June 8, 2010 Liz Borkowski, MPH 14Comment

Melanie Trottman reported in the Wall Street Journal last week that US Representatives James Oberstar and Jerrold Nadler have demanded that Gulf response and recovery workers be provided with respirators (among other protective equipment), but OSHA doesn’t think respirators should be required:

David Michaels, assistant secretary for the Department of Labor’s OSHA, said in an interview Thursday that based on test results so far, cleanup workers are receiving “minimal” exposure to airborne toxins. OSHA will require that BP provide certain protective clothing, but not respirators.

The “based on test results so far” phrase is key.

We know oil contains toxic compounds (see Deborah Blum’s helpful explanations on oil and oil-dispersant mixtures at Speakeasy Science for details), but we don’t know how much of its constituent chemicals workers are likely to breathe in. Given that we have thousands of workers doing a variety of jobs across a multi-state area, appropriate monitoring is a challenge. Workers handling controlled burns will get different exposures from those laying booms or cleaning beaches.

Elizabeth reported here yesterday about the air monitoring results that OSHA has just released; they cover sampling performed at two beach cleanup locations and on board one vessel, and OSHA’s conclusion was that data do not indicate workers “are being exposed to hazardous levels of substances or agents.”

Previously, OSHA stated that its recommendations were based on BP data, and they may still be using BP data in addition to their own. Presumably, OSHA can get the raw data from BP and its contractors and judge whether the sampling protocols are adequate. Member of the public have to content themselves with visiting OSHA’s website and accessing a BP summary report, which doesn’t provide details on where and how air samples have been taken. The report states that “approximately 400 personal samples have been taken” and that personal monitoring is going on in three work areas. The BP report shows the number of benzene and hydrocarbon samples with results falling into different ranges, with none of the benzene samples falling below the action limit of 0.5ppm and none of the hydrocarbon samples reaching the VOC action limit of 100ppm. It does not show results for other substances.

What needs to be happening in the Gulf is a large-scale exposure assessment of the individuals involved in the hazardous material clean-up efforts. Exposure assessments identify the chemical, biological, and physical agents present in a work environment and evaluate the extent to which workers in that environment are exposed to those agents. It’s important to consider different routes of exposure, since some agents are inhaled, others penetrate the skin, and some do both.

Ideally, those conducting exposure assessments consult with workers to identify the many different tasks they perform, the possible agents of concern, and which tasks pose the greatest potential risk for workers’ exposure to the hazards in the work environment. A thorough exposure assessment will strive to evaluate workers’ exposures during typical work-shift circumstances. Assessments can focus on the workers who are expected to have the greatest potential for exposure; this can give the people relying on the results greater confidence that workers in other settings have less exposure to the agents being assessed. It’s also helpful if exposure assessments can consider agents that may not yet have been identified as having adverse health effects, but that might turn out to play a role in health outcomes upon further analysis.

Difficulties in the Gulf
I do want to note that some hazards of the oil response work are relatively straightforward – things like heat illness and unintentional injury – and the WSJ article reports that OSHA is paying attention to those. But then there are several ways the situation in the Gulf makes it hard to follow good occupational health procedures.

If exposure assessments show that workers performing certain tasks are exposed to measurable levels of toxic substances, precautions must be taken. In many workplaces, employers can eliminate a harmful substance from the work environment, substitute a less-toxic alternative, or use engineering controls to reduce exposures. That’s not so easy in the Gulf, since the geyser of oil is hard to control and oil cleanup workers have to handle oil as part of their jobs.

When exposures can’t be completely eliminated, the goal is to get them within safe levels – but we have too little information about “safe” levels of many of the substances present (which include oil in various states, dispersants, smoke from controlled burns, UV, etc) either individually or in combination. OSHA has admitted for decades that its exposure limits for toxic agents are scandalously out of date, so we can’t rely on OSHA permissible exposure limits to tell us whether workers’ exposures to these compounds are likely to harm their health. A preacautionary approach suggests we should consider the exposures harmful in the absence of evidence to the contrary.

