A EPA
PEER REVIEW DRAFT - DO NOT CITE OR QUOTE
United States Office of Chemical Safety and
Environmental Protection Agency Pollution Prevention
Draft Risk Evaluation for
Methylene Chloride
(Dichloromethane, DCM)
DCM Supplemental File:
Supplemental Information on Releases and Occupational Exposure
Assessment
CASRN: 75-09-2
H
..^Cl
October 2019
NOTICE: This information is distributed solely for the purpose of pre-dissemination peer review under
applicable information quality guidelines. It has not been formally disseminated by EPA. It does not
represent and should not be construed to represent any Agency determination or policy. It is being
circulated for review of its technical accuracy and science policy implications.
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TABLE OF CONTENTS
ABBREVIATIONS 13
1 INTRODUCTION 15
1.1 Overview 15
1.2 Scope 15
1.3 Components of the Occupational Exposure and Environmental Release Assessment 22
1.4 General Approach and Methodology for Occupational Exposures and Environmental Releases
22
1.4.1 Process Description 22
1.4.2 Facility Estimates and Number of Workers and Occupational Non-Users 22
1.4.3 Worker Activities 23
1.4.4 Inhalation Exposure Assessment Approach and Methodology 23
1.4.4.1 General Approach 23
1.4.4.2 Approach for thi s Ri sk Evaluati on 25
1.4.4.3 Respiratory Protection 25
1.4.5 Dermal Exposure Assessment Approach 27
1.4.6 Water Release Assessment Approach 27
2 ENGINEERING ASSESSMENT 28
2.1 Manufacturing 28
2.1.1 Process Description 28
2.1.2 Number of Sites and Potentially Exposed Workers 29
2.1.3 Exposure Assessment 30
2.1.3.1 Worker Activities 30
2.1.3.2 Inhalation Exposures 30
2.1.4 Water Release Assessment 31
2.1.5 Uncertainties 33
2.2 Processing as a Reactant 33
2.2.1 Process Description 33
2.2.2 Number of Sites and Potentially Exposed Workers 33
2.2.3 Exposure Assessment 34
2.2.3.1 Worker Activities 34
2.2.3.2 Inhalation Exposures 34
2.2.4 Water Release Assessment 35
2.2.5 Uncertainties 35
2.3 Processing - Incorporation into Formulation, Mixture, or Reaction Product 36
2.3.1 Process Description 36
2.3.2 Number of Sites and Potentially Exposed Workers 36
2.3.3 Exposure Assessment 37
2.3.3.1 Worker Activities 37
2.3.3.2 Inhalation Exposures 37
2.3.4 Water Release Assessment 38
2.3.5 Uncertainties 39
2.4 Repackaging 39
2.4.1 Process Description 39
2.4.2 Number of Sites and Potentially Exposed Workers 40
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2.4.3 Exposure Assessment 41
2.4.3.1 Worker Activities 41
2.4.3.2 Inhalation Exposures 42
2.4.4 Water Release Assessment 43
2.4.5 Uncertainties 43
2.5 Batch Open-Top Vapor Degreasing 44
2.5.1 Process Description 44
2.5.2 Number of Sites and Potentially Exposed Workers 45
2.5.3 Exposure Assessment 45
2.5.3.1 Worker Activities 45
2.5.3.2 Inhalation Exposures 45
2.5.4 Water Release Assessment 46
2.5.5 Uncertainties 46
2.6 Conveyorized Vapor Degreasing 46
2.6.1 Process Description 46
2.6.2 Number of Sites and Potentially Exposed Workers 50
2.6.3 Exposure Assessment 50
2.6.3.1 Worker Activities 50
2.6.3.2 Inhalation Exposures 50
2.6.4 Water Release Assessment 51
2.6.5 Uncertainties 51
2.7 Cold Cleaning 51
2.7.1 Process Description 51
2.7.2 Number of Sites and Potentially Exposed Workers 52
2.7.3 Exposure Assessment 52
2.7.3.1 Worker Activities 52
2.7.3.2 Inhalation Exposures 53
2.7.4 Water Release Assessment 54
2.7.5 Uncertainties 54
2.8 Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care
Products) 54
2.8.1 Process Description 54
2.8.2 Number of Sites and Potentially Exposed Workers 55
2.8.3 Exposure Assessment 57
2.8.3.1 Worker Activities 57
2.8.3.2 Inhalation Exposures 58
2.8.4 Water Release Assessment 60
2.8.5 Uncertainties 60
2.9 Adhesives and Sealants 60
2.9.1 Process Description 60
2.9.2 Number of Sites and Potentially Exposed Workers 61
2.9.3 Exposure Assessment 64
2.9.3.1 Worker Activities 64
2.9.3.2 Inhalation Exposures 64
2.9.4 Water Release Assessment 65
2.9.5 Uncertainties 65
2.10 Paints and Coatings 65
2.10.1 Process Description 66
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2.10.2 Number of Sites and Potentially Exposed Workers 66
2.10.3 Exposure Assessment 68
2.10.3.1 Worker Activities 68
2.10.3.2 Inhalation Exposures 68
2.10.4 Water Release Assessment 70
2.10.5 Uncertainties 70
2.11 Adhesive and Caulk Removers 70
2.11.1 Process Description 70
2.11.1 Number of Sites and Potentially Exposed Workers 71
2.11.2 Exposure Assessment 72
2.11.2.1 Worker Activities 72
2.11.2.2 Inhalation Exposures 72
2.11.3 Water Release Assessment 73
2.11.4 Uncertainties 73
2.12 Fabric Finishing 73
2.12.1 Process Description 73
2.12.2 Number of Sites and Potentially Exposed Workers 73
2.12.3 Exposure Assessment 74
2.12.3.1 Worker Activities 74
2.12.3.2 Inhalation Exposure 74
2.12.4 Water Release Assessment 75
2.12.5 Uncertainties 75
2.13 Spot Cleaning 75
2.13.1 Process Description 75
2.13.2 Number of Sites and Potentially Exposed Workers 76
2.13.3 Exposure Assessment 77
2.13.3.1 Worker Activities 77
2.13.3.2 Inhalation Exposures 77
2.13.4 Water Release Assessment 78
2.14 Cellulose Triacetate Film Production 79
2.14.1 Process Description 79
2.14.2 Number of Sites and Potentially Exposed Workers 79
2.14.3 Exposure Assessment 79
2.14.3.1 Worker Activities 79
2.14.3.2 Inhalation Exposure 79
2.14.4 Water Release Assessment 80
2.14.5 Uncertainties 80
2.15 Flexible Polyurethane Foam Manufacturing 80
2.15.1 Process Description 81
2.15.2 Number of Sites and Potentially Exposed Workers 81
2.15.3 Exposure Assessment 82
2.15.3.1 Worker Activities 82
2.15.3.2 Inhalation Exposures 82
2.15.4 Water Release Assessment 83
2.15.5 Uncertainties 84
2.16 Laboratory Use 84
2.16.1 Process Description 84
2.16.2 Number of Sites and Potentially Exposed Workers 84
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2.16.3 Exposure Assessment 85
2.16.3.1 Worker Activities 85
2.16.3.2 Inhalation Exposure 85
2.16.4 Water Release Assessment 87
2.16.5 Uncertainties 88
2.17 Plastic Product Manufacturing 88
2.17.1 Process Description 88
2.17.2 Number of Sites and Potentially Exposed Workers 88
2.17.3 Exposure Assessment 89
2.17.3.1 Worker Activities 89
2.17.3.2 Inhalation Exposure 89
2.17.4 Water Release Assessment 91
2.17.5 Uncertainties 92
2.18 Pharmaceutical Production 92
2.18.1 Process Description 92
2.18.2 Number of Sites and Potentially Exposed Workers 93
2.18.3 Exposure Assessment 93
2.18.3.1 Worker Activities 93
2.18.3.2 Inhalation Exposure 93
2.18.4 Water Release Assessment 94
2.18.5 Uncertainties 95
2.19 Lithographic Printing Plate Cleaning 95
2.19.1 Process Description 95
2.19.2 Number of Sites and Potentially Exposed Workers 96
2.19.3 Exposure Assessment 96
2.19.3.1 Worker Activities 96
2.19.3.2 Inhalation Exposure 96
2.19.4 Water Release Assessment 97
2.19.5 Uncertainties 98
2.20 Miscellaneous Non-Aerosol Industrial and Commercial Uses 98
2.20.1 Process Description 98
2.20.2 Number of Sites and Potentially Exposed Workers 98
2.20.3 Exposure Assessment 98
2.20.3.1 Worker Activities 98
2.20.3.2 Inhalation Exposure 98
2.20.4 Water Release Assessment 99
2.20.5 Uncertainties 99
2.21 Waste Handling, Disposal, Treatment, and Recycling 99
2.21.1 Process Description 99
2.21.2 Number of Sites and Potentially Exposed Workers 103
2.21.3 Exposure Assessment 104
2.21.3.1 Worker Activities 104
2.21.3.2 Inhalation Exposures 105
2.21.4 Water Release Assessment 106
2.21.5 Uncertainties 108
2.22 Other Reported Water Releases 108
3 SUMMARY OF OCCUPATIONAL EXPOSURE ASSESSMENT Ill
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3.1 Inhalation Exposure Assessment Ill
3.2 Dermal Exposure Assessment 113
4 DISCUSSION OF UNCERTAINTIES AND LIMITATIONS 120
4.1 Variability 120
4.2 Uncertainties and Limitations 120
4.2.1 Number of Workers 120
4.2.2 Analysis of Exposure Monitoring Data 121
4.2.3 Near-Field/Far-Field Model Framework 122
4.2.3.1 Vapor Degreasing Models 123
4.2.3.2 Brake Servicing Model 123
4.2.4 Modeling Dermal Exposures 124
4.2.5 Release Estimates 124
APPENDICES 126
Appendix A. Inhalation Monitoring Data 126
A. 1 Manufacturing............ ...126
A.2 Processing as a Reactant .162
A.3 Processing - Incorporation into Formulation, Mixture, or Reaction Product.................... ..166
A.4 Import and Repackaging 169
A.5 Cold Cleaning. .......1.................................... ...............................................172
A.6 Adhcsives and Sealants 174
A.7 Paints and Coatings ................................185
AJ Adheshe and Caulk Removers 190
A.9 Fabric Finishing.................. .................193
A. 10 Spot Cleaning .......................196
A.11 Cellulose Triacetate Film Production.......... 199
A.12 Flexible Polyurethane Foam Manufacturing....................... ...................203
A. 13 Laboratory Use..... ...........................210
A. 14 Plastic Product Manufacturing 216
A. 15 'Lithographic Printing Plate Cleaning........ ....................224
A, 16 Pharmaceutical Manufacturing ............................229
A. 17 Non-Aerosol Industrial and Commercial Use................. ..........232
A.18 Waste Handling, Disposal, Treatment, arid Recycling......... 240
Appendix B. Approach for Estimating Number of Workers 244
Appendix C. Equations for Calculating Acute and Chronic Exposures for Non-Cancer and
Cancer 249
Appendix D. Sample Calculations for Calculating Acute and Chronic (Non-Cancer and Cancer)
Inhalation Exposures 253
D.l Example High-End YDC and LADC. 253
D.2 Example Central Tendency ADC and LADC......... 253
Appendix E. Dermal Exposure Assessment Method 254
E.l Incorporating the Effects of Evaporation .............254
E. 1.1 Modification of EPA/OPPT Models 254
E.2 Calculation of fabs 254
E.2.1 Small Doses (Case 1: Mo < Msat) 255
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E.2.2 Large Doses (Case 2: Mo > Msat) 256
E.3 Comparison of fabsto Experimental Values for l-BP 257
E.4 Potential for Occlusion,...., .257
E.5 Incorporating Glove Protection., 259
E.6 Proposed Dermal Dose Equation ......260
Appendix F. Description of Models used to Estimate Worker and ONU Exposures 262
F. I Brake Servicing Near-Field/Far-Field Inhalation Exposure Model Approach and Parameters262
F. 1.1 Model Design Equations 263
F. 1.2 Model Parameters 268
F.1.2.1 Far-Field Volume 271
F.l.2.2 Air Exchange Rate 271
F.l.2.3 Near-Field Indoor Air Speed 271
F. 1.2.4 Near-Field Volume 272
F.l.2.5 Application Time 272
F.l.2.6 Averaging Time 272
F. 1.2.7 Methylene Chloride Weight Fraction 272
F.l.2.8 Volume of Degreaser Used per Brake Job 273
F. 1.2.9 Number of Applications per Brake Job 273
F.1.2.10 Amount of Methylene Chloride Used per Application 273
F. 1.2.11 Operating Hours per Week 274
F. 1.2.12 Number of Brake Jobs per Work Shift 274
F.2 Occupational Exposures during Vapor Degreasing and Cold Cleaning .,,...,....274
F.2.1 Model Design Equations 275
F.2.2 Model Parameters 279
F.2.2.1 Far-Field Volume 283
F.2.2.2 Air Exchange Rate 283
F.2.2.3 Near-Field Indoor Air Speed 283
F.2.2.4 Near-Field Volume 284
F.2.2.5 Exposure Duration 284
F.2.2.6 Averaging Time 284
F.2.2.7 Vapor Generation Rate 284
F.2.2.8 Operating Hours 286
REFERENCES 287
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LIST OF TABLES
Table 1-1. Crosswalk of Conditions of Use to Occupational Exposure Scenarios Assessed in the Risk
Evaluation 17
Table 1-2. Assigned Protection Factors for Respirators in OSHA Standard 29 CFR 1910.134a 26
Table 2-1 Number of Potentially Exposed Workers at Manufacturing Facilities (2016 CDR) 30
Table 2-2. Full-Shift Worker Exposure to Methylene Chloride During Manufacturing 31
Table 2-3. Short-Term Worker Exposure to Methylene Chloride During Manufacturing 31
Table 2-4. Reported TRI Releases for Organic Chemical Manufacturing Facilities 32
Table 2-5. Number of U.S. Establishments, Workers, and ONUs for Processing as a Reactant from 2016
CDR 33
Table 2-6. Number of U.S. Establishments, Workers, and ONUs for Processing as a Reactant 34
Table 2-7. Worker Exposure to Methylene Chloride During Processing as a Reactant During
Fluorochemicals Manufacturing 35
Table 2-8. Summary of Personal Short-Term Exposure Data for Methylene Chloride During Processing
as a Reactant 35
Table 2-9. Reported 2016 TRI and DMR Releases for Potential Processing as Reactant Facilities 35
Table 2-10. Number of U.S. Establishments, Workers, and ONUs for Processing - Incorporation into
Formulation, Mixture, or Reaction Product from 2016 CDR 37
Table 2-11. Worker Exposure to Methylene Chloride During Processing - Incorporation into
Formulation, Mixture, or Reaction Product 38
Table 2-12. Potential Industries Conducting Methylene Chloride Processing - Incorporation into
Formulation, Mixture, or Reaction Product in 2016 TRI or DMR 38
Table 2-13. Reported 2016 TRI and DMR Releases for Potential Processing—Incorporation into
Formulation, Mixture, or Reaction Product Facilities 39
Table 2-14 Number of Potential Import Facilities and Exposed Workers (2016 CDR) 40
Table 2-15. Number of U.S. Establishments, Workers, and ONUs for Processing - Repackaging from
2016 CDR 41
Table 2-16. Worker Exposure to Methylene Chloride During Import and Repackaging 42
Table 2-17. Summary of Personal Short-Term Exposure Data for Methylene Chloride During Import
and Repackaging 43
Table 2-18. Reported 2016 TRI and DMR Releases for Import and Repackaging Facilities 43
Table 2-19. Statistical Summary of Methylene Chloride 8-hr TWA Exposures (ADC and LADC) for
Batch Open-Top Vapor Degreasing 46
Table 2-20. Statistical Summary of Methylene Chloride 8-hr TWA Exposures (ADC and LADC) for
Conveyorized Vapor Degreasing 51
Table 2-21. Exposure to Methylene Chloride During Cold Cleaning 54
Table 2-22. NAICS Codes for Aerosol Degreasing and Lubricants 55
Table 2-23. Estimated Number of Workers Potentially Exposed to Methylene Chloride During Use of
Aerosol Degreasers and Aerosol Lubricants 57
Table 2-24. Statistical Summary of Methylene Chloride 8-hr TWA Exposures (ADC and LADC) for
Aerosol Products Based on Modeling 59
Table 2-25. US Number of Establishments and Employees for Industries Conducting Adhesive and
Sealant Application 62
Table 2-26. Exposure to Methylene Chloride During Industrial Non-Spray Adhesives and Sealants Use
64
Table 2-27. Exposure to Methylene Chloride During Industrial Spray Adhesives and Sealants Use 65
Table 2-28. Summary of Personal Short-Term Exposure Data for Methylene Chloride During Industrial
Adhesives and Sealants Use 65
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Table 2-29. Number of U.S. Establishments, Workers, and ONU for Industries Performing Paint and
Coating Application 67
Table 2-30. Exposure to Methylene Chloride During Paint/Coating Spray Application 69
Table 2-31. Exposure to Methylene Chloride During Paint/Coating (Unknown Application Method)... 69
Table 2-32. Summary of Personal Short-Term Exposure Data for Methylene Chloride During
Paint/Coating Use 69
Table 2-33. Number of U.S. Establishments, Workers, and ONUs for Industries Conducting Paint
Stripping 72
Table 2-34. Full-Shift Exposure to Methylene Chloride During Adhesive and Caulk Removal (Using
Professional Contractor Paint Stripping Data as Surrogate) 72
Table 2-35. Short-Term Exposure to Methylene Chloride During Adhesive and Caulk Removal (Using
Professional Contractor Paint Stripping Data as Surrogate) 73
Table 2-36. Number of U.S. Establishments, Workers, and ONUs for Fabric Finishing Sites 74
Table 2-37. Worker Exposure to Methylene Chloride During Fabric Finishing 75
Table 2-38. SOC Codes for Worker Exposure in Dry Cleaning 76
Table 2-39. Number of U.S. Establishments, Workers, and ONUs for Industries Using Spot Removers at
Dry Cleaners 77
Table 2-40. Exposure to Methylene Chloride During Spot Cleaning 78
Table 2-41. Summary of Personal Short-Term Exposure Data for Methylene Chloride During Spot
Cleaning 78
Table 2-42. Surface Water Releases of Methylene Chloride During Spot Cleaning 79
Table 2-43. Worker Exposure to Methylene Chloride During CTA Film Manufacturing 80
Table 2-44. Reported 2016 TRI and DMR Releases for CTA Manufacturing Facilities 80
Table 2-45. Number of U.S. Establishments, Workers, and ONUs for Industries Conducting
Polyurethane Foam Manufacturing 81
Table 2-46. Exposure to Methylene Chloride During Industrial Polyurethane Foam Manufacturing 83
Table 2-47. Summary of Personal Short-Term Exposure Data for Methylene Chloride During
Polyurethane Foam Manufacturing 83
Table 2-48. Water Releases Reported in 2016 TRI for Polyurethane Foam Manufacturing 84
Table 2-49. Number of U.S. Establishments, Workers, and ONUs for Testing Laboratories 85
Table 2-50. Worker Exposure to Methylene Chloride During Laboratory Use 86
Table 2-51. Worker Personal Short-Term Exposure Data for Methylene Chloride During Laboratory Use
86
Table 2-52. Number of U.S. Establishments, Workers, and ONUs for Testing Laboratories 89
Table 2-53. Worker and ONU Exposure to Methylene Chloride During Plastic Product Manufacturing90
Table 2-54. Worker Short-Term Exposure Data for Methylene Chloride During Plastic Product
Manufacturing 90
Table 2-55. Potential Industries Conducting Plastics Product Manufacturing in 2016 TRI or DMR 91
Table 2-56. Reported 2016 TRI and DMR Releases for Potential Plastics Product Manufacturing
Facilities 91
Table 2-57. Number of U.S. Establishments, Workers, and ONUs for Testing Laboratories 93
Table 2-58. Worker Exposure to Methylene Chloride During Pharmaceutical Production 94
Table 2-59. Potential Industries Conducting Pharmaceutical Production in 2016 TRI or DMR 94
Table 2-60. Reported 2016 TRI and DMR Releases for Pharmaceutical Manufacturing Facilities 95
Table 2-61. Number of U.S. Establishments, Workers, and ONUs for Printing 96
Table 2-62. Worker Exposure to Methylene Chloride During Printing Plate Cleaning 97
Table 2-63. Worker Short-Term Exposure Data for Methylene Chloride During Printing Plate Cleaning
97
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Table 2-64. Reported 2016 TRI and DMR Releases for Potential Lithographic Printing Facilities 98
Table 2-65. Worker Exposure to Methylene Chloride During Industrial and Commercial Non-Aerosol
Use 99
Table 2-66. Number of U.S. Establishments, Workers, and ONUs for Waste Handling 104
Table 2-67. Exposure to Methylene Chloride During Waste Handling and Disposal 105
Table 2-68. Worker Short-Term Exposure Data for Methylene Chloride During Waste Handling and
Disposal 106
Table 2-69. Potential Industries Conducting Waste Handling, Disposal, Treatment, and Recycling in
2016 TRI or DMR 107
Table 2-70. Reported 2016 TRI and DMR Releases for Potential Recycling/Disposal Facilities 107
Table 2-71. Reported 2016 DMR Releases for Wastewater Treatment Facilities 108
Table 2-72. Reported 2016 TRI and DMR Releases for Unclassified Facilities 110
Table 3-1. Summary of Acute and Chronic Inhalation Exposures to Methylene Chloride for Central and
Higher-End Scenarios by Use Ill
Table 3-2. Glove Protection Factors for Different Dermal Protection Strategies 113
Table 3-3. Modeled Dermal Retained Dose (mg/day) for Workers in All Conditions of Use 118
LIST OF FIGURES
Figure 2-1. Open Top Vapor Degreaser 44
Figure 2-2. Open Top Vapor Degreaser with Enclosure 45
Figure 2-3. Monorail Conveyorized Vapor Degreasing System {U.S. EPA, 1977, 3827321} 47
Figure 2-4. Cross-Rod Conveyorized Vapor Degreasing System {U.S. EPA, 1977, 3827321} 48
Figure 2-5. Vibra Conveyorized Vapor Degreasing System {U.S. EPA, 1977, 3827321} 48
Figure 2-6. Ferris Wheel Conveyorized Vapor Degreasing System {U.S. EPA, 1977, 3827321} 49
Figure 2-7. Belt/Strip Conveyorized Vapor Degreasing System {U.S. EPA, 1977, 3827321} 50
Figure 2-8 Typical Batch-Loaded, Maintenance Cold Cleaner {U.S. EPA, 1981, 3045012} 52
Figure 2-9 Illustration for Use of Cold Cleaner in a Variety of Industries 53
Figure 2-10 Overview of Aerosol degreasing 55
Figure 2-11 Schematic of the Near-Field/Far-Field Model for Aerosol degreasing 59
Figure 2-12 Overview of Use of Spot Cleaning at Dry Cleaners 76
Figure 2-13. Typical Waste Disposal Process {U.S. EPA, 2017, 5080418} 101
Figure 2-14. Typical Industrial Incineration Process 102
LIST OF APPENDIX TABLES
TableApx A-l. Summary of Full-Shift Inhalation Monitoring Data for Manufacturing 127
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing 144
TableApx A-3. Summary of Full-Shift Inhalation Monitoring Data for Processing as a Reactant 163
Table Apx A-4. Summary of Short-Term Inhalation Monitoring Data for Processing as a Reactant... 165
TableApx A-5. Summary of Full-Shift Inhalation Monitoring Data for Processing - Incorporation into
Formulation, Mixture, or Reaction Product 167
Table Apx A-6. Summary of Short-Term Inhalation Monitoring Data for Processing - Incorporation
into Formulation, Mixture, or Reaction Product 168
Table Apx A-7. Summary of Full-Shift Inhalation Monitoring Data for Import and Repackaging 170
Table Apx A-8. Summary of Short-Term Inhalation Monitoring Data for Import and Repackaging... 170
Table Apx A-9. Summary of Full-Shift Inhalation Monitoring Data for Cold Cleaning 173
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and
Sealants 175
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TableApx A-l 1. Summary of Short-Term Inhalation Monitoring Data for Application of Adhesives
and Sealants 183
Table Apx A-12. Summary of Full-Shift Inhalation Monitoring Data for Application of Paints and
Coatings 186
TableApx A-13. Summary of Short-Term Inhalation Monitoring Data for Application of Paints and
Coatings 188
Table Apx A-14. Summary of Full-Shift Inhalation Monitoring Data for Paint Stripping by Professional
Contractors 192
Table Apx A-15. Summary of Short-Term Inhalation Monitoring Data for Paint Stripping by
Professional Contractors 192
Table Apx A-16. Summary of Full-Shift Inhalation Monitoring Data for Fabric Finishing 194
Table Apx A-17. Summary of Full-Shift Inhalation Monitoring Data for Spot Cleaning 197
Table Apx A-18. Summary of Short-Term Inhalation Monitoring Data for Spot Cleaning 198
Table Apx A-19. Summary of Full-Shift Inhalation Monitoring Data for Cellulose Triacetate Film
Manufacturing 200
Table Apx A-20. Summary of Full-Shift Inhalation Monitoring Data for Flexible Polyurethane Foam
Manufacturing 204
Table Apx A-21. Summary of Short-Term Inhalation Monitoring Data for Flexible Polyurethane Foam
Manufacturing 209
Table Apx A-22. Summary of Full-Shift Inhalation Monitoring Data for Laboratory Use 211
Table Apx A-23. Summary of Short-Term Inhalation Monitoring Data for Laboratory Use 212
Table Apx A-24. Summary of Full-Shift Inhalation Monitoring Data for Plastic Product Manufacturing
217
Table Apx A-25. Summary of Short-Term Inhalation Monitoring Data for Plastic Product
Manufacturing 221
Table Apx A-26. Summary of Full-Shift Inhalation Monitoring Data for Lithographic Printing Plate
Cleaning 225
Table Apx A-27. Summary of Short-Term Inhalation Monitoring Data for Lithographic Printing Plate
Cleaning 228
Table Apx A-28. Summary of Full-Shift Inhalation Monitoring Data for Pharmaceutical Manufacturing
230
Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
233
Table Apx A-30. Summary of Full-Shift Inhalation Monitoring Data for Waste Handling, Disposal,
Treatment, and Recycling 241
Table Apx A-31. Summary of Short-Term Inhalation Monitoring Data for Waste Handling, Disposal,
Treatment, and Recycling 241
TableApx B-l. SOCs with Worker and ONU Designations for All Conditions of Use Except Dry
Cleaning 245
Table_Apx B-2. SOCs with Worker and ONU Designations for Dry Cleaning Facilities 245
Table_Apx B-3. Estimated Number of Potentially Exposed Workers and ONUs under NAICS 812320
246
Table Apx C-l. Parameter Values for Calculating Inhalation Exposure Estimates 250
Table_Apx C-2. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+) 252
Table_Apx C-3. Median Years of Tenure with Current Employer by Age Group 252
Table Apx E-l. Estimated Fraction Evaporated and Absorbed (fabs) using Equation E 8 257
Table Apx E-2. Exposure Control Efficiencies and Protection Factors for Different Dermal Protection
Strategies from ECETOC TRA v3 260
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TableApx F-l. Summary of Parameter Values and Distributions Used in the Brake Servicing Near-
Field/Far-Field Inhalation Exposure Model 269
Table Apx F-2. Summary of Methylene Chloride-Based Aerosol Degreaser Formulations 273
TableApx F-3. Summary of Parameter Values and Distributions Used in the Open-Top Vapor
Degreasing Near-Field/Far-Field Inhalation Exposure Model 280
Table Apx F-4. Summary of Parameter Values and Distributions Used in the Conveyorized Degreasing
Near-Field/Far-Field Inhalation Exposure Model 281
TableApx F-5. Summary of Parameter Values and Distributions Used in the Cold Cleaning Near-
Field/Far-Field Inhalation Exposure Model 282
Table Apx F-6. Summary of Methylene Chloride Vapor Degreasing and Cold Cleaning Data from the
2014 Mil 284
TableApx F-7. Distribution of Methylene Chloride Open-Top Vapor Degreasing Unit Emissions.... 284
Table Apx F-8. Distribution of Methylene Chloride Conveyorized Degreasing Unit Emissions 285
Table Apx F-9. Distribution of Methylene Chloride Cold Cleaning Unit Emissions 285
Table Apx F-10. Distribution of Methylene Chloride Open-Top Vapor Degreasing Operating Hours 286
TableApx F-l 1. Distribution of Methylene Chloride Conveyorized Degreasing Operating Hours 286
Table Apx F-12. Distribution of Methylene Chloride Cold Cleaning Operating Hours 286
LIST OF APPENDIX FIGURES
FigureApx F-l. The Near-Field/Far-Field Model as Applied to the Brake Servicing Near-Field/Far-
Field Inhalation Exposure Model 263
Figure Apx F-2. The Near-Field/Far-Field Model as Applied to the Open-Top Vapor Degreasing Near-
Field/Far-Field Inhalation Exposure Model and the Cold Cleaning Near-Field/Far-Field
Inhalation Exposure Model 276
Figure Apx F-3. The Near-Field/Far-Field Model as Applied to the Conveyorized Degreasing Near-
Field/Far-Field Inhalation Exposure Model 276
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ABBREVIATIONS
°C Degrees Celsius
1-BP 1-Bromopropane
ACGIH American Conference of Government Industrial Hygienists
ACH Air Changes per Hour
APF Assigned Protection Factor
APR Air Purifying Respirator
atm Atmosphere(s)
BLS Bureau of Labor Statistics
CARB California Air Resources Board
CASRN Chemical Abstracts Service Registry Number
CBI Confidential Business Information
CDR Chemical Data Reporting
CEHD Chemical Exposure Health Data
CEM Consumer Exposure Model
cm3 Cubic Centimeter(s)
cP Centipoise
CPS Current Population Survey
CTA Cellulose Triacetate
DMR Discharge Monitoring Report
DOD Department of Defense
ECETOC TRA European Centre for Ecotoxicology and Toxicology of Chemicals Targeted Risk
Assessment
ECHO Enforcement and Compliance History Online
EDC Ethylene Dichloride
EPA Environmental Protection Agency
ESD Emission Scenario Documents
EU European Union
g Gram(s)
HFC Hydrofluorocarbon
HHE Health Hazard Evaluation
HSE Health and Safety Executive (United Kingdom)
HSIA Halogenated Solvents Industry Association
HPV High Production Volume
IARC International Agency for Research on Cancer
IPCS International Programme on Chemical Safety
kg Kilogram(s)
L Liter(s)
lb Pound
LOD Limit of Detection
Log Kow Logarithmic Octanol:Water Partition Coefficient
LPG Liquefied Petroleum Gas
m3 Cubic Meter(s)
mg Milligram(s)
|ig Microgram(s)
mmHg Millimeter(s) of Mercury
n Number
NAICS North American Industry Classification System
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NEI
National Emissions Inventory
NIOSH
National Institute of Occupational Safety and Health
NKRA
Not known or reasonably attainable
NMP
N-Methylpyrrolidone
NPDES
National Pollutant Discharge Elimination System
OARS
Occupational Alliance for Risk Sciences
OECD
Organisation for Economic Co-operation and Development
OEL
Occupational Exposure Limit
OES
Occupational Exposure Scenarios
ONU
Occupational Non-User
OPPT
Office of Pollution Prevention and Toxics
OSHA
Occupational Safety and Health Administration
OTVD
Open Top Vapor Degreaser
PCE
Perchloroethylene
PEL
Permissible Exposure Limit
POTW
Publicly Owned Treatment Works
PPE
Personal Protective Equipment
ppm
Part(s) per Million
RCRA
Resource Conservation and Recovery Act
RDF
Refuse-derived fuel
SAR
Supplied-Air Respirator
SCBA
Self-Contained Breathing Apparatus
SDS
Safety Data Sheet
SIPP
Survey of Income and Program Participation
SpERC
Specific Environmental Release Category
STEL
Short-Term Exposure Limit
SUSB
Statistics of U.S. Businesses
TCE
T ri chl oroethy 1 ene
TLV
Threshold Limit Value
TRI
Toxics Release Inventory
TSCA
Toxic Substances Control Act
TWA
Time-Weighted Average
U.S.
