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THE NATIONAL ACADEMIES

Advisers to the Nation on Science, Engineering, and Medicine

Board on Army Science and Technology

Mailing Address:
500 Fifth Street, NW
Washington, DC 20001
www.nationalacademies.org

January 5, 2007

Mr. Michael A. Parker

Director

Chemical Materials Agency

5183 Blackhawk Road
Edgewood Area
Aberdeen Proving Ground, MD 21010-5424

Re: Review and Assessment of Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility

Dear Mr. Parker:

At your request, the National Research Council (NRC) of the National Academies established the Committee to Review and Assess Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility to review and assess the industrial hygiene (IH) standards and practices at Tooele Chemical Agent Disposal Facility (TOCDF) as they relate to the U.S. Army Materiel Command’s Surety Management Review (SMR) of TOCDF conducted October 11, 2005, through October 21, 2005 (see Attachment A for the statement of task). This letter report documents the results of the committee’s effort.


The committee met November 6-8, 2006; at the request of the sponsor, the report was to be completed within 60 days of that meeting. In view of the short study schedule and the detailed nature of the task, the NRC selected committee members with experience in safety, industrial hygiene, and/or the destruction of chemical weapons (see Attachment B for a list of committee members and information on their expertise). The committee reviewed the October 2005 SMR of TOCDF and made its assessment in light of information presented in the documents listed in Attachment D of this letter report.


During the November 6-8, 2006, meetings, oral presentations were made by personnel from TOCDF, the U.S. Army Chemical Materials Agency (CMA), the U.S. Army Center for Health Promotion and Preventative Medicine, and EG&G (the site contractor) staff, and discussions took place between the committee and the subject-matter experts (see Attachment C for the list of participants). Follow-on exchanges took place electronically in response to additional questions from the committee.



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THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine Board on Army Science and Technology Mailing Address: 500 Fifth Street, NW Washington, DC 20001 www.nationalacademies.org January 5, 2007 Mr. Michael A. Parker Director Chemical Materials Agency 5183 Blackhawk Road Edgewood Area Aberdeen Proving Ground, MD 21010-5424 Re: Review and Assessment of Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility Dear Mr. Parker: At your request, the National Research Council (NRC) of the National Academies established the Committee to Review and Assess Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility to review and assess the industrial hygiene (IH) standards and practices at Tooele Chemical Agent Disposal Facility (TOCDF) as they relate to the U.S. Army Materiel Command’s Surety Management Review (SMR) of TOCDF conducted October 11, 2005, through October 21, 2005 (see Attachment A for the statement of task). This letter report documents the results of the committee’s effort. The committee met November 6-8, 2006; at the request of the sponsor, the report was to be completed within 60 days of that meeting. In view of the short study schedule and the detailed nature of the task, the NRC selected committee members with experience in safety, industrial hygiene, and/or the destruction of chemical weapons (see Attachment B for a list of committee members and information on their expertise). The committee reviewed the October 2005 SMR of TOCDF and made its assessment in light of information presented in the documents listed in Attachment D of this letter report. During the November 6-8, 2006, meetings, oral presentations were made by personnel from TOCDF, the U.S. Army Chemical Materials Agency (CMA), the U.S. Army Center for Health Promotion and Preventative Medicine, and EG&G (the site contractor) staff, and discussions took place between the committee and the subject-matter experts (see Attachment C for the list of participants). Follow-on exchanges took place electronically in response to additional questions from the committee.