If employers have done all they can to eliminate or control harmful exposures but workers are still exposed to a hazard, personal protective equipment like respirators is a logical next step. Occupational health advocates are often reluctant to recommend respirators, though, because they’re not a great solution. They’re uncomfortable to wear – especially in hot, humid conditions like the Gulf in summer; they impede communication; and they can even be hazardous to people with respiratory or other health problems.

If, despite their drawbacks, respirators turn out to be the best option for some groups of Gulf cleanup workers, BP will need to provide the workers not with just any old respirator, but with one approved for use with the substances they’re encountering. The N95 respirators that were widely used during the swine flu pandemic aren’t approved for use with oil. Respirators also need to be properly fitted to make sure they work as designed, and people with facial hair can’t get a proper fit.

One possibility is to give workers extensive training on the different exposures, what we know and don’t know about health risks, how to use respirators and the pros and cons of their use – and then let individual workers decide whether to wear them on or not. If the respirators aren’t required, though, some workers who consider respirators their best option might forgo wearing them anyway if their co-workers are going without.

Based on some comments I’ve heard and seen, I think some people believe that supplying and using respirators in the Gulf is the simple, obvious, and easy thing to do. Respirators may be necessary for some Gulf workers, but they’re not a panacea. OSHA should be working to get the best exposure data they can for different workers in different locations, and using it to make exposure-reduction recommendations that involve a variety of tools from the occupational health toolbox.

14 thoughts on “Are Respirators Necessary in the Gulf?

  1. Nah. Respirators make no sense.

    They won’t stop enough of volatile compounds, you need gas masks for it. And concentrations of volatiles from the oil spill honestly can’t be high enough to be dangerous.

    People in labs are routinely subjected to similar chemicals without much problems.

  2. There is very little that is more frustrating to me than scientists who misuse their own jargon. Crude oil IS NOT TOXIC! It is clearly hazardous, but it does not meet the scientific or regulator definition of toxic.

    OSHA’s definition of toxic is below, and Wikipedia has a nice description of toxicity, which includes the definition that the GHS will use to define toxic.

    This link [http://www.epa.gov/chemrtk/pubs/summaries/crdoilct/c14858tp.pdf] includes a pretty extensive discussion of crude oil, and notes that the oral LD50 in rats is >5,000 mg/kg, and the dermal LD50 in rabbits is >2,000 mg/kg. Both of those values put crude oil outside of the definition of toxic, for both OSHA and GHS.

    I realize it’s all the rage right now to throw around the word toxic to make a point, but scientists shouldn’t allow themselves to get caught up in the hype and ignore the science just to be part of the crowd.

    OSHA Definition of toxic (from 29 CFR 1910.1200 Appendix A)

    6. “Toxic.” A chemical falling within any of the following categories:

    (a) A chemical that has a median lethal dose (LD(50)) of more than 50 milligrams per kilogram but not more than 500 milligrams per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each.

    (b) A chemical that has a median lethal dose (LD(50)) of more than 200 milligrams per kilogram but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each.

    (c) A chemical that has a median lethal concentration (LC(50)) in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than two milligrams per liter but not more than 20 milligrams per liter of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each.

  3. IMO, the while bunny suits and masks are just not needed in most cases. Even the gloves and rubber boots are more about not getting less easy to clean coverings dirty than any actual protective function.

    There are situations where respirators are needed. Anywhere where the fumes are thick and clearly oppressive a respirator is a good choice. Working in crude tanks, pump rooms, and areas with huge volumes of crude exposed are likely spots.

    People wearing Tyvek bunny suits with gloves and boots taped on and wearing masks as they double bag half a shovelful of tar balls strikes me as over the top.

    Picking up tar balls gloves keep your hands clean and remove any need to use harsh chemicals to remove the goo. Boots avoid getting your shoes dirty. The double bagging and Tyvek suits seem like a waste of resources.

