Letter Report: Review and Assessment of Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility (2007) / Chapter Skim
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Letter Report
Letter Report
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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)
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. SURETY MANAGEMENT REVIEW FINDINGS The SMR findings cited one "systemic" TOCDF IH program limitation (finding IH007)
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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.
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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.
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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.
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Based on its limited assessment of the Tooele Chemical Agent Disposal Facility (TOCDF) industrial hygiene (IH)
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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.
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Sincerely, J Robert Gibson, Chair Committee to Review and Assess Industrial Hygiene Standards and Practices at Tooele Chemical Agent Disposal Facility 8
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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 9
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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. 10Although 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.
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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.
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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.
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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.
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in environmental health engineering/industrial hygiene from Johns Hopkins in 1986. He is a member of numerous professional societies.
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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 15
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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.
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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 17
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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.
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