An Inconvenient Truth - Respirators Needed in the Gulf Cleanup

by Eileen Senn, MS

It seems obvious to many that respirators are needed to protect cleanup workers in the Gulf from inhaling air contaminants that are making some sick now and may make many more chronically ill in the future. I will describe a combination of political and scientific issues conspiring to prevent the needed respirators from being provided. They include:

*Lack of focus on the adverse health effects of airborne contaminants
*Limited air sampling
*Outdated exposure limits
*Oil company protocols for limiting respirator use

*Concerns that respirators will worsen heat stress to workers

*OSHA requirements for respirator use

Adverse Health Effects Data Out of Sight

Depending on their proximity to the oil leak, wind direction, wave action, and cleanup tasks being performed, BP Deepwater Horizon cleanup workers in the Gulf are potentially exposed to the Mississippi Canyon crude oil components n-hexane, naphthalene, benzene, ethyl benzene, toluene, and xylene; other Volatile Organic Compounds (VOCs) in dispersants and other oil spill remediation chemicals; methane, sulfur dioxide, hydrogen sulfide, carbon monoxide and other toxic gases; acid gases like sulfuric acid; Polycyclic Aromatic Hydrocarbons (PAHs) and particulates from diesel and gasoline engine exhaust and burning oil. Even this list is not exhaustive. Potential short-term health effects from these exposures include Irritation to eyes, skin, and respiratory system; dizziness; rapid heart rate; headaches; tremors; confusion; unconsciousness. Potential long-term health effects include cancer, birth defects, and permanent nerve damage as well as damage to the liver, kidneys, respiratory, reproductive, blood, and immune systems.

Honest and complete information from the toxicology and epidemiology literature on the adverse health effects of exposure to these hazardous substances is generally not being provided to workers or the public. The best information I have been able to find on government websites is a table from "Training Marine Oil Spill Response Workers under OSHA's Hazardous Waste Operations and Emergency Response Standard," which does not include all the chemicals involved. Here is an excerpt.

Table 1. Hazardous Chemicals and Their Effects
Benzene (crude oils high in BTEX, benzene, toluene, ethylbenzene, and xylene)
Adverse Health Effects: Irritation to eyes, skin, and respiratory system; dizziness; rapid heart rate; headaches; tremors; confusion; unconsciousness; anemia; cancer

Carbon monoxide (byproduct of combustion)
Adverse Health Effects:Irritation to eyes, skin, and respiratory; Dizziness, confusion, headaches, nausea, weakness, loss of consciousness, asphyxiation, coma

Hydrogen sulfide (oils high in sulfur, decaying plants and animals)
Adverse Health Effects:Irritation to eyes, skin, and respiratory system; dizziness; drowsiness; cough; headaches; nervous system effects

Polycyclic aromatic hydrocarbons (PAHs) (occur in crude oil, and formed during burning of oil)
Adverse Health Effects:Irritation to eyes and skin, cancer, possible reproductive effects, immune system effects

Xylenes (high BTEX crude oils)
Adverse Health Effects: Irritation to eyes, skin, respiratory system; dizziness; confusion; change in sense of balance; nervous system gastrointestinal system, liver, kidney, and blood effects

Even legally required Material Safety Data Sheets (MSDSs) on Gulf chemicals are notably absent from government websites, where it would make sense to post them all. An MSDS on raw Mississippi Canyon crude oil has yet to be provided by BP. Self- servingly, BP does provide the MSDS on less toxic "weathered" crude.

Thankfully, there are a few scientists trying to get better health effects information out.
Natural Resources Defense Council (NRDC) Senior Scientist Gina Solomon, MD, MPH has been blogging and testifying about the chemical hazards in the Gulf. Kathy Burns, Ph.D. and Michael Harbut, MD have summarized the health effects of Gulf oil spill chemicals at the Science Corp. website and produced a 1-page factsheet for cleanup workers. Riki Ott, PhD, author, activist, and veteran of the Exxon Valdez oil spill has health effects information on her website Claudia Miller, MD, MS also has health effects information on her website and blog.

