Talking Points For Welcome Address

Martin S. Mathamel

Thank you for the opportunity to welcome you to this symposium which I believe addresses a very relevant topic, not only within the Department of Energy, but also throughout the commercial and government hazardous waste remediation industry. I believe the issues that you are going to discuss are vitally important in terms of worker safety and health. I have been with DOE for three years. For 15 years prior to DOE, I was involved with private sector hazardous waste cleanup. I can tell you that we struggled with the issue of worker exposure monitoring and tracking. I don't believe we ever found a solution that was acceptable to the ES&H professionals, the managers, and the workers. Alot of work got done, and whole lot of doctors made a bunch of money performing medical examinations, but, in my opinion, we never really were able to come up with a definitive worker surveillance protocol. I'm sure all of you share my frustration with the level of effort, money, and uncertainty involved with protecting workers during clean-up.

Today, I would like to frame this issue by discussing three items an ongoing debate within the Department on controlling exposures to beryllium, particularly in the context of DOE's massive clean-up effort;

DOE's worker protection initiative; and some "real-world" observations relative to worker exposure at commercial hazardous waste sites.

First, some background.

The challenges that confront us with beryllium exposure are the very ones I believe are on the table during this symposium.

Beryllium is an essential metallic element used in industry for its physical and chemical properties. Once used in fluorescent lights and other electrical components, it is still present in such applications as X-ray machines and other electronic devices.

Since the 1940s, beryllium has been widely used in DOE nuclear operations. Beryllium metal and ceramics are used in nuclear weapons, as moderators and reflectors in nuclear reactors, and as fuel element cladding. Past beryllium operations in DOE include foundry, grinding and machine tooling of parts.

Beryllium is classified as a carcinogen. Workers who inhale beryllium dust can develop a chronic, irreversible, sometimes fatal granulomatous lung disease known as chronic beryllium disease (or CBD). CBD has a delayed onset, meaning it may appear years after exposure. Drugs can curb the progression of the disability in many patients, but the disease cannot be cured. Symptoms resemble those of other chronic lung diseases such as tuberculosis.

DOE has a steadily increasing number of workers with CBD - 96 confirmed cases to date, or 1% of the roughly 9600 screened workers.

At the present, DOE has 500 current beryllium workers, with the prospect of many more as DOE cleanup expands. From a stable fabrication operation with a set worker population, what we address increasingly today are facility D&D and hazardous waste cleanup supported by an intermittent, cyclical workforce of subcontractors.

D&D refers to decontamination and dismantlement. Decontamination is the removal of radioactive and hazardous contamination. Dismantlement is disassembly or demolition.

In terms of potential worker exposure, D&D is perhaps the most dangerous aspect of the remedial process.

The current beryllium exposure limit was established by OSHA in 1970, based upon the 1949 Atomic Energy Commission standard of 2 micrograms per cubic meter. Current health effects data indicates that this standard is not protective of all workers. With some workers who are particularly immunological sensitive, no minimum threshold for safe exposure may be demonstrable.

In terms of worker monitoring and surveillance, uncertainty exists over how to characterize measurable contamination levels and how to relate them to potential inhalation hazard.

To sum up the issue - DOE is facing D&D mid cleanup of numerous facilities in which beryllium contamination exists to varying degrees; confronted by an OSHA standard that may not be sufficiently protective; with a need to monitor beryllium exposures in dynamic environments down to levels of delectability; with a growing and cyclical worker population who will likely be exposed on an intermittent basis and whose protection regime is currently focused on radiation exposure.

In the recent past, once CBD began to show up among older workers, the strategy was to improve ventilation, require more PPE, and to limit area access. Some sites have instituted administrative actions below the OSHA PEL and have invested in medical surveillance and research. This is pretty much a traditional IH response for a traditional workplace environment.

For DOE's current mission -- D&D and cleanup -- a much different strategy is called for.

With D&D, we first must "find" beryllium contamination, then minimize instances where inhalation may occur, and fit local protection measures to specific contamination. This is consistent with the familiar tenets of radiological ALARA, the control strategy calls for a reliance on job hazard analysis, frequent "real-time" exposure measurements, and a premium on exposure prevention techniques.

Within DOE, there is agreement that an "ALARA-like" approach makes sense. Secretary Peņa recently signed an Departmental notice requiring contractors to develop interim CBD exposure prevention programs by mid-Fall of this year. And, DOE is proceeding with rulemaking (expected to be complete next year) to ultimately codify these programs.

What will be adopted as DOE policy will of course be based on what's protective, and will also be based on what's practical, feasible. In a broader sense, we will need to balance the resources devoted to controlling potential beryllium exposures with those for other onsite hazards, which, within the context of DOE, are significant. The cost of developing interim CBD measures is thought to be $25 million, though this estimate has not been validated.

DOE's Beryllium notice requires:

• Comprehensive beryllium inventories and hazard assessments

• Minimize the number of exposed workers and worker exposure
• Monitor worker exposure to beryllium
• Monitor beryllium worker health, especially for beryllium sensitization Analyze monitoring and medical data to asses program effectiveness

So, what do we lack for in beryllium worker protection measures?