  4. Mark – You’re right, I should have said “oil contains toxic compounds” – I fixed it above.

    Art – Tyvek suits must also be uncomfortable (and potentially hazardous) under hot, humid conditions. Dermal exposures are definitely a concern, though, and ordinary gloves may not give enough protection.

  5. Mark: I’m not quite as quick as Liz to give you a pass on this one. What exactly is your point? There is no “official” scientific definition of “toxic,” since it depends heavily on context. The potential toxicity of the mixture that is crude oil is beyond doubt in many test systems and the hair splitting about “hazardous” versus “toxic” seems merely to obscure the point: that we don’t know about the health effects of these exposures with any confidence. We need to have good exposure assessments that are representative, inclusive and also make the effort to provide an accurate inventory of things to which people may be exposed. This may entail a research level effort at first but it is an effort that needs to be made.

    Alex:We don’t know if respirators are needed (no one says “gas masks” any more) until we know to what and how much people are being exposed. We need a quick assessment to find the really bad spots and provide exposure relief and a more extended and systematic assessment to get a better, accurate and more in depth look. Until then I’m not willing to make aa judgment.

  6. [b]… ordinary gloves may not give enough protection.[/b]

    True that. I chuckle when I see video of people wearing latex gloves messing around with the oil. Neither petroleum products nor sunshine are compatible with latex. Nitrile, PVC or vinyl would be my choice.

    But disposable ‘examination gloves’ aren’t my choice anyway because they are thin, single use, and leave the wrists exposed.

    I would go with a heavy-duty coated cotton lined version with a good 6″ cuff because they are reusable and give more coverage. In the sun in hot weather gloves are miserable to wear. So people take them off when not in use. The heavy-duty gloves can be taken off and put back on many times. Disposable gloves are trash once you take them off. Adding a pile of single-use disposable gloves to any oil or tar you clean up seems wasteful, counterproductive.

    I would lean toward wearing boots, carry a bucket and using a trowel to pick up tar balls. Keeping a pair of forearm length heavy-duty gloves in my back pocket but avoiding using gloves at all if possible.

    Hand cleaners used by mechanics (Go-Jo. Fast Orange or similar), petroleum jelly, or turpentine will take off any tar/goo spots you get on you, your clothes, tools.

    If your a careful sort you might want to wear safety glasses. Getting crude oil in your eye won’t do you any good.

    Yes, crude oil has some level of toxicity, and there is some risk. But life is 100% fatal and always risky. I’m not likely to get naked and roll around in crude but I have an issue with people using an excessive amount of protective gear, equipment that is often manufactured from oil, to avoid any possible exposure to even the slightest amount of oil. It isn’t radioactive or immediately toxic to life in small quantities. You don’t need a fully sealed hazmat suit to pick up a few tar balls on a otherwise relatively clean beach.

    Simple, practical precautions and common sense will do in my humble opinion.

  7. The crude oil is toxic!! Workers cleaning the oily Gulf beaches need to know the danger. Don’t become BP’s Collateral Damaged, like Exxon’s Collateral Damaged.


    My name is Merle Savage, a female general foreman during the Exxon Valdez oil spill (EVOS) beach cleanup in 1989. I am one of the 11,000+ cleanup workers from the Exxon Valdez oil spill (EVOS), who is suffering from health issues from that toxic cleanup, without compensation from Exxon.

    Dr. Riki Ott visited me in 2007 to explain about the toxic spraying on the beaches. She also informed me that Exxon’s medical records and the reports that surfaced in litigation by sick workers in 1994, had been sealed from the public, making it impossible to hold Exxon responsible for their actions.

    Exxon developed the toxic spraying; OSHA, the Coast Guard, and the state of Alaska authorized the procedure. Beach crews breathed in crude oil that splashed off the rocks and into the air — the toxic exposure turned into chronic breathing conditions and central nervous system problems, neurological impairment, chronic respiratory disease, leukemia, lymphoma, brain tumors, liver damage, and blood disease.

