Industrial Hygiene in the BP Oil Spill Event: What's Public and What We Should Learn From the Event

1. Industrial Hygiene in the BP Oil Spill Event: What's Public and What We Should Learn From the Event Thomas Grumbles, CIH Senior Consultant Cardno ENTRIX California Industrial Hygiene Council December 6, 2010

2. The most “public” emergency response event to date

3. Scope Of Work • At the peak of activity • 47,848 workers • 8,044 vessels • 123 aircraft   • $65 million /day • September 20 • 25,200 workers • 2,600 vessels • dozens of aircraft • November 12 • 9,300 workers • 135 vessels • $27 million/day • Federal response led by the U.S. Coast Guard under the National Contingency Plan

4. BP IH Activity • Source strategy different from on shore/near shore strategy • Source Strategy ( BP Source Monitoring Strategy ) • On-Shore Strategy ( BP Onshore Monitoring Strategy ) • Sampling results are published in two ways: ( BP IH Data ) • Summary form • Full details • Personal monitoring results mostly indicate there are no significant exposures to airborne concentrations of chemicals of interest • >200 industrial hygienists and technicians to monitor area and personal exposures in the identified work areas • As of 15th October 2010, • ~70 industrial hygienists providing support to the ongoing restoration • ~23,000 personal samples collected

6. Area and personnel monitoring during: On Shore and Near Shore Monitoring Strategy 4 “strike teams” PBZ for BTEX, Total hydrocarbons (THC) Area for VOC’s, CO, LEL and Benzene Priority was decontamination activity Goal to sample 10% of identified groups Professional judgment for additional monitoring Action levels developed for taking specific control actions • Beach clean up • Vessel decontamination • Wildlife decontamination • Skimming operations • Boom deployment and retrieval operations • Area monitoring in response to odor complaints

7. Off Shore (Source) Monitoring Strategy • Monitoring plan purpose: • Protect potential downwind receptors • Protect worker health • Support safe operations with task monitoring • Action levels developed for taking specific control actions • Every vessel assigned to the source area was equipped for monitoring

8. Off Shore (Source) Monitoring Strategy • VOC’s (THC) • Benzene • H2S • Oxygen • LEL • CO • PM10 • SO2 Area and personnel monitoring

9. BP Sampling Results: Summary

10. BP Sampling Results: Full Details

11. OSHA Activity thru 10/1/10 • OSHA averaged over 146 professionals throughout the Gulf Region during the event • The Agency developed a sampling protocol and strategy and took samples resulting in over 5,731 exposure assessments (exposure assessments) • To date, no air sampling by OSHA has detected any hazardous chemical at levels of concern. (Spill Home Page) • All OSHA results are posted (sampling results) OSHA staff made over 4,266 site visits to: vessels of opportunity staging areas decontamination sites offshore and onshore clean up activities

13. OSHA Activity thru 10/1/10 • OSHA averaged over 146 professionals throughout the Gulf Region during the event • The Agency developed a sampling protocol and strategy and has taken samples resulting in over 5,731 exposure assessments (exposure assessments) • To date, no air sampling by OSHA has detected any hazardous chemical at levels of concern. (Spill Home Page) • All OSHA results are posted (sampling results) OSHA staff made over 4,266 site visits to vessels of opportunity staging area decontamination sites offshore and onshore clean up activities

15. OSHA Sampling Strategy: What hazards to evaluate in an event like this? • Most of the cleanup workers are exposed to “weathered oil” • more volatile substances have evaporated • Potential health effects from inhaling other non oil chemicals • oil dispersants, cleaning agents, and others are an ongoing concern Among the many hazards workers face--such as falls, drowning, fatigue, sharp objects and animal bites--the number one health concern was heat stresswith more than 700 incidents reported by 8/16

16. OSHA Sampling Strategy: Systematic approaches to assessing hazards • OSHA devised a systematic approach to assess hazards, a Sampling Strategy, to characterize and document hazards of commonly observed work activities • “OSHA is also analyzing the "soup" of crude oil, oil by-products, dispersants, and any other material to determine what hazards the mixture might present workers as they respond to and cleanup the oil spill”

17. OSHA Sampling Strategy

18. OSHA Sampling Strategy

19. APPLICABLE OEL’S • OSHA recognizes that most of its PELs are outdated and inadequate measures of worker safety. • Crude oil is a complex mixture of chemical constituents that are not easily addressed by exposure limits for individual substances • In characterizing worker exposure OSHA instead relies on more up-to-date recommended protective limits set by organizations such as NIOSH, ACGIH, and AIHA, not on the older, less protective PELS • Results of air monitoring are compared to the lowest known OEL for the listed contaminant for purposes of risk assessment and protective equipment recommendations