United States
WHO
World Health Organization
WWTP
Wastewater Treatment Plants
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1 INTRODUCTION
1.1 Overview
TSCA § 6(b)(4) requires the United States Environmental Protection Agency (U.S. EPA) to establish a
risk evaluation process. In performing risk evaluations for existing chemicals, EPA is directed to
"determine whether a chemical substance presents an unreasonable risk of injury to health or the
environment, without consideration of costs or other non-risk factors, including an unreasonable risk to a
potentially exposed or susceptible subpopulation identified as relevant to the risk evaluation by the
Administrator under the conditions of use." In December of 2016, EPA published a list of 10 chemical
substances that are the subject of the Agency's initial chemical risk evaluations (81 FR 91927), as
required by TSCA § 6(b)(2)(A). Methylene chloride was one of these chemicals.
Methylene chloride, also known as dichloromethane and DCM, is a volatile and high production volume
(HPV) chemical that is used as a solvent in a wide range of industrial, commercial and consumer
applications.
This document supports occupational exposure assessment in the "Risk Evaluation for
Methylene Chloride (Dichloromethane, DCM)."
1.2 Scope
Workplace exposures and releases to water have been assessed for the following industrial and
commercial occupational exposure scenarios (OES) of methylene chloride:
1. Manufacturing (Section 2.1)
2. Processing as a Reactant (Section 2.2)
3. Processing - Incorporation into Formulation, Mixture, or Reaction Product (Section 2.3)
4. Repackaging (Section 2.4)
5. Batch Open-Top Vapor Degreasing (Section 2.5)
6. Conveyorized Vapor Degreasing (Section 2.6)
7. Cold Cleaning (Section 2.7)
8. Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care
Products) (Section 2.8)
9. Adhesives and Sealants (Section 2.9)
10. Paints and Coatings (Section 2.10)
11. Adhesive and Caulk Removers (Section 2.11)
12. Fabric Finishing (Section 2.12)
13. Spot Cleaning (Section 2.13)
14. Cellulose Triacetate Film Production (Section 2.14)
15. Flexible Polyurethane Foam Manufacturing (Section 2.15)
16. Laboratory Use (Section 2.16)
17. Plastic Product Manufacturing (Section 2.17)
18. Pharmaceutical Production (Section 2.18)
19. Lithographic Printing Plate Cleaning (Section 2.19)
20. Miscellaneous Non-Aerosol Industrial and Commercial Uses (Section 2.20)
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21. Waste Handling, Disposal, Treatment, and Recycling (Section 2.21)
For workplace exposures, EPA considered exposures to both workers who directly handle methylene
chloride and occupational non-users (ONUs) who do not directly handle methylene chloride but may be
exposed to vapors or mists that enter their breathing zone while working in locations in close proximity
to where methylene chloride is being used.
For purposes of this report, "releases to water" include both direct discharges to surface water and
indirect discharges to publicly-owned treatment works (POTW) or non-POTW wastewater treatment
(WWT).
The assessed conditions of use were described in Table 2-3 of the Problem Formulation of the Risk
Evaluation of Methylene Chloride (Dichlorome thane, DCM) (U.S. EPA. 2.018d); however, due to
expected similarities in both processes and exposures/releases several of the subcategories of use in
Table 2-3 were grouped and assessed together into various OES during the risk evaluation process. A
crosswalk of the conditions of use in Table 2-3 to the OES assessed in this report is provided in Table
1-1.
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Table 1-1. Crosswalk of Conditions of Use to Occupational Exposure Scenarios Assessed in the Risk Evaluation
l.ilo ( >cle
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Manufacturing
Domestic
manufacturing
Manufacturing
Section 2.1- Manufacturing
Import
Import
Section 2.4 - Repackaging
Processing
Processing as a
reactant
Intermediate in industrial gas manufacturing (e.g., manufacture of fluorinated
gases used as refrigerants)
Section 2.2 - Processing as a Reactant
Intermediate for pesticide, fertilizer, and other agricultural chemical
manufacturing
CBI function for petrochemical manufacturing
Intermediate for other chemicals
Incorporated
into
formulation,
mixture, or
reaction
product
Solvents (for cleaning or degreasing), including manufacturing of:
• All other basic organic chemical
• Soap, cleaning compound and toilet preparation
Section 2.3 - Processing - Incorporation into
Formulation, Mixture, or Reaction Product
Solvents (which become part of product formulation or mixture), including
manufacturing of:
• All other chemical product and preparation
• Paints and coatings
Propellants and blowing agents for all other chemical product and preparation
manufacturing
Propellants and blowing agents for plastics product manufacturing
Paint additives and coating additives not described by other codes for CBI
industrial sector
Laboratory chemicals for all other chemical product and preparation
manufacturing
Laboratory chemicals for CBI industrial sectors
Processing aid, not otherwise listed for petrochemical manufacturing
Adhesive and sealant chemicals in adhesive manufacturing
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Table 1-1. Crosswalk of Conditions of Use to Occupational Exposure Scenarios Assessed in the Risk Evaluation
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Scenarios
L iiknow 11 l uiiijlion lor oil and gab drilling, extraction, and support acli\ ilies.
Repackaging
Solvents (which become part of product formulation or mixture) for all other
chemical product and preparation manufacturing
Section 2.4 - Repackaging
CBI functions for all other chemical product and preparation manufacturing
Recycling
Recycling
Section 2.21 - Waste Handling, Disposal,
Treatment, and Recycling
Distribution in
commerce
Distribution
Distribution
Section 2.4 - Repackaging
Industrial,
commercial and
Solvents (for
cleaning or
Batch vapor degreaser (e.g., open-top, closed-loop)
Section 2.5 - Batch Open-Top Vapor
Degreasing
consumer uses
degreasing) d
In-line vapor degreaser (e.g., conveyorized, web cleaner)
Section 2.6 - Conveyorized Vapor
Degreasing
Cold cleaner
Section 2.7 - Cold Cleaning
Aerosol spray degreaser/cleaner
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Adhesives and
sealants
Single component glues and adhesives and sealants and caulks
Section 2.9 - Adhesives and Sealants
Paints and
coatings
including paint
and coating
removers
Paints and coatings use and paints and coating removers, including furniture
refinisherse
Section 2.10- Paints and Coatings
Adhesive/caulk removers
Section 2.11 — Adhesive and Caulk
Removers
Metal products
not covered
elsewhere
Degreasers - aerosol and non-aerosol degreasers and cleaners e.g., coil cleaners
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Section 2.20 - Miscellaneous Non-Aerosol
Industrial and Commercial Uses
Fabric, textile
and leather
Textile finishing and impregnating/ surface treatment products e.g. water repellant
Section 2.12 - Fabric Finishing
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Table 1-1. Crosswalk of Conditions of Use to Occupational Exposure Scenarios Assessed in the Risk Evaluation
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products not
covered
elsewhere
Automotive
care products
Function fluids for air conditioners: refrigerant, treatment, leak sealer
Section 2.20 - Miscellaneous Non-Aerosol
Industrial and Commercial Uses
Interior car care - spot remover
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Automotive
care products
Degreasers: gasket remover, transmission cleaners, carburetor cleaner, brake
quieter/cleaner
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Apparel and
footwear care
products
Post-market waxes and polishes applied to footwear e.g. shoe polish
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Laundry and
dishwashing
products
Spot remover for apparel and textiles
Section 2.13 - Spot Cleaning
Lubricants and
greases
Liquid and spray lubricants and greases
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Degreasers - aerosol and non-aerosol degreasers and cleaners
Automotive Care Products)
Section 2.20 - Miscellaneous Non-Aerosol
Industrial and Commercial Uses
Building/
construction
materials not
covered
elsewhere
Cold pipe insulation
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Solvents
(which
become part of
product
formulation or
mixture)
All other chemical product and preparation manufacturing
Section 2.3 - Processing - Incorporation into
Formulation, Mixture, or Reaction Product
Processing aid
not otherwise
listed
In multiple manufacturing sectorsf
Section 2.14- Cellulose Triacetate Film
Production
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Table 1-1. Crosswalk of Conditions of Use to Occupational Exposure Scenarios Assessed in the Risk Evaluation
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Propellanb
and blowing
agents
Flexible pol\ urelhane foam nianufae luring
Seelion 2.15 Flexible Pol) urelhane l oam
Manufacturing
Arts, crafts
and hobby
materials
Crafting glue and cement/concrete
Section 2.9 - Adhesives and Sealants
Other Uses
Laboratory chemicals - all other chemical product and preparation manufacturing
Section 2.16- Laboratory Use
Electrical equipment, appliance, and component manufacturing
Section 2.20 - Miscellaneous Non-Aerosol
Industrial and Commercial Uses
Plastic and rubber products
Section 2.17- Plastic Product Manufacturing
Section 2.14- Cellulose Triacetate Film
Production
Anti-adhesive agent - anti-spatter welding aerosol
Section 2.8 - Commercial Aerosol Products
(Aerosol Degreasing, Aerosol Lubricants,
Automotive Care Products)
Oil and gas drilling, extraction, and support activities
Section 2.20 - Miscellaneous Non-Aerosol
Industrial and Commercial Uses
Functional fluids (closed systems) in pharmaceutical and medicine manufacturing
Section 2.18- Pharmaceutical Production
Toys, playground, and sporting equipment - including novelty articles (toys, gifts,
etc.)
Section 2.20 - Miscellaneous Non-Aerosol
Industrial and Commercial Uses
Carbon remover, lithographic printing cleaner, wood floor cleaner, brush cleaner
Section 2.19- Lithographic Printing Plate
Cleaning
Disposal
Disposal
Industrial pre-treatment
Section 2.21 - Waste Handling, Disposal,
Treatment, and Recycling
Industrial wastewater treatment
Publicly owned treatment works (POTW)
Underground injection
Municipal landfill
Hazardous landfill
Other land disposal
Municipal waste incinerator
Hazardous waste incinerator
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Table 1-1. Crosswalk of Conditions of Use to Occupational Exposure Scenarios Assessed in the Risk Evaluation
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Off-site waste transfer
a - These categories of conditions of use appear in the initial life cycle diagram, reflect CDR codes and broadly represent conditions of use for methylene chloride in
industrial and/or commercial settings.
b - These subcategories reflect more specific uses of methylene chloride.
c - Industrial and Commercial designations for certain conditions of use denote different dermal risk calculator assessments.
d - Reported for the following sectors in the 2016 CDR for manufacturing of: plastic materials and resins, plastics products, miscellaneous, all other chemical product
and preparation. (U.S. EPA. 2016b")
e -This includes uses (paints and coatings removers) assessed in the U.S. EPA (20.1.4") risk assessment and therefore those uses are out of scope for the risk evaluation,
f-Reported for the following sectors in the 2016 CDR for manufacturing of: petrochemicals, plastic materials and resins, plastics products, miscellaneous, all other
chemical product and CBI (U.S. EPA. 20.1.6b") which may include chemical processor for polycarbonate resins and cellulose triacetate - photographic film, developer
(Abt. 20.1.7").
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1.3 Components of the Occupational Exposure and Environmental Release
Assessment
The occupational exposure and environmental release assessment of each condition of use comprises the
following components:
• Facility Estimates: An estimate of the number of sites that use methylene chloride for the given
condition of use.
• Process Description: A description of the condition of use, including the role of the chemical in
the use; process vessels, equipment, and tools used during the condition of use.
• Worker Activities: A descriptions of the worker activities, including an assessment for potential
points of worker and ONU exposure.
• Number of Workers and Occupational Non-Users: An estimate of the number of workers and
occupational non-users potentially exposed to the chemical for the given condition of use.
• Occupational Inhalation Exposure Results: Central tendency and high-end estimates of
inhalation exposure to workers and occupational non-users. See Section XX for a discussion of
EPA's statistical analysis approach for assessing inhalation exposure.
• Water Release Sources: A description of each of the potential sources of water releases in the
process for the given condition of use.
• Water Release Assessment Results: Estimates of chemical released into water (surface water,
POTW, or non-POTW WWT).
In addition to the above components for each condition of use, a separate dermal exposure section is
included that provides estimates of the dermal exposures for all the assessed conditions of use.
1.4 General Approach and Methodology for Occupational Exposures and
Environmental Releases
1.4.1 Process Description
EPA performed a literature search to find descriptions of processes involved in each condition of use.
Where process descriptions were unclear or not available, EPA referenced relevant ESD's or GS's.
Process descriptions for each condition of use can be found in Section 2.
1.4.2 Facility Estimates and Number of Workers and Occupational Non-Users
Where available, EPA used publicly available data (typically CDR) to provide a basis to estimate the
number of sites, workers and ONUs. EPA supplemented the available CDR data with U.S. economic
data using the following method:
1. Identify the North American Industry Classification System (NAICS) codes for the industry
sectors associated with these uses.
2. Estimate total employment by industry/occupation combination using the Bureau of Labor
Statistics' Occupational Employment Statistics (OES) data (BLS Data).
3. Refine the OES estimates where they are not sufficiently granular by using the U.S. Census'
Statistics of US Businesses (SUSB) (SUSB Data) data on total employment by 6-digit NAICS.
4. Use market penetration data to estimate the percentage of employees likely to be using
methylene chloride instead of other chemicals.
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5. Where market penetration data are not available, use the estimated workers/ONUs per site in the
6-digit NAICS code and multiply by the number of sites estimated from CDR, TRI, or NEI.
6. Combine the data generated in Steps 1 through 5 to produce an estimate of the number of
employees using methylene chloride in each industry/occupation combination (if available), and
sum these to arrive at a total estimate of the number of employees with exposure within the
condition of use.
1.4.3 Worker Activities
EPA performed a literature search to identify worker activities that could potentially result in
occupational exposures. Where worker activities were unclear or not available, EPA referenced relevant
ESD's or GS's. Worker activities for each condition of use can be found in Section 2.
Workers may generally be exposed to methylene chloride when performing activities associated with the
conditions of use, including, but not limited to:
• Unloading and transferring methylene chloride to and from storage containers to process vessels;
• Using methylene chloride in process equipment (e.g., vapor degreasing machine, process
equipment used to manufacture refrigerants);
• Applying formulations and products containing methylene chloride onto substrates (e.g.,
applying adhesive removers containing methylene chloride onto substrates requiring adhesive
removal);
• Cleaning and maintaining equipment;
• Sampling chemical, formulations or products containing methylene chloride for quality control
(QC);
• Repackaging chemical, formulations or products containing methylene chloride;
• Handling, transporting and disposing waste containing methylene chloride;
• Performing other work activities in or near areas where methylene chloride is used.
In addition, exposures to ONUs, who do not directly handle the chemical but perform work in an area
where the chemical is present are listed. Engineering controls and/or personal protective equipment may
impact the occupational exposure levels.
1.4.4 Inhalation Exposure Assessment Approach and Methodology
Based on the high volatility of methylene chloride, EPA anticipates inhalation exposure to vapor to be
the most important methylene chloride exposure pathway for workers and ONUs. Additionally, there is
the potential for spray application of some products containing methylene chloride; therefore, exposures
to mists are also expected for workers and ONUs.
1.4.4.1 General Approach
EPA provided occupational exposure results representative of central tendency conditions and high-end
conditions. A central tendency is assumed to be representative of occupational exposures in the center of
the distribution for a given condition of use. For risk evaluation, EPA used the 50th percentile (median),
mean (arithmetic or geometric), mode, or midpoint values of a distribution as representative of the
central tendency scenario. EPA's preference is to use the 50th percentile of the distribution. However, if
the full distribution is not known, EPA may assume that the mean, mode, or midpoint of the distribution
represents the central tendency depending on the statistics available for the distribution.
A high-end estimate is assumed to be representative of occupational exposures that occur at probabilities
above the 90th percentile but below the exposure of the individual with the highest exposure (
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1992). For risk evaluation, EPA provided high-end results at the 95th percentile. If the 95th percentile
was not available, EPA used a different percentile greater than or equal to the 90th percentile but less
than or equal to the 99.9th percentile, depending on the statistics available for the distribution. If the full
distribution is not known and the preferred statistics are not available, EPA estimated a maximum or
bounding estimate in lieu of the high-end.
For occupational exposures, EPA used measured or estimated air concentrations to calculate exposure
concentration metrics required for risk assessment, such as average daily concentration (ADC) and
lifetime average daily concentration (LADC). These calculations require additional parameter inputs,
such as years of exposure, exposure duration and frequency, and lifetime years. EPA estimated exposure
concentrations from monitoring data, modeling, or occupational exposure limits.
For the final exposure result metrics, each of the input parameters (e.g., air concentrations, working
years, exposure frequency, lifetime years) may be a point estimate (i.e., a single descriptor or statistic,
such as central tendency or high-end) or a full distribution. EPA considered three general approaches for
estimating the final exposure result metrics:
• Deterministic calculations: EPA used combinations of point estimates of each parameter to
estimate a central tendency and high-end for each final exposure metric result. EPA documented
the method and rationale for selecting parametric combinations to be representative of central
tendency and high-end in 4.2.5Appendix C.
• Probabilistic (stochastic) calculations: EPA used Monte Carlo simulations using the full
distribution of each parameter to calculate a full distribution of the final exposure metric results
and selecting the 50th and 95th percentiles of this resulting distribution as the central tendency and
high-end, respectively.
• Combination of deterministic and probabilistic calculations: EPA had full distributions for some
parameters but point estimates of the remaining parameters. For example, EPA used Monte
Carlo modeling to estimate exposure concentrations, but only had point estimates of exposure
duration and frequency, and lifetime years. In this case, EPA documented the approach and
rationale for combining point estimates with distribution results for estimating central tendency
and high-end results in 4.2.5Appendix C.
EPA follows the following hierarchy in selecting data and approaches for assessing inhalation
exposures:
1. Monitoring data:
a. Personal and directly applicable
b. Area and directly applicable
c. Personal and potentially applicable or similar
d. Area and potentially applicable or similar
2. Modeling approaches:
a. Surrogate monitoring data
b. Fundamental modeling approaches
c. Statistical regression modeling approaches
3. Occupational exposure limits:
a. Company-specific OELs (for site-specific exposure assessments, e.g., there is only one
manufacturer who provides to EPA their internal OEL but does not provide monitoring data)
b. OSHA PEL
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c. Voluntary limits (ACGIH TLV, NIOSH REL, Occupational Alliance for Risk Science
(OARS) workplace environmental exposure level (WEEL) [formerly by AIHA])
1.4.4.2 Approach for this Risk Evaluation
EPA reviewed workplace inhalation monitoring data collected by government agencies such as OSHA
and NIOSH, monitoring data found in published literature (i.e., personal exposure monitoring data and
area monitoring data), and monitoring data submitted via public comments. Data found in sources were
evaluated using the evaluation strategies laid out in the Application of Systematic Review in TSCA Risk
Evaluations ( i). Results of the evaluations are in the supplemental files titled "Risk
Evaluation for Methylene Chloride, Systematic Review Supplemental File: Data Quality Evaluation of
Environmental Release and Occupational Exposure Data. Docket ##." (U.S. EPA. 2019b) and "Risk
Evaluation for Methylene Chloride, Systematic Review Supplemental File: Data Quality Evaluation of
Environmental Release and Occupational Exposure Data Common Sources. Docket ##" (
2019a). Data from sources included in the risk evaluation were found acceptable for risk assessment
purposes.
Exposures are calculated from the datasets provided in the sources depending on the size of the dataset.
For datasets with six or more data points, central tendency and high-end exposures were estimated using
the 50th percentile and 95th percentile. For datasets with three to five data points, central tendency
exposure was calculated using the 50th percentile and the maximum was presented as the high-end
exposure estimate. For datasets with two data points, the midpoint was presented as a midpoint value
and the higher of the two values was presented as a higher value. Finally, data sets with only one data
point presented the value as a what-if exposure. For datasets including exposure data that were reported
as below the limit of detection (LOD), EPA estimated the exposure concentrations for these data,
following EPA/OPPT's Guidelines for Statistical Analysis of Occupational Exposure Data (1994) which
recommends using the LOD / 2°5 if the geometric standard deviation of the data is less than 3.0 and
LOD / 2 if the geometric standard deviation is 3.0 or greater ( s94). Specific details related to
each condition of use can be found in Section 2. For each condition of use, these values were used to
calculate acute and chronic (non-cancer and cancer) exposures. Equations and sample calculations for
chronic exposures can be found in 4.2.5Appendix C and 4.2.5Appendix D, respectively.
EPA used exposure monitoring data or exposure models to estimate inhalation exposures for workers
and ONUs during all conditions of use. Data sources did not often indicate whether methylene chloride
exposure concentrations were for occupational users or ONUs. In these cases, EPA/OPPT assumed that
inhalation exposure data were applicable for a combination of workers and nearby ONUs. Some nearby
ONUs users may have lower inhalation exposures than users, especially when they are further away
from the source of exposure. EPA/OPPT assumed that ONUs that may be in close proximity to workers
handling methylene chloride usually do not directly contact the liquids containing methylene chloride.
Specific details related to the use of monitoring data for each condition of use can be found in Section 2.
Descriptions of the development and parameters used in the exposure models used for this assessment
can be found in 4.2.5Appendix F.
1.4.4.3 Respiratory Protection
The Occupational Safety and Health Administration (OSHA) Respiratory Protection Standard (29 CFR
1910.134) provides a summary of respirator types by their assigned protection factor (APF). Assigned
Protection Factor (APF) "means the workplace level of respiratory protection that a respirator or class of
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respirators is expected to provide to employees when the employer implements a continuing, effective
respiratory protection program" according to the requirements of OSHA's Respiratory Protection
Standard. Because methylene chloride may cause eye irritation or damage, the OSHA standard for
methylene chloride (29 CFR 1910.1052) prohibits use of quarter and half mask respirators; additionally,
only supplied air respirators (SARs) can be used because methylene chloride may pass through air
purifying respirators.
Respirator types and corresponding APFs indicated in bold font in Table l-2comply with the OSHA
standard for protection against methylene chloride. APFs are intended to guide the selection of an
appropriate class of respirators to protect workers after a substance is determined to be hazardous, after
an occupational exposure limit is established, and only when the exposure limit is exceeded after
feasible engineering, work practice, and administrative controls have been put in place. For methylene
chloride, the OSHA PEL is 25 ppm, or 87 mg/m3 as an 8-hr TWA, and the OSHA short-term exposure
limit (STEL) is 125 ppm, or 433 mg/m3 as a 15-min TWA. For each occupational exposure scenario,
EPA compares the exposure data and estimates to the PEL and STEL. Exceedance of the PEL or STEL
would indicate that the exposure would need to be addressed, and respirator use would be the last line of
defense.
The current OSHA PEL was updated in 1997; prior to the change the OSHA PEL had been 500 ppm as
an 8-hr TWA, which was 20 times higher than the current PEL. An analysis of more than 12,000
personal samples obtained from OSHA by Finkel (2017) shows the PEL change appears to have
produced a general average reduction from 85 ppm to 72 ppm (about 15%) in methylene chloride
exposures. This incremental general exposure reduction due to the PEL change indicates that exposure
data from before the PEL change are adequate for EPA's risk evaluation purposes.
Based on the protection standards, inhalation exposures may be reduced by a factor of 25, 50, 1,000, or
10,000, if respirators are required and properly worn and fitted. Air concentration data are assumed to be
pre-APF unless indicated otherwise in the source, and APFs acceptable under the OSHA standards are
not otherwise considered or used in the occupational exposure assessment but are considered in the risk
characterization and risk determination.
Table 1-2. Assigned Protection Factors for Respirators in OSHA Standard 29 CFR
Type of Respirator
Quarter
Mask
Half Mask
Full
Facepiece
Helmet/
Hood
Loose-fitting
Facepiece
1. Air Purifying Respirator
5
10
50
2. Powered Air-Purifying Respirator
50
1,000
25/1,000
25
3. Supplied-Air Respirator (SAR) or Airline
Respirator
• Demand mode
• Continuous flow mode
• Pressure-demand or other positive-pressure
mode
10
50
50
50
1,000
1,000
25/1,000
25
4. Self-Contained Breathing Apparatus (SCBA)
• Demand mode
• Pressure-demand or other positive-pressure
mode
10
50
10,000
50
10,000
910.134a
a - Note that only APFs indicated in bold are acceptable to OSHA for methylene chloride protection.
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Based on the protection standards, inhalation exposures may be reduced by a factor of 25, 50, 1,000, or
10,000, assuming that workers/ONUs are complying with the standard.
1.4.5 Dermal Exposure Assessment Approach
Based on the conditions of use EPA expects workers to have potential for skin contact with liquids and
vapors. Where workers may be exposed to methylene chloride, the OSHA standard requires that workers
are protected from contact (e.g. gloves) (29 CFR 1910.1052). ONUs are not directly handling methylene
chloride; therefore, skin contact with liquid methylene chloride is not expected for ONUs but skin
contact with vapors is expected for ONUs.
Dermal exposure data was not readily available for the conditions of use in the assessment. Because
methylene chloride is a volatile liquid, the dermal absorption of methylene chloride depends on the type
and duration of exposure. Where exposure is not occluded, only a fraction of methylene chloride that
comes into contact with the skin will be absorbed as the chemical readily evaporates from the skin.
However, dermal exposure may be significant in cases of occluded exposure, repeated contacts, or
dermal immersion. For example, work activities with a high degree of splash potential may result in
methylene chloride liquids trapped inside the gloves, inhibiting the evaporation of methylene chloride
and increasing the exposure duration.
EPA estimated dermal exposures using the Dermal Exposure to Volatile Liquids Model. This model
determines a dermal potential dose rate based on an assumed amount of liquid on skin during one
contact event per day and the steady-state fractional absorption for methylene chloride based on a
theoretical framework provided by Kasting (2005). The amount of liquid on the skin is adjusted by the
weight fraction of methylene chloride in the liquid to which the worker is exposed. Specific details of
the dermal exposure assessment can be found in Section 3.2 and equations and sample calculations for
estimating dermal exposures can be found in 4.2.5Appendix E.
1.4.6 Water Release Assessment Approach
EPA/OPPT performed a literature search to identify process operations that could potentially result in
direct or indirect discharges to water for each condition of use. Where available, EPA/OPPT used 2016
TRI ( ) and 2016 DMR (U.S. EPA. 2016a) data to provide a basis for estimating
releases. Facilities are only required to report to TRI if the facility has 10 or more full-time employees,
is included in an applicable NAICS code, and manufactures, processes, or uses the chemical in
quantities greater than a certain threshold (25,000 pounds for manufacturers and processors of
methylene chloride and 10,000 pounds for users of methylene chloride). Due to these limitations, some
sites that manufacture, process, or use methylene chloride may not report to TRI and are therefore not
included in these datasets.
For the 2016 DMR (U.S. EPA. 2016a). EPA/OPPT used the Water Pollutant Loading Tool within
EPA's Enforcement and Compliance History Online (ECHO) to query all methylene chloride point
source water discharges in 2016. DMR data are submitted by National Pollutant Discharge Elimination
System (NPDES) permit holders to states or directly to the EPA according to the monitoring
requirements of the facility's permit. States are only required to load major discharger data into DMR
and may or may not load minor discharger data. The definition of major vs. minor discharger is set by
each state and could be based on discharge volume or facility size. Due to these limitations, some sites
that discharge methylene chloride may not be included in the DMR dataset.
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Facilities reporting releases in TRI and DMR also report associated NAICS and SIC industry codes,
respectively. EPA reviewed the NAICS and SIC descriptions for each reported release and mapped each
facility to a potential condition of use, if possible. For facilities that did not report a NAICS or SIC code,
EPA performed supplemental internet search of the specific facility to determine the categorization.
Releases that could not be classified were grouped together into an "Other" category.
When possible for each condition of use, EPA/OPPT estimated annual releases, average daily releases,
and number of release days per year. Where TRI and/or DMR were available, EPA/OPPT used the
reported annual releases for each site and estimated the daily release by averaging the annual release
over the expected release days per year. Where releases are expected but TRI and DMR data were not
available, EPA/OPPT included a qualitative discussion of potential release sources.
The following guidelines were used to estimate the number of release days per year:
• Manufacturing: For the manufacture of the large-PV solvents, EPA assumes 350 day/yr for
release frequency. This assumes the plant runs 7 day/week and 50 week/yr (with two weeks
down for turnaround), and assumes that the plant is always producing the chemical.
• Processing as Reactant: Methylene chloride is largely used to manufacture other commodity
chemicals, such as refrigerants or other chlorinated compounds, which will likely occur year-
round. Therefore, EPA assumes 350 days/yr for release frequency.
• Processing into Formulation Product: For these facilities, EPA does not expect that methylene
chloride will be used year-round, even if the facility operates year-round. Therefore, EPA
assumes 300 day/yr for release frequency, which is based on an EU SpERC that uses a default of
300 days/yr for release frequency for the chemical industry (Group. 2019).
• Wastewater Treatment Plants: For these facilities, EPA expects that they will be used year-round.
Therefore, EPA assumes 365 days/yr for release frequency.
• All Other Scenarios: For all other scenarios, EPA assumes 250 days/yr for release frequency (5
days/week, 50 weeks/yr).
2 Engineering Assessment
2.1 Manufacturing
2.1.1 Process Description
Methylene chloride is primarily manufactured through the gas-phase reaction of hydrogen chloride with
methanol to produce methyl chloride, which is then reacted with chlorine to produce methylene chloride,
along with chloroform and carbon tetrachloride as coproducts. This reaction is typically driven by high
temperature, but may also be driven through catalysis or photolysis. This reaction may alternatively be
conducted in the liquid phase at low temperatures and high pressures, which can yield high selectivity of
methylene chloride (Holbrook. 2003).
An antiquated production method of methylene chloride is the reaction of excess methane with chlorine
at temperatures of approximately 400 to 500°C. Lower reaction temperatures are possible through the
use of catalysis or photolysis. This reaction produces methylene chloride with methyl chloride,
chloroform and carbon tetrachloride as coproducts and unreacted methane with hydrogen chloride as
byproducts. The unreacted methane and hydrogen chloride are removed through a water wash, dried,
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and recycled. The liquid stream of chlorinated organic products is washed, alkali scrubbed, dried and
fractionated (Holbrook. 2003).
Other minor production methods of methylene chloride exist, such as: the reduction of chloroform or
carbon tetrachloride with hydrogen over a platinum catalyst; the molten salt oxychlorination of methane;
the reaction of phosgene and formaldehyde over an activated carbon catalyst; and the reduction of
carbon tetrachloride with ferrous hydroxide in the presence of alkaline hydroxides or carbonates
(Holbrook. 2003).
Methylene chloride production is accomplished in an enclosed system and bypasses are considered to be
an integral part of the continuous production process. This continuous production process contributes
significantly to the elimination or substantial reduction of worker exposure to methylene chloride
vapors. After production, methylene chloride is stored in outdoor tanks and is shipped in bulk quantity
by rail car, tank truck, barge or in 55-galIon Drums (OSHA. 1991).