    My web site is devoted to searching for EVOS cleanup workers who were exposed to the toxic spraying, and are suffering from the same illnesses that I have. There is an on going Longshoreman’s claim for workers with medical problems from the oil cleanup. Our summer employment turned into a death sentence for many — and a life of unending medical conditions for the rest of Exxon’s Collateral Damaged.

  8. I’m with revere on the ‘hair-splitting’ part, and I want to highlight his point AGAIN

    we don’t know about the health effects of these exposures with any confidence

    I agree with you all that there needs to be very extensive exposure assessment, not least because this will not be the last oil cleanup, and the next time, we’ll STILL have the same problem of not knowing how safe is safe.

    I want to raise some issues that I haven’t come across (or may have missed) in reading prior posts. Boats are not like regular workplaces. These fishermen are out there on the ocean, not just during ‘work’ hours, but also when they are ‘off duty’. I don’t know whether they move their boats out of the contaminated areas as a team, or whether they just stay in the area and take shifts. Even if, and it’s a big if, that they ‘only’ work the usual 8 hours a day, it’s likely that they are in fact being exposed for much longer periods than in other occupational settings.

    In addition, there’s the issue of decontamination, laundry, and personal hygiene. I don’t know how well they can do decon on these small boats, or whether there are dedicated decon vessels. My understanding (and I may be incorrect) is that they stay out on the ocean for days. So the question is, do they have adequate access to clean clothes should their own clothes be inadvertently contaminated? Do they have adequate supply of clean water for personal hygiene? Do they ‘wash’ their boat decks with seawater? If yes, can they find uncontaminated seawater to do the washing?

    I was reading about the Exxon Valdez cleanup. It seemed that very often the fishermen just spent many hours working on the cleanup AND THEN they take breaks or go to sleep in the clothes that they worked in, and only got a chance to shower and change when they got back to shore, so the crew sleeping quarters were in fact reeking of chemicals the whole time!!

  9. SusanC, those are excellent questions about workers on boats. I don’t know the answers, but will see if we can find out.

  10. revere: First, I don’t think “hazardous” versus “toxic” is splitting hairs. I think that in common usage “hazardous” implies that you may become sick or injured, but “toxic” implies that you will die. Here are the definitions from Merriam-Webster: Hazardous; 2: involving or exposing one to risk (as of loss or harm); synonyms see dangerous. Toxic; 1: containing or being poisonous material especially when capable of causing death or serious debilitation. I don’t think those are subtle differences. I’ll get to my point in the third paragraph.

    Second, almost all of the chemicals in use in this country have an MSDS, created by the chemical manufacturer and used by employers and workers. All of those MSDSs use the OSHA definition of “toxic.” In other words, the OSHA definition is being used by almost everyone (even if they don’t know it). That seems to me to make it an authoritative and universally accepted definition. That doesn’t mean that everyone necessarily agrees with the definition, but everyone is using it.

    Now to my point: I am concerned with risk perception, and when it comes to the use of the word “toxic” I’m constantly reminded of the boy who cried wolf. Desensitization is a pretty well studied within the world of media. Admittedly the research predominantly involves violence on television, but I don’t think it’s a huge leap to apply the same psychology to risk. The glaring examples today are the two wars we are currently engaged in. Most days neither one of them makes the nightly news, and I would be willing to bet real money that if you took a poll, at least 30% of the people in the US would say we have pulled our troops out of Iraq. That is desensitization.

    To bring this into the occupational realm, in the 80’s and early 90’s we had a lot of chemical plants blowing up around the country, some spectacularly so. One of the common causes was that in some plants the operators were hearing/see so many alarms that they bypassed the alarm systems. Some of the reasons for the alarms being shut off were that the trigger points were set too low and many of the alarms were unnecessary. The upshot is that operators had become desensitized to the alarms and didn’t always recognize when something bad was about to happen until it was too late (this is also a great study in unintended consequences).