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BACKGROUND On October 11-21, 2005, the U.S. Army Materiel Command conducted an SMR for various functional areas within TOCDF and the Deseret Chemical Depot in Utah. Based on the findings presented in the SMR, each area was rated as “Mission Capable,” “Mission Capable with Limitations,” or “Not Mission Capable.” The SMR evaluated the TOCDF IH program for its effectiveness in supporting the Army’s Chemical Surety Program. The evaluation consisted of a review of IH program documents and the IH implementation plan; a site walk-through; interviews; a review of the Health Hazard Inventory Modules; and a review of selected portions of IH supporting programs. The IH program at TOCDF was given a rating of “Mission Capable with Limitations” (Army Materiel Command, 2005). SURETY MANAGEMENT REVIEW FINDINGS The SMR findings cited one “systemic” TOCDF IH program limitation (finding IH007), the management of carcinogens in the hazards communication (HAZCOM) program (Army Materiel Command, 2005). The SMR listed three carcinogens on-site that were not identified and/or fully evaluated for potential exposure. A review of the complete chemical inventory to identify whether other carcinogens were present was not documented. The SMR recommended that all material safety data sheets (MSDSs) for new chemicals be reviewed for carcinogens that might be present and that attempts be made to find substitutions. The SMR identified four other deficiencies at TOCDF, as listed below: SMR Finding IH003: Contract Data Requirement List Item 20, Occupational Health and Hygiene Plan, was not updated annually and did not reflect the current regulatory requirements in Department of the Army Pamphlet (DA PAM) 40-503, Industrial Hygiene Program. SMR Finding IH008: The personnel responsible for creating Hazardous Materials Identification System and National Fire Protection Association labels were not aware that these two hazard rating systems are not interchangeable. SMR Finding IH009: The IH Program Manager did not generate risk assessment codes in accordance with the methods outlined in DA PAM 40-503. SMR Finding IH011: The enrollment of personnel in the Hearing Conservation Program (HCP) was not accomplished on the basis of time-weighted average (TWA) noise-exposure levels to steady-state noise. Also, statistically valid sampling strategies were not used. ANALYSIS OF SURETY MANAGEMENT REVIEW FINDINGS The SMR relied heavily on DA PAM 40-503 (U.S. Army, 2000) in identifying deficiencies—four of the five noted deficiencies refer to DA PAM 40-503. The site contractor,

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EG&G, responded that DA PAM 40-503 is not referenced in its contract with CMA and is therefore not applicable.1 In any case, it is clear to the committee that DA PAM 40-503 is a guidance document that does not bear the full force of regulation. Chapter 1 of DA PAM 40-503 succinctly states the documents purpose: This pamphlet— Provides guidance [emphasis added] for implementing the essential element of the industrial hygiene (IH) program. Defines industrial hygienist’s role in other Army programs. Describes the IH mission by law, policy, and professional practice. (U.S. Army, 2000, p. 1) Further, DA PAM 40-503 specifies that the provisions of 29 CFR 1910 (i.e., Occupational Safety and Health Standards, the Occupational Safety and Health Administration (OSHA) standards) are the principal standards against which compliance is to be measured. Thus, while the SMR is correct in pointing out that TOCDF is not in complete conformance with DA PAM 40-503, the site should not be labeled as deficient because it followed other guidance.2 The committee analyzed all SMR cited IH program limitations and deficiencies with respect to compliance with OSHA standards. It is noted that the HAZCOM program, as promulgated in 29 CFR 1910, is a performance rule, and the Hearing Conservation Program’s performance objective is to identify and protect all individuals who are exposed to potentially hazardous noise levels. The IH program evaluation conducted by this committee was based only on selected documents (see Attachment D) and on briefings by TOCDF IH program staff, without the benefit of access to more detailed written documentation regarding IH program activities, the monitoring of data, observation of the work sites, or discussions with workers. Based on the limited review performed by the committee, it appears that the OSHA requirements were met and that in some cases TOCDF procedures were more protective of workers than what is required by OSHA. It is the committee’s opinion that the specific deficiencies cited in the SMR were in themselves relatively minor with respect to an encompassing IH program; they were primarily administrative in nature. It is recognized that virtually every inspection of a large and complex facility will result in the identification of some problems. It is the experience of the committee that in a mature IH program such as that at TOCDF, one would not expect to find major problems, although minor deficiencies would not be unusual. The SMR does not differentiate the enumerated deficiencies as to their significance. 1 “CMA Industrial Hygiene Overview,” briefing by Irene L. Richardson, Industrial Hygienist, U.S. Army Center for Health Promotion and Preventative Medicine, to the committee, November 6, 2006. 2 While its statement of task did not direct the committee to review the language of the contract between EG&E and the CMA, the committee notes that some of the issues raised in the SMR report are apparently the result of differences in the guidance expected to be employed by the TOCDF IH program and that actually employed. Furthermore, it is the committee’s opinion that the SMR process cannot presume that DA PAM 40-503 (U.S. Army, 2000) supersedes Technical Bulletin Medical (TB MED) 503 (U.S. Army, 1985) from a contractual point of view, as this implies unilateral modification of the underlying contract. If CMA wishes to include DA PAM 40-503 as the referenced guidance document in future SMRs at TOCDF, a contract amendment would be appropriate. It should be noted that the wording of DA PAM 40-503 does not specifically apply to Department of Defense contractors, as do DA PAM 40-8 (U.S. Army, 1990) and DA PAM 40-173 (U.S. Army, 2003).