2.1.2 Number of Sites and Potentially Exposed Workers
The 2016 Public CDR shows three sites in calendar year 2015 that manufactured methylene chloride
domestically, one site that both manufactured and imported methylene chloride, and an additional 10
where the activity is marked as CBI or withheld, as shown in Table 2-1. The table also shows the
number of workers reasonably likely to be exposed to methylene chloride at these facilities. The term
"reasonably likely to be exposed", for the purpose of CDR, means "an exposure to a chemical substance
which, under foreseeable conditions of manufacture, processing, distribution in commerce, or use of the
chemical substance, is more likely to occur than not to occur". These exposures would include activities
such as charging reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations,
materials handling and transfer, and analytical operations. The estimate also includes persons whose
employment requires them to pass through areas where chemical substances are manufactured,
processed, or used, i.e., those who may be considered "occupational non-users", such as production
workers, foremen, process engineers, and plant managers.
Of the 14 sites, five reported between 225 and 445 workers and ONUs. Assuming 89 workers and ONUs
per site, the additional 9 sites may have 801 workers and ONUs. Therefore, EPA assumes a total of 14
sites and up to 1,246 workers and ONUs.
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Table 2-1 >
umber of Potentially Ex
posed Workers at Manufacturing Facilities (2016 CDR)
Manufacture/
Import
Company
Facility
Facility
Workers"
likely to be
exposed
City
State
Manufacture
Olin Corporation
Olin Blue Cube,
FREEPORT, TX
Freeport
TX
50 to 99
Manufacture
Tedia Company Inc.
Tedia Company Inc.
Fairfield
OH
50 to 99
Manufacture
Solvay Holding Inc
Advanced Composites
Group Inc.
Tulsa
OK
50 to 99
Manufacture
/Import
Sempre Avant LLC
Solvents & Chemicals
Pearland
TX
50 to 99
CBI
The Dow Chemical
Company
The Dow Chemical
Company
Pittsburg
CA
25 to 49
CBI
CBI
EMD Millipore Corp.
Norwood
OH
CBIb
CBI
INEOS Chlor Americas Inc.
INEOS Chlor America
Inc.
Wilmington
DE
CBIb
CBI
CBI
GreenChem
West Palm Beach
FL
CBIb
CBI
Occidental Chemical
Holding Corp.
Occidental Chemical
Corporation
Geismar
LA
CBIb
CBI
Occidental Chemical
Holding Corp.
Occidental Chemical
Corporation
Wichita
KS
CBIb
Withheld
FRP Services & Co.
(America) Inc.
FRP Services & Co.
(America) Inc.
New York
NY
Withheld13
Withheld
Solvay USA Inc
Solvay USA INC
Princeton
NJ
Withheld13
Withheld
Global Chemical Resources
Inc.
Global Chemical
Resources Inc.
Toledo
OH
Withheld13
Withheld
Shrieve Chemical Company
Shrieve Chemical
Products, Inc.
The Woodlands
TX
Withheld13
Total establishments and number of potentially exposed workers during
Manufacture/Import
up to 14 sites
up to 1,200
Source: U.S. EPA (2016b)
NKRA - Not known or reasonably ascertainable
a - May include both workers and ONUs
b - Number of relevant workers and ONUs per site were estimated by assuming up to 445 workers and ONUs over the 5
reported sites (average of 89 workers and ONUs per site, based on known sites)
2.1.3 Exposure Assessment
2.1.3.1 Worker Activities
Typical worker activities at a manufacturing facility include: 1) collecting and analyzing quality control
(QC) samples; 2) routine monitoring of the process, making process changes, or responding to process
upsets; and 3) loading finished products containing methylene chloride into containers and tank trucks.
The specific activity and the potential exposure level may differ substantially depending on the facility's
operation, process enclosure, level of automation, engineering control, and PPE.
2.1.3.2 Inhalation Exposures
TableApx A-l and TableApx A-2 in 4.2.5Appendix A summarize the inhalation monitoring data for
methylene chloride manufacturing that EPA compiled from published literature sources, including 8-
hour TWA, short-term, and partial shift sampling results. This appendix also includes EPA's rationale
for inclusion or exclusion of these data in the risk evaluation.
The Halogenated Solvents Industry Alliance (HSIA) provided personal monitoring data from 2005
through 2018 at two manufacturing facilities (Halogenated Solvents Industry Alliance. 2018). From this
monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA concentrations to represent a
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central tendency and worst-case estimate of potential occupational inhalation exposures, respectively,
for this life cycle stage. Both the central tendency and high-end 8-hr TWA exposure concentrations for
this scenario are at least one order of magnitude below the OSHA PEL value of 87 mg/m3 (25 ppm).
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as described in
4.2.5Appendix B. The results of these calculations are shown in Table 2-2.
Table 2-2. Full-Shift Worker Exposure to Methylene Chloride During Manufacturing
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
0.36
4.6
Average Daily Concentration (ADC)
136
0.08
1.1
Lifetime Average Daily Concentration (LADC)
0.14
2.4
Sources: Halogenated Solvents Industry Alliance (2018)
Table 2-3 summarizes available short-term exposure data for workers provided by HSIA (Halogenated
Solvents Industry Alliance. 2018). Because of the number of data points, details are provided in
Table_Apx A-2.
Table 2-3. Short-Term Worker Exposure to Methylene Chloride During Manufacturing
Number of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
15-minute a
148
9.6
180
30-minute b
1
2.6
1-hour
3
6.6
15
Source: Halogenated Solvents Industry Alliance (2018). Full results are presented in Table Apx A-2.
a - EPA assumed sampling times of 15 minutes to 29 minutes as 15-minute exposures,
b - EPA assumed sampling times of 30 minutes to 59 minutes as 30-minute exposures.
EPA has not identified data on potential ONU inhalation exposures from methylene chloride
manufacturing. Since ONUs do not directly handle methylene chloride, EPA expects ONU inhalation
exposures to be lower than worker inhalation exposures.
2.1.4 Water Release Assessment
EPA assumed that sites under NAICS 325199 (All Other Basic Organic Chemical Manufacturing) or
SIC 2869 (Industrial Organic Chemicals, Not Elsewhere Classified) are potentially applicable to
manufacturing of methylene chloride. Note that these NAICS codes may be applicable to other
conditions of use (processing as a reactant, processing—incorporation into formulation, mixture, or
reaction product); however, insufficient information were available to make these determinations.
Table 2-4 lists all facilities under these NAICS and SIC codes that reported direct or indirect water
releases in the 2016 TRI or 2016 DMR. Of the potential manufacturing sites listed in CDR (Table 2-1),
only one facility was present in Table 2-4, which reported 128 pounds (58 kg) of methylene chloride
transferred off-site to wastewater treatment (Olin Blue Cube, Freeport, TX) (U.S. EPA. 2017c).
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Table 2-4. E
eported TRI Releases for Organic Chemical Manufacturing Facilities
Site Identity
City
State
Annual
Release
(kg/site-
yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources & Notes
COVESTRO LLC
BAYTOWN
TX
1
350
0.004
Surface
Water
U.S. EPA (2017c)
EMERALD
PERFORMANCE
MATERIALS LLC
HENRY
IL
0.5
350
0.001
Surface
Water
U.S. EPA (2017c)
FISHER SCIENTIFIC
CO LLC
FAIR LAWN
NJ
2
350
0.01
POTW
U.S. EPA (2017c)
FISHER SCIENTIFIC
CO LLC
BRIDGEWATER
NJ
2
350
0.01
POTW
U.S. EPA (2017c)
OLIN BLUE CUBE
FREEPORT TX
FREEPORT
TX
58
350
0.2
Non-
POTW
WWT
U.S. EPA (2017c)
REGIS
TECHNOLOGIES
INC
MORTON
GROVE
IL
2
350
0.01
POTW
U.S. EPA (2017c)
SIGMA-ALDRICH
MANUFACTURING
LLC
SAINT LOUIS
MO
2
350
0.01
POTW
U.S. EPA (2017c)
VANDERBILT
CHEMICALS LLC-
MURRAY DIV
MURRAY
KY
0.5
350
0.001
Non-
POTW
WWT
U.S. EPA (2017c)
E I DUPONT DE
NEMOURS -
CHAMBERS
WORKS
DEEPWATER
NJ
76
350
0.2
Surface
Water
U.S. EPA (2016a)
BAYER
MATERIALSCIENCE
BAYTOWN
BAYTOWN
TX
10
350
0.03
Surface
Water
U.S. EPA (2016a)
INSTITUTE PLANT
INSTITUTE
WV
3
350
0.01
Surface
Water
U.S. EPA (2016a)
MPM SILICONES
LLC
FRIENDLY
WV
2
350
0.005
Surface
Water
U.S. EPA (2016a)
BASF
CORPORATION
WEST
MEMPHIS
AR
1
350
0.003
Surface
Water
U.S. EPA (2016a)
ARKEMA INC
PIFFARD
NY
0.3
350
0.001
Surface
Water
U.S. EPA (2016a)
EAGLE US 2 LLC -
LAKE CHARLES
COMPLEX
LAKE
CHARLES
LA
0.2
350
0.001
Surface
Water
U.S. EPA (2016a)
BAYER
MATERIALSCIENCE
NEW
MARTINSVILLE
WV
0.2
350
0.001
Surface
Water
U.S. EPA (2016a)
ICL-IP AMERICA
INC
GALLIPOLIS
FERRY
WV
0.1
350
0.0004
Surface
Water
(U.S. EPA. 2016a)
KEESHAN AND
BOST CHEMICAL
CO., INC.
MANVEL
TX
0.02
350
0.00005
Surface
Water
U.S. EPA (2016a)
INDORAMA
VENTURES
OLEFINS, LLC
SULPHUR
LA
0.01
350
0.00003
Surface
Water
U.S. EPA (2016a)
CHEMTURA NORTH
AND SOUTH
PLANTS
MORGANTOWN
WV
0.01
350
0.00002
Surface
Water
U.S. EPA (2016a)
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2.1.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 4.2.
2.2 Processing as a Reactant
2.2.1 Process Description
Processing as a reactant or intermediate is the use of methylene chloride as a feedstock in the production
of another chemical product via a chemical reaction, in which methylene chloride is consumed to form
the product. Methylene chloride is used as an intermediate for the production of difluoromethane, also
known as HFC-32, which is used in fluorocarbon blends for refrigerants (Marshall and Pottenger. 2004).
Methylene chloride is also a feedstock in the production of bromochloromethane. Bromochloromethane
is produced through a halogen exchange reaction with methylene chloride and either bromine or
hydrogen bromide, with an aluminum or aluminum trihalide catalyst. Alternative processes include the
gas-phase bromination of methylene chloride with hydrogen bromide and the liquid-phase displacement
reaction of methylene chloride with inorganic bromides (Technology. 2011).
2.2.2 Number of Sites and Potentially Exposed Workers
In the 2016 CDR, two submissions reported downstream industrial processing and use of methylene
chloride as a chemical intermediate. Based on information reported by these companies, and as shown in
Table 2-5, methylene chloride is potentially used as a chemical intermediate at up to 18 sites, where 75
to 148 workers and ONUs are potentially exposed.
Table 2-5. Number of U.S. Establishments, Workers, and ONUs for Processing as a Reactant from
2016 CDR
Industry
Sector
Industry Function Category
Number of
Establishments
Workers" likely to be
exposed
CBI
Intermediates
<10
25 to <50
CBI
Intermediates
<10
50 to <100
Total establishments and number of potentially exposed
workers and ONUs =
up to 18
up to 150
Source: U.S. EPA (2016b)
a - May include both workers and ONUs.
Table 2-6 presents the estimated numbers of workers and ONUs per site obtained from EPA's analysis
of BLS data for the two industry sectors relevant to this condition of use: NAICS 325120 and 325320
(U.S. BLS. 2016; U.S. Census Bureau. 2015). The estimated numbers of workers and ONUs per site are
multiplied by the number of establishments reported in the CDR to calculate the total number of
potentially exposed workers and ONUs. Based on a high-end estimate of 18 sites, a total of 319 workers
and 126 ONUs are potentially exposed (442 total workers and ONUs). It should be noted that the
number of sites are reported as ranges in CDR, and the actual number of sites may be significantly lower
than 18.
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Table 2-6. Number of U.S. Establishments, Workers, and ONUs for Processing as a Reactant
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers per Site
b
Number of
ONUs per Site
b
325120
Industrial Gas Manufacturing
18 a
14
7
325320
Pesticide and Other Agricultural Chemical
Manufacturing
25
7
Total establishments and number of potentially exposed
workers and ONUs = c
319
123
a - Based on CDR estimates in Table 2-5.
b - Rounded to the nearest worker.
c - Unrounded figures were used for total worker and ONU calculations.
2.2.3 Exposure Assessment
2.2.3.1 Worker Activities
At industrial facilities, workers are potentially exposed when unloading methylene chloride from
transport containers into intermediate storage tanks and process vessels. Workers may be exposed via
inhalation of vapor or via dermal contact with liquids while connecting and disconnecting hoses and
transfer lines. Once methylene chloride is unloaded into process vessels, it is consumed as a chemical
intermediate.
ONUs are employees who work at the facilities that process and use methylene chloride, but who do not
directly handle the material. ONUs may also be exposed to methylene chloride, but are expected to have
lower inhalation exposures and are not expected to have dermal exposures. ONUs for this condition of
use may include supervisors, managers, engineers, and other personnel in nearby production areas.
2.2.3.2 Inhalation Exposures
TableApx A-3 and TableApx A-4 in 4.2.5Appendix A summarize the inhalation monitoring data for
processing of methylene chloride as a reactant that EPA compiled from published literature sources,
including 8-hour TWA, short-term, and partial shift sampling results. This appendix also includes EPA's
rationale for inclusion or exclusion of these data in the risk evaluation.
HSIA provided monitoring data from 2010 through 2017 for maintenance workers, operators, and
laboratory technicians at a fluorochemical manufacturing facility. Eight-hour exposure concentrations
ranged from ND to 13.9 mg/m3 (15 samples) (Halogenated Solvents Industry Alliance. 2018).
From this monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA concentrations to
represent a central tendency and worst-case estimate of potential occupational inhalation exposures,
respectively, for this life cycle stage. The central tendency 8-hr TWA exposure concentration is more
than an order of magnitude lower than the OSHA PEL value of 87 mg/m3 (25 ppm), while the high-end
8-hr TWA exposure concentrations for this scenario is more than 8 times lower than the OSHA PEL.
Table 2-7 presents the calculated the AC, ADC, and LADC for these 8-hr TWA exposure
concentrations, as described in 4.2.5Appendix B.
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Table 2-7. Worker Exposure to Methylene Chloride During Processing as a Reactant During
Fluorochemicals Manufacturing
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
1.6
10
Average Daily Concentration (ADC)
15
0.37
2.4
Lifetime Average Daily Concentration (LADC)
0.65
5.3
Sources: Halogenated Solvents Industry Alliance (2018)
Table 2-8 summarizes available short-term exposure data available for "other chemical industry" and
during drumming at a pesticide manufacturing site.
Table 2-8. Summary of Personal Short-Term Exposure Data for Methylene Chloride During
Processing as a Reactant
Occupational
Exposure Scenario
Source
Worker Activity
Methylene Chloride
Short-Term
Concentration (mg/m3)
Exposure Duration
(min)
Other Chemical
Industry
TOO (CIVO)
(1999)
filter changing, charging and
discharging, etc
350 (max)
10
Pesticides Mfg
Olin Core
(1979)
Drumming
1,700
25
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly handle
formulations containing methylene chloride, EPA expects ONU inhalation exposures to be lower than
worker inhalation exposures.
2.2.4 Water Release Assessment
EPA assumed that sites classified under NAICS 325320 (Pesticide and Other Agricultural Chemical
Manufacturing) or SIC 2879 (Pesticides and Agricultural Chemicals, Not Elsewhere Classified) are
potentially applicable to processing of methylene chloride as a reactant. Table 2-9 lists all facilities
under these NAICS and SIC codes that reported direct or indirect water releases in the 2016 TRI or 2016
DMR.
Table 2-9. Reported 2016 TRI and D
MR Releases for Potential Processing as Reactant
facilities
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-day)
Release
Media
Sources &
Notes
AMVAC
CHEMICAL CO
AXIS
AL
213
350
0.6
Non-
POTW
WWT
U.S. EPA
(2017c)
THE DOW
CHEMICAL CO
MIDLAND
MI
25
350
0.1
Surface
Water
U.S. EPA
(2017c)
FMC
CORPORATION
MIDDLEPORT
NY
0.1
350
0.0003
Surface
Water
U.S. EPA
(2016a)
2.2.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 4.2.
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2.3 Processing
Product
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
- Incorporation into Formulation, Mixture, or Reaction
2.3.1 Process Description
Incorporation into a formulation, mixture or reaction product refers to the process of mixing or blending
of several raw materials to obtain a single product or preparation. The uses of methylene chloride that
may require incorporation into a formulation include paint removers; adhesives and sealants; paints and
coatings; degreasers, cleaners, and spot removers; and lubricants. Methylene chloride-specific
formulation processes were not identified; however, several ESDs published by OECD provide general
process descriptions for formulating some of these products. For example, the formulation of paints and
coatings typically involves dispersion, milling, finishing and filling into final packages (OE 09b).
Adhesive/sealant formulation involves mixing together volatile and non-volatile chemical components
in sealed, unsealed or heated processes (OECD. 2009a). Sealed processes are most common for
adhesive/sealant formulation because many adhesives/sealants are designed to set or react when exposed
to ambient conditions (OE' 09a). Lubricant formulation typically involves the blending of two or
more components, including liquid and solid additives, together in a blending vessel (OECD. 2004).
Formulated products are stored in drums or packaged in various size containers. Those drums and other
containers are then shipped to industrial end points or to retail markets for consumer use (OSHA. 1991).
Many of these formulated products may be packed in aerosol form. Methylene chloride cannot function
alone as a propellent because of its low vapor pressure relative to other propellants. A solvent such as
methylene chloride brings the active ingredient into solution with the propellants. It is sometimes
desirable to have another liquid present which is not miscible with the propellent (e.g. water and
propylene glycol). In these cases, a cosolvent such as methylene chloride or ethyl alcohol is added to
obtain a homogeneous mixture. Another function of a solvent such as methylene chloride is to help
produce a spray with a particle size most effective for a particular application. Solvents prevent the
propellants from evaporating completely in air shortly after discharge from the can. Therefore, a solvent
also assists in atomization and allows for a higher delivery rate (OSHA. 1991).
Methylene chloride is used as a solvent in many products because of its high vapor pressure compared to
other economically viable solvents, its high boiling point, its compatibility with many types of
formulations, and because it depresses the vapor pressure of high pressure propellants. As a result, the
flammability of the mixture is reduced and the dispersion of the aerosol spray is enhanced (OSHA..
1991).
Methylene chloride may be shipped in tank cars, or 55-gallon drums. Methylene chloride is either
transferred directly from the shipping containers to the packaging line (to avoid loss of solvent due to
volatilization), or it is transferred to storage tanks for subsequent mixing with other products (i.e. active
ingredients and solvents). The aerosol can is charged with the active ingredients and solvent (either
individually or premixed), and then filled with the propel 1 ant in an explosion proof room (OSH ).
2.3.2 Number of Sites and Potentially Exposed Workers
In the 2016 CDR, several submitters reported downstream industrial processing and use of methylene
chloride as incorporation into formulation, mixture or reaction products ( 2016b). Based on
information reported by these companies, and as shown in Table 2-10, methylene chloride is potentially
used in the formulation of adhesives and sealants; paints and coatings; and pesticide, fertilizer, and other
agricultural chemicals, at up to 261 sites and 2,032 workers and ONUs are potentially exposed.
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Table 2-10. Number of U.S. Establishments, Workers, and ONUs for Processing - Incorporation
into Formulation, Mixture, or Reaction Product from 2016 CDR
Industry Sector
Industry Function Category
Number of
Establishments
Workers3 likely
to be exposed
Adhesive manufacturing
Adhesives and sealant chemicals
NKRAb
NKRAb
Adhesive manufacturing
Adhesives and sealant chemicals
<10
NKRAb
All other basic organic chemical
manufacturing
Solvents (for cleaning and degreasing)
NKRAa
NKRAb
All other basic organic chemical
manufacturing
Solvents (for cleaning and degreasing)
<10
100 to < 500
All other chemical product and
preparation manufacturing
Solvents (which become part of
product formulation or mixture)
<10
100 to < 500
All other chemical product and
preparation manufacturing
Solvents (which become part of
product formulation or mixture)
25 to <100
100 to < 500
All other chemical product and
preparation manufacturing
Laboratory chemicals
25 to <100
100 to < 500
Oil and gas drilling, extraction, and
support activities
Not known or reasonably ascertainable
NKRAb
NKRAb
Paint and coating manufacturing
Solvents (which become part of
product formulation or mixture)
NKRAb
NKRAb
Pesticide, fertilizer, and other
agricultural chemical manufacturing
Intermediates
<10
<10
Soap, cleaning compound, and toilet
preparation manufacturing
Solvents (for cleaning and degreasing)
<10
<10
CBI
Paint additives and coating additives
not described by other categories
<10
<10
CBI
Paint additives and coating additives
not described by other categories
<10
<10
Total establishments and number of potentially exposed workers and ONUs = c
up to 477
up to 4,500
Source: U.S. EPA (2016b)
NKRA - Not known or reasonably ascertainable
a - Assumed <10 sites per similar entries for adhesive manufacturing and all other basic organic chemical manufacturing.
B - Assumed highest values reported for sites (25 to <100) and number of workers (100 to 499) as conservative.
2.3.3 Exposure Assessment
2.3.3.1 Worker Activities
At formulation facilities, workers are potentially exposed during product mixing operations; during
packaging and container filling operations; and during methylene chloride transfer activities (OSHA,
1991). The exact activities and associated level of exposure will differ depending on the degree of
automation, presence of engineering controls, and use of PPE at each facility.
2.3.3.2 Inhalation Exposures
TableApx A-5 and TableApx A-6 in 4.2.5Appendix A summarize the inhalation monitoring data that
EPA compiled from published literature sources, including 8-hour TWA, short-term, and partial shift
sampling results. This appendix also includes EPA's rationale for inclusion or exclusion of these data in
the risk evaluation.
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U.S. EPA (1985) provided exposure data for packing at paint/varnish and cleaning products sites,
ranging from 52 mg/m3 (mixing) to 2,223 mg/m3 (valve dropper) (10 data points).
From this monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA concentrations to
represent a central tendency and worst-case estimate of potential occupational inhalation exposures,
respectively, for this life cycle stage. The central tendency 8-hr TWA exposure concentration for this
scenario is approximately twice the OSHA PEL value of 87 mg/m3 (25 ppm), while the high-end
estimate is approximately 21 times higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as described in
4.2.5Appendix B. The results of these calculations are shown in Table 2-11.
Table 2-11. Worker Exposure to Methylene Chloride During Processing - Incorporation into
Formulal
tion, Mixture, or Reaction Product
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
180
1,800
Average Daily Concentration (ADC)
10
41
410
Lifetime Average Daily Concentration
(LADC)
72
920
Sources: US EPA (1985).
a - No data for ONUs were found; EPA assumes that ONU exposures are less than worker exposures.
TNO (CIVO) (1999) indicated that the peak exposure during filling may be up to 180 mg/m3, but did not
provide exposure duration.
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly handle
formulations containing methylene chloride, EPA expects ONU inhalation exposures to be lower than
worker inhalation exposures.
2.3.4 Water Release Assessment
EPA identified six NAICS and SIC codes, listed in Table 2-12, that reported water releases in the 2016
TRI and may be related to use as Processing - Incorporation into Formulation, Mixture, or Reaction
Product. Table 2-13 lists all facilities classified under these NAICS and SIC codes that reported direct or
indirect water releases in the 2016 TRI or 2016 DMR.
Table 2-12. Potential Industries Conducting Methylene Chloride Processing - Incorporation into
Formulation, Mixture, or Reaction Product in 2016 TRI or DMR
NAICS Code
NAICS Description
325180
Other Basic Inorganic Chemical Manufacturing
325510
Paint and Coating Manufacturing
325998
All Other Miscellaneous Chemical Product and Preparation Manufacturing
2819
INDUSTRIAL INORGANIC CHEMICALS
2843
SURF ACTIVE AGENT, FIN AGENTS
2899
CHEMICALS & CHEM PREP, NEC
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Table 2-13. Reported 2016 TRI and DMR Releases for Potential Processing—Incorporation into
Formulation, Mixture, or React
tion Product
facilities
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources &
Notes
ARKEMA INC
CALVERT
CITY
KY
31
300
0.1
Surface
Water
U.S. EPA
(2017c)
MCGEAN-ROHCO
INC
LIVONIA
MI
113
300
0.4
POTW
U.S. EPA
(2017c)
WMBARR& CO
INC
MEMPHIS
TN
0.5
300
0.002
POTW
U.S. EPA
(2017c)
BUCKMAN
LABORATORIES
INC
MEMPHIS
TN
254
300
1
POTW
U.S. EPA
(2017c)
EUROFINS MWG
OPERON LLC
LOUISVILLE
KY
5,785
300
19
POTW
U.S. EPA
(2017c)
SOLVAY-
HOUSTON PLANT
HOUSTON
TX
12
300
0.04
Surface
Water
U.S. EPA
(2016a)
HONEYWELL
INTERNATIONAL
INC - GEISMAR
COMPLEX
GEISMAR
LA
4
300
0.01
Surface
Water
U.S. EPA
(2016a)
STEP AN CO
MILLSDALE
ROAD
EL WOOD
IL
2
300
0.01
Surface
Water
U.S. EPA
(2016a)
ELEMENTIS
SPECIALTIES,
INC.
CHARLESTON
WV
0.2
300
0.001
Surface
Water
U.S. EPA
(2016a)
2.3.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 4.2.
2.4 Repackaging
2.4.1 Process Description
Commodity chemicals such as methylene chloride may be imported into the United States in bulk via
water, air, land, and intermodal shipments (Tomer and Kane. 2015). These shipments take the form of
oceangoing chemical tankers, railcars, tank trucks, and intermodal tank containers. Chemicals shipped in
bulk containers may be repackaged into smaller containers for resale, such as drums or bottles.
Domestically manufactured commodity chemicals may be shipped within the United States in liquid
cargo barges, railcars, tank trucks, tank containers, intermediate bulk containers (IBCs)/totes, and drums.
Both imported and domestically manufactured commodity chemicals may be repackaged by wholesalers
for resale; for example, repackaging bulk packaging into drums or bottles. The type and size of container
will vary depending on customer requirement. In some cases, QC samples may be taken at import and
repackaging sites for analyses. Some import facilities may only serve as storage and distribution
locations, and repackaging/sampling may not occur at all import facilities.
Methylene chloride may be imported neat or as a component in formulation. In the 2016 CDR, most
companies reported importing methylene chloride at concentrations greater than 90 percent; one
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company reported importing a formulation containing 1 to 30 percent methylene chloride (U.S. EPA.
2016b).
2.4.2 Number of Sites and Potentially Exposed Workers
The 2016 Public CDR shows that in calendar year 2015, seven sites imported methylene chloride, one
site that both manufactured and imported methylene chloride, and an additional 10 sites were marked as
CBI or withheld, as shown in Table 2-14 (U.S. EPA. 2016b). Seven sites provided number of worker
estimates. The number of workers and ONUs at the remaining sites was reported as Not Known or
Reasonably Ascertainable, CBI, or withheld.
EPA anticipates that most import facilities fall under NAICS 424690, Other Chemical and Allied
Product Merchant Wholesalers. This industry sector comprises establishments primarily engaged in the
merchant wholesale distribution of chemicals and allied products, including wholesale and distribution
of methylene chloride. Based on analysis of BLS data for NAICS 424690, EPA estimates that on
average, one worker per site and one ONU per site are potentially exposed. EPA's estimate is generally
consistent with the CDR data for import-only sites, where most importers report fewer than 10
employees are potentially exposed. Therefore, EPA assumed up to 10 workers and ONUs may
potentially be exposed at the import-only Brenntag North America facility.
For the remaining sites where the number of workers and ONUs were marked as CBI or withheld, EPA
assumed up to 99 workers exposed per site, based on the estimate for the manufacture/import site
(Sempre Avant). As shown in the table, this results in up to 21 sites and 1,102 workers and ONUs
potentially exposed during import and repackaging.
Table 2-14 Number of Potential Import Facilities and Exposed Workers (2016 CDR)
Manufacture/
Import
Company
Facility
Facility
Workers3
likely to be
exposed
City
State
Manufacture
/Import
Sempre Avant LLC
Solvents & Chemicals
Pearland
TX
50 to 99
Imported
CBI
Tricon International, Ltd.
Houston
TX
<10
Imported
Wego Chemical Group
Wego Chemical &
Mineral Corp.
Great Neck
NY
<10
Imported
Univar Inc.
Univar USA Inc.
Redmond
WA
<10
Imported
M.A. Global Resources Inc.
M.A. Global Resources
Inc.
Apex
NC
<10
Imported
AllChem Industries Holding
Corp.
AllChem Industries
Industrial Chemicals
Group, Inc.
Gainesville
FL
<10
Imported
Brenntag North America
Inc.
Brenntag Southwest Inc.
Longview
TX
NKRAb
Imported
Transchem, Inc.
Transchem Corporate
Carlsbad
CA
<10
CBI
The Dow Chemical
Company
The Dow Chemical
Company
Pittsburg
CA
25 to 49
CBI
CBI
EMD Millipore Corp.
Norwood
OH
CBI°
CBI
INEOS Chlor Americas Inc.
INEOS Chlor America
Inc.
Wilmington
DE
CBI°
CBI
CBI
GreenChem
West Palm Beach
FL
CBI°
CBI
Occidental Chemical
Holding Corp.
Occidental Chemical
Corporation
Geismar
LA
CBI0
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Table 2-14 Number of Potential Import Facilities and Exposed Workers (2016 CDR)
Manufacture/
Import
Company
Facility
Facility
Workers"
likely to be
exposed
City
State
CBI
Occidental Chemical
Holding Corp.
Occidental Chemical
Corporation
Wichita
KS
CBI0
Withheld
FRP Services & Co.
(America) Inc.
FRP Services & Co.
(America) Inc.
New York
NY
Withheld0
Withheld
Solvay USA Inc
Solvay USA INC
Princeton
NJ
Withheld0
Withheld
Global Chemical Resources
Inc.
Global Chemical
Resources Inc.
Toledo
OH
Withheld0
Withheld
Shrieve Chemical Company
Shrieve Chemical
Products, Inc.
The Woodlands
TX
Withheld0
Total establishments and number of potentially exposed workers during
Manufacture/Import
up to 18 sites
up to 1,100
Source: U.S. EPA (2016b)
NKRA - Not known or reasonably ascertainable
a - May include both workers and ONUs
b - For import-only sites, EPA assumed <10 workers potentially exposed.
c - For sites where the number of workers and ONUs were marked as CBI or withheld, EPA assumed up to 99 workers
exposed per site, based on the estimate for the manufacture/import site (Sempre Avant).
For repackaging, CDR reports up to 66 sites and 656 workers and ONUs, as shown in Table 2-15. It
should be noted that the number of sites are reported as ranges in CDR, and the actual number of sites
may be significantly lower than 66.
Table 2-15. Number of U.S. Establishments, Workers, and ONUs for Processing - Repackaging
from 2016 CDR
Industry Sector
Industry Function Category
Number of
Establishments
Workers3 likely
to be exposed
Wholesale and retail trade
CBI
CBIb
50 to <100
Wholesale and retail trade
Solvents (which become part of
product formulation or mixture)
<10
<10
CBI
Intermediates
10 to <25
100 to <500
CBI
Intermediates
10 to <25
NKRA0
CBI
Laboratory chemicals
<10
25 to <50
Total establishments and number of potentially exposed workers during
Repackaging
up to 75
up to 1,200
Source: U.S. EPA (2016b)
NKRA - Not known or reasonably ascertainable
a - May include both workers and ONUs
b - EPA assumed <10 sites, based on the similar entry for Wholesale and retail trade
c - EPA assumed 100 to <500 workers, based on the similar submission for intermediates.