    If we constantly bombard people with “this is toxic, that is toxic, everything is toxic,” the word itself begins to lose meaning. Those of us of a certain age remember Love Canal and the shear panic that swept the country when the word “toxic” was used. Would that happen today? I don’t think so. Sure, there would be local anger, but national fear? Nope. My suggestion is that we stop using the word toxic for everything under the sun and save it for times when people are likely to die, your local chemical plant releasing 15,000 pounds of chlorine is an example that comes to mind.

    But also, if we don’t use a common definition, then where does it end? In San Francisco in 2007 Jennifer Strange literally drank herself to death, with water (http://www.msnbc.msn.com/id/16614865/). Shall we now start referring to drinking water as toxic because it was in Jennifer’s case (please say ‘no’)? Liz’s correction stated that there were toxic chemicals in the oil, which is true enough, but there are also toxic chemicals in almost all drinking water (lead, benzene, MTBE, etc.) so should we stop drinking water? Where does it end?

    Crude oil clearly causes negative health effects to people exposed, no rational person could argue otherwise, but we need to keep some perspective. Is it as bad as methyl isocyanate? Chlorine? Ammonia? Diacetyl? Some 300 people die every year from exposure to sand (silicosis), how many die from crude oil exposure?

  11. Mark – your argument is good to a point. The only problem is that you could never answer the question how many people a year are killed from crude oil exposure because you could not differentiate the exposure (chronic) from other sources. The ATSDR discussion about crude and total petroleum hydrocarbons makes it clear that the health effects are poorly understood for the total suite of compounds included. Toxic surely is an inflammatory word choice, but let’s not downplay the potential health effects from exposure to crude, it is not understood in this context – it is not a studied, controlled or all that predictable (steady state/recurring) industrial exposure. Consider acute toxicity versus chronic toxicity – those are obviously very different risks and outcomes of exposure, but toxic is the proper word in both cases.

  12. (I’m sorry if this gets double posted, I forgot to add my name before I submitted it.)

    Andy; I apologize for even asking how many people die from crude oil, it was too flippant and I’m sorry for that.

    By returning to the concept of risk perception I’m only kind of trying to downplay the risk from exposure to crude oil. I’ve seen mass-spec analyses’ for other crude oils so I know what’s in them and I have an idea of we’re dealing with. But the thing is, where you and I could sit down and have a discussion of chronic versus acute toxicity of PNAs versus PAHs and understand what that means, most people can’t. Most people can’t distinguish toxic from toxicity (it’s not that they aren’t capable, it’s just that they don’t have the background).

    Let me explain myself from a different perspective. When the financial meltdown happened there were a lot of talking heads saying the problem was the derivatives market. I have no idea what that means, nor do I really care to know. But what I have in my mind, and I think a lot of other people do as well, is that derivatives are bad. I have a friend who does understand the financial system and swears derivatives aren’t bad, unregulated derivatives are bad. Like a lot of people, I don’t understand the word “derivative” in its professional context, I’ve simply associated it with “bad.” But how bad are derivatives really? When I’m being honest (i.e. not sitting around with friends arguing debating) I have to admit that I don’t know.

    I think that most of the public is in the same situation with the word “toxic.” My lament is that when Pandora opened the box Zeus had given her, not only did all the evils of the world escape, so did the word “toxic.” If we could go back in time and keep the word “toxic” from escaping into the mainstream media, keep it within the profession, then I would have no hesitation using the word in this situation.

  13. I think that most of the public is in the same situation with the word “toxic.” My lament is that when Pandora opened the box Zeus had given her, not only did all the evils of the world escape, so did the word “toxic.” If we could go back in time and keep the word “toxic” from escaping into the mainstream media, keep it within the profession, then I would have no hesitation using the word in this situation.

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