Interim Guidance for Protecting Deepwater Horizon Response Workers and Volunteers

C. Use of Respiratory Protection

A decision to use respiratory protection should be based on the best available qualitative information using the expert opinion method and on the best available comprehensive quantitative information about the type and level of exposure to toxic chemical and physical agents by the inhalational route. The use of effective engineering and administrative controls, and other personal protective equipment should be implemented before the use of respirators for worker protection is considered.

1. Source Control Activities

The source control vessels conduct activities closest to the area where crude oil appears on the surface, including drilling relief wells, conducting underwater operations at the source including dispersant application, and providing support and supplies. If surface application of dispersant is deemed necessary, it should be applied at a safe distance from vessels operating in the area. Variable concentrations of hydrocarbons are likely present in the air in and around these vessels. Engineering and administrative controls should be used to control hydrocarbon vapor levels during source control activities, but exposures to crude oil-derived VOCs and other constituents may not be eliminated entirely. Significant spikes in concentrations may occur unexpectedly, and would necessitate donning a respirator especially when engineering and administrative controls cannot provide protection.

For workers involved in source control activities, respirators should be used in those situations where potentially excessive exposure is reasonably anticipated or where indicated by exposure assessment or where symptoms/health effects are being reported. Where eye protection is not needed against irritating gases/vapors, NIOSH and OSHA recommend using a half facepiece respirator. If eye protection is needed, NIOSH and OSHA recommend a full facepiece elastomeric respirator with an organic vapor/P100 cartridge. A full facepiece respirator provides eye protection against irritating gases/vapors and a relatively high level of respiratory protection when exposures are variable and potentially higher. Cartridges including P100 particulate filters (oil resistant) are recommended over N95 filters (not resistant to oil aerosols). The combination organic vapor/P100 cartridge provides comprehensive protection against both particulates and gases and vapors, and the P100 filter provides some protection against water mist for the organic vapor filter component.

2. Off-Shore Activities

a. Vessels Involved in Burning Crude Oil

Vessels involved in crude oil burning are exposed to crude oil/dispersant that is less aged and may emit more VOCs than crude/dispersant closer to shore that may have undergone more weathering. The primary hazards from in-situ burns are likely to be heat, exposure to products of combustion and, rarely, flash fire. Some vessels engaged in burning may be working in close proximity to source control activities.

Products of combustion will include a complex mixture of particulate matter, smoke and soot; VOCs such as partially oxidized alcohols, aldehydes, and ketones; metals like vanadium, chromium, and nickel; and gases such as carbon dioxide and carbon monoxide.²⁷,²⁸ The chemical composition of these emissions will vary based on the oil composition, weather conditions during each burn, and the completeness of the combustion process. When in-situ (i.e., on-site) burns are conducted, they should be conducted remotely with all vessels positioned upwind at an adequate distance away from the resultant smoke plume. Every effort should be made to keep workers from the area of the smoke plume, and to evacuate them as quickly as possible when changing conditions may put them in the area of the contaminants of the burn.

Under ideal conditions, vessels will be located a sufficient distance upwind from burns, and respiratory protection may not be necessary. The employer should assess the specific job tasks before the burning activity to evaluate potential worker exposures and then select respiratory protection and other PPE according to the results of their evaluation. Respiratory protection will be needed, however, when shifts in wind cause exposure to the combustion products in the plume. Under such circumstances, or where symptoms/health effects are being reported, inhalational exposure may occur and NIOSH and OSHA recommend respiratory and eye protection.

For unexpected exposures, protection can be provided by use of a full facepiece elastomeric respirator with an organic vapor/P100 cartridge. A full facepiece respirator is preferred because it provides both eye protection against irritating smoke and an appropriate level of respiratory protection. Cartridges including P100 particulate filters (oil resistant) are recommended over N95 filters (not resistant to oil aerosols). The combination organic vapor/P100 cartridge provides comprehensive protection against soot, gases and vapors. Another means of protection is non-vented safety goggles to prevent eye irritation and a half-mask respirator with an organic vapor/P100 cartridge.