2.4.3 Exposure Assessment
2.4.3.1 Worker Activities
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Workers are not expected to be exposed to methylene chloride during import operations where
containers are not opened or unloaded. During repackaging, workers are potentially exposed while
connecting and disconnecting hoses and transfer lines to containers and packaging to be unloaded (e.g.,
railcars, tank trucks, totes), intermediate storage vessels (e.g., storage tanks, pressure vessels), and final
packaging containers (e.g., drums, bottles). Workers near loading racks and container filling stations are
potentially exposed to fugitive emissions from equipment leaks and displaced vapor as containers are
filled. These activities are potential sources of worker exposure through dermal contact with liquid and
inhalation of vapors.
ONUs are employees who work at the site where methylene chloride is repackaged, but who do not
directly perform the repackaging activity. ONUs for repackaging include supervisors, managers, and
tradesmen that may be in the repackaging area but do not perform tasks that result in the same level of
exposures as repackaging workers.
2.4.3.2 Inhalation Exposures
TableApx A-7 and TableApx A-8 in 4.2.5Appendix A summarize the inhalation monitoring data for
import and repackaging (distribution) that EPA compiled from published literature sources. This
appendix also includes EPA's rationale for inclusion or exclusion of these data in the risk evaluation.
A 1986 IH study at Unocal Corporation found full-shift exposures during filling drums, loading trucks,
and transfer loading to be between 6.0 and 137.8 mg/m3 (5 data points) (Unocal Corporation. 1986).
Because only five data points were available, EPA assessed the median value of 8.8 mg/m3 as the central
tendency, and the maximum reported value of 137.8 mg/m3 as the high-end estimate of potential
occupational inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentration for this scenario is approximately 10 times lower the OSHA PEL value of 87
mg/m3 (25 ppm), while the high-end estimate is approximately 1.5 times higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as described in
4.2.5Appendix B. The results of these calculations are shown in Table 2-21.
Table 2-16. Worker Exposure to Methylene Chloride During Import and Repackaging
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
8.8
140
Average Daily Concentration (ADC)
5
2.0
31
Lifetime Average Daily Concentration (LADC)
3.5
71
Source: Unocal Corporation (1986)
Table 2-17 summarizes available short-term exposure data available from the same source identified
above for the 8-hr TWA data (Unocal Corporation. 1986).
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Table 2-17. Summary of Personal Short-Term Exposure Data for Methylene Chloride During
Import and Repackaging
Methylene Chloride
Occupational
Short-Term
Exposure Duration
Exposure Scenario
Source
Worker Activity
Concentration (mg/m3)
(min)
Transfer loading from truck
Distribution
Unocal
Corporation
(1986)
to storage tank (4,100
gallons)
0.35
30
Truck loading (2,000 gal)
330
50
Truck loading (800 gal)
35
30
Truck loading (250 gal)
30
47
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly handle
formulations containing methylene chloride, EPA expects ONU inhalation exposures to be lower than
worker inhalation exposures.
2.4.4 Water Release Assessment
EPA assumed that sites classified under NAICS 424690 (Other Chemical and Allied Products Merchant
Wholesalers) or SIC 5169 (Chemicals and Allied Products) are potentially applicable to import and/or
repackaging of methylene chloride. Table 2-18 lists all facilities in these industries that reported direct or
indirect water release to the 2016 TRI or 2016 DMR. None of the potential import sites listed in CDR
(Table 2-14) reported water releases to TRI or DMR in reporting year 2016.
Table 2-18. Reported 2016 TRI and DMR Releases for Impor
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources &
Notes
CHEMISPHERE
CORP
SAINT LOUIS
MO
2
250
0.01
POTW
U.S. EPA
(2017c)
HUBBARD-
HALL INC
WATERBURY
CT
144
250
1
Non-
POTW
WWT
U.S. EPA
(2017c)
WEBB
CHEMICAL
SERVICE CORP
MUSKEGON
HEIGHTS
MI
98
250
0.4
POTW
U.S. EPA
(2017c)
RESEARCH
SOLUTIONS
GROUP INC
PELHAM
AL
0.09
250
0.0003
Surface
Water
U.S. EPA
(2016a)
EMD
MILLIPORE
CORP
CINCINNATI
OH
0.03
250
0.0001
Surface
Water
U.S. EPA
(2016a)
and Repackaging Facilities
2.4.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 1.4.2.
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2.5 Batch Open-Top Vapor Degreasing
2.5.1 Process Description
Methylene chloride is used as a degreasing solvent to remove drawing compounds, cutting fluids,
coolants, and lubricants from metal parts. It can be used in cold cleaning, open top vapor degreasing, or
conveyorized vapor degreasing. It is difficult to characterize the establishments that use methylene
chloride for metal cleaning or degreasing because of widespread and nonspecific use patterns.
Methylene chloride is generally chosen when other organic solvents fail to provide the desired
characteristics such as nonflammability, nonreactivity with metals, the ability to dissolve a broad range
of greases and industrial chemicals, high solvency for most industrial contaminants, and a rapid rate of
evaporation (OSHA. 1991).
In batch open top vapor degreasers (OTVDs), a vapor cleaning zone is created by heating the liquid
solvent in the OTVD causing it to volatilize. Workers manually load or unload fabricated parts directly
into or out of the vapor cleaning zone. The tank usually has chillers along the side of the tank to prevent
losses of the solvent to the air. However, these chillers are not able to eliminate emissions, and
throughout the degreasing process significant air emissions of the solvent can occur. These air emissions
can cause issues with both worker health and safety as well as environmental issues. Additionally, the
cost of replacing solvent lost to emissions can be expensive (NEWMOA. 2001). Figure 2-1 illustrates a
standard OTVD.
:§
Boiling sump-
Vapor Zone
]
.Condensing Coils
^,Water Jacket
]^/Water Separator
Heat Source
Figure 2-1. Open Top Vapor Degreaser
OTVDs with enclosures operate the same as standard OTVDs except that the OTVD is enclosed on all
sides during degreasing. The enclosure is opened and closed to add or remove parts to/from the machine,
and solvent is exposed to the air when the cover is open. Enclosed OTVDs may be vented directly to the
atmosphere or first vented to an external carbon filter and then to the atmosphere (U.S. EPA; ICF
Consulting). Figure 2-2 illustrates an OTVD with an enclosure. The dotted lines in Figure 2-2 represent
the optional carbon filter that may or may not be used with an enclosed OTVD.
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¦*! Carbon Filter
vent
-II
Loading/
unloading
lock
M
Condensing Coils
^Wate Jacket
Vapor Zone
er Separator
O
Boiling sump'
Heat Sou ce
I
Figure 2-2. Open Top Vapor Degreaser with Enclosure
2.5.2 Number of Sites and Potentially Exposed Workers
The OSHA (1991) proposed rule estimated 271 exposed workers over 124 facilities using 129
methylene chloride open top degreasers (~2 workers per site). It is unclear whether this estimate also
includes ONUs.
2.5.3 Exposure Assessment
When operating OTVD, workers manually load or unload fabricated parts directly into or out of the vapor
cleaning zone. Worker exposure can occur from solvent dragout or vapor displacement when the
substrates enter or exit the equipment, respectively (Kanegsberg and Kanegsberg. 2011). Worker
exposure is also possible while charging new solvent or disposing spent solvent.
EPA performed a Monte Carlo simulation with 100,000 iterations and the Latin hypercube sampling
method to model near-field and far-field exposure concentrations in the OTVD scenario. EPA calculated
the 50th and 95th percentile 8-hr TWA concentrations to represent a central tendency and worst-case
estimate of potential occupational inhalation exposures, respectively, for this life cycle stage. For
workers, the modeled 8-hr TWA exposures are 168.3 mg/m3 at the 50th percentile and 744.8 mg/m3 at
the 95th percentile. For occupational non-users, the modeled 8-hr TWA exposures are 86.5 mg/m3 at the
50th percentile and 455.6 mg/m3 at the 95th percentile. The central tendency 8-hr TWA exposure
concentration for this scenario is approximately twice the OSHA PEL value of 87 mg/m3 (25 ppm),
while the high-end estimate is almost nine times higher.
Estimates of Average Daily Concentrations (ADC) and Lifetime Average Daily Concentration (LADC)
for use in assessing risk were made using the approach and equations described in 4.2.5Appendix B, and
are presented in Table 2-19.
2.5.3.1 Worker Activities
2.5.3.2 Inhalation Exposures
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Table 2-19. Statistical Summary of Methylene Chloride 8-hr TWA Exposures (ADC and LADC)
for Batch
Dpen-Top Vapor Degreasing
Central Tendency (mg/m3)
High-End (mg/m3)
Workers (Near-Field)
8-hr TWA Exposure Concentration
170
740
Average Daily Concentration (ADC)
29
130
Lifetime Average Daily Concentration (LADC)
15
66
Occupational Non-Users (Far-Field)
8-hr TWA Exposure Concentration
86
460
Average Daily Concentration (ADC)
15
78
Lifetime Average Daily Concentration (LADC)
7.6
40
2.5.4 Water Release Assessment
The primary source of water releases from OTVDs is wastewater from the water separator. Water in the
OTVD may come from two sources: 1) Moisture in the atmosphere that condenses into the solvent when
exposed to the condensation coils on the OTVD; and/or 2) steam used to regenerate carbon adsorbers
used to control solvent emissions on OTVDs with enclosures (Durkee. 2014; Kanegsberg and
Kanegsberg. 2011; (NIOSH). 2002a. b; NIOSH. 2002a. b). The water is removed in a gravity separator
and sent for disposal ((NIOSH). 2002a. b; NIOSH. 2002a. b). The current disposal practices of the
wastewater are unknown; however, a U.S. EPA (1982) report estimated 20% of water releases from
metal cleaning (including batch systems, conveyorized systems, and vapor and cold systems) were direct
discharges to surface water and 80% of water releases were discharged indirectly to a POTW.
2.5.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 4.2.
2.6 Conveyorized Vapor Degreasing
2.6.1 Process Description
In conveyorized systems, an automated parts handling system, typically a conveyor, continuously loads
parts into and through the vapor degreasing equipment and the subsequent drying steps. Conveyorized
degreasing systems are usually fully enclosed except for the conveyor inlet and outlet portals.
Conveyorized degreasers are likely used in shops where there are a large number of parts being cleaned.
There are seven major types of conveyorized degreasers: monorail degreasers; cross-rod degreasers;
vibra degreasers; ferris wheel degreasers; belt degreasers; strip degreasers; and circuit board degreasers
(U.S. EPA. 1977).
• Monorail Degreasers - Monorail degreasing systems are typically used when parts are already
being transported throughout the manufacturing areas by a conveyor. They use a straight-line
conveyor to transport parts into and out of the cleaning zone. The parts may enter one side and
exit and the other or may make a 180° turn and exit through a tunnel parallel to the entrance
(U.S. EPA. 1977). Figure 2-3 illustrates a typical monorail degreaser.
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Monorail
Conveyop^ —
BoiTTftg-
Chamber
Water
Jacket
Figure 2-3. Monorail Conveyorized Vapor Degreasing System (U.S. EPA, 1977)
• Cross-rod Degreasers - Cross-rod degreasing systems utilize two parallel chains connected by a
rod that support the parts throughout the cleaning process. The parts are usually loaded into
perforated baskets or cylinders and then transported through the machine by the chain support
system. The baskets and cylinders are typically manually loaded and unloaded ( J .S. EPA. 1977).
Cylinders are used for small parts or parts that need enhanced solvent drainage because of
crevices and cavities. The cylinders allow the parts to be tumbled during cleaning and drying and
thus increase cleaning and drying efficiency. Figure 2-4 illustrates a typical cross-rod degreaser.
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Conveyor Path
Chain Suppori
Work Basket
Water
Jacket
Boiling Chamber
Figure 2-4. Cross-Rod Convevorized Vapor Degreasing System ( J.S. EPA, 1977)
Vibra Degreasers - In vibra degreasing systems, parts are fed by conveyor through a chute that leads to
a pan flooded with solvent in the cleaning zone. The pan and the connected spiral elevator are
continuously vibrated throughout the process causing the parts to move from the pan and up a spiral
elevator to the exit chute. As the parts travel up the elevator, the solvent condenses and the parts are
dried before exiting the machine ( J.S. EPA 1977). Figure 2-5 illustrates a typical vibra degreaser (U.S.
EPA 1977).
Workload Discharger Chute
Ascending
Vibrating
Trough —
Condensers
Distillate
Trough
Workload
Entry Chute
G2
Distillate Return
For Counter-
flow Wash
Steam Coils
Figure 2-5. Vibra Conveyorized Vapor Degreasing System (U.S. EPA, 1977)
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Ferris wheel degreasers - Ferris wheel degreasing systems are generally the smallest of all the
conveyorized degreasers ( J.S. EPA. 1977). In these systems, parts are manually loaded into perforated
baskets or cylinders and then rotated vertically through the cleaning zone and back out. Figure 2-6
illustrates a typical ferns wheel degreaser ( J.S. EPA, 1977).
Boiling
Chamber
Figure 2-6. Ferris Wheel Conveyorized Vapor Degreasing System ( J.S. EPA, 1977)
• Belt degreasing systems (similar to strip degreasers; see next bullet) are used when simple and
rapid loading and unloading of parts is desired ( J.S. EPA 1977). Parts are loaded onto a mesh
conveyor belt that transports them through the cleaning zone and out the other side. Figure 2-7
illustrates a typical belt or strip degreaser ( J.S. EPA 1977).
Work _
Basket
Sear to tumble
baskets
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Conveyor.
Path
Boiling
Chamber
Figure 2-7. Belt/Strip Conveyorized Vapor Degreasing System (U.S. EPA, 1977)
• Strip degreasers - Strip degreasing systems operate similar to belt degreasers except that the belt
itself is being cleaned rather than parts being loaded onto the belt for cleaning. Figure 2-7
illustrates a typical belt or strip degreaser ( J.S. EPA 1977).
• Circuit board cleaners - Circuit board degreasers use any of the conveyorized designs. However,
in circuit board degreasing, parts are cleaned in three different steps due to the manufacturing
processes involved in circuit board production (J.S. EPA 1977).
Note, methylene chloride cannot be used in vapor degreasing of parts soiled with grease or oil that has a
high paraffmic content because a high rate of solvent flushing is required in such circumstances.
Furthermore, methylene chloride cannot be used on thin parts because they heat too quickly and good
condensation cannot be achieved (OSFLA 1991).
2.6.2 Number of Sites and Potentially Exposed Workers
OSHA estimated 177 exposed workers over 107 facilities (~2 workers per site) in 1991, using 111
methylene chloride conveyorized vapor degreasers (OSHA. 1991). It is unclear whether this estimate
also includes ONUs.
2.6.3 Exposure Assessment
2.6.3.1 Worker Activities
For conveyorized vapor degreasing, worker activities can include placing or removing parts from the
basket, as well as general equipment maintenance. Depending on the level of enclosure and specific
conveyor design, workers can be exposed to vapor emitted from the inlet and outlet of the conveyor
portal.
Degreasing equipment must also be cleaned periodically to maintain its efficiency. High exposure to
methylene chloride is possible when tanks are being cleaned because the worker often simply empties
the tank of solvent, rinses it with water from a high pressure hose and then climbs inside the tank to
scrub it with brushes (OSHA 1991).
2.6.3.2 Inhalation Exposures
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EPA performed a Monte Carlo simulation with 100,000 iterations and the Latin hypercube sampling
method to model near-field and far-field exposure concentrations in the conveyorized vapor degreasing
scenario. EPA calculated the 50th and 95th percentile 8-hr TWA concentrations to represent a central
tendency and worst-case estimate of potential occupational inhalation exposures, respectively, for this
life cycle stage. For workers, the modeled 8-hr TWA exposures are 162.1 mg/m3 at the 50th percentile
and 465.0 mg/m3 at the 95th percentile. For occupational non-users, the modeled 8-hr TWA exposures
are 253.0 mg/m3 at the 50th percentile and 900 mg/m3 at the 95th percentile. The central tendency 8-hr
TWA worker exposure concentration for this scenario is approximately twice the OSHA PEL value of
87 mg/m3 (25 ppm), while the high-end estimate is approximately five times higher. Exposure
concentrations for ONUs are also considerably higher than the OSHA PEL.
Estimates of Average Daily Concentrations (ADC) and Lifetime Average Daily Concentration (LADC)
for use in assessing risk were made using the approach and equations described in 4.2.5Appendix B, and
are presented in Table 2-20.
Table 2-20. Statistical Summary of Methylene Chloride 8-hr TWA Exposures (ADC and LADC)
for Conveyorized Vapor Degreasing
Central Tendency (mg/m3)
High-End (mg/m3)
Workers (Near-Field)
8-hr TWA Exposure Concentration
490
1,400
Average Daily Concentration (ADC)
84
240
Lifetime Average Daily Concentration (LADC)
43
120
Occupational Non-Users (Far-Field)
8-hr TWA Exposure Concentration
250
900
Average Daily Concentration (ADC)
44
150
Lifetime Average Daily Concentration (LADC)
22
79
2.6.4 Water Release Assessment
EPA did not identify quantitative information about water releases during vapor degreasing. Potential
sources of water releases for vapor degreasing and cold cleaning are discussed in Section 2.5.4.
2.6.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 4.2.
2.7 Cold Cleaning
2.7.1 Process Description
Cold cleaners are non-boiling solvent degreasing units. Cold cleaning operations include spraying,
brushing, flushing, and immersion. Figure 2-8 shows the design of a typical batch-loaded, maintenance
cold cleaner, where dirty parts are cleaned manually by spraying and then soaking in the tank. After
cleaning, the parts are either suspended over the tank to drain or are placed on an external rack that
routes the drained solvent back into the cleaner. Batch manufacturing cold cleaners could vary widely,
but have two basic equipment designs: the simple spray sink and the dip tank. The dip tank design
typically provides better cleaning through immersion, and often involves an immersion tank equipped
with agitation (U.S. EPA. 1981). Emissions from batch cold cleaning machines typically result from (1)
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evaporation of the solvent from the solvent-to-air interface, (2) "carry out" of excess solvent on cleaned
parts, and (3) evaporative losses of the solvent during filling and draining of the machine (U.S. EPA.
2006).
I1 Limp
Figure 2-8 Typical Batch-Loaded, Maintenance Cold Cleaner (U.S. EPA, 1981)
Emissions from cold in-line (conveyorized) cleaning machines result from the same mechanisms, but
with emission points only at the parts' entry and exit ports (U.S. EPA. 2006).
2.7.2 Number of Sites and Potentially Exposed Workers
The OSHA (1991) proposed rule estimated 90,293 exposed workers over 22,652 facilities (~4 workers
per site) using 23,664 methylene chloride cold degreasers. In 1998, OSHA estimated around 23,717
facilities performing cold degreasing and cold cleaning operations using methylene chloride ((OSHA).
1998). EPA assumes 4 workers per site, over the 23,717 facilities in 1998, for up to 95,000 workers
potentially exposed. It is unclear whether this estimate also includes ONUs.
2.7.3 Exposure Assessment
2.7.3.1 Worker Activities
The general worker activities for cold cleaning include placing the parts that require cleaning into a
vessel. The vessel is usually something that will hold the parts but not the liquid solvent (i.e., a wire
basket). The vessel is then lowered into the machine, where the parts could be sprayed, and then
completely immersed in the solvent. After a short time, the vessel is removed from the solvent and
allowed to drip/air dry. Depending on the industry and/or company, these operations may be performed
manually (i.e., by hand) or mechanically. Sometimes parts require more extensive cleaning; in these
cases, additional operations are performed including directly spraying solvent on the part, agitation of
the solvent or parts, wipe cleaning and brushing (NIOSH. 2001; U.S. EPA. 1997).
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Fabrication
Shops
Metal
Plating
Shops
Electronics
Assembly
Shops
Repair
Shops
> * d
i •
*
V
* 1
0:
t i
V-
t \
:•€>:
Figure 2-9 Illustration for Use of Cold Cleaner in a Variety of Industries
2.7.3.2 Inhalation Exposures
Table Apx A-9 in 4.2.5Appendix A summarizes the 8-hr TWA inhalation monitoring data for cold
cleaning manufacturing that EPA compiled from published literature sources. This appendix also
includes EPA's rationale for inclusion or exclusion of these data in the risk evaluation.
TNO (CIVO) (1999) indicated that mean exposure values for cold degreasing were found to be
approximately 280 mg/m3 on average, ranging from 14 to over 1,000 mg/m3. The referenced data were
from United Kingdom (UK) Health and Safety Executive (HSE) reports from 1998, but details,
including specific worker activities and sampling times were not available.
Because only three data points were available, EPA assessed the average value of 280 mg/m3 as the
central tendency, and the maximum reported value of 1,000 mg/m3 as the high-end estimate of potential
occupational inhalation exposure for this life cycle stage. The central tendency 8-hr TWA exposure
concentration for this scenario is approximately three times the OSHA PEL value of 87 mg/m3 (25
ppm), while the high-end estimate is almost 12 times higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as described in
4.2.5Appendix B. The results of these calculations are shown in Table 2-21.
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Table 2-21. Exposure to Methylene Chloride During Cold Cleaning
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
280
1,000
Average Daily Concentration (ADC)
unknown3
64
230
Lifetime Average Daily Concentration (LADC)
110
510
Source: TNO (CIVO) (1999)
a - One source provided a range of values for an unknown number of samples.
EPA has not identified short-term exposure data from cold cleaning using methylene chloride, nor data
on potential ONU inhalation exposures. Since ONUs do not directly handle formulations containing
methylene chloride, EPA expects ONU inhalation exposures to be lower than worker inhalation
exposures.
Note that EPA also performed a Monte Carlo simulation with 100,000 iterations and the Latin
hypercube sampling method to model near-field and far-field exposure concentrations for the cold
cleaning scenario. EPA calculated the 50th and 95th percentile 8-hr TWA concentrations to represent a
central tendency and worst-case estimate of potential occupational inhalation exposures, respectively,
for this life cycle stage. For workers, the modeled 8-hr TWA exposures are 1 mg/m3 at the 50th
percentile and 103.8 mg/m3 at the 95th percentile. For ONUs, the modeled 8-hr TWA exposures are 0.5
mg/m3 at the 50th percentile and 60 mg/m3 at the 95th percentile. For the risk evaluation, EPA used the
available monitoring data as discussed above, because the modeled data do not capture the full range of
possible exposure concentrations identified by the monitored data. Modeling details are in Appendix
4.2.5F.2
2.7.4 Water Release Assessment
EPA did not identify quantitative information about water releases during cold cleaning. Potential
sources of water releases for vapor degreasing and cold cleaning are discussed in Section 2.5.4.
2.7.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or indirect
water releases. EPA has not identified additional uncertainties for this use beyond those discussed in
Section 4.2.
2.8 Commercial Aerosol Products (Aerosol Degreasing, Aerosol
Lubricants, Automotive Care Products)
2.8.1 Process Description
Aerosol degreasing is a process that uses an aerosolized solvent spray, typically applied from a
pressurized can, to remove residual contaminants from fabricated parts. A propellant is used to
aerosolize the formulation, allowing it to be sprayed onto substrates. The aerosol droplets bead up on the
fabricated part and then drip off, carrying away any contaminants and leaving behind a clean surface.
Similarly, aerosol lubricant products use an aerosolized spray to help free frozen parts by dissolving rust
and leave behind a residue to protect surfaces against rust and corrosion. Based on identified safety data
sheets (SDS), methylene chloride-based formulations typically use carbon dioxide and liquified
petroleum gas (LPG) (i.e., propane and butane) as the propellant (Abt 2017; U.S. EPA. 2017b).
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Figure 2-10 illustrates the typical process of using aerosol degreasing to clean components in
commercial settings. One example of a commercial setting with aerosol degreasing operations is repair
shops, where service items are cleaned to remove any contaminants that would otherwise compromise
the service item's operation. Internal components may be cleaned in place or removed from the service
item, cleaned, and then re-installed once dry (U.S. EPA. 2014).
O
4 4
Figure 2-10 Overview of Aerosol degreasing
Aerosol degreasing may occur at either industrial facilities or at commercial repair shops to remove
contaminants on items being serviced. Aerosol degreasing products may also be purchased and used by
consumers for various applications.
Products containing methylene chloride may be used in aerosol degreasing applications such as brake
cleaning, engine degreasing, and metal product cleaning. Additionally, a variety of other commercial
aerosol products may contain methylene chloride, including weld spatter protectants, shoe polish spray,
carbon cleaners, coil cleaners, and cold pipe insulation (U.S. EPA. 2017b). EPA found very little
information on non-automotive commercial aerosol applications. Therefore, EPA assessed all
commercial applications using the aerosol degreasing and lubricants scenario.
2.8.2 Number of Sites and Potentially Exposed Workers
EPA/OPPT estimated the number of workers and occupational non-users potentially exposed to aerosol
degreasers and aerosol lubricants containing methylene chloride using Bureau of Labor Statistics' OES
data (U.S. BLS. 2016) and the U.S. Census' SUSB (U.S. Census Bureau. 2015). The method for
estimating number of workers is detailed above in Section 1.4.2. These estimates were derived using
industry- and occupation-specific employment data from the BLS and U.S. Census. Table 2-22 presents
the NAICS industry sectors relevant to aerosol degreasing and aerosol lubricants.
Table 2-22. NAICS Codes for Aerosol Degreasing and Lubricants
NAICS
Industry
811111
General Automotive Repair
811112
Automotive Exhaust System Repair
811113
Automotive Transmission Repair
811118
Other Automotive Mechanical and Electrical Repair and Maintenance
811121
Automotive Body, Paint, and Interior Repair and Maintenance
811122
Automotive Glass Replacement Shops
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811191
Automotive Oil Change and Lubrication Shops
811198
All Other Automotive Repair and Maintenance
811211
Consumer Electronics Repair and Maintenance
811212
Computer and Office Machine Repair and Maintenance
811213
Communication Equipment Repair and Maintenance
811219
Other Electronic and Precision Equipment Repair and Maintenance
811310
Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and
Maintenance
811411
Home and Garden Equipment Repair and Maintenance
811490
Other Personal and Household Goods Repair and Maintenance
451110
Sporting Goods Stores
441100
Automobile Dealers
There are 256,850 establishments among the industry sectors expected to use aerosol degreasers and/or
aerosol lubricants (U.S. Census Bureau. 2015). Because perchloroethylene (PCE) comprises the
majority of the chlorinated solvent-based aerosol degreaser volume, EPA used the PCE market
penetration to establish an upper bound for methylene chloride.
In 1997, the California Air Resources Board (CARB) conducted a survey of automotive maintenance
and repair facilities, which that approximately 44% of all aerosol brake cleaning products sold in
California contained PCE and approximately 37% of aerosol brake cleaning products available
contained PCE (CARB. 2000). Similarly, a CARB survey of automotive maintenance and repair
facilities found, of the 73% of facilities that use brake cleaning products to perform brake jobs,
approximately 38% of these facilities used brake cleaning products containing chlorinated chemicals
(CARB. 2000).
These data only relate to aerosol brake cleaning products used in the automotive repair industry;
however, aerosol degreasing and lubricant products may also be used in electronics repair, industrial
equipment repair, home and garden equipment repair, or other similar industries. Market penetration
data for these industries were not identified; therefore, in lieu of other information, EPA assumed a
similar market penetration rate as for brake cleaning products. It is also possible the brake cleaning
product manufacturer and facility surveys completed by CARB underestimate the total number of
establishments that may use a PCE-containing product as some establishments may use an aerosol
lubricant containing PCE but not a brake cleaning product containing PCE. However, EPA expects the
potential error from this to be relatively small as only approximately 0.1% (317,000 lbs) of the total U.S
production volume of PCE is expected to be used in lubricants (U.S. EPA. 2016b). For comparison,
based on reported sales in 1996, CARB estimated approximately 2.7 million pounds of PCE were used
in brake cleaning products in California alone (CARB. 2000).
EPA assumed the average market penetration rate for PCE aerosol degreasers and lubricants was the
average of the low- and high-end values found by CARB, or 40.5% multiplied by the 73% of facilities
that use brake cleaning products, or 29.6% (40.5% x 73%=29.6%) (CARB. 2000). This results in
approximately 75,938 establishments using aerosol products containing PCE.
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Based on the market penetration of 29.6% and data from the BLS and U.S. Census, there are
approximately 247,073 workers and 29,399 occupational non-users potentially exposed to PCE as an
aerosol degreasing solvent or aerosol lubricant (see Table 2-23) (CARB. 2000)
(U.S. BLS. 2016; U.S. Census Bureau. 2015). Therefore, EPA uses these estimates as an upper-bound
for methylene chloride.
Table 2-23. Estimated Number of Workers Potentially Exposed to Methylene Chloride During Use
of Aerosol Degreasers and Aerosol Lubricants
2016
NAICS
Number of
Number of
Number of
2016 NAICS Title
Establishments
a
Workers
per Site b
ONUs per
Site"
811111
General Automotive Repair
23,724
1
0.1
811112
Automotive Exhaust System Repair
564
0.5
0.0
811113
Automotive Transmission Repair
1,385
1
0.1
811118
Other Automotive Mechanical and Electrical Repair and
Maintenance
1,135
1
0.1
811121
Automotive Body, Paint, and Interior Repair and
Maintenance
9,948
1
0.1
811122
Automotive Glass Replacement Shops
1,805
1
0.1
811191
Automotive Oil Change and Lubrication Shops
2,478
1
0.1
811198
All Other Automotive Repair and Maintenance
1,224
1
0.1
811211
Consumer Electronics Repair and Maintenance
536
1
0.1
811212
Computer and Office Machine Repair and Maintenance
1,536
1
0.1
811213
Communication Equipment Repair and Maintenance
474
1
0.2
811219
Other Electronic and Precision Equipment Repair and
Maintenance
1,026
2
0.2
811310
Commercial and Industrial Machinery and Equipment (except
Automotive and Electronic) Repair and Maintenance
6,422
1
0.2
811411
Home and Garden Equipment Repair and Maintenance
513
0.2
0.2
811490
Other Personal and Household Goods Repair and
Maintenance
2,940
0.3
0.2
451110
Sporting Goods Stores
6,472
0.2
0.0
441100
Automobile Dealers
13,757
2
0.2
Total establishments and number of potentially exposed workers and
ONUs = c
75,938
250,000
29,000
A - All values assume methylene chloride market penetration of 29.6% (based on market penetration of perchloroethylene as
an upper-bound).
b - Rounded to the nearest whole number, unless less than one.
c - Unrounded figures were used for total worker and ONU calculations.
2.8.3 Exposure Assessment
2.8.3.1 Worker Activities
For aerosol degreasing, worker activities involve manual spraying of methylene chloride products from
an aerosol can onto a substrate, and then subsequently wiping of that substrate. The same worker may
also perform other types of degreasing activities, if those process operations are present at the same
facility.
Workers at these facilities are expected to be exposed through dermal contact with and inhalation of
mists during application of the aerosol product to the service item. ONUs include employees that work
at the facility but do not directly apply the aerosol product to the service item and are therefore expected
to have lower inhalation exposures and are not expected to have dermal exposures.
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2.8.3.2 Inhalation Exposures
As previously discussed in Section 2.8.1, a variety of workplaces can use aerosol degreaser containing
methylene chloride. For the purpose of modeling, EPA models worker exposure to methylene chloride
during brake servicing as a representative exposure scenario. EPA chooses to model this scenario
because the process of brake servicing is well understood and there are sufficient data to construct such
a model.