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In summary, the committee concluded that the deficiencies noted in the SMR regarding the IH program at TOCDF would at most constitute de minimis violations pursuant to 29 CFR 1910. Further, the rating of the TOCDF IH program as “Mission Capable with Limitations” was not supported by SMR findings and is therefore inappropriate. Finding 1. It is clearly the intent of the U.S. Army that the principal standard against which industrial hygiene programs should be measured is 29 CFR 1910, Occupational Safety and Health Standards. Finding 2. The deficiencies noted in the Surety Management Review regarding the industrial hygiene program at the Tooele Chemical Agent Disposal Facility (TOCDF) are based primarily on reference to nonbinding guidance documents, but at most they would constitute de minimis violations pursuant to 29 CFR 1910, Occupational Safety and Health Standards, and would have no impact on operational risk or program performance at TOCDF. Finding 3. The rating of the industrial hygiene program of the Tooele Chemical Agent Disposal Facility as “Mission Capable with Limitations” was not supported by Surety Management Review findings and was therefore inappropriate. THE TOCDF INDUSTRIAL HYGIENE PROGRAM The overarching goal of an IH program, and hence the measure of its success, is the protection of worker safety and health. The IH program at TOCDF includes several elements designed to anticipate, recognize, evaluate, and control hazards present in the facility. A facility such as TOCDF contains hazards found in other industrial settings as well as hazards that are unique. The majority of these hazards are covered under OSHA standards found in 29 CFR 1910. For hazards unique to TOCDF that are not covered under the OSHA regulations, the facility uses other guidelines, such as DA PAM 40-8 (U.S. Army, 1990) and DA PAM 40-173 (U.S. Army, 2003). In addition, the facility has chosen to adopt several guidelines that provide more employee protection than is required by OSHA standards. For example, OSHA has not promulgated a standard for worker protection from heat stress, and so the guideline TB MED 507, Heat Stress Control and Heat Casualty Management, is used.3 Specifically, the TOCDF IH program includes the following elements:4 Health Hazard Inventories, Process Hazard Analysis (PHA) and Work Control Support, Respiratory Protection, Personal Protective Equipment, Confined Space Entry, Radiation Safety, 3 “TOCDF Industrial Hygiene Program,” briefing to the committee, November 6, 2006. 4 “TOCDF Industrial Hygiene Program,” briefing to the committee, November 6, 2006.

