Industrial Hygiene Monitoring

Phoenix has conducted a variety of industrial hygiene services, both comprehensive and limited, for a wide range of industry related work activities and parameters in anticipation of litigation. Industrial hygiene services were conducted in response to regularly scheduled monitoring events, employee complaints or emergency incidents. All sampling procedures were performed in accordance with standard industry methodology (e.g. National Institute of Occupational Safety and Health [NIOSH] and the Occupational Safety and Health Administration [OSHA]). Phoenix provided a wide range of both personal and area monitoring. Air monitoring campaigns included, but were not limited to the following: respirable silica, diesel exhaust, airborne lead, welding fumes and hexavalent chromium. Phoenix has also conducted extensive noise monitoring campaigns in a variety of indoor and outdoor environments.

Phoenix was often directed to conduct an exposure assessment of a facility or a facility process to identify potential risks to employees. Phoenix evaluated all aspects related to the facility or process to determine the level of employee occupational exposures. Once the potential exposures were identified, Phoenix developed a sampling plan to monitor for the potential exposures. The sampling campaign typically consisted of collecting personal and area samples for a full working shift (typically 8 to 12 hours). Collected samples were submitted to qualified American Industrial Hygiene Associated (AIHA) accredited laboratories for analysis.

Upon receipt of laboratory results, Phoenix reviewed the analytical results to identify those constituents to which employees may be overexposed. The results were compared to industry standards including, but not limited to, OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), NIOSH Recommended Exposure Limits (RELs), AIHA Workplace Environmental Exposure Limits (WEELs) and company instituted exposure limits. If requested, Phoenix also assisted in determining corrective actions to reduce occupational exposure (e.g. implementation of engineering controls, administrative controls, etc.) This may have included altering an existing process, change of raw material or the introduction of personal protective equipment to protect the employee(s).

Reports included the monitoring activities, methodology, facility description, data summary, conclusions, laboratory reports, photographs and recommended actions.

Industrial Hygiene Program Development and Implementation

Phoenix was tasked with assisting in the development and implementation of industrial hygiene processes and programs. Phoenix utilized current OSHA regulations to create processes specifically tailored to meet the client’s needs. Processes developed included, but were not limited to, Confined Space, Hazard Communication, Control of Hazardous Energy, Worker Exposure Monitoring, Biological Monitoring (Blood Lead Monitoring, Legionella Monitoring), Radiation Exposure, Heat Stress, Cold Stress, and Personal Protective Equipment. These processes were implemented to assist facilities in ensuring compliance with applicable OSHA regulations. The processes allowed for consistency in both routine operations and during response activities.

The processes developed by Phoenix were developed based on OSHA regulations and internal company policies. Each process identified requirements which must be met by each facility; this included process documentation, inspections and required reviews of existing programs. These processes were developed to provide facility employees with a consistent set of guidelines to follow to ensure compliance with applicable regulations.

In addition, Phoenix personnel were tasked with implementing Confined Space and Control of Hazardous Energy programs throughout the client’s operating system. This was a large undertaking due to the sheer volume of facilities across the system. Phoenix assisted the client with developing a process to identify confined spaces at every facility. Once the confined spaces were identified at a facility, Phoenix determined if proper training had been conducted, appropriate equipment was available and functional and proper documentation was maintained. Phoenix assisted the client with mobilizing and managing a team of contractors to visit every facility to identify each piece of equipment which requires lockout / tagout procedures. The contractors then provided each piece of equipment with lockout / tagout procedures to be followed by the facility employees.

Industrial Hygiene Compliance Training

Through specialized air monitoring campaigns, Phoenix assisted their client in identifying a potentially negative employee exposure occurring during welding operations conducted on frogs. Rail frogs are intersections between two rails at a crossing, with clearances or channels for the wheel flanges to pass through when going in any direction from one track to the other. Welding fumes are generated during the frog repair operations. Welding fumes have the potential for causing occupational injury and / or illness. Air monitoring of employees performing welding operations on frogs resulted in the identification of higher than acceptable levels of hexavalent chromium present in the welding fumes. As a result, Phoenix assisted in the identification and implementation of engineering controls for use during frog welding operations. Air monitoring conducted by Phoenix determined the usage of a portable fan during welding reduced hexavalent chromium constituents below regulatory permissible exposure limits. As a result, new processes were required to be implemented throughout the system. In response to this need, Phoenix assisted in the development of a training video directed to all employees who may conduct welding operations on frogs. The training video identified who was affected by the new requirements, potential health effects in association with the inhalation of hexavalent chromium fumes and specific instructions for the implemented frog welding procedure. Phoenix developed the script for the video and assisted a media publications contractor in designing the scenes for the video.

