove, California for

analysis through appropriate test methods. L.A. Testing is accredited for the analysis of

environmental and industrial hygiene samples by the American Industrial Hygiene Association

(AIHA) and the National Environmental Laboratory Accreditation Program (NELAP). All samples

were collected during the use of the formaldehyde and phenol mixture.

Employee exposure monitoring and air sampling for formaldehyde and phenol was in

accordance with NIOSH Method 2016 and NIOSH Method 2546, respectively, and applicable

standard industry sampling practices. Samples were collected on solid sorbent tubes, attached

to personal pumps via Tygon™ tubing. Sampling was performed during cadaver dissection tasks

(opening of chest cavity). The flow rates of the sampling pumps were calibrated using a

DrycalTM primary standard.

Formaldehyde: A total of two (2) air samples were taken, in addition to one (1) field blank.

Personal sampling pumps were calibrated to a flow rate of approximately 0.2 liters per minute

(L/min) for the TWA sample and approximately 0.5 L/min for the STEL sample.

Phenol: A total of two (2) air samples were taken, in addition to one (1) field blank. Personal

sampling pumps were calibrated to a flow rate of approximately 0.1 L/min for the TWA sample

and approximately 0.1 L/min for the STEL sample.

4.0 OBSERVATIONS, RESULTS, AND DISCUSSION

The monitoring was performed on September 24, 2015. A walkthrough and brief interview with

the instructor were completed to review chemical product use and existing safety controls. Field

notes are presented in Appendix A.

Walkthrough and Visual Inspection

The following observations were noted during the investigation on September 24, 2015:

The Anatomy & Physiology (A&P) Laboratory Technician (Employee ID #6850), donned

appropriate personal protective equipment (PPE) prior to entering the Cadaver Room.

PPE included full-face respirator with 3M 6005 formaldehyde/organic vapor cartridges and

integrated glasses holder; scrubs, chemical-resistant full length apron, and chemical

resistant gloves and sleeves.

STEL and TWA samples for both formaldehyde and phenol were taken during the chest

cracking procedure, when exposure is expected to be highest.

Citadel placed pumps on the instructor around 09:20am before she entered the Cadaver

Room. Citadel removed the STEL samples at 9:35am and TWA samples at 9:35am. Citadel

noted a strong odor each time the A&P Lab Technician stepped out of the Cadaver Room

to remove the STEL samples and TWA samples.






YUCAIPA, CALIFORNIA

OCTOBER 14, 2015


Formaldehyde and Phenol Sampling

Per the sampling strategy outlined in the scope of work and CHC’s Formaldehyde and Phenol

Program, Citadel collected personal (TWA and short-term) samples for both formaldehyde and

phenol. TWA sample results were calculated to reflect an 8-hour time-weighted average. The

TWA and STEL were compared to the following regulatory limits that are also in Table 1.0: Cal-

OSHA Permissible Exposure Limit (PEL) time-weighted average (TWA), the Cal-OSHA action level

(AL), the Cal-OSHA Short Term Exposure Limit (STEL), and recommended American Conference

of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value-Ceiling (TLV-C). It is

important to note that the ACGIH TLVs are only recommended guidelines used by industrial

hygiene professionals and are not developed for use as legal standards, such as OSHA PELs.

Personal Sampling

The long-term personal sampling was collected for approximately fifty-six (56) minutes, during

tasks directly involving work in the Cadaver Room and exposure to the embalming fluid

(including formaldehyde and phenol). The short-term personal sample was collected during this

same period of time, for approximately fifteen (15) minutes.

Time weighted averages (TWAs) were calculated over an eight (8) hour work day. It is

calculated by the following equation in Figure 1.0. Sample results were extrapolated to reflect

an 8-hour time-weighted average shift, with zero concentrations assumed when working with

the cadaver was not taking place, in order to more accurately compare with recognized

occupational exposure limits.

hr

CTCTCTTWA nn

8

...2211

Where T is the duration in hours of the exposure to a substance at the concentration C, and 8 hours is a work day.

Figure 1.0 Calculating TWAs

Results

Formaldehyde: The long-term personal sample concentration exceeded the Cal-OSHA AL but

was lower than Cal-OSHA PEL TWA. The short-term personal sample concentration exceeded

the Cal-OSHA STEL and the recommended ACGIH TLV-C (STEL-C).

Phenol: The long-term and short-term personal sample concentrations were lower than the Cal-

OSHA PEL, NIOSH STELs, and recommended ACGIH TLV (TWA).

A summary of the results and applicable exposure limits is presented below in Tables 1.0 and 2.0.

The laboratory analytical report is presented in Appendix B.