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HAZCOM/Chemical Control, Hearing Conservation, Monitoring for Non-Agent Hazards, Laboratory Fume Hoods, Ergonomic Principles, Laboratory Hygiene, and Heat Stress. The TOCDF IH program is conducted under the leadership of a safety manager who is a certified safety professional (CSP) with an undergraduate degree in public health/industrial hygiene and more than 10 years of experience in the field of occupational health and safety. At the time of the SMR, the industrial hygienist with direct responsibility for the program was a certified industrial hygienist with relevant graduate degrees. His previous experience included more than 10 years as a manager and supervisor in health and safety programs. Two other industrial hygienists in the program hold degrees in public health/industrial hygiene and possess relevant experience. Additionally, military oversight for the IH program is provided by the CMA deputy site project manager, a safety engineer, and a CSP. In summary, the IH program personnel at the time of the SMR possessed the credentials and qualifications required for their positions.5 Based on the committee’s general knowledge of IH program requirements, along with reports by committee members who have toured the facility and are familiar with the operations involved in chemical demilitarization, it appears that the program elements address the major recognized hazards at this site. Additionally, the EG&G IH staff clearly indicated that these elements are prioritized with regard to time and resource allocation according to their relative frequency and severity of adverse health events. For example, because the site activities are judged to present low ergonomic risks, this program element is not given the same priority as other hazards such as heat stress or work in confined spaces. The SMR report did not acknowledge the comprehensive nature of the TOCDF IH program, nor did it comment on the effectiveness of the program in protecting against the health consequences of the most significant hazards. The deficiencies that are cited in the report are not considered in the context of the overall constellation of threats to the worker population and do not appear to be aligned with the most serious threats to the health of TOCDF personnel. Finding 4. The industrial hygiene program at the Tooele Chemical Agent Disposal Facility meets the goal of protecting the safety and health of the workers employed at the facility. The IH program information provided by TOCDF staff was compared with the industrial experience of committee members with regard to hazard anticipation, recognition, evaluation, and control. The documentation presented on program elements tracked closely with the elements of an industrial program.6 5 Information provided to the committee by TOCDF staff, November 8, 2006. 6 “TOCDF Industrial Hygiene Program,” briefing to the committee, November 6, 2006.

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The committee identified no specific need for changes in the TOCDF IH program based on a comparison with IH practices in industrial programs. The TOCDF IH program relies on annual inspections by various external entities and on preparation for such inspections to serve as program audits. These audits complement quarterly and annual inspections conducted by on-site personnel. Finding 5. Based on its limited assessment of the Tooele Chemical Agent Disposal Facility (TOCDF) industrial hygiene (IH) program, the committee found the TOCDF IH program to be essentially equivalent to IH programs in industry. The committee did not find any apparent shortcomings in the TOCDF IH program. PERFORMANCE VERSUS SPECIFICATION STANDARDS EG&G’s contract with CMA is performance-based, incorporating by reference certain guidelines and other requirements.7 Consequently, the contractor is of the opinion that unless compliance with a standard is specifically mandated by contract, EG&G is free to design and implement programs and practices that will enable it to meet the contractual performance goals. The underlying issue considered in this committee’s review was not a matter of contract language, but rather one of performance-based versus specification-based standards in IH programs. The deficiencies noted in the SMR report are largely a result of an attempt to impose specification compliance on programs that are being conducted on the basis of performance compliance. The conceptual differences are significant: specification-based programs operate on the premise that if all of the standards are met, the desired performance will be achieved; by contrast, performance-based programs focus on applying practices that will ensure performance. The decision to apply one type of standard or the other is based largely on knowing what the desired performance criteria are and assessing the most appropriate process for achieving the performance goal. In some cases specification standards are appropriate. Performance standards are less rigid and allow the local program manager(s) to make changes and immediate corrections to ensure results. According to OSHA, the use of performance rules means that you have the flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific, rigid requirements. It also means that you have to exercise more judgment to implement an appropriate and effective program. (29 CFR 1910.1200, Subpart Z, Toxic and Hazardous Substances, Hazard Communication) The following observation illustrates the application of this concept. The SMR found the TOCDF IH program deficient in the area of hearing protection. Specifically, the SMR report stated that “enrollment of personnel into the site Hearing Conservation Program (HCP) was not 7 “CMA Industrial Hygiene Overview,” briefing by Irene L. Richardson, Industrial Hygienist, U.S. Army Center for Health Promotion and Preventative Medicine; and “TOCDF Industrial Hygiene Program,” briefing to the committee, November 6, 2006.