A more detailed description of the modeling approach is provided in 4.2.5Appendix F. Figure 2-11
illustrates the near-field/far-field for the aerosol degreasing scenario. As the figure shows, methylene
chloride in aerosolized droplets immediately volatilizes into the near-field, resulting in worker exposures
at a concentration Cnf. The concentration is directly proportional to the amount of aerosol degreaser
applied by the worker, who is standing in the near-field-zone (i.e., the working zone). The volume of
this zone is denoted by Vnf. The ventilation rate for the near-field zone (Qnf) determines how quickly
methylene chloride dissipates into the far-field (i.e., the facility space surrounding the near-field),
resulting in occupational non-user exposures to methylene chloride at a concentration Cff. Vff denotes
the volume of the far-field space into which the methylene chloride dissipates out of the near-field. The
ventilation rate for the surroundings, denoted by Qff, determines how quickly methylene chloride
dissipates out of the surrounding space and into the outside air.
In this scenario, methylene chloride vapors enter the near-field in non-steady "bursts," where each burst
results in a sudden rise in the near-field concentration, followed by a more gradual rise in the far-field
concentration. The near-field and far-field concentrations then decay with time until the next burst
causes a new rise in near-field concentration.
The product application rate is based on a 2000 CARB report for brake servicing, which estimates that
each facility performs on average 936 brake jobs per year, and that each brake job requires
approximately 14.4 ounces of product (CARB. 2000). It is uncertain whether this use rate is
representative of a typical aerosol degreasing facility. EPA modeled the operating hours per week using
a distribution based on the weekly operating hours reported by the responding automotive repair
facilities to CARB's survey. Model parameters and assumptions for aerosol degreasing are presented in
4.2.5Appendix F.
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nf C
Non-
volatile Source
Figure 2-11 Schematic of the Near-Field/Far-Field Model for Aerosol degreasing
EPA performed a Monte Carlo simulation with 100,000 iterations and the Latin hypercube sampling
method to model near-field and far-field exposure concentrations in the aerosol degreasing scenario.
EPA calculated the 50th and 95th percentile 8-hr TWA concentrations to represent a central tendency
and worst-case estimate of potential occupational inhalation exposures, respectively, for this life cycle
stage. For workers, the modeled 8-hr TWA exposures are 22.0 mg/m3 at the 50th percentile and 78.7
mg/m3 at the 95th percentile; the modeled maximum 1-hr TWA exposures are 68.0 mg/m3 at the 50th
percentile and 230.3 mg/m3 at the 95th percentile. For occupational non-users, the modeled 8-hr TWA
exposures are 0.40 mg/m3 at the 50lil percentile and 3.26 mg/m3 at the 95th percentile; the modeled
maximum 1-hr TWA exposures are 1.2 mg/m3 at the 50th percentile and 9.7 mg/m3 at the 95th percentile.
Both the central tendency and high-end 8-hr TWA exposure concentrations for workers in this this
scenario are lower than the OSHA PEL value of 87 mg/m3 (25 ppm). ONU exposures are an order of
magnitude lower.
Estimates of Average Daily Concentrations (ADC) and Lifetime Average Daily Concentration (LADC)
for use in assessing risk were made using the approach and equations described in 4.2.5Appendix B, and
are presented in Table 2-24.
Table 2-24. Statistical Summary of Methylene Chloride 8-hr TWA Exposures (ADC and LADC)
for Aerosol Products Based on Modeling
Central Tendency (mg/m3)
High-End (mg/m3)
Workers (Near-Field)
8-hr TWA Exposure Concentration
22
79
Average Daily Concentration (ADC)
3.8
14
Lifetime Average Daily Concentration (LADC)
1.9
6.9
Maximum 1-hrTWA Exposures
68
230
Occupational Non-Users (Far-Field)
8-lir TWA Exposure Concentration
0.40
3.3
Average Daily Concentration (ADC)
0.07
0.56
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C'enli'iil Tendency
lli<>h-Knd (mg/nr')
Lifetime Average Daily Concentration (LADC)
0.04
0.29
Maximum 1-hr TWA Exposures
1.2
9.7
2.8.4 Water Release Assessment
EPA does not expect releases of methylene chloride to water from the use of aerosol products. Due to
the volatility of methylene chloride the majority of releases from the use of aerosol products will likely
be to air as methylene chloride evaporates from the aerosolized mist and the substrate surface. There is a
potential that methylene chloride that deposits on shop floors during the application process could
possibly end up in a floor drain (if the shop has one) or could runoff outdoors if garage doors are open.
However, EPA expects the potential release to water from this to be minimal as there would be time for
methylene chloride to evaporate before entering one of these pathways. This is consistent with estimates
from the International Association for Soaps, Detergents and Maintenance Products (AISE) SpERC for
Wide Dispersive Use of Cleaning and Maintenance Products, which estimates 100% of volatiles are
released to air (Products. 2012). EPA/OPPT expects residuals in the aerosol containers to be disposed of
with shop trash that is either picked up by local waste management or by a waste handler that disposes
shop wastes as hazardous waste.
2.8.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use. EPA has not identified
additional uncertainties for this use beyond those discussed in Section 4.2.
2.9 Adhesives and Sealants
2.9.1 Process Description
Based on products identified in EPA's Preliminary Information on Manufacturing, Processing,
Distribution, Use, and Disposal for Methylene Chloride ( 017b). 2016 CDR reporting (U.S.
EPA. 2016b). and the Draft Use and Market Profile for Methylene Chloride and NMP (Abt. 2017).
methylene chloride may be used in adhesives and sealants for industrial, commercial, and consumer
applications. Thq Preliminary Information on Manufacturing, Processing, Distribution, Use and
Disposal for Methylene Chloride (U.S. EPA. 2017b) and Draft Market Profile (Abt. ) identify
liquid adhesive and sealant and aerosol and canister adhesive and sealant products that contain
methylene chloride. In these applications, the methylene chloride likely serves as a solvent and
evaporates during adhesive and sealant drying and curing. These adhesive and sealant products are
identified for use on substrates such as metal, foam, plastic, rubber, fabric, leather, wood, and fiberglass.
The types of adhesives and sealants identified in the Preliminary Information on Manufacturing,
Processing, Distribution, Use and Disposal for Methylene Chloride (i__S .-.QjJh) and Market
Profile (AM. 2017) also include upholstery contact adhesives, crosslinking adhesives, pressure sensitive
adhesives, duct and duct liner sealants, gasket sealants, and cements, which contain between 30 and 100
weight percent methylene chloride. The 2015 Use of Adhesives ESD lists typical organic solvent (such
as methylene chloride) content between 60 and 75 weight percent in adhesives (C ).
In addition to typical adhesive use, EPA's Preliminary Information on Manufacturing, Processing,
Distribution, Use, and Disposal for Methylene Chloride (I' ^ l'P \ 2017b) includes two sealant
products, which are in gel and aerosol form, containing between 10 and 65 weight percent methylene
chloride.
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2.9.2 Number of Sites and Potentially Exposed Workers
Application of methylene chloride-based adhesives and sealants are widespread, occurring in many
industries. EPA determined the industries likely to use methylene chloride in adhesives and sealants
from the following sources: the non-CBI 2016 CDR results for methylene chloride ( 2.016b).
the 2017 market profile for methylene chloride (Abt. 2017). the 2017 document on the Preliminary
Information on Manufacturing, Processing, Distribution, Use, and Disposal of NMP (U.S. EPA. 2017b).
the 2015 OECD ESD on the Use of Adhesives (OECD. 2015). and NAICS codes reported in monitoring
data obtained from OSHA (CM ).
The industries that distinctly perform the various methods of adhesive and sealant application are
unknown. EPA assumes that all industries may perform all methods of application. EPA compiled the
associated NAICS codes for the identified industries in Table 2-25. EPA determined the number of
workers associated with each industry from US Economic Census and Bureau of Labor Statistics (BLS)
data. The number of establishments within each industry that use methylene chloride-based adhesives
and sealants and the number of employees within an establishment exposed to these methylene chloride-
based products are unknown. Therefore, EPA provides the total number of establishments as a bounding
estimate, and estimates the number of workers and ONUs that are potentially exposed to methylene
chloride-based adhesive and sealant products. These estimates likely overestimate the actual number of
establishments and employees potentially exposed to methylene chloride during adhesive and sealant
application.
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Table 2-25. US Number of Establishments and Employees for Industries Conducting Adhesive and Sea
Industry
Source
2016
NAICS
2016 NAICS Title
Number of
Establishments
Number of
Workers
per Sitea
Number of
ONUs per
Site3
Specialty Trade
Contractors
Market Profile
238200
Building Equipment Contractors
176,142
8 b
lb
238330
Flooring Contractors
14,601
4
0
Wood Product
Manufacturing
OSHA
321200
Veneer, Plywood, and Engineered Wood Product Manufacturing
1,407
25 d
7 d
Plastics and
Rubber Products
Manufacturing
326150
Urethane and Other Foam Product (except Polystyrene)
Manufacturing
654
15
4
Fabricated Metal
Product
Manufacturing
332300
Fabricated Metal Product Manufacturing
12,309
10
3
Machinery
Manufacturing
333900
Other General Purpose Machinery Manufacturing
6,048
13
6
Computer and
Electronic
Product
Manufacturing
2015 OECD ESD
on Use of
Adhesives;
OSHA
334100
Computer and Peripheral Equipment Manufacturing
1,091
12 b
12 b
334200
Communications Equipment Manufacturing
1,369
13
14
334300
Audio and Video Equipment Manufacturing
486
6 b
6 b
334400
Semiconductor and Other Electronic Component Manufacturing
3,979
30
27
334500
Navigational, Measuring, Electromedical, and Control
Instruments Manufacturing
5,231
17
18
334600
Manufacturing and Reproducing Magnetic and Optical Media
521
6 b
6 b
335100
Electric Lighting Equipment Manufacturing
1,104
17
5
335200
Household Appliance Manufacturing
303
102
20
335300
Electrical Equipment Manufacturing
2,124
28
12
335900
Other Electrical Equipment and Component Manufacturing
2,140
23
8
Transportation
Equipment
Manufacturing
336100
Motor Vehicle Manufacturing
340
234 b
97 b
336200
Motor Vehicle Body and Trailer Manufacturing
1,917
40
5
336300
Motor Vehicle Parts Manufacturing
5,088
51
15
336400
Aerospace Product and Parts Manufacturing
1,811
75
64
336500
Railroad Rolling Stock Manufacturing
243
35
15
336600
Ship and Boat Building
1,541
36
11
Furniture and
Related Product
Manufacturing
OSHA
Market Profile
337100
Household and Institutional Furniture and Kitchen Cabinet
Manufacturing
10,759
5
4
Repair and
Maintenance
Market Profile
811420
Personal and Household Goods Repair and Maintenance
3,720
1
1
ant Application
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Industry
Source
2016
NAICS
2016 NAICS Title
Number of
Establishments
Number of
Workers
per Sitea
Number of
ONUs per
Site3
Total establishments and number of potentially exposed workers and ONUs = d
254,928
2,700,000
810,000
a - Rounded to the nearest whole number.
b - No 2016 BLS data was available for this NAICS. Number of relevant workers per site and ONUs per site within this NAICS were calculated using the ratios of
relevant workers and ONUs to the number of total employees at the 3-digit NAICS level.
c - No 2016 BLS data was available for this NAICS or at the 3-digit level. Number of relevant workers per site and ONUs per site within this NAICS were calculated
using the ratios of relevant workers and ONUs to the number of total employees for all NAICS codes in the table,
d - Unrounded figures were used for total worker and ONU calculations.
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2.9.3 Exposure Assessment
2.9.3.1 Worker Activities
The 2015 ESD for Use of Adhesives (OECD. 2015) provides a variety of potential adhesive and sealant
application processes, depending on a variety of factors including the type of adhesive/sealant, type of
substrate, size and geometry of the substrate, and the precision requirement of the bond. Workers may
be exposed to the volatile methylene chloride during container cleaning, container unloading, equipment
cleaning, application (spray, roll, curtain, bead), and during drying/curing.
Given the identified applications of methylene chloride in liquid, aerosol, and canister adhesives and
sealants (Abt. 2017). EPA anticipates workers may apply adhesives and sealants via any method, with
particular use as a spray adhesive/sealant. The adhesives and sealants are likely sold and used in sealed
containers such as spray cans or canister tanks.
2.9.3.2 Inhalation Exposures
TableApx A-10 and TableApx A-l 1 in 4.2.5Appendix A summarize the inhalation monitoring data
for methylene chloride adhesive and sealant application that EPA compiled from published literature
sources, including 8-hour TWA, short-term, and partial shift sampling results. This appendix also
includes EPA's rationale for inclusion or exclusion of these data in the risk evaluation.
EPA found inhalation exposure data for both spray and non-spray industrial adhesive and sealant
application; EPA did not identify non-industrial data. 8-hr TWA data are primarily from a 1985 EPA
Risk Assessment that compiled laminating and gluing activities in various industries, ranging from ND
to 575 mg/m3 (97 samples) (US EPA. 1985). A 1984 NIOSH HHE performed at a flexible circuit board
manufacturing site encompassed various worker activities in adhesive/sealant mixing and laminating
areas, ranging from 86.8 to 458.5 mg/m3 (12 samples) (NIOSH. 1985).
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. Central tendency 8-hr TWA exposure
concentrations for these scenarios are less than half of the OSHA PEL value of 87 mg/m3 (25 ppm),
while worst-case estimates are between three and seven times the OSHA PEL.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as described in
4.2.5Appendix B. The results of these calculations are shown in Table 2-26 and Table 2-27 for industrial
non-spray and spray adhesives and sealants application, respectively.
Table 2-26. Exposure to Methylene Chloride During Industrial Non-Spray Adhesives and Sealants
Use
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
10
300
Average Daily Concentration (ADC)
98
2.4
70
Lifetime Average Daily Concentration (LADC)
4.2
150
Sources: NIOSH (1985): US EPA (1985)
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Table 2-27. Exposure to Methylene Chloride During Industrial Spray Adhesives and Sealants Use
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
39
560
Average Daily Concentration (ADC)
16
8.9
130
Lifetime Average Daily Concentration (LADC)
16
290
Sources: TNO (CIVO) (1999): (IPCS) (1996): US EPA (1985)
Table 2-28 summarizes available short-term exposure data available from the same references and
industries identified above for the 8-hr TWA data. Data range from 12 mg/m3 to 720 mg/m3 during
adhesive/sealant spraying.
Table 2-28. Summary of Personal Short-Term Exposure Data for Methylene Chloride During
Industrial Adhesives and Sealants Use
Methylene Chloride
Exposure
Occupational Exposure
Short-Term
Duration
Scenario
Source
Worker Activity
Concentration (mg/m3)
(min)
Metal Window and Door
720
Manufacturing
580
140
OSHA (2019)
480
Wood Kitchen Cabinet and
Adhesive/Sealant Sprayer
160
15
Countertop Manufacturing
360
100
280
12
Flexible Circuit Board
Manufacturing
NIOSH (1985)
Operator, laminator #3 & #4,
cleaning (Non-Spray)
420
10
Employee mixing
adhesives/sealants, Dept 12
(Non-Spray)
570
12
Note: The OSHA Short-term exposure limit (STEL) is 433 mg/m3 as a 15-min TWA.
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly handle
formulations containing methylene chloride, EPA expects ONU inhalation exposures to be lower than
worker inhalation exposures.
2.9.4 Water Release Assessment
Based on a mass balance study on the Dutch use of methylene chloride as adhesives/sealants, TNO
calculated an emission of 100% to air (TNO (CIVO). 1999). EPA did not find information on potential
water releases. Water releases may occur if equipment is cleaned with water.
2.9.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as potential direct or
indirect water releases. EPA has not identified additional uncertainties for this use beyond those
discussed in Section 4.2.
2.10Paints and Coatings
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2.10.1 Process Description
Based on the Preliminary Information on Manufacturing, Processing, Distribution, Use, and Disposal:
Methylene Chloride and Use and Market Profile for Methylene Chloride, both available in the public
docket (AM. 2017). methylene chloride may be used in various paints and coatings for industrial,
commercial, and consumer applications. Typical industrial and commercial coating applications include
manual application with roller or brush, air spray systems, airless and air-assisted airless spray systems,
electrostatic spray systems, electrodeposition/electrocoating and autodeposition, dip coating, curtain
coating systems, roll coating systems, and supercritical carbon dioxide systems. After application,
solvent-based coatings typically undergo a drying stage in which the solvent evaporates from the coating
(OECD. 2009b).
2.10.2 Number of Sites and Potentially Exposed Workers
2017 document on the Preliminary Information on Manufacturing, Processing, Distribution, Use, and
Disposal of NMP ( 2017b) and Market Profile (Abt. 2017) both identified methylene chloride
in use in paints and coatings, but did not identify specific products that use methylene chloride.
Application of methylene chloride-based paints and coatings are widespread, occurring in many
industries. EPA identified potential industries likely to use methylene chloride in paints and coatings
based on 2014 NEI data and NAICS codes reported in monitoring data obtained from OSHA.
The industries that distinctly perform the various methods of paint and coating application are unknown.
EPA assumes that all industries may perform all methods of application. EPA compiled the associated
NAICS codes for the identified industries in Table 2-29. EPA determined the number of workers
associated with each industry from US Economic Census and Bureau of Labor Statistics (BLS) data.
The number of establishments within each industry that use methylene chloride-based paints and
coatings and the number of employees within an establishment exposed to these methylene chloride-
based products are unknown. Therefore, EPA provides the total number of establishments as a bounding
estimate, and estimates the number of workers and ONUs that are potentially exposed to methylene
chloride-based adhesive and sealant products. These estimates likely overestimate the actual number of
establishments and employees potentially exposed to methylene chloride during paint and coating
application.
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Table 2-29. Number of U.S. Establishments, Workers, and ONU for Industries Performing Paint and Coating Application
Industry
Source
2016
NAICS
2016 NAICS Title
Number of
Establishments
Number of
Workers
per Sitea
Number of
ONUs per
Site3
Specialty Trade
Contractors
Market Profile;
OSHA
238320
Painting and Wall Covering Contractors
31,943
4
0
Printing and
Related Support
Activities
OSHA
323113
Commercial Screen Printing
4,956
1
1
Fabricated Metal
Product
Manufacturing
OSHA; NIOSH
HHE
332000
Fabricated Metal Product Manufacturing
54,767
12 b
2b
Furniture and
Related Product
Manufacturing
OSHA
337100
Household and Institutional Furniture and Kitchen Cabinet
Manufacturing
10,759
5
4
Clothing and
Clothing
Accessories
Stores
OSHA
448100
Clothing Stores
98,485
6
1
Amusement,
Gambling, and
Recreation
Industries
OSHA
713100
Amusement Parks and Arcades
3,280
28 b
5b
Repair and
Maintenance
OSHA
811111
General Automotive Repair
80,243
2
0
Total establishments and number of potentially exposed workers and ONUs = c
284,433
1,800,000
340,000
a - Rounded to the nearest whole number.
b - No 2016 BLS data was available for this NAICS or at the 3-digit level. Number of relevant workers per site and ONUs per site within this NAICS were calculated
using the ratios of relevant workers and ONUs to the number of total employees for all NAICS codes in the table,
c - Unrounded figures were used for total worker and ONU calculations.
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2,10,3 Exposure Assessment
2.10.3.1 Worker Activities
Similar to adhesive and sealant use, paint and coating application depends on a variety of factors
including the type of adhesive/sealant, type of substrate, size and geometry of the substrate, and
the precision requirement of the paint or coating. Workers may be exposed to the volatile
methylene chloride during container cleaning, container unloading, equipment cleaning,
application (spray, roll, curtain, etc.), and during drying/curing (OECD. 2015).
2.10.3.2 Inhalation Exposures
TableApx A-12 and TableApx A-13 in 4.2.5Appendix A summarize the inhalation monitoring
data for methylene chloride paint and coating application that EPA compiled from published
literature sources, including 8-hour TWA, short-term, and partial shift sampling results. This
appendix also includes EPA's rationale for inclusion or exclusion of these data in the risk
evaluation.
8-hr TWA data during spray coating are primarily from monitoring data at various types of
facilities types, such as sporting goods stores, metal products, air conditioning equipment, etc., as
compiled in the 1985 EPA assessment (US EPA. 1985). Two additional spray painting data
points were available from OSHA inspections between 2012 and 2016, one in the general
automotive repair sector, and the other in the Wood Kitchen Cabinet and Countertop
Manufacturing sector. The U.S. Department of Defense (DOD) provided five monitoring data
points from painting operations during structural repair. The worker activities did not indicate the
method of paint application. The activities were also stated to have low durations (0-15 minutes)
but provided sampling data that occurred over 2-hr periods. EPA assumed that there was no
exposure to methylene chloride over the remainder of the shift, and calculated 8-hr TWA
exposures.
Because the method of paint application is unknown, EPA presents the spray application data
and the unknown application data separately.
For spray coating operations, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentration for this scenario is below the OSHA PEL value of 87 mg/m3 (25 ppm),
but the high-end estimate is approximately four times higher.
For unknown application method operations, because only five data points were available, EPA
assessed the median value of 7.1 mg/m3 as the central tendency, and the maximum reported
value of 10.7 mg/m3 as the high-end estimate of potential occupational inhalation exposures. The
central tendency 8-hr TWA exposure concentration for this scenario is an order of magnitude
below the OSHA PEL value of 87 mg/m3 (25 ppm), and the high-end estimate is approximately
eight times lower.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-30 and
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Table 2-31, respectively for spray paint/coating application and unknown application method
paint/coating application.
Table 2-30. Exposure to Methylene Chloride During Paint/Coating Spray Application
Number of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
70
360
Average Daily Concentration (ADC)
27
16
83
Lifetime Average Daily Concentration
(LADC)
28
190
Sources: OSHA (2019): US EPA (1985)
Table 2-31. Exposure to Methylene Chloride During Paint/Coating (Unknown Application
Method)
Number of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
7.1
11
Average Daily Concentration (ADC)
5
1.6
2.4
Lifetime Average Daily Concentration
(LADC)
2.8
5.5
Sources: (DOEHRS-IH) (2018)
Table 2-32 summarizes available short-term exposure data available from the same OSHA
inspections and DOD data identified above for the 8-hr TWA data, as well as short-term
exposure data during painting at a Metro bus maintenance shop in 1981, and spray painting in a
spray booth at a metal fabrication plant in 1973.
Table 2-32. Summary of Personal Short-Term Exposure Data for Methylene Chloride
During Paint/Coating Use
Occupational
Exposure Scenario
Source
Worker Activity
Methylene Chloride
Short-Term
Concentration (mg/m3)
Exposure
Duration
(min)
Metro Bus Maintenance
Shop
Love and
Painting
ND (<0.01)
40
Kern (1981)
Painting
ND (<0.01)
50
Metal Fabrication Plant
Vandervort
and Polakoff
(1973)
Spray Painter in Aisle No. 2
(Front) Spray Booth
64
32
54
32
63
27
36
20
74
29
Spray Painter in Aisle No. 1
(Rear) Spray Booth
1.0
18
3.0
23
4.0
22
Painting/Coating
Operations
(DOEHRS-
IH) (2018)
Painting Operations
4.1
15
Painting Operations
4.1
Painting Operations
4.1
Painting Operations
4.1
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Occupational
Exposure Scenario
Source
Worker Activity
Methylene Chloride
Short-Term
Concentration (mg/m3)
Exposure
Duration
(min)
Priming Operations
5.2
IND-002-00 Chemical
cleaning multi ops.
1.7
IND-006-00 Coating
Operations, Multiple
Operations
1.9
IND-006-00 Coating
Operations, Multiple
Operations
1.9
NPS ECE aerosol can
painting
13.5
ND - not detected
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle formulations containing methylene chloride, EPA expects ONU inhalation exposures to
be lower than worker inhalation exposures.
2.10.4 Water Release Assessment
EPA did not identify information about potential water releases during application of paints and
coatings. Water releases may occur if equipment is cleaned with water; however, industrial and
commercial sites would likely be expected to dispose of solvent-based paints as hazardous waste.
2.10.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as potential direct
or indirect water releases. EPA has not identified additional uncertainties for this use beyond
those discussed in Section 4.2.
2.11 Adhesive and Caulk Removers
2.11.1 Process Description
EPA did not find specific exposure data for adhesive and caulk removers. Products listed in the
market profile (Abt 2017) indicate potential use in flooring adhesive removal. Based on
expected worker activities, EPA assumes that the use of adhesive and caulk removers is similar
to paint stripping by professional contractors, as outlined in the 2014 Risk Assessment on Paint
Stripping Use for Methylene Chloride (U.S. EPA. 2014).
Paint strippers can be used by professional contractors to strip paint and varnish from walls,
wood flooring, and kitchen and wood cabinets. Professional contractors are expected to
purchase strippers in commercially available container sizes that commonly range from one
liter up to 5 gallons, although they may also purchase consumer paint stripper products from
hardware stores.
Stripper is typically applied to wall or floor surfaces using a hand-held brush. Strippers used in
these applications often have a high viscosity since they can be applied to vertical surfaces. After
application, the stripper is allowed to set and soften the old coating. Once the stripper has
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finished setting, the old coating is removed from the surface by scraping and brushing. During
wood floor stripping, old coating and stripper may also be removed using an electric floor buffer.
After the old coating is removed, the surface is wiped clean before moving to the next stages of
the job. The stripping process is often completed on an incremental basis with treatment for one
section of wall or flooring being completed before moving to the next section. Professional
contractors can use portable local exhaust ventilation machines to increase ventilation in the
vicinity of the paint stripping (U.S. EPA. 2014).
Professional contractors may also be employed to refinish or reglaze bathtubs. Various health
case studies have noted the use of methylene chloride -based strippers during bathtub refinishing
or reglazing. Case studies have identified professional bathtub refinishers that repaired and
resurfaced countertops, tubs, and sinks in both apartment buildings and private homes (U.S.
EPA. 2014).
In addition, the OSHAIMIS data identified two OSHA or state health inspections in 2004 and
2007 of two bathtub reglazers/refinishers. The bathtub reglazers' company in the 2007 inspection
was identified under NAICS code 811420 - Reupholstery and Furniture Repair (U.S. EPA.
2014). However, this assessment discusses bathtub reglazing/refinishing in the context of
professional contractors, as professional contractors and professional bathtub refinishers or
reglazers are both expected to perform their work at customer sites (for example, in the cited
case studies of bathtub refinishers/reglazers, apartment buildings, and private homes). This
professional contractor-type work differs from furniture refinishing, which typically entails the
refinishing of customer furniture at fixed furniture refinishing facilities.
Bathtub refinishing or reglazing can involve a worker pouring and brushing stripper onto a
bathtub using a paintbrush. The worker then scrapes the finish from the bathtub after leaving the
stripper in contact with the bathtub for 20 to 30 minutes. This information was obtained from a
case study that noted a stripper methylene chloride concentration of 60 to 100 percent. However,
multiple health case studies have reported the use of aircraft and marine coating remover in
bathtub refinishing/reglazing (U.S. EPA. )
2,11,1 Number of Sites and Potentially Exposed Workers
EPA estimated the number of workers and occupational non-users potentially exposed to
methylene chloride during furniture stripping using Bureau of Labor Statistics' OES data (U.S.
n '16) and the U.S. Census' SUSB (U.S. Census Bureau. J*' I *)• The method for estimating
number of workers is detailed above in Section 1.4.2. These estimates were derived using
industry- and occupation-specific employment data from the BLS and U.S. Census. No market
penetration information was available; therefore, EPA assumed a bounding number of sites, and
estimated the associated number of workers and ONUs for each paint stripping scenario, as
shown in Table 2-33 (r S HIS. 2016; U.S. Census Bureau. 2015).
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Table 2-33. Number of U.S. Establishments, Workers, and ONUs for Industries
Conducting Paint Stripping
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers Site a
Number of
ONUs per Sitea
Professional Contractors
238320
Painting and Wall Covering
Contractors
31,943
4
0.4
238330
Flooring Contractors
14,601
4
0.3
Total establishments and number of potentially
exposed workers and ONUs = a
46,544
190,000
18,000
a - Rounded to the nearest worker. Unrounded figures were used for total worker and ONU calculations.
2.1 U2 Exposure Assessment
2.11.2.1 Worker Activities
Workers may be exposed to methylene chloride during application of the adhesive remover
stripper (brush, spray, dip), soaking of the surfaces, scraping and brushing of the coatings from
the surfaces, and washing residuals.
2.11.2.2 Inhalation Exposures
TableApx A-14 and TableApx A-15in Appendix A summarize the inhalation monitoring data
for methylene chloride in professional contractor paint stripping that EPA compiled from
published literature sources. This appendix also includes EPA's rationale for inclusion or
exclusion of these data in the risk evaluation.
U.S. EPA (2014) compiled four studies that sampled between 1981 and 2004, resulting in a
range of 8-hr TWA exposure concentrations between 60 and 2,980 mg/m3, and a midpoint of
1,520 mg/m3. The central tendency 8-hr TWA exposure concentration for this scenario is
approximately 17 times the OSHA PEL value of 87 mg/m3 (25 ppm), while the high-end
estimate is almost 34 times higher.
From these personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. Using these 8-hr TWA exposure
concentrations, EPA calculated the ADC and LADC as described in 4.2.5Appendix B. The
results of these calculations are shown in Table 2-34.
Table 2-34. Full-Shift Exposure to Methylene Chloride During Adhesive and Caulk
Removal (Using Professional Contractor Paint Stripping Data as Surrogate)
Number
of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
1,500
3,000
Average Daily Concentration (ADC)
unknown
350
680
Lifetime Average Daily Concentration
(LADC)
600
1,500
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Source: U.S. EPA (2014)
Table 2-35 summarizes available short-term exposure data from paint stripping using methylene
chloride.
Table 2-35. Short-Term Exposure to Methylene Chloride During Adhesive and Caulk
Removal (Using Professional Contractor Paint Stripping Data as Surrogate)
Number of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
Professional Contractors
unknown
7,100
14,100
Source: U.S. EPA (2014)
EPA did not identify exposure data on potential ONU inhalation exposures. Since ONUs do not
directly handle formulations containing methylene chloride, EPA expects ONU inhalation
exposures to be lower than worker inhalation exposures.
2.11.3 Water Release Assessment
Based on process information, water may be used to rinse stripper containing methylene chloride
from substrates during graffiti removal, wood furniture stripping, aircraft stripping, or ship
stripping. The wastewater may be is collected and either recycled or disposed of as waste.
Therefore, water releases may be expected for these uses, but EPA did not identify quantitative
information in the 2016 TRI or 2016 DMR. Commercial stripping operation facilities likely do
not handle enough methylene chloride to meet the reporting thresholds of TRI and would not
likely report to DMR because they are not industrial facilities.
EPA also did not identify quantitative information on methylene chloride release during other
stripping uses (professional contractors, automotive body stripping, and art restoration and
conservation). The majority of methylene chloride is expected to evaporate into the air, but
releases to water may occur if equipment is cleaned with water.
2.11.4 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as potential direct
or indirect water releases. EPA has not identified additional uncertainties for this use beyond
those discussed in Section 4.2.
2.12 Fabric Finishing
2.12.1 Process Description
Workers may be potentially exposed to methylene chloride during application on to fabrics, or
during volatilization during pressing. It is unclear whether there are additional worker activities
that use methylene chloride. The 2017 Draft Use and Market Profile for Methylene Chloride did
not identify any specific fabric finishing products (Abt 2017). EPA assumes that fabric finishing
operations occur industrially at fabric mills.