Note: Flame resistant clothing will help protect workers, for instance, such as those workers in the igniter boat during in-situ burning. The clothing should be cleaned, maintained, and regularly inspected in accordance with the manufacturer’s instructions. Some flame resistant clothing may lose its protective qualities after repeated or improper cleanings. Wearing any flammable clothing over flame resistant clothing will negate the flame resistant protection. Flame resistant clothing should be selected in accordance with 29 CFR Subpart I (Personal Protective Equipment), Section 1910.132, General Requirements.

b. Vessels Not Involved in Source Control or Burning

Some vessels operating off-shore engage in deployment of containment and sorbent booms, skimming operations to remove oil from the water, and dispersant application. These vessels are not involved in burning nor are they located in close proximity to in-situ burning. Generally, these vessels have contact with oil that has weathered, and, as such, does not emit significant amounts of VOCs. Respiratory protection generally will not be necessary as symptoms/health effects are not expected to occur in this setting. Dermal protection is needed.

Other vessels not involved in burning may operate at a farther distance from shore and possibly encounter more volatile crude. In this case, administrative controls (e.g., worker rotation and decrease in work hours) and respiratory protection (e.g., half-mask elastomeric respirator with an organic vapor cartridge) should be implemented where symptoms/health effects are being reported.

Note: Representative and routine air and personal breathing zone monitoring should be conducted to verify that unsafe exposures are not occurring, especially when these vessels operate in areas where partially weathered crude oil exist.

3. Shoreline Clean-up Activities

The types of activities associated with shoreline cleaning include manual removal of “tarballs” or “tarpatties,” shovel removal of oiled-contaminated sand, low pressure flushing, manual sorbent application, and manual cutting of vegetation. Since inhalational exposure to oil and dispersants during shoreline clean-up operations is low because of weathering, respiratory protection is not recommended. However, if symptoms/health effects occur, the affected worker(s) should be removed and evaluated medically, and then the worksite should be assessed for potential exposure to heat and VOCs for the remaining workers.

Note: If high pressure washing is conducted, aerosolization of oil mist into respirable droplets could occur and respiratory protection is recommended with use of at least the level of a disposable P100 filtering facepiece respirator. The use of highly concentrated detergents, degreasers, and solvents, and the use of heated water during pressure washing, may volatilize hydrocarbons and result in the need for respiratory protection. Respiratory protection, if deemed necessary by professional judgment and/or air monitoring results, should include the use of a combination organic vapor/P100 cartridge half mask respirator. Eye and skin protection during such activities also will be necessary.

4. Decontamination Activities

a. PPE and Other Equipment

Vessels, PPE and other equipment may become contaminated with weathered oil. Respiratory protection is generally not necessary for this activity, although other PPE, including dermal, eye, face protection and protective footwear is necessary. If a high pressure washing mechanical sprayer is used to decontaminate PPE and other equipment, respirable particle aerosolization of oil mist could occur. When there is potential exposure to oil mist, particulate respiratory protection of at least the level of a P100 disposable filtering facepiece respirator is recommended in addition to skin, eye, face protection and protection footwear, particularly if highly concentrated detergents, solvents or degreasers are used.

b. Cleaning Wildlife

Task observations of cleaning and caring for birds, turtles and other wildlife indicate that aerosols of water, crude oil, soap, ammonia and other chemicals are likely to be generated. Eye and face protection, in addition to skin protection is recommended. When irritating concentrations of ammonia are experienced, dilutional ventilation, for example, by means of fans and other means to increase air exchange, are recommended.
Recommended PPE includes eye protection, i.e., safety glasses, goggles or face shields. Birds will peck under stress and may aim for the eyes. Eye protection is also necessary to protect against large droplet sprays from struggling birds. Oil-resistant outer protective clothing is recommended. An oil-resistant gown may provide sufficient upper body protection, avoiding the need for coveralls. Gloves (neoprene or nitrile rubber) that are oil resistant and provide protection against pecking and sharp talons are recommended. Non-skid footwear or boots that are oil-resistant and waterproof are also recommended.²⁹ Respiratory protection is not generally recommended, unless wildlife is heavily coated with fresh crude oil. In such cases, a half mask respirator with an organic vapor cartridge is recommended.

5. Waste Stream Management Activities

Response and remediation workers are engaged in the disposal and recycling of hazardous solid and liquid wastes during collection, storage, transport and final disposal. Deepwater Horizon Response waste management workers are at risk of a number of hazards including falls, other musculoskeletal injury, and dermal exposure to the components of the waste stream. Waste stream management workers should be trained, provided appropriate PPE, and have their work activities monitored for exposure in compliance with applicable state and Federal laws and regulations. ³⁰