YUCAIPA, CALIFORNIA

OCTOBER 14, 2015


Table 1.0 Summary of Results for Formaldehyde

Sample

Number

Sample

Description

Sample

Results

(ppm)

Calculated

TWA1 Results

(ppm)

Regulatory Limits for Formaldehyde

Cal-

OSHA PEL

TWA

(ppm)

Cal-

OSHA AL

(ppm)

Cal-OSHA

STEL

(ppm)

ACGIH

TLV-C

(ppm)

F01

Personal

Sample –

(TWA)

4.7 0.56

0.75

0.5

N/A

N/A

F02

Personal

Sample –

(STEL)

7.1 N/A

N/A N/A 2 0.3

F03 Field Blank N/A N/A

N/A N/A N/A N/A

*It is important to note that ACGIH TLVs are only recommended guidelines used by industrial hygiene professionals and

are not developed for use as legal standards, such as OSHA PELs.

N/A = Not Applicable

ppm = parts per million

Table 2.0 Summary of Results for Phenol

Sample Number

Sample

Description

Sample

Results

(ppm)

Calculated

PEL TWA1

Results (ppm)

Regulatory Limits for Phenol

Cal-OSHA

PEL TWA

(ppm)

NIOSH STEL

(ppm)

ACGIH TLV

(ppm)

PO1

Personal

Sample –

(TWA)

<0.92 <0.11

5

N/A

5

PO2

Personal

Sample –

(STEL)

<3.5 N/A

N/A 15.6 N/A

PO3 Field Blank N/A N/A

N/A N/A N/A

*It is important to note that ACGIH TLVs are only recommended guidelines used by industrial hygiene professionals and

are not developed for use as legal standards, such as OSHA PELs.

N/A = Not Applicable

ppm = parts per million

1 Sample results were extrapolated to reflect an 8-hour time-weighted average shift, with zero concentrations assumed

when chemicals were not in use, in order to more accurately compare with recognized occupational exposure limits.






YUCAIPA, CALIFORNIA

OCTOBER 14, 2015


5.0 RECOMMENDATIONS During the monitoring performed on September 24, 2015:

Formaldehyde: The long-term personal sample concentration exceeded the Cal-OSHA AL but

was lower than Cal-OSHA PEL TWA. The short-term personal sample concentration exceeded

the Cal-OSHA STEL and the recommended ACGIH TLV-C (STEL-C). Citadel notes that ACGIH TLVs

are only recommended exposure limits used by industrial hygiene professionals, and are not

developed for use as legal standards (such as OSHA PELs). The TWA result that was higher than

the Cal-OSHA AL indicates that the cadaver dissection activities within the Cadaver Room are

subject to the sampling and monitoring requirements promulgated by the OSHA Formaldehyde

standard (29 CFR 1910.1048). Exposure monitoring shall occur every six (6) months for

formaldehyde.

Phenol: The long-term personal sample concentration was lower than the Cal-OSHA PEL TWA

and the recommended ACGIH TLV (TWA). The short-term personal sample concentration was

lower than the NIOSH STEL. Citadel notes that ACGIH TLVs are only recommended exposure limits

used by industrial hygiene professionals, and are not developed for use as legal standards (such

as OSHA PELs). While these results indicate that the cadaver dissection activities within the

Cadaver Room are not subject to the sampling and monitoring requirements promulgated by

the OSHA Guidance for Phenol, Citadel recommends annual exposure monitoring for phenol

given the lack of historical phenol exposure monitoring data.

Based upon sample results, Citadel additionally recommends that the following:

Continued implementation of existing engineering controls including isolation activation

of the exhaust system during periods of formaldehyde and phenol use/exposure.

Continued implementation of the existing safety programs, including (but not limited to):

o Adhering to the policies and procedures described in CHC’s Formaldehyde and

Phenol Program and Chemical Hygiene Plan;

o Providing, maintaining, and ensuring the employees don appropriate respiratory

protection. The use of respirators shall be in accordance with the OSHA

Respiratory Protection Standard 29 CFR.1910.134. Employees must also receive

training and be medically approved and fit-tested prior to donning a respirator;

o Providing, maintaining, and ensuring the employees don appropriate PPE;

o Ensuring that employees receive initial and annual hazard communication and

formaldehyde and phenol safety training;

o Ensuring proper storage, handling, labeling, decontamination and disposal

procedures for formaldehyde and phenol use are being followed.