2.12.2 Number of Sites and Potentially Exposed Workers
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EPA determined the number of workers associated with fabric finishing using US Economic
Census and Bureau of Labor Statistics (BLS) data. The number of establishments within the
fabric finishing industry that use methylene chloride-based products and the number of
employees within an establishment exposed to these methylene chloride-based products are
unknown. Therefore, EPA provides the total number of establishments as a bounding estimate of
the number of establishments that use methylene chloride and estimates the number of
employees that are potentially exposed to methylene chloride-based products at these
establishments. These are likely overestimates of the actual number of establishments and
employees potentially exposed to methylene chloride. EPA estimates 1,886 establishments,
18,800 workers, and 12,340 ONUs, as shown in Table 2-36 (U.S. BLS. 2016; U.S. Census
Bureau. 2015).
Table 2-36. Number of U.S. Establishments, Workers, and ONUs for Fabric Finishing Sites
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers Sitea
Number of
ONUs per Sitea
313210
Broadwoven Fabric Mills
281
14
10
313220
Narrow Fabric Mills and Shiffli
Machine Embroidery
190
7
6
313230
Nonwoven Fabric Mills
204
19
14
313240
Knit Fabric Mills
174
10
7
313310
Textile and Fabric Finishing Mills
755
7
3
313320
Fabric Coating Mills
167
14
10
Total establishments and number of
potentially exposed workers and ONUs = b
1,886
19,000
12,000
a - Rounded to the nearest worker.
b - Unrounded figures were used for total worker and ONU calculations.
2.12.3 Exposure Assessment
2.12.3.1 Worker Activities
Workers may be exposed to methylene chloride during pressing or spray finishing.
2.12.3.2 Inhalation Exposure
Table Apx A-16 in 4.2.5Appendix A summarizes the inhalation monitoring data for methylene
chloride for fabric finishing that EPA compiled from published literature sources, including 8-
hour TWA, short-term, and partial shift sampling results. This appendix also includes EPA's
rationale for inclusion or exclusion of these data in the risk evaluation.
8-hr TWA data are from monitoring data from various OSHA inspections between 1985 and
2008 at apparel manufacturing sites and ranged from 42.0 mg/m3 to 164.6 mg/m3(14 data
points). Specific worker activities were not identified. Exposures at these facilities was assumed
to be representative of exposures for fabric finishing activities (Tinkel. 2017).
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From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentration for workers is approximately the OSHA PEL value of 87 mg/m3 (25
ppm), while the high-end estimate for workers is approximately twice the PEL value.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-37 for
workers and ONUs during fabric finishing.
Table 2-37. Worker Exposure t
o Methylene Chloride During Fabric Finishing
Number
of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
15
87
160
Average Daily Concentration (ADC)
20
37
Lifetime Average Daily Concentration
(LADC)
35
84
Source: Finkel (2017): TNO (CIVO) (1999).
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle formulations containing methylene chloride, EPA expects ONU inhalation exposures to
be lower than worker inhalation exposures.
2.12.4 Water Release Assessment
EPA did not identify quantitative information about potential water releases during use of
methylene chloride in fabric finishing. The majority of methylene chloride is expected to
evaporate into the air, but releases to water may occur if equipment or fabric is cleaned with
water.
2.12.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as potential direct
or indirect water releases. EPA has not identified additional uncertainties for this use beyond
those discussed in Section 4.2.
2.13 Spot Cleaning
2.13.1 Process Description
The Preliminary Information on Manufacturing, Processing, Distribution, Use and Disposal for
Methylene Chloride (U.S. EPA. 2017b) includes use as spot cleaner for apparel and textiles (>60
to 95 percent methylene chloride).
Spot cleaning products can be applied to the garment either before or after the garment is dry
cleaned. The process and worker activities associated with commercial dry cleaning and spot
cleaning have been previously described in the 1-Bromopropane Draft Risk Assessment (U.S.
EPA. 2016c).
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On receiving a garment, dry cleaners inspect for stains or spots they can remove as much of as
possible before cleaning the garment in a dry cleaning machine. As Figure 2-12 shows, spot
cleaning occurs on a spotting board and can involve the use of a spotting agent containing
various solvents, such as methylene chloride. The spotting agent can be applied from squeeze
bottles, hand-held spray bottles, or even from spray guns connected to pressurized tanks. Once
applied, the dry cleaner may come into further contact with the methylene chloride if using a
brush, spatula, pressurized air or steam, or their fingers to scrape or flush away the stain (Young.
2012); (NIOSH. 1997).
Figure 2-12 Overview of Use of Spot Cleaning at Dry Cleaners
2.13.2 Number of Sites and Potentially Exposed Workers
EPA/OPPT estimated the number of workers and occupational non-users potentially exposed to
methylene chloride at dry cleaners using Bureau of Labor Statistics' OES data (U.S. BLS. 2016)
and the U.S. Census' SUSB (U.S. Census Bureau. 2015). The method for estimating number of
workers is detailed above in Section 1.4.2. These estimates were derived using industry- and
occupation-specific employment data from the BLS and U.S. Census.
Table 2-38 presents BLS occupation codes where workers are potentially exposed to dry
cleaning solvents. EPA/OPPT designated each occupation code as either "Worker (W)" or
"Occupational non-user (O)" to separately estimate the number of potentially exposed workers
and occupational non-users. EPA/OPPT classified laundry and dry cleaning workers, pressers,
and machine repairers as "Workers" because they are likely to have direct exposure to the dry
cleaning solvents. EPA/OPPT classified retail sales workers (e.g., cashiers), sewers, tailors, and
other textile workers as "occupational non-users" because they perform work at the dry cleaning
shop, but do not directly handle dry cleaning solvents.
Table 2-38. SOC Codes for Worker Exposure in Dry Cleaning
SOC
Occupation
Exposure
Designation
41-2000
Retail Sales Workers
O
49-9040
Industrial Machinery Installation Repair, and Maintenance Workers
w
49-9070
Maintenance and Repair Workers, General
w
49-9090
Miscellaneous Installation Maintenance, and Repair Workers
w
51-6010
Laundry and Dry-Cleaning Workers
w
51-6020
Pressers, Textile, Garment, and Related Materials
w
51-6030
Sewing Machine Operators
0
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51-6040
Shoe and Leather Workers
O
51-6050
Tailors, Dressmakers, and Sewers
O
51-6090
Miscellaneous Textile, Apparel, and Furnishings Workers
O
Source: U.S. BLS (2016)
W - worker, O - occupational non-user
No market penetration information was available; therefore, EPA assesses a bounding estimate
of 21,370 establishments, with four workers/site, and 0.4 ONUs/site, as shown in Table 2-39
(U.S. BLS. 2016; U.S. Census Bureau. 2015).
Table 2-39. Number of U.S. Establishments, Workers, and ONUs for Industries Using Spot
Removers at Dry Cleaners
NAICS
Codes
NAICS Description
Number of
Establishment
s
Number of
Workers per Site
a
Number of
ONUs per Site
a
812320
Drycleaning and Laundry Services
(except Coin-Operated)
21,370
4
0.4
Total establishments and number of potentially
exposed workers and ONUs = b
76,000
7,900
a - Rounded to the nearest worker unless less than one.
b - Unrounded figures were used for total worker and ONU calculations.
^.13.3 Exposure Assessment
2.13.3.1 Worker Activities
As previously described, workers manually apply the spotting agent from squeeze bottles, hand-
held spray bottles, or spray guns, either before or after a cleaning cycle. After application, the
worker may manually scrape or flush away the stain using a brush, spatula, pressurized air or
steam, or their fingers (Young. 2012; NIOSH. 1997).
2.13.3.2 Inhalation Exposures
TableApx A-17 and TableApx A-18 in 4.2.5Appendix A summarize the inhalation monitoring
data for methylene chloride that EPA compiled from published literature sources, including 8-
hour TWA, short-term, and partial shift sampling results. This appendix also includes EPA's
rationale for inclusion or exclusion of these data in the risk evaluation.
EPA did not find any specific exposure monitoring data for methylene chloride-containing
products during use as a spot cleaner. EPA used OSHA data for Industrial Launderers and
Drycleaning and Laundry Services (except Coin-Operated) (Finkel. 2017).
Sample times ranged from 173 to 270 minutes. EPA used exposure concentrations with sample
times greater than 240 minutes (4 hours) and converted the exposures to 8-hr TWAs assuming
zero concentrations outside sampling time.
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. Both the central tendency and high-
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end 8-hr TWA exposure concentrations for this scenario are below the OSHA PEL value of 87
mg/m3 (25 ppm).
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-40.
Table 2-40. Exposure to Methylene Chloride During Spot Cleaning
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
2.6
64
Average Daily Concentration (ADC)
6
0.58
15
Lifetime Average Daily Concentration
(LADC)
1.0
33
Source: Finkel (2017)
Table 2-41 summarizes available short-term exposure data available from the same OSHA
source identified above for the 8-hr TWA data (Finkel 2017).
Table 2-41. Summary of Personal Short-Term Exposure Data for Methylene Chloride
During Spot Cleaning
Occupational
Exposure Scenario
Source
Worker Activity
Methylene Chloride
Short-Term
Concentration (mg/m3)
Exposure
Duration
(min)
Industrial Launderers
Finkel (2017)
unknown
67
197
230
185
160
187
8.7
173
12
174
980
202
980
202
0.29
225
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle formulations containing methylene chloride, EPA expects ONU inhalation exposures to
be lower than worker inhalation exposures.
2.13.4 Water Release Assessment
The majority of methylene chloride in spot removers is expected to evaporate into the air, but
releases to water may occur if residue remains in the garment during washing. EPA identified
one facility in the 2016 DMR with SIC code 7216 (Drycleaning Plants, Excluding Rug
Cleaning). This facility reported 0.1 kg annual release of methylene chloride to surface water, as
shown in Table 2-42. EPA did not identify any potential spot cleaning facilities in the 2016 TRI
that reported water releases. Other facilities in this industry may not dispose to water, or may not
use methylene chloride in quantities that meet the TRI reporting threshold.
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Table 2-42. Surface Water Releases of Methylene Chloride During Spot Cleaning
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-day)
Release
Media
Sources
& Notes
BOISE STATE
UNIVERSITY
BOISE
ID
0.1
250
0.0002
Surface
Water
U.S.
EPA
(2016a)
2.14 Cellulose Triacetate Film Production
2.14.1 Process Description
During Cellulose Triacetate (CTA) film production, CTA is dissolved in an organic solvent
(approximately 65% methylene chloride) to make a film substance, which is then poured on a
metal drum or a continuous metal belt. After the methylene chloride evaporates, a film having a
thickness of 0.02 to 0.03 mm forms. The film then passes through a water sealer by means of a
heated cylinder onto a chromium roller where it is dried. For safety reasons, the drum and metal
belt are in a hermetically sealed channel separated from the water sealed environment and closed
off by a moderately high nitrogen pressure. Note that CTA was historically also used to
manufacture CTA fibers, but OSHA indicates that the single CTA fiber manufacturing plant was
closed in 1982 (OSHA. 1991). Therefore, EPA did not assess exposures for CTA fiber
manufacturing.
2.14.2 Number of Sites and Potentially Exposed Workers
OSHA (1991) estimated that there were two triacetate film manufacturing sites, covering 700
potentially exposed workers (350 workers per site). It is unclear whether these sites still perform
these processes using methylene chloride.
2.14.3 Exposure Assessment
2.14.3.1 Worker Activities
During CTA film manufacturing, exposures can occur during evaporation of the methylene
chloride, material set up, disruption in apparatus, and pouring CTA-containing film onto the
metal drums. Film splicing can also occur, where methylene chloride as a solvent in the glue may
be used to splice pieces of film together. The methylene chloride dissolves the plastic interfaces
of the pieces and then evaporates, leaving the pieces "welded" together. This process is either
done manually or by machine (OSHA. 1991).
2.14.3.2 Inhalation Exposure
Table Apx A-19 in 4.2.5Appendix A summarizes the inhalation monitoring data for methylene
chloride used in CTA film and manufacture that EPA compiled from published literature
sources, including 8-hour TWA, short-term, and partial shift sampling results. This appendix also
includes EPA's rationale for inclusion or exclusion of these data in the risk evaluation.
8-hr TWA data are primarily from six studies performed in the 1970s and 1980s. Worker
activities encompassed various areas of CTA production, including preparation, extrusion, and
coating, but each study compiled data into overall statistics for each worker type instead of
presenting separate data points (Ott et al.. 1983); (Dell et al.. 1999); (TNO (CIVO). 1999).
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Because the individual data points were not available, EPA presents the average of the median,
and average of maximum values as central tendency and high end, respectively. The central
tendency and high end 8-hr TWA exposure concentrations for this scenario are approximately 12
to 16 times the OSHA PEL value of 87 mg/m3 (25 ppm), respectively.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-43 for CTA
film manufacturing.
Table 2-43. Worker Exposure to Met
thylene Chlorit
e During CTA Film Manufacturing
Number of
Samples
Central Tendency
(mg/m3)
High-End
(mg/m3)
8-hr TWA Exposure Concentration
>166a
1,000
1,400
Average Daily Concentration (ADC)
240
320
Lifetime Average Daily Concentration
(LADC)
410
560
Sources: Dell et al. (1999): TNO (CIVO) (1999): Ottetal. (1983)
a - Various studies were compiled to determine central tendency and high-end estimates; however, not all indicated
the number of samples. Therefore, actual number of samples is unknown.
EPA has not identified specific short-term data or data on potential ONU inhalation exposures;
some ONUs may be included in the estimates for workers. Since ONUs do not directly handle
methylene chloride, EPA expects ONU inhalation exposures to be lower than worker inhalation
exposures.
2.14.4 Water Release Assessment
EPA identified one facility in the 2016 DMR, potentially related to CTA manufacturing (SIC
code 3861 - Photographic Equipment and Supplies) that reported water releases. Release for this
facility is summarized in Table 2-44. EPA did not identify any potential CTA manufacturing
facilities in the 2016 TRI that reported water releases.
Table 2-44. Reported 2
016 TRI and DMR
Releases for CTA Manufacturing Facilities
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-day)
Release
Media
Sources
& Notes
KODAK
PARK
DIVISION
ROCHESTER
NY
29
250
0.1
Surface
Water
U.S. EPA
(2016a)
2.14.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or
indirect water releases. EPA has not identified additional uncertainties for this use beyond those
discussed in Section 4.2.
2.15Flexible Polyurethane Foam Manufacturing
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2.15.1 Process Description
Methylene chloride is used as a blowing agent and as a solvent for cleaning equipment in the
production of polyurethane foam (PU). In the "one shot" PU foam process, foam materials are
prepared by simultaneously mixing the co-reactants (polyol and isocyanate) directly with
additives (blowing agents [e.g., methylene chloride], catalysts, foam stabilizers, and flame
retardants). The variability and the sequence of production processes and the type of equipment
needed for each process affect worker exposure to methylene chloride.
In the "two part" PU foam process, polyurethane foam ingredients, polyol and isocyanate, are
stored in separate tanks, with auxiliary agents such as blowing agents, catalysts, and pigment
pastes added to the polyol tank. If direct metering is used, the additives are blended inline on the
suction side of the pump with the use of premix chambers. Components are passed through the
mix-head, in which the components are brought together to form the reaction mix. The reaction
mix can be poured into open or closed molds. Pouring into open molds or onto a substrate can be
done at one spot or along a pattern. Pouring into a closed mold is done through fill holes or gates
(OSHA, 1991).
^.15.2_ Number of Sites and Potentially Exposed Workers
EPA estimated the number of workers and occupational non-users potentially exposed to
methylene chloride during polyurethane foam manufacturing using Bureau of Labor Statistics'
OES data (U.S. BLS. 2016) and the U.S. Census' SUSB (U.S. Census Bureau. 2015). The
method for estimating number of workers is detailed above in Section 1.4.2. These estimates
were derived using industry- and occupation-specific employment data from the BLS and U.S.
Census. No market penetration information was available; this assumes a bounding estimate of
654 establishments, with an estimated 9,567 workers and 2,707 ONUs, as shown in Table 2-45
(U.S. BLS. 2016; U.S. Census Bureau. 2015).
Table 2-45. Number of U.S. Establishments, Workers, and ONUs for Industries
Conducting Polyurethane Foam Manufacturing
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers Sitea
Number of ONUs
per Sitea
326150
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
654
15
4
Total establishments and number of potentially
exposed workers and ONUs = b
9,600
2,700
a - Rounded to the nearest worker.
b - Unrounded figures were used for total worker and ONU calculations.
Alternatively, an industry survey compiled for the 1991 proposed OSHA rule indicated 1,169
exposed workers at 180 foam blowing sites (approximately seven workers per site) (OSHA.
1991). Based on the overall decline in methylene chloride usage from the 1980s through 2011
(U.S. EPA. 2014). EPA assumes that this is an upper-bound estimate for the number of
potentially exposed workers. Because the data from the 1991 OSHA study were specific to sites
using methylene chloride, EPA assumes there are up to 1,169 workers potentially exposed.
Note that regulations have limited the use of methylene chloride in polyurethane foam
production and fabrication. OAR's July 16, 2007 Final NESHAP for Area Sources: Polyurethane
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Foam Production and Fabrication (72 FR 38864) prohibited the use of methylene chloride-based
mold release agents at molded and rebond foam facilities, methylene chloride-based equipment
cleaners at molded foam facilities, and the use of methylene chloride to clean mix heads and
other equipment at slabstock facilities. Slabstock area source facilities are required to comply
with emissions limitations for methylene chloride used as an auxiliary blowing agent, install
controls on storage vessels, and comply with management practices for equipment leaks. The
rule also prohibits methylene chloride-based adhesives for foam fabrication. The April 4, 2007
proposed area source rule (72 FR 16636) indicated that there were hundreds of facilities in the
Flexible Polyurethane Foam Production and Flexible Polyurethane Foam Fabrication area source
categories, which were listed because of the use of methylene chloride. However, because of
several reasons, including State air emissions standards and OSHA worker exposure limits,
methylene chloride use was expected to be virtually eliminated. The August 15, 2014 NESHAP
Final Residual Risk and Technology Review for the Flexible Polyurethane Foam Production
Source Category (79 FR 48073) identified 13 major source facilities, a subset of which may use
methylene chloride. It is unclear how many total sources continue to use methylene chloride in
the present day.
2,15,3 Exposure Assessment
2.15.3.1 Worker Activities
Workers use methylene chloride as a blowing agent in the production of flexible PU and as a
flushing media of the mixing head in the production of rigid foam. The cleaning of the mixing
chamber and all the elements of the mixers with agitators is usually done by purging solvents,
such as methylene chloride. The small volumes of the impingement mixers allow purging with
air. For example, in the process of mixing some of the reaction mixture is left behind in the
mixing chamber after each pour. Methylene chloride is used to flush the residual foam mix if the
duration between shots is longer than the time for the foam reaction to begin (OSHA. 1991).
2.15.3.2 Inhalation Exposures
TableApx A-20. and TableApx A-21 in 4.2.5Appendix A summarize the inhalation
monitoring data for methylene chloride used in polyurethane foam blowing that EPA compiled
from published literature sources, including 8-hour TWA, short-term, and partial shift sampling
results. This appendix also includes EPA's rationale for inclusion or exclusion of these data in
the risk evaluation. Note that these data were prior to promulgation of the polyurethane foam
NESHAPs, as discussed in Section 2.15.2.
8-hr TWA data are from various sources, and cover activities such as application of mold
release, foam manufacturing (blowing), blending, and sawing, that include use as a blowing and
mold release agent. Exposures varied from 0.3 mg/mg3 from purge operations, to 2,200.9 mg/m3
during laboratory operations.
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
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exposure concentration for this scenario is approximately 2.5 times higher than the OSHA PEL
value of 87 mg/m3 (25 ppm), while the high-end estimate is almost 12 times higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-46 for
flexible polyurethane foam manufacturing.
Table 2-46. Exposure to Methylene Chloride During Industrial Polyurethane Foam
Manufacturing
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
210
1,000
Average Daily Concentration (ADC)
82
48
230
Lifetime Average Daily Concentration
(LADC)
84
510
Sources: IARC (2016): TNO (CIVO) (1999): (IPCS) (1996): Vulcan Chemicals (1991): Reh and Lushniak (1990):
Cone Mills Corp (1981a): Cone Mills Corp (1981b): US EPA (1985):01in Chemicals (1977)
Table 2-47 summarizes available short-term exposure data.
Table 2-47. Summary of Personal Short-Term Exposure Data for Methylene Chloride
During Polyurethane Foam Manufacturing
Occupational
Methylene Chloride
Short-Term
Exposure
Duration
Exposure Scenario
Source
Worker Activity
Concentration (mg/m3)
(min)
Foam Blowing
5.2
360
Foam Blowing
13
360
Foam Blowing
19
360
Polyurethane Foam
US EPA
Foam Blowing
17
360
Manufacturing
(1985)
Foam Blowing
5.2
240
Foam Blowing
38
360
Foam Blowing
11
360
Nozzle Cleaning
55
30
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle formulations containing methylene chloride, EPA expects ONU inhalation exposures to
be lower than worker inhalation exposures.
^.15.4 Water Release Assessment
EPA assumed that sites classified under NAICS code 326150 (Urethane and Other Foam Product
(except Polystyrene) Manufacturing) are potentially applicable to polyurethane foam
manufacturing.
Table 2-48 lists one facility under this NAICS code that reported direct or indirect water releases
in the 2016 TRI. EPA did not identify water releases for polyurethane manufacturing sites in the
2016 DMR. This facility (Previs Innovative Packaging, Inc. in Wurtland, KY), reported 2
kilograms release to surface water (U.S. EPA. 2017c). Other facilities in this industry may not
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dispose to water, or may not use methylene chloride in quantities that meet the TRI reporting
threshold.
Table 2-48. Water Releases B
Reported in 2016 TRI for Polyurethane Foam Manu
'acturing
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources
& Notes
PREGIS
INNOVATIVE
PACKAGING INC
WURTLAN
D
KY
2
250
0.01
Surface
Water
U.S.
EPA
(2017c)
For chemical industries (including blowing agent in PUR production), calculations for the Dutch
chemical industry estimated emissions of 0.2 % to water, 64.8 % to air and 35 % to waste, based
on a mass balance study (TNO (CIVO). 1999).
2.15.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or
indirect water releases. In addition to uncertainties identified for this use discussed in Section
4.2, NESHAPs on Polyurethane Foam Production and Fabrication (discussed in Section 2.15.2)
have regulated the use of methylene chloride. The effects of these regulations on the number of
workers potentially exposed and potential exposure levels is not known due to a lack of recent
data.
2.16Laboratory Use
2.16.1 Process Description
Methylene chloride has various laboratory uses in gas and liquid chromatography (0.3 to 100%
methylene chloride) (Abt 2017). Specific uses are unclear.
^.16.2^ Number of Sites and Potentially Exposed Workers
EPA determined the number of workers associated with laboratory use from US Economic
Census and Bureau of Labor Statistics (BLS) data, using NAICS codes from OSHA monitoring
data. The number of establishments within the laboratory sector that use methylene chloride-
based products and the number of employees within an establishment exposed to these
methylene chloride-based products are unknown. Therefore, EPA provides the total number of
establishments as a bounding estimate of the number of establishments that use methylene
chloride and estimates the number of employees that are potentially exposed to methylene
chloride-based products at these establishments. These are likely overestimates of the actual
number of establishments and employees potentially exposed to methylene chloride. EPA
estimates 17,511 establishments, 17,511 workers, 151,506 ONUs, as shown in Table 2-49
(citation for BLS and Census).
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Table 2-49. Number of U.S. Establishments, Workers, and ONUs for Testing Laboratories
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers Site a
Number of
ONUs per Sitea
541380
Testing Laboratories
17,511
1
9
625511
Medical Laboratories
lb
9b
Total establishments and number of potentially
exposed workers and ONUs = c
17,000
150,000
a - Rounded to the nearest worker.
b - No 2016 BLS data was available for this NAICS. Number of relevant workers per site and ONUs per site within
this NAICS were calculated using the ratios of relevant workers and ONUs to the number of total employees under
NAICS 541380 - Testing Laboratories.
c - Unrounded figures were used for total worker and ONU calculations.
2.16.3 Exposure Assessment
2.16.3.1 Worker Activities
Workers in laboratory settings may be potentially exposed during sample preparation and
transfers.
2.16.3.2 Inhalation Exposure
TableApx A-22 and TableApx A-23 in 4.2.5Appendix A summarize the inhalation monitoring
data for methylene chloride used in laboratories that EPA compiled from published literature
sources, including 8-hour TWA, short-term, and partial shift sampling results. This appendix also
includes EPA's rationale for inclusion or exclusion of these data in the risk evaluation.
8-hr TWA data are primarily from a 1989 NIOSH inspection of an analytical laboratory
(Mccammon. 1990). an IH study at Texaco (Texaco Inc. 1993). and samples from the U.S. DOD
((DOEHRS-IH). 2018). Worker descriptions include laboratory staff, and activities include
sample preparation and transfer. Note that the NIOSH data were for various sample durations;
EPA included samples that were more than 4 hours long as full-shift exposures and adjusted the
exposures to 8-hr TWAs, assuming that the exposure concentration for the remainder of the time
was zero, because workers were not expected to perform the activities all day.
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentration for this scenario is an order of magnitude lower than the OSHA PEL
value of 87 mg/m3 (25 ppm), while the high-end estimate is seven times lower.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-50.
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Table 2-50. Worker Exposure
to Methylene (
Chloride During La
joratory Use
Number of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
10
3.5
12
Average Daily Concentration (ADC)
0.79
2.7
Lifetime Average Daily Concentration
(LADC)
1.4
6.0
Sources: (Mccammon. 1990): (Texaco Inc. 1993): ((DOEHRS-IH). 2018)
Table 2-51 summarizes available short-term exposure data available from the 1989 NIOSH
inspection and the DOD provided data identified above for the 8-hr TWA data.
Table 2-51. Worker Personal Short-Term Exposure Data for Methylene Chloride During
Laboratory Use
Methylene Chloride
Exposure
Occupational
Short-Term
Duration
Exposure Scenario
Source
Worker Activity
Concentration (mg/m3)
(min)
sample concentrating
2.7
233
sample sonification
3.9
218
sample sonification
4.5
218
washing separatory funnels
in sink near CLLE
110
10
column cleaning
10
200
Mccammon (1990)
sample concentrating
30
210
sample concentrating
4.2
234
sample concentrating
6.8
198
transferring 100 ml MeCl
into soil samples
9.8
115
collecting waste chemicals
& dumping into waste
1,000
24
chemical storage
Analytical
Laboratory
Miscellaneous lab
operations
3.1
244
Miscellaneous lab
operations
3.1
238
Sample extraction and
analysis (3809, OCD)
34.7
180
(3)GC Extraction
0.7
154
134: Extraction of PCB in
(DOEHRS-IH)
(2018)
water samples (Rm 221 -
Prep & Rm 227 - GC)
22.5
130
134: Extraction of total
64.7
130
volatiles (TCLP)(Rm 227)
Analysis, chemical
(Laboratory Operations)
1.7
59
Analysis, chemical
(Laboratory Operations)
2.4
48
LAB ACTIVITIES
3.3
31
LAB ACTIVITIES
6.4
30
LAB ACTIVITIES
16.6
30
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Methylene Chloride
Exposure
Occupational
Short-Term
Duration
Exposure Scenario
Source
Worker Activity
Concentration (mg/m3)
(min)
LAB ACTIVITIES
3.4
30
LAB ACTIVITIES
3.4
30
LAB ACTIVITIES
3.4
30
LAB ACTIVITIES
3.4
30
PRO-OOl-Ol
LABORATORY
5.4
30
CHEMICAL
ANALYSIS/SAMPLING
514A Using Solvents
1830.0
25
EXTRACTION OP
3.6
19
EXTRACTION OP
24.8
19
(3)GC Extraction
10.4
15
(3)GC Extraction
10.4
15
Sample extraction and
62.5
15
analysis (3809, OCD)
Miscellaneous lab
operations
6.7
15
EXTRACTION OP
4.6
15
EXTRACTION OP
4.6
15
134: Extraction of PCB in
water samples (Rm 221 -
5.3
15
Prep & Rm 227 - GC)
134: Extraction of total
5.0
15
volatiles (TCLP)(Rm 227)
PRO-OOl-Ol
LABORATORY
5.4
15
CHEMICAL
ANALYSIS/SAMPLING
IND-025-10 HM/HW
HANDLING CLEANUP,
6.1
15
CONTAINER
SAMPLE/OPEN
PRO-OOl-Ol
LABORATORY
10.9
15
CHEMICAL
ANALYSIS/SAMPLING
PRO-OOl-Ol
LABORATORY
13.2
15
CHEMICAL
ANALYSIS/SAMPLING
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle products containing methylene chloride, EPA expects ONU inhalation exposures to be
lower than worker inhalation exposures.
2.16.4 Water Release Assessment
EPA did not identify quantitative information about potential water releases during laboratory
use of methylene chloride. The majority of methylene chloride is expected to evaporate into the
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air or disposed as hazardous waste, but releases to water may occur if equipment is cleaned with
water.
2,16.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as potential direct
or indirect water releases. EPA has not identified additional uncertainties for this use beyond
those discussed in Section 4.2.
2.17Plastic Product Manufacturing
2.17.1 Process Description
According to OSHA, methylene chloride has had confirmed use in interfacial polymerization for
polycarbonate plastic manufacturing (OSHA. 1991). In this process, a jacketed vessel equipped
with an agitator is charged with the reactants and methylene chloride solvent. The polymerized
liquified reactor contents are then pumped to wash tanks to remove residual pyridine using
hydrochloric acid and water. Methylene chloride is removed by steam stripping. The
polycarbonate polymer is precipitated from the polymer methylene chloride stream and is
separated by filtration. At this stage, the various producers use a number of different processes,
including devolatilization extrusion, granulation, and spray drying (OSHA. 1991). EPA has not
found specific information on other types of plastic processing; therefore, it is unknown whether
methylene chloride is used in other types of plastic manufacturing.
2.17.2 Number of Sites and Potentially Exposed Workers
EPA determined five NAICS codes potentially applicable to the use of methylene chloride in
plastics manufacturing based on NAICS codes reported in TRI and OSHA. Using these NAICS
codes, EPA determined the number of workers associated with plastics manufacturing using US
Economic Census and Bureau of Labor Statistics (BLS) data. The number of establishments
within the plastics manufacturing sector that use methylene chloride-based products and the
number of employees within an establishment exposed to these methylene chloride-based
products are unknown. Therefore, EPA provides the total number of establishments as a
bounding estimate of the number of establishments that use methylene chloride and estimates the
number of employees that are potentially exposed to methylene chloride-based products at these
establishments. These are likely overestimates of the actual number of establishments and
employees potentially exposed to methylene chloride. EPA estimates 7,974 establishments,
212,422 workers, and 90,096 ON Us, as shown in Table 2-52 (U.S. BLS. 2016; U.S. Census
Bureau.: ).
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Table 2-52. Number of U.S. Establishments, Workers, and ONUs for Testing Laboratories
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers Site a
Number of
ONUs per Sitea
325211
Plastics Material and Resin
Manufacturing
1,135
27
12
325212
Synthetic Rubber Manufacturing
153
25
11
325220
Artificial and Synthetic Fibers and
Filaments Manufacturing
126
47
21
325991
Custom Compounding of Purchased
Resins
432
20
7
326199
All Other Plastics Product
Manufacturing
6,128
27 b
llb
Total establishments and number of potentially
exposed workers and ONUs = c
7,974
210,000
90,000
a - Rounded to the nearest worker.
b - No 2016 BLS data was available for this NAICS. Number of relevant workers per site and ONUs per site within
this NAICS were calculated using the ratios of relevant workers and ONUs to the number of total employees for
other listed NAICS.
c - Unrounded figures were used for total worker and ONU calculations.