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accomplished based on time-weighted-average (TWA) noise exposure levels to steady state noise” (SMR IH011; Army Materiel Command, 2005). However, at TOCDF, all workers potentially exposed at any time to noise levels in excess of 85 A-weighted decibels (dBA), no matter how short the duration, are enrolled in the HCP regardless of their TWA noise exposure. The TOCDF IH program uses the guideline DA PAM 40-501, Hearing Conservation Program, which states that “personnel will be enrolled in an HCP when they are exposed to (1) steady-state noise with a TWA of 85 dBA or greater …” (U.S. Army, 1998, p. 3). DA PAM 40-501 further states that “the IHPM [Industrial Hygiene Program Manager] … determines the TWA for all Department of Defense (DOD) civilian employees routinely working in hazardous noise areas and military personnel working in hazardous noise industrial-type operations at least once and within 30 days of any change in operations affecting noise levels” (U.S. Army, 1998, p. 4). The Industrial Hygiene Program Manager is required to notify the unit commander or supervisor, in writing, about the “magnitude of noise exposure based on a TWA for civilian employees working in noise-hazardous areas and for soldiers working in noise-hazardous industrial operation” (U.S. Army, 1998, p. 4). Since TOCDF IH staff state that they comply with DA PAM 40-501, TWA noise sampling has been conducted and reported to the unit commander. Employees who are exposed to noise at 85 dB of noise, but whose noise exposure may fall below the TWA of 85 dBA, are included in the HCP.8 Applying the guidance cited by the SMR (DA PAM 40-503, Section 4-8, Item b[2]) would serve no purpose other than to meet a specification without any material benefit to program performance or worker protection. The committee notes that in reality the matter discussed above is largely moot, because approximately 50 percent of TOCDF site personnel are subject to the Chemical Surety Program and are, by definition, included in the HCP and receive annual audiometric evaluations. All site employees are assigned to the HCP on the basis of the criteria discussed above.9 As a result, far more employees are included in the HCP than would be the case if the requirement cited in the SMR were the basis on which they were included. FINDINGS AND RECOMMENDATIONS Finding 1. It is clearly the intent of the U.S. Army that the principal standard against which industrial hygiene programs should be measured is 29 CFR 1910, Occupational Safety and Health Standards. Finding 2. The deficiencies noted in the Surety Management Review regarding the industrial hygiene program at the Tooele Chemical Agent Disposal Facility (TOCDF) are based primarily on reference to nonbinding guidance documents, but at most they would constitute de minimis violations pursuant to 29 CFR 1910, Occupational Safety and Health Standards, and would have no impact on operational risk or program performance at TOCDF. 8 “TOCDF Industrial Hygiene Program,” briefing to the committee, November 6, 2006. 9 “TOCDF Industrial Hygiene Program,” briefing to the committee, November 6, 2006.

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Finding 3. The rating of the industrial hygiene program of the Tooele Chemical Agent Disposal Facility as “Mission Capable with Limitations” was not supported by Surety Management Review findings and was therefore inappropriate. Finding 4. The industrial hygiene program at the Tooele Chemical Agent Disposal Facility meets the goal of protecting the safety and health of the workers employed at the facility. Finding 5. Based on its limited assessment of the Tooele Chemical Agent Disposal Facility (TOCDF) industrial hygiene (IH) program, the committee found the TOCDF IH program to be essentially equivalent to IH programs in industry. The committee did not find any apparent shortcomings in the TOCDF IH program. Recommendation 1. Occupational Safety and Health Administration standards and applicable program-specific guidance (e.g., Department of the Army Pamphlet 40-501, Hearing Conservation Program) should be used as a basis for identifying deficiencies during industrial hygiene program reviews and audits. Observations stemming from general guidance documents (e.g., Department of the Army Pamphlet 40-503, Industrial Hygiene Program) could form the basis for a dialogue that leads to mutual understanding and improvement(s) in program design, implementation, execution, and management. Recommendation 2. The nature and significance of deficiencies should be considered when assessing whether an industrial health program meets its objectives. Recommendation 3. The Tooele Chemical Agent Disposal Facility should strive to improve its industrial hygiene program continuously. For example, contractors should consider all available information when conducting their IH programs, whether or not the information is contractually required. Sincerely, J. Robert Gibson, Chair Committee to Review and Assess Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility

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Attachments: A Statement of Task B Committee Membership C Subject Matter Experts Participating in Meeting D Bibliography E Acronyms F Acknowledgment of Reviewers