Continue providing medical surveillance and air monitoring, per the OSHA

Formaldehyde standard (29 CFR 1910.1048) and OSHA Guidance for Phenol, on

instructors who perform dissections in the Cadaver Room.

o Based on the sample results, this shall include monitoring every six (6) months for

formaldehyde and annual monitoring for phenol, or more often if employees

experience signs or symptoms of respiratory or dermal conditions associated with

the formaldehyde and phenol exposure.

o Periodic monitoring for employees may be discontinued if results from two

consecutive sampling periods (taken at least 7 days apart) show that employee






YUCAIPA, CALIFORNIA

OCTOBER 14, 2015


exposure is below the Cal-OSHA action level and STEL for formaldehyde, and

below the PEL for Phenol.

6.0 DISCLAIMER AND LIMITATIONS

This report has been prepared by Citadel Environmental Services, Inc. exclusively for our Client

and their Authorized Representatives. The information contained herein pertains only to issues

reported by the Client to be present at the referenced property which were evaluated in

accordance with a mutually agreed upon scope of work. The findings and recommendations

presented are based upon observations of present conditions, and may not necessarily indicate

future conditions. Citadel Environmental Services, Inc. implies no warranty to the accuracy of

information provided to them by the Client or outside agents and transmitted herein. The

information contained herein may not be used, disclosed, or copied without written permission

of the Client.

7.0 SIGNATURES

All work was conducted in accordance with Client-established protocols, and the standards of

care and diligence normally practiced by recognized consulting firms in performing services of a

similar nature.

Work Completed By:

[see field documentation for signature]

Jessica Small

Project Industrial Hygienist

Report Reviewed By:

Nalinna Rasu, CAC, CDPH, CHMM, LEED AP

Director, Environmental Compliance

Attachments

AppendixAFieldDocumentation

AppendixBLaboratoryReports

LA Testing 11652 Knott Street, Unit F5, Garden Grove, CA 92841

Order ID: 331517533

Attn:

Fax:

Phone:

Email:

Report Date:

Nalinna Rasu

Citadel Environmental Services, Inc.

1725 Victory Boulevard

Glendale, CA 91201

818-246-2707

10/01/15

Customer ID:

Customer PO:

Date Received:

LA Testing Order:

Project:

Date Analyzed:

32CITA50

0069.1080.0

09/24/15

331517533

CHC 2015 Form / Phen Personal

Sampling / 0069.1080.0

09/28/15

FORMALDEHYDE by NIOSH 2016M, Issue 2, March 2003

SKC 226-119

Sample received in acceptable condition unless otherwise noted. This report relates only to the samples reported above. This report may not be reproduced except in full, without written approval by LA Testing. Quality Control Data associated with this sample set is within acceptable limits. The results for this sample set have not been blank corrected. Tube front and tube back analyzed separately, tube backs are ND unless otherwise indicated.

JD

Analyst Michael Chapman, Laboratory Manager

AIHA Accredited - Laboratory ID #101650

Page 1 of 1

LA Testing

Sample ID

Client ID

Air

Volum

e

(L)

Component Result

(µg/sample)

Result

(ppm)

Reporting

Limit

(µg/sample)

331517533-0001 F01 11.4 Formaldehyde 66 4.7 0.10

331517533-0002 F02 7.5 Formaldehyde 66 7.1 0.10

331517533-0003 F03 - Formaldehyde <0.10 N/A 0.10

OrderID: 331517533

Page 1 Of

2

OrderID: 331517533

Page 2 Of

2

LA Testing 11652 Knott Street, #F-5, Garden Grove, CA 92841

Order ID: 331517545

Attn: Nalina Rasu

Citadel Environmental Services, Inc.

1725 Victory Boulevard

Glendale, CA 91201

Customer ID:

Customer PO:

Date Received:

32CITA50

0069.1080.0

09/24/15

Fax:

Phone:

818-462-2707

LA Testing Order: 331517545

E-mail:

Project:

CHC 2015 FORM/PHENOL

Personal Sampling

Report Date: 10/01/15 Date Analyzed: 09/29/15

Phenol in SKC 226-95 with NIOSH 2546M

MNH

Analyst Michael Chapman, Laboratory Manager

Or other approved signatory

AIHA Accredited - Laboratory ID #101650

Page 1 of 1

Sample received in acceptable condition unless otherwise noted. This report may not be reproduced except in full, without written

approval by LA Testing. Unless otherwise noted, the results in this report have not been blank corrected. Quality Control Data

associated with this sample set is within acceptable limits, unless otherwise noted.

Sample ID

Volume

(L)

Lab ID

Analyte

mg/tube

ppm

Reporting Limit

(mg/tube)

PO1 5498300803 5.7 331517545-0001 Phenol <0.020 <0.92 0.020

PO2 5498300795 1.5 331517545-0002 Phenol <0.020 <3.5 0.020

PO3 5498300797 NA 331517545-0003 Phenol <0.020 NA 0.020

OrderID: 331517545

Page 1 Of

2

OrderID: 331517545

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2

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