2.1_7.3 Exposure Assessment
2.17.3.1 Worker Activities
Workers are potentially exposed when unloading methylene chloride from transport containers
into storage tanks and process vessels. Workers may be exposed via inhalation of vapor or via
dermal contact with liquids while connecting and disconnecting hoses and transfer lines, or
during solvent recovery.
ONUs are employees who work at the facilities that process and use methylene chloride, but who
do not directly handle the material. ONUs may also be exposed to methylene chloride, but are
expected to have lower inhalation exposures and are not expected to have dermal exposures.
ONUs for this condition of use may include supervisors, managers, engineers, and other
personnel in nearby production areas. One sample was for an OSHA inspector and may or may
not be reflective of industry ONUs, but was included to increase the sample size.
2.17.3.2 Inhalation Exposure
TableApx A-24 and TableApx A-25 in 4.2.5Appendix A summarize the inhalation monitoring
data for methylene chloride in plastic product manufacturing that EPA compiled from published
literature sources, including 8-hour TWA, short-term, and partial shift sampling results. This
appendix also includes EPA's rationale for inclusion or exclusion of these data in the risk
evaluation.
8-hr TWA data are primarily from monitoring data from HSIA sampling from 2005 through
2017, for production technicians during plastic product manufacturing. Exposure concentrations
ranged from 3.9 to 134.1 mg/m3 (20 samples) (Halogenated Solvents Industry Alliance. 2018).
Additional data were found for various other sources that ranged from 9 mg/m3 to 2,685.1
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mg/m3 (for hop area operator KHalo^enated Solvents Industry Alliance. 2018; Fairfax and Porter.
2006; (IPCS). 1996; GE. 1989V
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentrations for workers and ONUs is approximately six times lower the OSHA PEL
value of 87 mg/m3 (25 ppm), while the high-end estimate for workers is three times higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-53 for
workers and ONUs during plastic product manufacturing.
Table 2-53. Worker and ONU Exposure to Methylene Chloride During Plastic Product
Manufacturing
Number of
Samples
Central Tendency
(mg/m3)
High-End
(mg/m3)
Workers
8-hr TWA Exposure Concentration
30
14
260
Average Daily Concentration (ADC)
3.2
60
Lifetime Average Daily Concentration
(LADC)
5.5
130
ONUs
8-hr TWA Exposure Concentration
1
9.0
9.0
Average Daily Concentration (ADC)
2.1
2.1
Lifetime Average Daily Concentration
(LADC)
3.6
4.6
Sources: OSHA (2019); Halogenated Solvents Industry Alliance (2018); Fairfax and Porter (2006); (IPCS) (1996);
GE (1989).
Table 2-54 summarizes available short-term exposure data for workers and ONUs from the same
OSHA inspections identified above for the 8-hr TWA data, as well as short-term data provided
by HSIA (2018).
Table 2-54. Worker Short-Term Exposure Data for Methylene Chloride During Plastic
Product Manufacturing
Methylene
Chloride Short-
Occupational
Term
Exposure
Concentration
Exposure
Scenario
Source
Worker Activity
(mg/m3)
Duration (min)
Plastic Product
Manufacturing
OSHA
(2019)
ND
15
Plastics Manufacturer
28
15
21
20
Plastics Material
and Resin
Manufacturing
Halosenated
Solvents
Industry
Operator
100
13
Operator
74
18
Operator
94
14
Operator
66
20
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Methylene
Chloride Short-
Occupational
Term
Exposure
Concentration
Exposure
Scenario
Source
Worker Activity
(mg/m3)
Duration (min)
Alliance
Operator
66
20
(2018)
Operator
60
22
Operator
130
10
Operator
66
20
Operator
100
13
Operator
170
8
Operator
110
12
Operator
83
15
Product technician
120
11
Product technician
69
19
Product technician
83
16
Product technician
63
21
Product technician
88
15
Product technician
83
16
Product technician
100
13
Product technician
110
12
Product technician
51
26
ND - not detected
2.17.4 Water Release Assessment
EPA identified facilities classified under four NAICS and SIC codes, listed in Table 2-55, that
reported water releases in the 2016 TRI and 2016 DMR and may be related to plastic product
manufacturing. Table 2-56 lists all facilities classified under these NAICS and SIC codes that
reported direct or indirect water releases in the 2016 TRI or 2016 DMR.
Table 2-55. Potential Industries Conducting Plastics Product Manufacturing in 2016 TRI
or DMR
NAICS Code
NAICS Description
325211
Plastics Material and Resin Manufacturing
2821
PLSTC MAT./SYN RESINS/NV ELAST
2822
SYN RUBBER (VULCAN ELASTOMERS)
3081
UNSUPPORTED PLSTICS FILM/SHEET
Table 2-56. Reported 2016 TRI and DMR Releases for Potential Plastics Product
Manufacturing Facilities
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources
& Notes
SABIC
INNOVATIVE
PLASTICS US
LLC
BURKVILLE
AL
8
250
0.03
Surface
Water
U.S. EPA
(2017c)
SABIC
INNOVATIVE
MOUNT
VERNON
IN
28
250
0.1
Surface
Water
U.S. EPA
(2016a)
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PLASTICS MT.
VERNON, LLC
SABIC
INNOVATIVE
PLASTICS US
LLC
SELKIRK
NY
9
250
0.03
Surface
Water
U.S. EPA
(2016a)
EQUISTAR
CHEMICALS
LP
LA PORTE
TX
9
250
0.03
Surface
Water
U.S. EPA
(2016a)
CHEMOURS
COMPANY FC
LLC
WASHINGTON
WV
7
250
0.03
Surface
Water
U.S. EPA
SHINTECH
ADDIS PLANT
A
ADDIS
LA
3
250
0.01
Surface
Water
U.S. EPA
(20.1.6a)
STYROLUTION
AMERICA LLC
CHANNAHON
IL
0.2
250
0.001
Surface
Water
U.S. EPA
DOW
CHEMICAL CO
DALTON
PLANT
DALTON
GA
0.3
250
0.001
Surface
Water
U.S. EPA
PREGIS
INNOVATIVE
PACKAGING
INC
WURTLAND
KY
0.02
250
0.0001
Surface
Water
U.S. EPA
2.17.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or
indirect water releases. EPA has not identified additional uncertainties for this use beyond those
discussed in Section 4.2.
2.18 Pharmaceutical Production
2.18.1 Process Description
OSHA (1991) indicated that the pharmaceutical industry utilizes methylene chloride as an
extraction solvent in the purification of pharmaceutical products and in pill coatings. However,
because of health concerns, methylene chloride was expected to be phased out of pill coatings.
Methylene chloride is released during storage, reaction, separation, purification, and drying
processes. Storage emissions result from displacement of air containing the solvent during tank
charging. Reactor emissions result from displacement of air containing methylene chloride
during reactor charging, solvent evaporation during the reaction cycle, venting of uncondensed
methylene chloride from the overhead condenser during refluxing, purging of vaporized
methylene chloride following a solvent wash, and opening of reactors during the reaction cycle
to take quality control samples. Distillation condensers can emit methylene chloride as
uncondensed solvent. During crystallization, emissions can result from the venting of vaporized
solvent if the crystallization is being done by solvent evaporation. If crystallization is
accomplished by cooling of the solution, there is little emission. Dryers are potential large
emission sources, emission rates vary during drying cycles, and with the type of dryer being
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used. Emissions from air dryers are normally greater than those from vacuum dryers mainly
because air dryers emissions are more dilute and difficult to control (OSHA. 1991).
2.18.2 Number of Sites and Potentially Exposed Workers
In 1991, OSHA estimated that 28 million pounds of methylene chloride was used in 76
pharmaceutical production facilities, exposing an estimated 1,007 workers. Most of the
methylene chloride was used in pill coatings (OSHA. 1991). Because of the uncertainty in pill
coating use, EPA determined the number of workers associated with pharmaceutical production
using US Economic Census and Bureau of Labor Statistics (BLS) data. The number of
establishments within the pharmaceutical industry that use methylene chloride-based products
and the number of employees within an establishment exposed to these methylene chloride-based
products are unknown. Therefore, EPA provides the total number of establishments as a
bounding estimate of the number of establishments that use methylene chloride and estimates the
number of employees that are potentially exposed to methylene chloride-based products at these
establishments. These are likely overestimates of the actual number of establishments and
employees potentially exposed to methylene chloride. EPA estimates 18,687 establishments,
39,836 workers, and 19,010 ONUs, as shown in Table 2-61 (U.S. BLS. 2016; U.S. Census
Bureau. 2015).
Table 2-57. Number of U.S. Establishments, Workers, and ONUs for Testing Laboratories
NAIC
S
Codes
NAICS Description
Number of
Establishments
Number of
Workers Site a
Number of
ONUs per Sitea
32541
1
Medicinal and Botanical
Manufacturing
461
44b
27b
32541
2
Pharmaceutical Preparation
Manufacturing
1,290
44
27
Total establishments and number of
potentially exposed workers and ONUs = c
1,751
77,000
47,000
a - Rounded to the nearest whole number.
b - No 2016 BLS data was available for this NAICS. Number of relevant workers per site and ONUs per site within
this NAICS were calculated using the ratios of relevant workers and ONUs to the number of total employees for
NAICS code 325412 - Pharmaceutical Preparation Manufacturing,
c - Unrounded figures were used for total worker and ONU calculations.
^.18.3 Exposure Assessment
2.18.3.1 Worker Activities
Based on the process description, the main potential for worker exposures appear to be during
storage tank and reactor charging, when methylene chloride is added into the process.
2.18.3.2 Inhalation Exposure
Table Apx A-28 in 4.2.5Appendix A summarizes the 8-hr TWA inhalation monitoring data for
methylene chloride used in lithographic printing cleaning that EPA compiled from published
literature sources. This appendix also includes EPA's rationale for inclusion or exclusion of these
data in the risk evaluation.
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TNO (CIVO) (1999) reported that for pharmaceutical process operators, 8-hr exposure
concentrations can be between 3.5 to 10 mg/m3. IPCS (1996) also indicated that sealed
processes, high recovery rates, and careful handling of discharges can bring exposure rates to
around 106 mg/m3. Additional data were available from the 1985 EPA assessment, which
covered production workers at pharmaceutical manufacturing facilities and reported exposures
between ND (during film coating) and 4,628 mg/m3 (during production)(12 data points).
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentration for this scenario is approximately three times higher than the OSHA PEL
value of 87 mg/m3 (25 ppm), while the high-end estimate is approximately 41 times higher than
the PEL.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-58.
Table 2-58. Worker Exposure to Met
lylene Chloride During Pharmaceutical Production
Number
of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
15
230
3,600
Average Daily Concentration (ADC)
52
820
Lifetime Average Daily Concentration
(LADC)
91
1,800
Sources: TNO (CIVO) (1999): US EPA (1985).
^.18.4 Water Release Assessment
EPA identified facilities classified under three NAICS and SIC codes, listed in Table 2-59, that
reported water releases in the 2016 TRI or 2016 DMR and may be related to use in
pharmaceutical manufacturing. Table 2-60 lists all facilities classified under these NAICS and
SIC codes that reported direct or indirect water releases. Other facilities in this industry may not
dispose to water, or may not use methylene chloride in quantities that meet the TRI reporting
threshold.
Table 2-59. Potential Industries Conducting Pharmaceutical Production in 2016 TRI or
DMR
NAICS Code
NAICS Description
325411
Medicinal and Botanical Manufacturing
325412
Pharmaceutical Preparation Manufacturing
2833
MEDICINAL CHEM/BOTANICAL PRODU
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Table 2-60. Reported 2016 TRI and DMR Releases for Pharmaceutical Manufacturing
Facilities
Site Identity
City
State
Annual
Release
(kg/site-
yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources
& Notes
ABB VIE-NORTH CH
ICAGO FACILITY
NORTH
CHICAGO
IL
2
300
0.01
POTW
U.S. EPA
(2017c)
EUTICALS INC
SPRINGFIELD
MO
0.5
300
0.002
POTW
U.S. EPA
(2017c)
MALLINCKRODT
LLC
SAINT LOUIS
MO
7
300
0.02
POTW
U.S. EPA
(2017c)
NORAMCO INC
WILMINGTON
DE
2
300
0.01
POTW
U.S. EPA
(2017c)
AMRI RENSSELAER
INC
RENSSELAER
NY
340
300
1
POTW
U.S. EPA
(2017c)
E R SQUIBB & SONS
LLC
NORTH
BRUNSWICK
NJ
113
300
0.4
POTW
U.S. EPA
(2017c)
EVONIK CORP
TIPPECANOE
LABORATORIES
LAFAYETTE
IN
2
300
0.01
Surface
Water
U.S. EPA
(2017c)
PACIRA
PHARMACEUTICALS
INC
SAN DIEGO
CA
40
300
0.1
POTW
U.S. EPA
(2017c)
PCI SYNTHESIS
NEWBURYPORT
MA
0
300
0.002
POTW
U.S. EPA
(2017c)
PFIZER
PHARMACEUTICALS
LLC
BARCELONETA
PR
20
300
0.1
POTW
U.S. EPA
(2017c)
PHARMACIA &
UPJOHN CO LLC A
SUBSIDIARY OF
PFIZER INC
PORTAGE
MI
2,588
300
9
99.9%
POTW
0.1%
Surface
Water
U.S. EPA
(2017c)
SI GROUP INC
ORANGEBURG
SC
42
300
0.1
Surface
Water
U.S. EPA
(2017c)
TEVA
PHARMACEUTICALS
USA
MEXICO
MO
10
300
0.03
POTW
U.S. EPA
(2017c)
EVONIK DEGUSSA
CORP TIPPECANOE
LABORATORIES
LAFAYETTE
IN
3
300
0.01
Surface
Water
U.S. EPA
(2016a)
2.18.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or
indirect water releases. EPA has not identified additional uncertainties for this use beyond those
discussed in Section 4.2.
2.19Lithographic Printing Plate Cleaning
2.19.1 Process Description
Solvents are used in lithographic printing to clean the blankets and rollers. Press operators
commonly apply the solvent to a wipe cloth and wipe across the blanket to remove the ink, while
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companies have automated blanket wash systems where the solvent is applied to the blankets
with a spray bar. It is generally necessary with these automated systems to periodically also clean
the blankets by hand since they are not cleaned adequately with the automated systems. Press
operators commonly clean the ink roller train by standing above the rollers and dispensing the
cleaner from a squeeze bottle across the length of the top roller. Pressure is applied to the rollers
with a squeegee and an ink tray is placed at the bottom of the roller train to catch the solvent/ink
combination after it passes through the train ((IR.TA). 2006). EPA has identified several
lithographic printing cleaners (9.94 to 88.5 weight percent methylene chloride) (U.S. EPA.
2017b).
2.19.2 Number of Sites and Potentially Exposed Workers
EPA determined the number of workers associated with printing plate cleaning using US
Economic Census and Bureau of Labor Statistics (BLS) data. The number of establishments
within the lithographic printing sector that use methylene chloride-based products and the
number of employees within an establishment exposed to these methylene chloride-based
products are unknown. Therefore, EPA provides the total number of establishments as a
bounding estimate of the number of establishments that use methylene chloride and estimates the
number of employees that are potentially exposed to methylene chloride-based products at these
establishments. These are likely overestimates of the actual number of establishments and
employees potentially exposed to methylene chloride. EPA estimates 18,687 establishments,
39,836 workers, and 19,010 ONUs, as shown in Table 2-61 (U.S. BLS. 2016; U.S. Census
Bureau. 2015).
Table 2-61. Number of U.S. Esta
)lishments, Workers, and ONUs for Printing
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers Site a
Number of
ONUs per Sitea
323111
Commercial Printing (except Screen
and Books)
18,687
2
1
Total establishments and number of potentially
exposed workers and ONUs = b
40,000
19,000
a - Rounded to the nearest worker.
b - Unrounded figures were used for total worker and ONU calculations.
2.19.3 Exposure Assessment
2.19.3.1 Worker Activities
As discussed in the process description, workers may be exposed to methylene chloride when
manually wipe cleaning print blankets.
2.19.3.2 Inhalation Exposure
TableApx A-26 and TableApx A-27 in 4.2.5Appendix A summarize the inhalation monitoring
data for methylene chloride used in lithographic printing cleaning that EPA compiled from
published literature sources, including 8-hour TWA, short-term, and partial shift sampling
results. This appendix also includes EPA's rationale for inclusion or exclusion of these data in
the risk evaluation.
8-hr TWA data are primarily from the 1985 EPA assessment covering various printers and
activities, which ranged from ND (during printing) to 547.9 (during screen making for
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commercial letterpress) (44 data points) (US EPA. 1985). Additional data were also obtained
from a 1998 occupational exposure study and a 1980 NIOSH inspection of a printing facility
(Ukai et al.. 1998); (Ahrenholz. 1980). Exposure data were for workers involved in the printing
plate/roll cleaning. The 1998 occupational exposure study only presented the min, mean, and
max values for 61 samples, while the 1980 NIOSH inspection included two full-shift readings
(ND to 17.0 mg/m3; ND was assessed as zero).
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentrations for this scenario is one order of magnitude lower than the OSHA PEL
value of 87 mg/m3 (25 ppm), while the high-end estimate is approximately three times higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-62 for
workers during printing.
Table 2-62. Worker Exposure to Methylene Chloride During Printing Plate Cleaning
Number
of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
3.7
270
Average Daily Concentration (ADC)
>105a
0.84
62
Lifetime Average Daily Concentration
(LADC)
1.5
140
Sources: Ukai etal. (1998); US EPA (1985); Ahrenholz (1980)
a - One study indicated that statistics were based on 61 samples, but only provided the minimum, maximum, and
mean values. Another study provided two exposure values, one of which was ND. ND was assessed as zero
Table 2-63 summarizes the available 4-hr TWA exposure data for workers from the same source
identified above for the 8-hr TWA data. Data were taken in two 4-hr shifts.
Table 2-63. Worker Short-Term Exposure Data for Methylene Chloride During Printing
Plate Cleaning
Occupational
Exposure
Scenario
Source
Worker Activity
Methylene Chloride Short-
Term Concentration
(mg/m3)
Exposure
Duration (min)
Lithographic
Printing Plate
Cleaning
Ukai et al.
(1998)
Cleaning of printing
rolls / solvent in
production
3.5
240
940
3.6
480
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle methylene chloride, EPA expects ONU inhalation exposures to be lower than worker
inhalation exposures.
2.19.4 Water Release Assessment
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EPA identified one facility in the 2016 DMR, potentially related to lithographic printing (SIC
code 2752 - Commercial Printing, Lithographic) that reported water releases. Release for this
facility is summarized in Table 2-64. EPA did not identify any potential lithographic printing
facilities in the 2016 TRI that reported water releases. Other facilities in this industry may not
dispose to water or may not use methylene chloride in quantities that meet the TRI reporting
threshold.
Table 2-64. Reported 2016 TRI and DMR Releases for Potential Lithographic Printing
Faci ities
Site Identity
City
State
Annual
Release
(kg/site-yr)
Annual
Release Days
(days/yr)
Daily
Release
(kg/site-day)
Release
Media
Sources
& Notes
FORMER REXON
FACILITY AKA
ENJEMS
MILLWORKS
WAYNE
TWP
NJ
0.001
250
0.000004
Surface
Water
U.S.
EPA
(2016a)
2.19.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or
indirect water releases. EPA has not identified additional uncertainties for this use beyond those
discussed in Section 4.2.
2.20Miscellaneous Non-Aerosol Industrial and Commercial Uses
^.20.1 Process Description
Based on products identified in EPA's Preliminary Information on Manufacturing, Processing,
Distribution, Use, and Disposal: Methylene Chloride, a variety of other non-aerosol uses may
exist for methylene chloride, including use in crafting glues and cements, novelty items, and
miscellaneous cleaners (U.S. EPA. 2017b). It is unclear at this time the total volume of
methylene chloride used in any of these applications.
2.20.2 Number of Sites and Potentially Exposed Workers
Because of the breadth of industrial and commercial uses, the number of potential workers is
unknown. In the 1980s and 1990s, there were an estimated 1.4 million workers potentially
exposed to methylene chloride in the U.S., which is assumed as an upper bound (IARC, 2016,
3827786).
^.20.3 Exposure Assessment
2.20.3.1 Worker Activities
Workers using non-aerosol products containing methylene chloride in a commercial setting
would likely perform various manual activities, such as applying the product on to substrates
(wipe, brush, roller), or engage in transferring liquids between containers.
2.20.3.2 Inhalation Exposure
EPA compiled various miscellaneous 8-hr TWA monitoring data for non-aerosol commercial
settings as shown in Table_Apx A-29 of 4.2.5Appendix A. 8-hr TWA data are from various
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OSHA inspection at wholesalers and retail stores, and include generic worker activities, such as
plant workers, service workers, laborers, etc. Exposure concentrations for various workers
ranged from ND to 1,294.8 mg/m3 (US EPA. 1985).
From available personal monitoring data, EPA calculated the 50th and 95th percentile 8-hr TWA
concentrations to represent a central tendency and worst-case estimate of potential occupational
inhalation exposures, respectively, for this life cycle stage. The central tendency 8-hr TWA
exposure concentrations for workers is approximately three times higher than the OSHA PEL
value of 87 mg/m3 (25 ppm), while the high-end estimate for workers is more than nine times
higher.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-65 for
workers during industrial and commercial non-aerosol use.
Table 2-65. Worker Exposure to Methylene Chloride During Industrial and Commercial
Non-Aerosol Use
Number of
Samples
Central Tendency
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
108
57
930
Average Daily Concentration (ADC)
13
210
Lifetime Average Daily Concentration
(LADC)
23
480
Sources: US EPA (1985).
EPA has not identified data on potential ONU inhalation exposures. Since ONUs do not directly
handle formulations containing methylene chloride, EPA expects ONU inhalation exposures to
be lower than worker inhalation exposures.
2.20.4 Water Release Assessment
EPA did not identify quantitative information about potential water releases during non-aerosol
use of methylene chloride. The majority of methylene chloride is expected to evaporate into the
air, but releases to water may occur if equipment is cleaned with water.
2.20.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as potential direct
or indirect water releases. EPA has not identified additional uncertainties for this use beyond
those discussed in Section 4.2.
2.21Waste Handling, Disposal, Treatment, and Recycling
2.21.1 Process Description
Each of the conditions of use of methylene chloride may generate waste streams of the chemical
that are collected and transported to third-party sites for disposal, treatment, or recycling.
Industrial sites that treat or dispose onsite wastes that they themselves generate are assessed in
each condition of use assessment. Similarly, point source discharges of methylene chloride to
surface water are assessed in each condition of use assessment in Sections 2.1 through 2.20
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(point source discharges are exempt as solid wastes under RCRA). Wastes of methylene chloride
that are generated during a condition of use and sent to a third-party site for treatment, disposal,
or recycling may include the following:
• Wastewater: Methylene chloride may be contained in wastewater discharged to POTW or
other, non-public treatment works for treatment. Industrial wastewater containing
methylene chloride discharged to a POTW may be subject to EPA or authorized NPDES
state pretreatment programs. The assessment of wastewater discharges to POTWs and
non-public treatment works of methylene chloride is included in each of the condition of
use assessments in Sections 2.1 through 2.20.
• Solid Wastes: Solid wastes are defined under RCRA as any material that is discarded by
being: abandoned; inherently waste-like; a discarded military munition; or recycled in
certain ways (certain instances of the generation and legitimate reclamation of secondary
materials are exempted as solid wastes under RCRA). Solid wastes may subsequently
meet RCRA's definition of hazardous waste by either being listed as a waste at 40 CFR
§§ 261.30 to 261.35 or by meeting waste-like characteristics as defined at 40 CFR §§
261.20 to 261.24. Solid wastes that are hazardous wastes are regulated under the more
stringent requirements of Subtitle C of RCRA, whereas non-hazardous solid wastes are
regulated under the less stringent requirements of Subtitle D of RCRA.
Methylene chloride is a U-listed hazardous waste under code U080 under RCRA;
therefore, discarded, unused pure and commercial grades of methylene chloride are
regulated as a hazardous waste under RCRA (40 CFR § 261.33(f)). Additionally,
methylene chloride is included in multiple waste codes under the F-list of non-specific
source wastes (40 CFR § 261.31(a)).
• Wastes Exempted as Solid Wastes under RCRA: Certain conditions of use of methylene
chloride may generate wastes of methylene chloride that are exempted as solid wastes
under 40 CFR § 261.4(a). For example, the generation and legitimate reclamation of
hazardous secondary materials of methylene chloride may be exempt as a solid waste.
2016 TRI data lists off-site transfers of methylene chloride to land disposal, wastewater
treatment, incineration, and recycling facilities. About 93% of off-site transfers were incinerated,
6% sent to wastewater treatment, and less than 1% is recycled off-site or sent for land disposal
0 ? * \ _ ;0 IV); see Figure 2-13.
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Recycling
Hazardous Waste Hazardous Waste |
Generation Transportation
Treatment
I- | » ^ ^ Disp°sai
Figure 2-13. Typical Waste Disposal Process ( J.S. EPA, 2017a)
Municipal Waste Incineration
Municipal waste combustors (MWCs) that recover energy are generally located at large facilities
comprising an enclosed tipping floor and a deep waste storage pit. Typical large MWCs may
range in capacity from 250 to over 1,000 tons per day. At facilities of this scale, waste materials
are not generally handled directly by workers. Trucks may dump the waste directly into the pit,
or waste may be tipped to the floor and later pushed into the pit by a worker operating a front-
end loader. A large grapple from an overhead crane is used to grab waste from the pit and drop it
into a hopper, where hydraulic rams feed the material continuously into the combustion unit at a
controlled rate. The crane operator also uses the grapple to mix the waste within the pit, in order
to provide a fuel consistent in composition and heating value, and to pick out hazardous or
problematic waste.
Facilities burning refuse-derived fuel (RDF) conduct on-site sorting, shredding, and inspection of
the waste prior to incineration to recover recyclables and remove hazardous waste or other
unwanted materials. Sorting is usually an automated process that uses mechanical separation
methods, such as trommel screens, disk screens, and magnetic separators. Once processed, the
waste material may be transferred to a storage pit, or it may be conveyed directly to the hopper
for combustion.
Tipping floor operations may generate dust. Air from the enclosed tipping floor, however, is
continuously drawn into the combustion unit via one or more forced air fans to serve as the
primary combustion air and minimize odors. Dust and lint present in the air is typically captured
in filters or other cleaning devices in order to prevent the clogging of steam coils, which are used
to heat the combustion air and help dry higher-moisture inputs ( Citto. 1992).
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Hazardous Waste Incineration
Commercial scale hazardous waste incinerators are generally two-chamber units, a rotary kiln
followed by an afterburner, that accept both solid and liquid waste. Liquid wastes are pumped
through pipes and are fed to the unit through nozzles that atomize the liquid for optimal
combustion. Solids may be fed to the kiln as loose solids gravity fed to a hopper, or in drums or
containers using a conveyor (Center. 2018); (Heritage. 2018).
Incoming hazardous waste is usually received by truck or rail, and an inspection is required for
all waste received. Receiving areas for liquid waste generally consist of a docking area,
pumphouse, and some kind of storage facilities. For solids, conveyor devices are typically used
to transport incoming waste (Kitto. 1992); (Center. 2018)
Smaller scale units that burn municipal solid waste or hazardous waste (such as infectious and
hazardous waste incinerators at hospitals) may require more direct handling of the materials by
facility personnel. Units that are batch-loaded require the waste to be placed on the grate prior to
operation and may involve manually dumping waste from a container or shoveling waste from a
container onto the grate.
Emissions Stack
Heat Recovery
Waste Storage j—~
Teed Preparation
Combustion
Gas Temperature
Reduction
Air Pollution Control -
Ash Handling
Scrubber Water or
Ash Handling
Disposal
V
Disposal
Figure 2-14. Typical Industrial Incineration Process
Municipal Waste Landfill
Municipal solid waste landfills are discrete areas of land or excavated sites that receive
household wastes and other types of non-hazardous wastes (e.g. industrial and commercial solid
wastes). Standards and requirements for municipal waste landfills include location restrictions,
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composite liner requirements, leachate collection and removal system, operating practices,
groundwater monitoring requirements, closure-and post-closure care requirements, corrective
action provisions, and financial assurance. Non-hazardous solid wastes are regulated under
RCRA Subtitle D, but states may impose more stringent requirements.
Municipal solid wastes may be first unloaded at waste transfer stations for temporary storage,
prior to being transported to the landfill or other treatment or disposal facilities.
Hazardous Waste Landfill
Hazardous waste landfills are excavated or engineered sites specifically designed for the final
disposal of non-liquid hazardous wastes. Design standards for these landfills require double liner,
double leachate collection and removal systems, leak detection system, run on, runoff and wind
dispersal controls, and construction quality assurance program ( [18c). There are also
requirements for closure and post-closure, such as the addition of a final cover over the landfill
and continued monitoring and maintenance. These standards and requirements prevent potential
contamination of groundwater and nearby surface water resources. Hazardous waste landfills are
regulated under Part 264/265, Subpart N.
2.21.2 Number of Sites and Potentially Exposed Workers
The total number of sites that treat and disposal wastes containing methylene chloride is not
known. According to an OSHA source, there were an estimated 40 recovery facilities employing
approximately 161 workers in 1991 (OS! ). For reporting year 2016, TRI included 26
facilities that reported releases of methylene chloride under NAICS code 562 (Waste
Management and Remediation Services) ( 17c). Table 2-66 presents the estimated
number of workers and ONUs at these facilities based on EPA's analysis of typical employment
on those industry sectors (U.S. BLS. 2016; U.S. Census Bureau. 2015). It is possible that
additional hazardous waste treatment facilities treat and dispose methylene chloride, but do not
meet the TRI reporting threshold for reporting year 2016. In addition, it is possible that some
consumer products containing methylene chloride may be improperly disposed as municipal
solid wastes, and that some amount of methylene chloride is present in non-hazardous waste
streams. Therefore, there may be up to 12,260 workers and 7,633 ONUs potentially exposed to
methylene chloride.
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Table 2-66. Number of U.S. Establishments, Workers, and ONUs for Waste Handling
NAICS
Codes
NAICS Description
Number of
Establishments
Number of
Workers per Site
a
Number of
ONUs per Site
a
562211
Hazardous Waste Treatment and
Disposal
892
9
5
562213
Solid Waste Combustors and
Incinerators
102
13
8
562920
Materials Recovery Facilities
1,455
2
2
Total establishments and number of potentially
exposed workers and ONUs = bs
2,449
12,000
7,600
a - Rounded to the nearest worker.
b - Unrounded figures were used for total worker and ONU calculations.
^.21.3 Exposure Assessment
2.21.3.1 Worker Activities
At waste disposal sites, workers are potentially exposed via dermal contact with waste containing
methylene chloride or via inhalation of methylene chloride vapor. Depending on the
concentration of methylene chloride in the waste stream, the route and level of exposure may be
similar to that associated with container unloading activities. See Section 2.4.3.1 for the
assessment of worker exposure from chemical unloading activities during import/repackaging.
Municipal Waste Incineration
At municipal waste incineration facilities, there may be one or more technicians present on the
tipping floor to oversee operations, direct trucks, inspect incoming waste, or perform other tasks
as warranted by individual facility practices. These workers may wear protective gear such as
gloves, safety glasses, or dust masks. Specific worker protocols are largely up to individual
companies, although state or local regulations may require certain worker safety standards be
met. Federal operator training requirements pertain more to the operation of the regulated
combustion unit rather than operator health and safety.
Workers are potentially exposed via inhalation to vapors while working on the tipping floor.
Potentially-exposed workers include workers stationed on the tipping floor, including front-end
loader and crane operators, as well as truck drivers. The potential for dermal exposures is
minimized by the use of trucks and cranes to handle the wastes.