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Attachment A STATEMENT OF TASK The Committee to Review and Assess Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility (TOCDF) will: Review and analyze findings from the Surety Management Review conducted at TOCDF October 17, 2005 through October 21, 200510 in the point of view of actual policies and procedures in place at TOCDF, Industrial Hygiene Standards and practices identified therein, and the standards used by similar industries; Identify differences and assess their implications on safety and operational risk under the existing performance based contract with systems contractor (EG&G) for TOCDF; Recommend courses of action regarding Industrial Hygiene practices at TOCDF; Prepare a letter report of its findings and recommendations; Provide the sponsor the letter report within 60 days of the first meeting of the committee. 10 Although the statement of task indicates that the SMR took place on October 17, 2005, through October 21, 2005, when the committee reviewed the actual documents they found that the dates had been October 11, 2005, through October 21, 2005. Hence the reader will note two different sets of dates.

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Attachment B COMMITTEE MEMBERSHIP J. ROBERT GIBSON, Chair, Consultant, Wilmington, Delaware JACQUELINE AGNEW, Johns Hopkins Bloomberg School of Public Health, Baltimore, Maryland CHARLES BARTON, Iowa Department of Public Health, Des Moines RONALD M. BISHOP, AEHS, Inc., San Antonio, Texas RICHARD A. CONWAY, Union Carbide Corporation (retired), Charleston, West Virginia RANDAL J. KELLER, Murray State University, Murray, Kentucky W. MONROE KEYSERLING, University of Michigan, Ann Arbor PETER S. J. LEES, Johns Hopkins Bloomberg School of Public Health, Baltimore, Maryland Staff BRUCE A. BRAUN, Director, Board on Army Science and Technology MARGARET N. NOVACK, Study Director JAMES C. MYSKA, Senior Research Associate NIA JOHNSON, Senior Program Associate SARAH PELLEGRIN, Senior Program Assistant BIOGRAPHIES J. Robert Gibson is currently an independent consultant in the field of toxicology and occupational safety and health. Dr. Gibson graduated from Mississippi State University with a Ph.D. in physiology and holds a master’s degree in zoology and a bachelor of science degree in general science from the same institution. After completing a postdoctoral research fellowship in pesticide metabolism at the University of Kentucky, he joined DuPont’s Haskell Laboratory for Toxicology and Industrial Medicine as a research toxicologist. During his 30-year career with DuPont, Dr. Gibson held management positions in research and development, chemical manufacturing, and corporate administration (he was the corporate director of safety and health). He was also assistant director of DuPont’s Haskell Laboratory for Toxicology and Industrial Medicine. Dr. Gibson completed his career with DuPont as a director in the Crop Protection Products Division in Wilmington, Delaware, in December 2001. He was board-certified in toxicology by the American Board of Toxicology from 1980 through 2005. His numerous committee assignments include 8 years of service on the National Research Council’s (NRC’s) Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee), which provided oversight for the U.S. Army’s chemical weapons

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disposal program. Dr. Gibson is also the U.S. representative to the Scientific Advisory Board of the Organization for the Prohibition of Chemical Weapons. Jacqueline Agnew is a professor of environmental health sciences in the Division of Occupational and Environmental Health at the Johns Hopkins Bloomberg School of Public Health, Baltimore, Maryland. She received her Ph.D. in 1985 and M.P.H. in 1978, both from Johns Hopkins. Dr. Agnew is also a registered nurse. She is an elected fellow in the American Academy of Nursing and directs the Johns Hopkins Education and Research Center in Occupational Health and Safety, a multidisciplinary center, which prepares occupational health professionals and provides outreach to the practicing community. Within that center, she also directs the Occupational and Environmental Health Nursing Program. Dr. Agnew provides consultation to other institutions, nationally and internationally, on curriculum and educational program development in occupational and environmental health. She is currently a member of the Institute of Medicine’s Roundtable on Environmental Health Sciences, Research, and Medicine and a member of the National Institute for Occupational Safety and Health’s National Occupational Research Agenda Liaison Committee. Charles Barton is currently the Iowa state toxicologist at the Iowa Department of Public Health. Dr. Barton received his Ph.D. in toxicology from the University of Louisiana. In addition to being a certified toxicologist, he is certified in conducting public health assessments, health education activities, and risk assessments; in emergency response to terrorism and emergency-response incident command; and in hazardous waste operations and emergency response. In his position as the state toxicologist, Dr. Barton serves as the statewide public health resource, providing health consultations and advice to other environment and health-related agencies, as well as to health care providers and to business and industry representatives. He currently directs, or has directed, a host of Iowa Department of Public Health programs, including programs involving polychlorinated biphenyls (PCBs), radon, water-treatment-system registration, hazardous substances emergency surveillance, hazardous waste site health assessment, risk assessment for the Superfund program, the Iowa toxicology program, and many others. Ronald M. Bishop, founder and president of AEHS, Inc., has worked for 12 years as an environmental, safety, and industrial hygiene consultant. His experience includes not only consulting per se, but also instructing in a myriad of courses on indoor air quality, asbestos, and lead as well as respiratory protection, LO/TO, HAZCOM, confined space, and Occupational Safety and Health Administration’s (OSHA’s) 501 Voluntary Compliance. He earned his bachelor of science degree in preventive medicine (environmental health engineering) from the University of Washington and a master of public health in industrial hygiene, with additional concentration in Air Pollution, from the University of Minnesota. Mr. Bishop also served for 2 years as director of the Office of Safety and Health Protection at the Oak Ridge National Laboratory, where he was responsible for all safety, industrial hygiene, OSHA regulations, hazardous waste management, and technical training. Mr. Bishop spent 25 years in the U.S.