Limited Air Sampling Misleading
My review of BP's and OSHA's posted air sampling data was included in an earlier post . However, there is new data all the time and BP only posts occasional summaries which lack many details needed to interpret the data. BP should be making all their data publicly available in a timely manner in a clear and complete format. OSHA does a better job of presenting their data but it is very limited and does not include the worst offshore exposures (because OSHA isn't sampling offshore.) BP spokespeople continue to insist that air quality in the region of the spill is fine and that cleanup workers don't need to wear masks.

"We haven't provided respirators or masks because all the environmental data shows the air is safe," BP spokesman Graham MacEwen told Yahoo! News.

The truth is the air sampling in the Gulf is woefully incomplete in terms of which chemicals have been sampled. Yet even the limited sampling that has been done shows levels of enough concern to warrant the use of respirators for some workers.

Outdated Exposure Limits
OSHA Permissible Exposure Limits (PELs) have been the lynchpin of the agency's approach to chemical hazards for 40 years. Unfortunately they are hopelessly outdated and license to overexpose workers. PELs perpetuate an impractical and flawed approach to controlling chemical exposures whereby OSHA cannot require engineering controls, respiratory protection, or medical surveillance unless the agency collects air samples that prove that employee exposures exceed a PEL.

Respirator selection protocols depend on PELs. The use of respirators in oil cleanups also depends on PELs as described in the OSHA publication "Training Marine Oil Spill Response Workers under OSHA's Hazardous Waste Operations and Emergency Response Standard."

For one of the chemicals in the Gulf, benzene, some comparisons show how outdated the OSHA PELs are. The NIOSH standards are also old and the Recommended Exposure Limit (REL) for benzene was based on the lowest feasible level of detection at the time. You can see that EPA health risk based inhalation guidelines are orders of magnitude lower. The one below is based the non-carcinogenic health effect of decreased lymphocyte count.

Benzene Exposure Guidelines in parts per million of air (ppm)
OSHA PEL = 1.0 ppm
ACGIH TLV= 0.5 ppm
NIOSH REL= 0.1 ppm
USEPA RfC= 0.01 (0.03 mg/m3)

The EPA value is a Reference Concentration (RfCand comes from EPA's Integrated Risk Information System (IRIS). An RfC is defined as estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime.

Oil Company Protocols for Limiting Respirator Use
The oil industry has protocols in place and ready to go to manage chemical exposure issues whenever there is an oil spill. Their "modus operandi" involves conducting air sampling for a very limited number of chemicals and interpreting the results so that managers can proceed with the cleanup with a minimum of respiratory protection or other precautions. The BP Deepwater Horizon Offshore Monitoring Plan for Source Control is such a falsely reassuring protocol. Only four air contaminants are sampled - Volatile Organic Compounds (VOCs), benzene, carbon monoxide and hydrogen sulfide. BP's logic for selecting these four air contaminants and setting their trigger levels is not explained.

For VOCs, BP uses 100 ppm of air over 15 minutes as the trigger for using a respirator. For benzene, the trigger is three samples over 0.5 ppm in 15 minutes. Since there are no filtering respirators that work for them and supplied air respirators are not convenient to use, the protocol calls for workers to move away from alarms set to sound at 25 ppm of carbon monoxide over 15 minutes and 5 ppm of hydrogen sulfide over 15 minutes.

My research shows the BP benzene and hydrogen sulfide levels are set at one-half of the National Institute for Occupational Safety and Health (NIOSH) short term exposure limits and carbon monoxide at one-eighth of the NIOSH short term limit. Assuming the NIOSH limits are protective, this seems reasonable. The problems are that the NIOSH limit for benzene is not protective and that these are just three of a host of chemicals.

A bigger problem, however, is that there is no valid evaluation criteria for VOCs because the identity of individual component VOCs is unknown. There is no limit applicable to all the possible compounds combined. The key to the success of the protocol in keeping the use of respirators to a minimum is the lenient 100 ppm criteria BP uses to evaluate measurements of VOCs.

This Clean Bill of Health approach, carefully established over the past 40 years, is working well for BP in the Deepwater Horizon Gulf spill despite the fact that the failure to stop the leak is making chemical exposures offshore, nearshore, in marshes, and on beaches worse than in the usual oil spill.