Real-time, job-based, breathing zone monitoring technology protocols that can be linked to actual personnel exposure. Adequate exposure and medical records and experience feedback. The very items that you are addressing in this workshop.

We also lack effective on-the-job, work-specific safety training. A clear means to determine pre-entry conditions and potential hazards in uncertain D&D and cleanup environments.

As it stands, the pace of D&D and cleanup has overtaken the development and adaptation of effective management systems and control technologies for beryllium.

Current practice is under close scrutiny within DOE as a result of rulemaking, and I see the beryllium debate contributing to the larger question of managing complex worker hazards in dynamic workplace conditions.

As a result of DNFSB Recommendation 95-5 the Department has had to explain and demonstrate the basis for the site worker protection programs and how hazard analysis and resultant worker safety controls are derived from applicable requirements and standards.

Among the issues is the following question. Can judgments, criteria, and practices applied for work activities be justified across DOE from a technical and policy standpoint?

To answer this question, the Department began a Worker Protection Criteria initiative this year to provide factual answers to this question through self- assessment of hazard analysis and control derivation processes practiced at DOE sites involving a broad range of work activities.

The historical worker safety and health statistical record of the Department has been favorable and is getting better; however, the DNFSB is concerned that DOE is losing the institutional memory represented by the experienced line managers and technical professionals at various sites whose judgments have fon-ned the worker protection decision making process.

The overriding WPC goal is to reaffirm that the long standing process guiding worker protection criteria and procedures continues to be sound and is sufficiently documented.

To facilitate this process, a questionnaire was developed to survey DOE practices in several areas including hazard and risk management, linkage to Integrated Safety Management and Work Smart Standards, performance measures, and field perspectives, guidance, and approaches. The questions were designed to develop a picture of the worker protection criteria, hazard analysis, and hazard control programs currently in place at the work or task level.

The questionnaire was transmitted to the Fernald, Paducah, PUREX, Richland, Rocky Flats, Savannah River, and Y-12 sites to draw upon their experience in these areas. The depth to which a responding site examined any given question was based on the sites' specific program attributes and method of application of hazard analysis and risk management program concepts as tailored to their individual hazards, risks, and mission.

The intent of this activity was to highlight and focus on local procedures and processes concerning the judgments that lead to the establishment of local worker protection programs.

Responses from the seven volunteer sites are being compiled into a summary report of representative practices, entitled Worker Protection Criteria Field Perspectives. I would recommend that you get a copy of this report when it becomes available. The contact at DOE is Rick Jones, EH-51, U.S. Department of Energy, Washington, DC, 20585. Rick's Internet address is Rick.Jones@doe.hq.gov, and his phone is 301-903-6061.

As part of this initiative, DOE sponsored a WPC Workshop in June, 1997, in Washington, DC, to provide the participating organizations with a forum for presenting their best WPC practices and lessons learned to peers. The WPC Workshop concluded with a panel discussion and the development of a path forward for improvement with respect to worker safety that included:

• Targeting middle management to obtain greater support for worker protection programs and incorporating new approaches.

• Institutionalizing the concept that Line Management owns health and safety.

•  
• Incorporating Voluntary Protection Program (VPP) tenets into the conduct of work.

• Improving both internal and external communication.

Worker Exposure Challenges In The "Real World"

In May, at the AIHA annual meeting, AIHA!s hazardous waste committee held a roundtable discussion challenging industrial hygienists to identify ways that lack of information hinders their ability to protect hazardous waste workers. Did any of you attend? I believe that their discussion has some valuable insights for this symposium.

Mark McGowan of Malcolm-Pirnie called for instruments that provide a more complete characterization of hazardous conditions. He believes that using "yesterday's meters" often drives more protection than actual conditions warrant, which increases injury and heat stress hazards.

Dr. Michael Bisesi, of Medical College of Ohio, warned that bioremediation can disperse metabolic daughter products with new toxicity, microbes, and pathogens. He advocated monitoring the soil wid water for changes in total toxicity.

Dr. Bert Prader, of Environmental Medicine Resources, said that over the past eight years, his organization has performed 150,000 medical exams on hazardous waste workers without finding a health effect associated with site work. Chris Marlowe, of Camp Dresser and McKee added that a 1996 survey found that chemical exposure caused zero percent of hazardous waste worker illnesses. Marlowe suggested that a systematic approach be developed for physical injuries similar to the one for to health hazards, since safety hazards are responsible for the majority of accidents.

Mark Fisher, of the Army Corps of Engineers, said the worst chemical exposures during clean-up come from the chemicals that contractors use on site, not from the environmental contaminants. "The cure is worse than the cause."

Lastly, Roberta Hickman of Hawaii shared her frustration with the ACGIH heat exposure guidelines. She said that under the ACGIH exposure model, no work could occur in Hawaii or Louisiana from March until September.