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Army with numerous environmental, safety, and health positions, retiring as a colonel; his last assignment was as commander of the U.S. Army Environmental Hygiene Agency. Richard A. Conway (NAE) is currently retired from Union Carbide Corporation, where he was a senior corporate fellow working in health, safety, and environment. He received his M.S. from the Massachusetts Institute of Technology in environmental engineering and a B.S. in public health from the University of Massachusetts at Amherst. Mr. Conway has been very active within the NRC, recently serving on the Report Review Committee, and being named as a National Associate. Environmental protection, including the various disposal processes for industrial wastes, has been his lifelong focus. He is a Registered Professional Engineer and a Board Certified Environmental Engineer. Randal J. Keller is currently an associate professor in the Department of Occupational Safety and Health at Murray State University. He received a B.A. in chemistry from Eisenhower College in 1979, his M.S. in toxicology from Utah State University in 1984, and his Ph.D., also in toxicology, from Utah State University in 1988. He is certified in the Comprehensive Practice of Industrial Hygiene by the American Board of Industrial Hygiene, in the Comprehensive Practice of Safety by the Board of Certified Safety Professionals, and in the General Practice of Toxicology by the American Board of Toxicology. Dr. Keller is widely published and maintains an independent consulting practice related to toxicology, industrial hygiene, and safety. W. Monroe Keyserling, professor, University of Michigan, has 27 years’ experience in research and teaching activities focused on occupational safety and health. His teaching activities include courses in occupational safety engineering, work measurement, prevention of work-related musculoskeletal disorders, and a seminar in occupational health and safety engineering. Dr. Keyserling holds a B.I.E. in industrial and systems engineering from the Georgia Institute of Technology and an M.S.E. in industrial and operations engineering; M.S., industrial health science; and Ph.D., industrial and operations engineering and industrial health from the University of Michigan. He has written more than 120 journal articles, book chapters, and technical reports. His primary research area has been the development of methods and tools for measuring workplace exposures that increase the risk of work-related musculoskeletal disorders, such as low back pain and carpal tunnel syndrome. Dr. Keyserling has also been active in university-wide and national efforts to promote multidisciplinary education and research in occupational health and safety. From 1995 to 2000, he served as director of the University of Michigan Center for Occupational Health and Safety Engineering, a collaboration involving the College of Engineering, School of Public Health, and School of Nursing. From 1999 to 2002, he served as president of the Association of University Programs in Occupational Health and Safety, a national advocacy group that promotes safety and health education and research. Peter S. J. Lees is currently a professor of environmental health sciences at the Johns Hopkins Bloomberg School of Public Health. He serves concurrently at the same institution as the deputy director of the National Institute for Occupational Safety and Health’s (NIOSH’s) Education and

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Research Center on Occupational Safety and Health. Dr. Lees received his Ph.D. in environmental health engineering/industrial hygiene from Johns Hopkins in 1986. He is a member of numerous professional societies.