Heat Used to Deny Worker Protections
Heat stress and safety issues are standard oil industry excuses for minimizing personal protective equipment (PPE) and respirators during oil spills. Heat stress, especially, has been effectively used in this way in the Gulf spill where the heat and humidity are certainly very hazardous. Two Canadian occupational health consultants articulate the heat objections in Occupational Health Aspects of Marine Oil-Spill Response. In 1999 they wrote:

"Oil-spill cleanup workers may be exposed to crude oil through inhalation and dermal contact. Personal protective equipment can, of course, reduce these exposures, but care must be taken to ensure that the use of such equipment does not create hazards additional to the ones the equipment was originally intended to protect against. One can, for example, easily imagine situations where the wearing of excessive amounts of impermeable clothing may generate a hazard from heat stress. Similarly, prolonged wearing of respirators, particularly by workers involved in strenuous activity, can induce physiological stress or simply fatigue, and thus increase the potential for accidents."

The obvious solution is to control heat stress in every way possible to avoid denying other protections. So far in the Gulf, work-rest regimens, voluntary breaks, shade, and encouraging workers to drink water seem to be in use. Additional controls for heat stress that need more attention are:

*Maximally breathable protective clothing. Regular Tyvek is somewhat breathable but there are more breathable alternatives.

*Cooling vests containing freezable cooling panels

*Acclimatization for 5-7 days before starting work

*Air-conditioned rest areas with water or electrolyte drinks available

*Performing work only when there is less heat and solar load, for example, sunrise until 11 am, 7 pm to 11 pm and overnight. This would reduce exposure to both heat and chemicals that evaporate in the heat.

*Requiring a medical clearance to work in the heat. Obtaining this clearance could be combined with obtaining medical clearance to wear a respirator.

*Limiting hours worked. This would create more and safer jobs.

OSHA Requirements for Respirator Programs
Wearing the wrong type of respirator or an ill-fitting or dirty respirator is dangerous and gives a false sense of security. Therefore, the OSHA respirator standard, 1910.134 rightly requires employers who provide respirators to properly select them, medically evaluate employees for their ability to use a respirator, fit-test employees, provide for cleaning, disinfection, and proper storage of respirators, train workers on how to use respirators and the hazards they are meant to protect against, and to have a written respirator program.

With everything else going on in the Gulf cleanup, these requirements may seem like too much trouble. There are two exceptions to the respirators rules and there may be attempts to utilize these in the Gulf. The exceptions are:

1910.134(c)(2)(i): An employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard. If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D to this section ("Information for Employees Using Respirators When Not Required Under the Standard")

1910.134(c)(2)(ii): In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks).

Despite All the Obstacles, Respirators Are Needed and Feasible
None of the political and scientific issues described are insurmountable with enough political will and regulatory flexibility. A new narrative on respirators is needed and might go something like this.

Gulf clean-up workers are potentially exposed to a complex mixture of toxic chemicals. Exposures change with proximity to the oil leak, dispersants and other chemicals in use, wind direction, wave action, and cleanup tasks being performed. The scientific community lacks complete information on either the short-term or long-term health effects of this mixture. OSHA Permissible Exposure Limits (PELs) and NIOSH Recommended Exposure Limits (RELs) are not protective in this situation and are absent for many of the chemicals of concern. Workers are becoming ill. Therefore the only workable approach to protect clean-up workers from airborne chemical hazards is for BP and other employers to provide and enforce the use of respirators for many workers engaged in clean-up work. The types of respirators should be selected by an expert team of OSHA, NIOSH, and NIEHS in consultation with respirator manufactures, based on the anticipated chemical exposures in performing specific clean-up tasks in specific locations offshore, nearshore, in marshes, and on beaches. Because of the unique nature of this situation, it is not possible to strictly follow respirator selection protocols that are used when exposures and toxicity are better characterized.

Eileen Senn is an industrial hygienist who has performed occupational health work for government and unions for 40 years. She was an OSHA industrial hygiene inspector in Philadelphia for eight years in the 70s and 80s. She directed an OSHA New Directions grant from 1979 to 1981. She worked in occupational health surveillance for the state of New Jersey from 1986 to 2002. She has been an Independent consultant for the past eight years. She is perhaps best known for her seminal article, Playing Industrial Hygiene to Win.