20. NIOSH Health Hazard Evaluations (HHEs)

21. NIOSH HHEs • Evaluation of the hospitalization of  7  Fishermen on May  26 • Conclusion: Given the various descriptions and unspecified sources of the reported odors, the uncertain timing of the symptoms in relation to use of a new cleaner, and symptoms that could be related to a variety of causes: • it  is  unlikely  that  a  single  specific  trigger  for the reported symptoms can be determined • Dispersant  use  appears  unlikely  to  be  the  source  of the symptoms • symptoms  were  more  likely  to  have  been  aggravated  by  several  contributing  factors,  including  unpleasant  odors,  heat, and fatigue.  

22. NIOSH HHEs • June  4‐5  evaluation of M/V International Peace and MV  Warrior  Dispersant  Mission • Industrial  hygiene  surveys,  health  symptom  survey and  medical  interviews  during  a  small  scale dispersant mission • PBZ  and  area  air  concentrations  of  the contaminants measured  were  all  well  below  OELs • NIOSH  investigators  did  observe  the  potential  for  dermal contact with  the  dispersant   • On June 14-16 PBZ and area air concentrations of the contaminants measured during an oil skimming mission aboard the M/V Queen Bee were below occupational exposure limits

23. NIOSH HHEs • June 8–10 evaluation of In-situ Oil Burns • Based on sampling conducted over two days on ignition boats and vessels towing boom during burns, NIOSH investigators found exposures for all compounds sampled to be well below applicable OELs • One exception: peak exposures to CO recorded on the vessels due to exhaust from gasoline powered engines

24. NIOSH HHEs • June 25 evaluation of Barge Oil Vacuuming Operations in Coup Abel Pass Louisiana was conducted • Limited activity to sample • Safety and noise observations: • For example: A few workers wore safety harnesses. The harnesses were not tied off to any structure on the barges to arrest the workers’ fall

25. NIOSH HHEs • June 21-25 industrial hygiene surveys and self-administered health symptom surveys aboard two vessels at the site of the oil release • Airborne concentrations for all contaminants evaluated were well below applicable OELs • Some increase in psychosocial symptoms, reported on one vessel

26. NIOSH HHEs • September evaluation of 1,899 workers at 67 work sites in Louisiana, Alabama, Florida, and Mississippi • Surveys and interviews • Heat stress was the primary occupational health hazard for most shore cleaning workers • Ergonomic hazards from the unique work required to clean oil residue from sandy beaches • Use of tools that were never designed for this task • Workers had designed “homemade” tools that were more effective than standard tools

27. NIOSH HHEs • October evaluation and quantitative exposure assessment at two decontamination sites in Port Fourchon, Louisiana • Heat stress was the primary occupational health hazard for most repair/decontamination and waste management workers exacerbated by the use of personal protective equipment • Where measured, airborne concentrations of measured contaminants, including 2-butoxyethanol and other glycol ethers, limonene, benzene, ethyl benzene, toluene, xylenes, total hydrocarbons, diesel exhaust, PAHs, and CO were all well below OELs • Monitoring showed the potential for noise exposures above the NIOSH REL during pressure washing • Repair/decontamination and waste management workers faced ergonomic hazards from unique work activities such as handling and moving booms and other equipment to be cleaned and the actions associated with operating the pressure washers

28. Lessons Learned • Communication of large amounts of exposure data to unknown audiences is …..difficult • Conclusions from data for multiple diverse and constantly changing events is a challenge….patience is needed • Traditional IH monitoring strategies …may not suffice for large scale events • The public nature and political pressures involved in high profile events can result in good science being “underutilized”

29. Communicating Monitoring Results • BP June monthly summary report • Graph indicated 210 samples of 893 showed exposures between non detect and 10 ppm for 2-butoxyethanol • July 9 New York Times article • The Valdez-linked chemical 2-butoxyethanol was detected at levels up to 10 parts per million (ppm) in more than 20 percent of offshore responders . • Week of July 16 OSHA rebuttal • The headline is based on an incorrect interpretation of a misleading chart produced by BP. OSHA's analysis of the raw data reaches a very different conclusion • Sampling is not done randomly and is not necessarily representative of all exposed workers; in general, sampling is performed on workers who are most likely to have the heaviest exposures