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Attachment C SUBJECT MATTER EXPERTS PARTICIPATING IN MEETING, TOOELE CHEMICAL AGENT DISPOSAL FACILITY (TOCDF), UTAH NOVEMBER 6-8, 2006 Chemical Materials Agency Alan Cushen Raj Malhotra Trace Salmon (on-site at TOCDF) Site Management and Industrial Hygiene Staff of TOCDF Systems Contractor EG&G Paul Andersen Steve Bunn Vicky Edwards Thomas Hall Joe Majestic Gary McCloskey Dalene Nickelson Tooele Outreach Office Clint Warby U.S. Army Center for Health Promotion and Preventative Medicine Irene Richardson

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Attachment D BIBLIOGRAPHY Army Materiel Command. 2005. “Memorandum from Headquarters, Army Materiel Command, to Commander, Deseret Chemical Depot, AMC Surety Management Review Report,” October 27. Clean Harbors Aragonite, LLC. Industrial Hygiene Plan (Revised 2004). Aragonite, Utah. Deseret Chemical Depot. 2005. “Memorandum from Commander, Deseret Chemical Depot, to Headquarters, Army Materiel Command, Corrective Action Response to the AMC Surety Management Review 11-20 October 2005,” November 30. Deseret Chemical Depot. 2006. “Memorandum from Commander, Deseret Chemical Depot, to Headquarters, Army Materiel Command, Corrective Action Response to the AMC Surety Management Review 11-20 October 2005,” January 19. U.S. Army. 1985. TB MED (Technical Bulletin Medical) 503: Occupational and Environmental Health, The Army Industrial Hygiene Program. Headquarters, Department of the Army, Washington, D.C., February 1. U.S. Army. 1990. DA PAM (Department of the Army Pamphlet) 40-8: Medical Services, Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to Nerve Agents GA, GB, GD, and VX. Headquarters, Department of the Army, Washington, D.C., December 4. U.S. Army. 1998. DA PAM 40-501: Medical Services, Hearing Conservation Program. Headquarters, Department of the Army, Washington, D.C., December 10. U.S. Army. 2000. DA PAM 40-503: Medical Services, Industrial Hygiene Program. Headquarters, Department of the Army, Washington, D.C., October 30. U.S. Army. 2001. DA PAM 385-1: Safety, Small Unit Safety Officer/NCO Guide. Headquarters, Department of the Army, Washington, D.C., November 29. U.S. Army. 2003. DA PAM 40-173: Medical Services, Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to Mustard Agents H, HD, and HT. Department of the Army, Washington, D.C., June 3. U.S. Army. 2003. TB MED 507: Heat Stress Control and Heat Casualty Management. Headquarters, Department of the Army and Air Force, Washington, D.C., March 7. U.S. Department of Labor, Occupational Safety and Health Administration. 1998. Informational Booklet on Industrial Hygiene, OSHA 3143(Revised). Washington, D.C.

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Attachment E ACRONYMS CMA Chemical Materials Agency CSP certified safety professional DA PAM Department of the Army Pamphlet dBA A-weighted decibels HAZCOM hazards communication HCP Hearing Conservation Program IH industrial hygiene MSDS material safety data sheet NRC National Research Council OSHA Occupational Safety and Health Administration PHA Process Hazard Analysis SMR Surety Management Review TB MED technical bulletin—medical TOCDF Tooele Chemical Agent Disposal Facility TWA time-weighted average

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Attachment F ACKNOWLEDGMENT OF REVIEWERS This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the National Research Council’s (NRC’s) Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Robert F. Herrick, Harvard School of Public Health, Linda A. McCauley, University of Pennsylvania, Josef Michl, University of Colorado, Bruce Reinert, Los Alamos National Laboratory, Jim E. Riviere, North Carolina State University, and Bailus Walker, Jr., Howard University Medical Center. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of this report was overseen by Robert A. Beaudet, Jet Propulsion Laboratory. Appointed by the NRC, he was responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.