Locomotive Horn Testing

In accordance with the Federal Railroad Administration’s Rule, Use of Locomotive Horns at Highway-Rail Grade Crossings, all locomotives must be certified for compliance with 49 CFR Part 222 and 229 by June 24, 2010. This rule has been promulgated to ensure compliance with federal locomotive horn regulations enacted to protect the public at large at highway-rail grade crossings. The locomotive horn testing device designed and patented by Phoenix allows the client to comply with Rule 49 CFR Part 222 and 229 with minimal disturbance to normal operations, minimizing employee noise exposure to horn soundings.

The regulation specifies a range of meteorological conditions. Phoenix designed the locomotive horn testing device and all associated appurtenances to be solar powered, free standing and self contained; no phone or electrical wires are necessary to operate the device. It is capable of daily, electronic self-calibration checks and records ambient air temperature, relative humidity and wind velocity. In compliance with the Rule, the sound level meter on the device exceeds the International Electrotechnical Commission Standard 61672-1 for a class 2 instrument. The decibel level of the locomotive horn is tested by sounding the horn six times for 10-second intervals. Immediate results are displayed to allow the tester to determine appropriate actions such as repair or replacement of the horn. Once the horn has been tested, decibel levels, meteorological data and calibration data can be downloaded via communications or Ethernet to a central computer for processing and certifications.

The regulation specifies a range of meteorological conditions which must be satisfied for horn testing. Therefore, when meteorological conditions are not conducive to testing, an indicator light mounted on the device allows locomotive operators to quickly and easily determine when horns can and cannot be tested. A separate light will be activated to indicate if the resulting locomotive horn decibel level is within the acceptable decibel range on the A-weighted scale (96dBa – 110dBa). From start to finish, the estimated time for a locomotive operator to complete the horn test is less than six minutes.

Health and Safety Air Monitoring Campaigns and Program Development

Phoenix has conducted a variety of industrial hygiene services, both comprehensive and limited, for a federal interagency law enforcement training organization. Industrial hygiene services were conducted in response to regularly scheduled monitoring events, management concerns, federal regulations or emergency incidents. All sampling procedures were performed in accordance with standard industry methodology (e.g. National Institute of Occupational Safety and Health [NIOSH] and the Occupational Safety and Health Administration [OSHA]).

Air monitoring campaigns included, but were not limited to, airborne lead, copper, tin, zinc and a variety of other heavy metals and nitroglycerine. Phoenix also conducted numerous extensive noise monitoring campaigns. Phoenix is often requested to observe federal agent training activities and maintenance tasks to evaluate the processes to determine potential negative exposures or stressors to the trainers, students or maintenance staff.

A primary concern for the training facility was lead ammunitions used on the training grounds in firing ranges and in various training scenarios. Exposure to lead was evaluated by Phoenix to ensure lead emissions were properly captured and appropriate disposal procedures were followed. Firing ranges utilizing lead ammunitions were evaluated by Phoenix to ensure procedures were adequate to effectively limit exposure to lead as stated in 29 CFR 1910.1025. Phoenix verified the air handling systems were functioning as intended, recommended good housekeeping procedures were adhered to and maintenance staff was closely monitored during routine cleaning of the ranges and air handling units. Phoenix worked closely with the facility medical staff to ensure personnel were enrolled in the proper medical surveillance programs, informed of exposures in a timely manner and utilized the appropriate personal protective equipment.

If lead levels were determined to be at or above the Action Level or Permissible Exposure Level, Phoenix evaluated the process to determine if the exposure could be reduced to below applicable standards. If no viable options were available to eliminate or reduce the exposure, Phoenix recommended engineering and/or administrative controls (including introduction of personal protective equipment) to reduce the lead exposure to facility staff and students.