Hazardous Waste Incineration
More information is needed to determine the potential for worker exposures during hazardous
waste incineration and any requirements for personal protective equipment. There is likely a
greater potential for worker exposures for smaller scale incinerators that involve more direct
handling of the wastes.
Municipal and Hazardous Waste Landfill
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At landfills, typical worker activities may include operating refuse vehicles to weigh and unload
the waste materials, operating bulldozers to spread and compact wastes, and monitoring,
inspecting, and surveying and landfill site (CalRecvcle. 2018).
2.21.3.2 Inhalation Exposures
EPA assumes that any exposures related to on-site waste treatment and disposal are addressed in
the assessments for those uses in this report; therefore, this section assesses exposures to workers
for wastes transferred from the use site to an off-site waste treatment and disposal facility.
Bulk Shipments of Liquid Hazardous Waste
EPA assumes methylene chloride wastes that are generated, transported, and treated or disposed
as hazardous waste are done so as bulk liquid shipments. For example, a facility that uses
methylene chloride as a processing aid may generate and store the waste processing aid as
relatively pure methylene chloride and have it shipped to hazardous waste TSDFs for ultimate
treatment, disposal, or recycling.
TableApx A-30 and TableApx A-31 in 4.2.5Appendix A summarize the 8-hr TWA inhalation
monitoring data for waste handling and disposal that EPA compiled from published literature
sources. This appendix also includes EPA's rationale for inclusion or exclusion of these data in
the risk evaluation.
EPA's 1985 assessment included three full-shift data points for solvent reclaimers at solvent
recovery sites, ranging from 10.5 to 19.2 mg/m3 (US EPA. 1985). The U.S. DOD also provided
four data points during waste disposal and sludge operations ranging from 0.4 to 2.3 mg/m3
(YDOEHRS-IH). 2018). EPA assessed the 50th percentile value of 18.5 mg/m3 as the central
tendency, and the 95% percentile value of 19.0 mg/m3 as the high-end estimate of potential
occupational inhalation exposures for this life cycle stage. The central tendency exposure
concentration for this scenario is an order of magnitude lower than the OSHA PEL value of 87
mg/m3 (25 ppm) and high-end 8-hr TWA exposure concentration is approximately 4.5 times
lower.
Using these 8-hr TWA exposure concentrations, EPA calculated the ADC and LADC as
described in 4.2.5Appendix B. The results of these calculations are shown in Table 2-21.
Table 2-67. Exposure to Methylene Chloride During Waste Handling and Disposal
Number of
Central Tendency
Samples
(mg/m3)
High-End (mg/m3)
8-hr TWA Exposure Concentration
2.3
19
Average Daily Concentration (ADC)
7
0.5
4.4
Lifetime Average Daily Concentration
(LADC)
0.9
9.7
Source: (DOEHRS-IH) (2018): US EPA (1985)
Table 2-68 summarizes the available short-term exposure data for workers from the DOD data.
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Table 2-68. Worker Short-Term Exposure Data for Methylene Chloride During Waste
Handling and
)isposal
Occupational
Exposure
Scenario
Source
Worker Activity
Methylene Chloride Short-
Term Concentration
(mg/m3)
Exposure
Duration (min)
Waste Handling
(DOEHRS-
IH) (2018)
Transfer of solvent
during waste disposal
2.9
30
2.9
30
1.8
144
5.8
158
2.7
159
2.8
163
0.8
173
3.4
156
EPA has not identified exposure data on potential ONU inhalation exposures. Since ONUs do
not directly handle formulations containing methylene chloride, EPA expects ONU inhalation
exposures to be lower than worker inhalation exposures.
Municipal Solid Wastes
Certain commercial and consumer conditions of use of methylene chloride may generate solid
wastes that are sent to municipal waste combustors or landfills. For example, spent aerosol
degreasing cans containing residual methylene chloride used by mechanics or consumers may be
disposed as household hazardous waste, which is exempted as a hazardous waste under RCRA.
While some municipalities may have collections of household hazardous wastes to prevent the
comingling of household hazardous wastes with municipal waste streams, some users may
inappropriately dispose of household hazardous wastes in the municipal waste stream.
EPA is not able to quantitatively assess worker or ONU exposures to methylene chloride within
municipal solid waste streams. The quantities of methylene chloride are expected to be diluted
among the comingled municipal solid waste stream, and uses of methylene chloride, such as
aerosol degreasing, result in waste methylene chloride being contained in a sealed can.
Exposures to methylene chloride in spent pressurized cans are only expected if the can is
punctured during waste handling.
2.21.4 Water Release Assessment
EPA identified facilities classified under five NAICS and SIC codes, listed in Table 2-69, that
reported water releases in the 2016 TRI and 2016 DMR and may be related to recycling/disposal.
Table 2-70 lists all facilities classified under these NAICS and SIC codes that reported direct or
indirect water releases in the 2016 TRI or 2016 DMR. To estimate the daily release, EPA/OPPT
used a default assumption of 250 days/yr of operation and averaged the annual release over the
operating days.
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Table 2-69. Potential Industries Conducting Waste Handling, Disposal, Treatment, and
Recycling in 2016 TRI or DMR
NAICS/SIC
Code
NAICS/SIC Description
331492
Secondary Smelting, Refining, and Alloying of Nonferrous Metal (except Copper and
Aluminum)
562211
Hazardous Waste Treatment and Disposal
4953
REFUSE SYSTEMS
7699
REPAIR SHOPS & RELATED SERVICE
9511
AIR & WATER RES & SOL WSTE MGT
Table 2-70. Reported 2016 TRI and DMR Releases for Potential Recycling/Disposal
Facilities
Site Identity
City
State
Annual
Release
(kg/site-
yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources
& Notes
JOHNSON
MATTHEY
WEST
DEPTFORD
NJ
620
250
2
Non-
POTW
WWT
U.S. EPA
(2017c)
CLEAN
HARBORS
DEER PARK
LLC
LA PORTE
TX
522
250
2
Non-
POTW
WWT
U.S. EPA
(2017c)
CLEAN
HARBORS EL
DORADO LLC
EL DORADO
AR
113
250
0.5
Non-
POTW
WWT
U.S. EPA
(2017c)
TRADEBE
TREATMENT &
RECYCLING
LLC
EAST CHICAGO
IN
19
250
0.1
Non-
POTW
WWT
U.S. EPA
(2017c)
VEOLIA ES
TECHNICAL
SOLUTIONS
LLC
WEST
CARROLLTON
OH
2
250
0.01
POTW
U.S. EPA
(2017c)
VEOLIA ES
TECHNICAL
SOLUTIONS
LLC
AZUSA
CA
0
250
0.002
POTW
U.S. EPA
(2017c)
VEOLIA ES
TECHNICAL
SOLUTIONS
LLC
MIDDLESEX
NJ
115,059
250
460
99.996%
Non-
POTW
WWT
0.004%
POTW
U.S. EPA
(2017c)
CHEMICAL
WASTE
MANAGEMENT
EMELLE
AL
4
250
0.01
Surface
Water
U.S. EPA
(2016a)
OILTANKING
HOUSTON INC
HOUSTON
TX
1
250
0.003
Surface
Water
U.S. EPA
(2016a)
HOWARD CO
ALFA RIDGE
LANDFILL
MARRIOTTSVIL
LE
MD
0.1
250
0.0002
Surface
Water
U.S. EPA
(2016a)
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CLIFFORD G
HIGGINS
DISPOSAL
SERVICE INC
SLF
KINGSTON
NJ
0.02
250
0.0001
Surface
Water
U.S. EPA
(2016a)
CLEAN WATER
OF NEW YORK
INC
STATEN ISLAND
NY
2
250
0.01
Surface
Water
U.S. EPA
(2016a)
FORMER
CARBORUNDU
M COMPLEX
SANBORN
NY
0.2
250
0.001
Surface
Water
U.S. EPA
(2016a)
2.21.5 Uncertainties
In summary, dermal and inhalation exposures are expected for this use, as well as direct or
indirect water releases. EPA has not identified additional uncertainties for this use beyond those
discussed in Section 4.2.
2.22Other Reported Water Releases
Table 2-71 lists surface water releases of methylene chloride reported in the 2016 DMR from
wastewater treatment plants.
Table 2-71. Reported 2016 DMR Releases for Wastewater Treatment Facilities
Site Identity
City
State
Annual
Release
(kg/site
-yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site
-day)
Release
Media
Sources &
Notes
EDWARD C.
LITTLE WRP
EL SEGUNDO
CA
4
365
0.01
Surface
Water
U.S. EPA
(2016a)
JU ANITA
MILLENDER-
MCDONALD
CARSON
REGIONAL WRP
CARSON
CA
1
365
0.002
Surface
Water
U.S. EPA
(2016a)
LONDON WTP
LONDON
OH
0.4
365
0.001
Surface
Water
U.S. EPA
(2016a)
LONG BEACH
(C) WPCP
LONG BEACH
NY
2,730
365
7
Surface
Water
U.S. EPA
(2016a)
MIDDLESEX
COUNTY
UTILITIES
AUTHORITY
SAYREVILLE
NJ
1,634
365
4
Surface
Water
U.S. EPA
(2016a)
JOINT WATER
POLLUTION
CONTROL
PLANT
CARSON
CA
604
365
1.7
Surface
Water
U.S. EPA
(2016a)
HYPERION
TREATMENT
PLANT
PLAYA DEL REY
CA
164
365
0.5
Surface
Water
U.S. EPA
(2016a)
SD CITY PT
LOMA
SAN DIEGO
CA
164
365
0.5
Surface
Water
U.S. EPA
(2016a)
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Site Identity
City
State
Annual
Release
(kg/site
-yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site
-day)
Release
Media
Sources &
Notes
WASTEWATER
TREATMENT
REGIONAL
SANITATION
DISTRICT
ELK GROVE
CA
86
365
0.2
Surface
Water
U.S. EPA
(2016a)
BERGEN POINT
STP & BERGEN
AVE DOCK
W BABYLON
NY
65
365
0.2
Surface
Water
U.S. EPA
(2016a)
NEW ROCHETTE
STP
NEW ROCHELLE
NY
15
365
0.04
Surface
Water
U.S. EPA
(2016a)
SIMI VLY CNTY
SANITATION
SIMI VALLEY
CA
7
365
0.02
Surface
Water
U.S. EPA
(2016a)
OCEANSIDE
OCEAN
OUTFALL
OCEANSIDE
CA
4
365
0.01
Surface
Water
U.S. EPA
(2016a)
SANTA CRUZ
WASTEWATER
TREATMENT
PLANT
SANTA CRUZ
CA
2
365
0.01
Surface
Water
U.S. EPA
(2016a)
CORONA WWTP
1
CORONA
CA
2
365
0.005
Surface
Water
U.S. EPA
(2016a)
BLIND BROOK
SD WWTP
RYE
NY
1
365
0.003
Surface
Water
U.S. EPA
(2016a)
MCKINLEYVILL
ECSD-
WASTEWATER
TREATMENT
PLANT
MCKINLEYVILL
E
CA
1
365
0.003
Surface
Water
U.S. EPA
(2016a)
SAN JOSE
CREEK WATER
RECLAMATION
PLANT
WHITTIER
CA
0.4
365
0.001
Surface
Water
U.S. EPA
(2016a)
CARMEL AREA
WASTEWATER
DISTRICT
TREATMENT
FACILITY
CARMEL
CA
0.3
365
0.001
Surface
Water
U.S. EPA
(2016a)
CAMERON
TRADING POST
WWTP
CAMERON
AZ
0.2
365
0.001
Surface
Water
U.S. EPA
(2016a)
CITY OF RED
BLUFF
WASTEWATER
RECLAMATION
PLANT
RED BLUFF
CA
0.2
365
0.001
Surface
Water
U.S. EPA
(2016a)
91ST AVE
WASTEWATER
TREATMENT
PLANT
TOLLESON
AZ
31
365
0.1
Surface
Water
U.S. EPA
(2016a)
EVERETT
WATER
EVERETT
WA
30
365
0.1
Surface
Water
U.S. EPA
(2016a)
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Site Identity
City
State
Annual
Release
(kg/site
-yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site
-day)
Release
Media
Sources &
Notes
POLLUTION
CONTROL
FACILITY
PIMA COUNTY -
INA ROAD
WWTP
TUCSON
AZ
27
365
0.1
Surface
Water
U.S. EPA
(2016a)
23RD AVENUE
WASTEWATER
TREATMENT
PLANT
PHOENIX
AZ
19
365
0.1
Surface
Water
U.S. EPA
(2016a)
SUNNYSIDE STP
SUNNYSIDE
WA
2
365
0.005
Surface
Water
U.S. EPA
(2016a)
AGUA NUEVA
WRF
TUCSON
AZ
1
365
0.003
Surface
Water
U.S. EPA
(2016a)
PORT OF
SUNNYSIDE
INDUSTRIAL
WWTF
SUNNYSIDE
WA
1
365
0.002
Surface
Water
U.S. EPA
(2016a)
APACHE
JUNCTION
WWTP
APACHE
JUNCTION
AZ
0.1
365
0.0003
Surface
Water
U.S. EPA
(2016a)
Table 2-72 lists surface water releases of methylene chloride reported in the 2016 TRI from for
facilities that were unable to be associated with specific conditions of use outlined in Sections
2.1 through 2.21.
Table 2-72. Reported 2016 TRI and DMR Releases for Unclassified Facilities
Site Identity
City
State
Annual
Release
(kg/site-
yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources &
Notes
APPLIED
BIOSYSTEM
S LLC
PLEASANTON
CA
42
250
0.2
Non-
POTW
WWT
U.S. EPA
(2017c)
EMD
MILLIPORE
CORP
JAFFREY
NH
2
250
0.01
POTW
U.S. EPA
(2017c)
GBC
METALS LLC
SOMERS
THIN STRIP
WATERBURY
CT
0.2
250
0.001
Surface
Water
U.S. EPA
(2016a)
HYSTER-
YALE
GROUP, INC
SULLIGENT
AL
0.0002
250
0.000001
Surface
Water
U.S. EPA
(2016a)
AVNET INC
(FORMER
IMPERIAL
SCHRADE)
ELLENVILLE
NY
0.005
250
0.00002
Surface
Water
U.S. EPA
(2016a)
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Site Identity
City
State
Annual
Release
(kg/site-
yr)
Annual
Release
Days
(days/yr)
Daily
Release
(kg/site-
day)
Release
Media
Sources &
Notes
BARGE
CLEANING
AND REPAIR
CHANNEL VIE
W
TX
0.1
250
0.0003
Surface
Water
U.S. EPA
(2016a)
AC & S INC
NITRO
WV
0.01
250
0.00005
Surface
Water
U.S. EPA
(2016a)
MOOG INC -
MOOGIN-
SPACE
PROPULSION
ISP
NIAGARA
FALLS
NY
0.003
250
0.00001
Surface
Water
U.S. EPA
(2016a)
OILTANKIN
G JOLIET
CHANNAHON
IL
1
250
0.003
Surface
Water
U.S. EPA
(2016a)
NIPPON
DYNAWAVE
PACKAGING
COMPANY
LONGVIEW
WA
22
250
0.1
Surface
Water
U.S. EPA
(2016a)
TREE TOP
INC
WENATCHE
E PLANT
WENATCHEE
WA
0.01
250
0.00003
Surface
Water
U.S. EPA
(2016a)
CAROUSEL
CENTER
SYRACUSE
NY
0.001
250
0.000002
Surface
Water
U.S. EPA
(2016a)
3 Summary of Occupational Exposure Assessment
3.1 Inhalation Exposure Assessment
Table 3-1 summarizes the inhalation exposure assessment for each Occupational Exposure
Scenario as described in Section 2. For each scenario, central tendency and high-end estimates
are provided.
Table 3-1. Summary of Acute and Chronic Inhalation Exposures to Methylene Chloride for
Central and Higher-End Scenarios by Use
Chronic, Non-
Cancer Exposures
Chronic, Cancer
Acute Exposures
(ADCs)
Exposures
ACdcm, 8-hr TWA
ADCdcm, 24-hr
LADCdcm, 24-hr
(mg/m3)
TWA (mg/m3)
TWA (mg/m3)
OES
Occupational Exposure
Scenario
Category
Central
Tendency
High
End
Central
Tendency
High
End
Central
Tendency
High
End
Worker &
1
Manufacturing
ONU
0.36
4.6
0.08
1.1
0.14
2.4
Worker &
2
Processing as a Reactant
ONU
1.6
10
0.37
2.4
0.65
5.3
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3
Processing - Incorporation
into Formulation
Worker &
ONU
180
1,800
41
410
72
920
Worker &
4
Import and Repackaging
ONU
8.8
140
2.0
31
3.50
71
5
Batch Open-Top Vapor
Degreasing (Modeled)
Worker
170
740
29
130
15
66
5
Batch Open-Top Vapor
Degreasing (Modeled)
ONU
86
460
15
78
7.6
40
6
Conveyorized Vapor
Degreasing (Modeled)
Worker
490
1,400
84
240
43
120
6
Conveyorized Vapor
Degreasing (Modeled)
ONU
250
900
44
150
22
79
Worker &
7
Cold Cleaning
ONU
280
1,000
64
230
110
510
Aerosol
8
Degreasing/Lubricants
(Modeled)
Worker
22
79
3.8
14
1.9
6.9
Aerosol
8
Degreasing/Lubricants
(Modeled)
ONU
0.40
3.3
0.07
0.56
0.04
0.29
Worker &
9
Adhesives/Sealants (Spray)
ONU
39
560
8.9
130
16.0
290
Adhesives/Sealants (Non-
Worker &
9
Spray)
ONU
10
300
2.4
68
4.2
150
Worker &
10
Paints and Coatings (Spray)
ONU
70
360
16
83
28
190
10
Paints and Coatings
(Unknown Application
Method)
Worker &
ONU
7.1
11
1.6
2.4
2.80
5.5
Adhesive and Caulk
Worker &
11
Removers
ONU
1,500
3,000
350
680
600
1,500
Worker &
12
Fabric Finishing
ONU
87
160
20
37
35.0
84
Worker &
13
Spot Cleaning
ONU
2.6
64
0.6
15
1.00
33.0
Worker &
14
CTA Manufacturing
ONU
1,000
1,400
240
320
410
560
Flexible PU Foam
Worker &
15
Manufacturing
ONU
210
1,000
48
230
84
510
Worker &
16
Laboratory Use
ONU
3.5
12.0
0.8
2.7
1.40
6
Plastic Product
17
Manufacturing
Worker
14
260
3.2
60
5.5
130
Plastic Product
17
Manufacturing
ONU
9.0
9.0
2.1
2.1
3.6
4.6
Worker &
18
Pharmaceutical
ONU
230
3,600
53
820
91
1,800
Worker &
19
Lithographic Printing Cleaner
ONU
3.7
270
0.84
62
1.50
140
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20
Non-Aerosol Commercial
Use (Cleaning Solvent)
Worker &
ONU
57
930
13
210
23.0
480
21
Waste Handling, Disposal,
Treatment, and Recycling
Worker &
ONU
2.3
19
0.5
4.3
0.9
9.7
3.2 Dermal Exposure Assessment
Because methylene chloride is a volatile liquid, the dermal absorption of methylene chloride
depends on the type and duration of exposure. Where exposure is not occluded, only a fraction of
methylene chloride that comes into contact with the skin will be absorbed as the chemical readily
evaporates from the skin. However, dermal exposure may be significant in cases of occluded
exposure, repeated contacts, or dermal immersion. For example, work activities with a high
degree of splash potential may result in methylene chloride liquids trapped inside the gloves,
inhibiting the evaporation of methylene chloride and increasing the exposure duration.
To assess exposure, EPA used the equations and parameter values in 4.2.5Appendix E to
calculate the dermal retained dose for both non-occluded and occluded scenarios. The equation
modifies the EPA/OPPT 2-HandDermal Exposure to Liquids Model by incorporating a "fraction
absorbed (fabs)" parameter to account for the evaporation of volatile chemicals and a "protection
factor (PF)" to account for glove use. Default PF values, which vary depending on the type of
glove used and the presence of employee training program, are shown in Table 3-2:
n — V ( xf abs) X y y n-y
uexp pp 1 derm 11
Where:
S is the surface area of contact (cm2)
Qu is the quantity remaining on the skin (mg/cm2-event)
Yderm is the weight fraction of the chemical of interest in the liquid (0 < Yderm < 1)
FT is the frequency of events (integer number per day)
fabs is the fraction of applied mass that is absorbed (Default: 0.08 for methylene chloride
during industrial use; 0.13 for methylene chloride during commercial use)
PF is the glove protection factor (Default: see Table 3-2)
The steady state fractional absorption (fabs) for methylene chloride is estimated to be 0.08 and
0.13, for industrial use, and commercial use, respectively, based on a theoretical framework
provided by Kasting (2005). meaning approximately 8 to 13 percent of the applied dose is
absorbed through the skin following exposure.
Table 3-2. Glove Protection Factors for Different Dermal Protection Strategies
Dermal Protection Characteristics
Setting
Protection Factor,
PF
a. No gloves used, or any glove / gauntlet without permeation data and
without employee training
Industrial and
Commercial Uses
1
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b. Gloves with available permeation data indicating that the material of
construction offers good protection for the substance
5
c. Chemically resistant gloves (i.e., as b above) with "basic" employee
training
10
d. Chemically resistant gloves in combination with specific activity
training (e.g., procedure for glove removal and disposal) for tasks where
dermal exposure can be expected to occur
Industrial Uses
Only
20
Table 3-3 presents the estimated dermal retained dose for workers in various exposure scenarios,
including what-if scenarios for glove use. The dose estimates assume one exposure event
(applied dose) per work day and that approximately 8 to 13 percent1 of the applied dose is
absorbed through the skin. Table 3-3 also includes estimated dermal retained dose for occluded
scenarios for conditions of use where EPA determined occlusion was reasonably expected to
occur. Occluded scenarios are generally expected where workers are expected to come into
contact with bulk liquid methylene chloride during use in open systems (e.g., during solvent
changeout in vapor degreasing and dry cleaning) and not expected in closed-type systems (e.g.,
during connection/disconnection of hoses used in loading of bulk containers in manufacturing).
See discussion on occlusion in for further description of these scenarios. The exposure estimates
are provided for each condition of use, where the conditions of use are "binned" based on the
maximum possible exposure concentration (Yderm), the likely level of exposure, and potential for
occlusion. The exposure concentration is determined based on EPA's review of currently
available products and formulations containing methylene chloride.
• Bin 1: Bin 1 covers industrial uses that generally occur in closed systems. For these uses,
dermal exposure is likely limited to chemical loading/unloading activities (e.g.,
connecting hoses), and taking quality control samples. EPA assesses the following glove
use scenarios for Bin 1 conditions of use:
o No gloves used: Operators in these industrial uses, while working around closed-
system equipment, may not wear gloves or may wear gloves for abrasion
protection or gripping that are not chemical resistant,
o Gloves used with a protection factor of 5, 10, and 20: Operators may wear
chemical-resistant gloves when taking quality control samples or when
connecting and disconnecting hoses during loading/unloading activities. EPA
assumes gloves may offer a range of protection, depending on the type of glove
and employee training provided,
o Scenarios not assessed: EPA does not assess occlusion as workers in these
industries are not likely to come into contact with bulk liquid methylene chloride
that could lead to chemical permeation under the cuff of the glove or excessive
liquid contact time leading to chemical permeation through the glove.
• Bin 2: Bin 2 covers industrial degreasing uses, which are not closed systems. For these
uses, there is greater opportunity for dermal exposure during activities such as charging
and draining degreasing equipment, drumming waste solvent, and removing waste
sludge. EPA assesses the following glove use scenarios for Bin 2 conditions of use:
1 The absorbed fraction (fabs) is a function of indoor air speed, which differs for industrial and commercial settings.
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o No gloves used: Due to the variety of shop types in these uses the actual use of
gloves is uncertain. EPA assumes workers may not wear gloves or may wear
gloves for abrasion protection or gripping that are not chemical resistant during
routine operations such as adding and removing parts from degreasing equipment,
o Gloves used with a protection factor of 5, 10, and 20: Workers may wear
chemical-resistant gloves when charging and draining degreasing equipment,
drumming waste solvent, and removing waste sludge. EPA assumes gloves may
offer a range of protection, depending on the type of glove and employee training
provided.
o Occluded Exposure: Occlusion may occur when workers are handling bulk liquid
methylene chloride when charging and draining degreasing equipment, drumming
waste solvent, and removing waste sludge that could lead to chemical permeation
under the cuff of the glove or excessive liquid contact time leading to chemical
permeation through the glove.
• Bin 3: Bin 3 covers the use of methylene chloride in commercial activities that may
involve spray application. Workers (sprayers) can be dermally exposed when mixing
product, charging product to spray equipment, and cleaning spray equipment. Other
workers (non-sprayers) may also have incidental contact with the applied product during
subsequent fabrication steps. EPA assesses the following glove use scenarios for Bin 3
conditions of use:
o No gloves used: Actual use of gloves in this use is uncertain. EPA assumes
workers may not wear gloves or may wear gloves for abrasion protection or
gripping that are not chemical resistant during routine operations such as spray
applications and fabrication steps (non-sprayers),
o Gloves used with a protection factor of 5 and 10: Workers may wear chemical-
resistant gloves when mixing adhesive/sealant, charging adhesive/sealant to spray
equipment, and cleaning adhesive/sealant spray equipment. EPA assumes the
commercial facilities in Bin 3 do not offer activity-specific training on donning
and doffing gloves.
o Occluded Exposure: Occlusion may occur when workers are handling bulk liquid
methylene chloride when mixing adhesive/sealant, charging adhesive/sealant to
spray equipment, and cleaning adhesive/sealant spray equipment that could lead
to chemical permeation under the cuff of the glove or excessive liquid contact
time leading to chemical permeation through the glove,
o Scenarios not assessed: EPA does not assess glove use with protection factors of
20 as EPA assumes chemical-resistant gloves used in these industries would
either not be accompanied by training or be accompanied by basic employee
training, but not activity-specific training.
• Bin 4: Bin 4 covers non-aerosol commercial activities of similar maximum
concentration, such as in laboratories, or miscellaneous uses such as novelty item
manufacturing, general cleaning, or crafting products. Workers will likely apply the
products to relatively small surfaces via brush, roller, or wipe, or transfer liquids from
various containers. EPA assesses the following glove use scenarios for Bin 4 conditions
of use:
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o No gloves used: Actual use of gloves in this use is uncertain. EPA assumes
workers may not wear gloves during routine operations (e.g., spot cleaning),
o Gloves used with a protection factor of 5 and 10: Workers may wear chemical-
resistant gloves when charging and draining solvent to/from machines, removing
and disposing sludge, and maintaining equipment. EPA assumes site-specific
training practices on glove use may vary including potentially no training
activities for employees,
o Gloves used with a protection factor of 10: Workers may wear chemical-resistant
gloves when charging and draining solvent to/from machines, removing and
disposing sludge, and maintaining equipment. EPA assumes the commercial
facilities in Bin 4 do not offer activity-specific training on donning and doffing
gloves.
o Occluded Exposure: Occlusion may occur when workers are handling bulk liquid
methylene chloride when charging and draining solvent to/from machines,
removing and disposing sludge, and maintaining equipment that could lead to
chemical permeation under the cuff of the glove or excessive liquid contact time
leading to chemical permeation through the glove,
o Scenarios not assessed: EPA does not assess glove use with protection factors of
20 as EPA assumes chemical-resistant gloves used in these industries would
either not be accompanied by training or be accompanied by basic employee
training, but not activity-specific training.
• Bin 5: Bin 5 covers aerosol uses, where workers are likely to have direct dermal contact
with film applied to substrate and incidental deposition of aerosol to skin. EPA assesses
the following glove use scenarios for Bin 5 conditions of use:
o No gloves used: Actual use of gloves in this use is uncertain. EPA assumes
workers may not wear gloves or may wear gloves for abrasion protection or
gripping that are not chemical resistant during routine aerosol applications,
o Gloves used with a protection factor of 5 and 10: Workers may wear chemical-
resistant gloves when applying aerosol products. EPA assumes the commercial
facilities in Bin 5 do not offer activity-specific training on donning and doffing
gloves.
o Gloves used with a protection factor of 10: Workers may wear chemical-resistant
gloves when applying aerosol products. EPA assumes site-specific training
practices on glove use may vary and that the commercial facilities in Bin 5 may
offer basic employee training on glove use but not activity-specific training on
donning and doffing gloves,
o Scenarios not assessed: EPA does not assess glove use with protection factors of
20 as EPA assumes chemical-resistant gloves used in these industries would
either not be accompanied by training or be accompanied by basic employee
training, but not activity-specific training. EPA does not assess occlusion for
aerosol applications because methylene chloride formulation is often supplied in
an aerosol spray can and contact with bulk liquid is unlikely. EPA also does not
assess occlusion for non-aerosol niche uses because the potential for occlusion is
unknown
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As shown in the table, the calculated retained dose is low for all non-occluded scenarios as
methylene chloride evaporates quickly after exposure. Dermal exposure to liquid is not expected
for occupational non-users, as they do not directly handle methylene chloride.
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Table 3-3. Modeled Dermal Retained Dose (mg/day) for Workers in All Conditions of Use
Occupational Exposure Scenario
Bin
Max Yderm
Non-Occluded Exposure (mg/day)
Occluded
Exposure
No Gloves
(PF = 1)
Protective
Gloves
(PF = 5)
Protective
Gloves
(Commerci
al uses, PF
= 10)
Protective
Gloves
(Industrial
uses,
PF = 20)
Manufacturing
Import and Repackaging
Processing as a Reactant
Processing - Incorporation into Formulation,
Mixture, or R\n Product
Pharmaceutical
Waste Handling, Disposal, Treatment, and
Recycling
Bin 1 -
Industrial
1.0
60 (CT)
180 (HE)
12 (CT)
36 (HE)
6 (CT)
18 (HE)
3 (CT)
9 (HE)
N/A-
occlusion not
expected
Use of Adhesives and Sealants
Use of Paints and Coatings
Flexible PU Foam Manufacturing
Batch Open-Top Vapor Degreasing
Conveyorized Vapor Degreasing
Cold Cleaning
CTA Film Production
Plastic Product Manufacturing
Bin 2 -
Industrial
1.0
60 (CT)
180 (HE)
12 (CT)
36 (HE)
6 (CT)
18 (HE)
3 (CT)
9 (HE)
2,247
Use of Adhesives and Sealants
Use of Paints and Coatings
Bin 3 -
Commercial
1.0
94 (CT)
280 (HE)
19 (CT)
57 (HE)
9 (CT)
28 (HE)
5 (CT)
14 (HE)
2,247
Fabric Finishing
0.95
90 (CT)
270 (HE)
18 (CT)
54 (HE)
9 (CT)
27 (HE)
4 (CT)
13 (HE)
2,135
Adhesive and Caulk Removers
Spot Cleaning
0.9
85 (CT)
260 (HE)
17 (CT)
51 (HE)
9 (CT)
26 (HE)
4 (CT)
13 (HE)
2,022
Lithographic Printing Cleaner
0.885
84 (CT)
250 (HE)
17 (CT)
50 (HE)
8 (CT)
25 (HE)
4 (CT)
13 (HE)
1,989
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Table 3-3. Modeled Dermal Retained Dose (mg/day) for Workers in All Conditions of Use
Occupational Exposure Scenario
Bin
Max Yderm
Non-Occluded Exposure (mg/day)
Occluded
Exposure
No Gloves
(PF = 1)
Protective
Gloves
(PF = 5)
Protective
Gloves
(Commerci
al uses, PF
= 10)
Protective
Gloves
(Industrial
uses,
PF = 20)
Laboratory Use
Bin 4 -
Commercial
1.0
94 (CT)
280 (HE)
19 (CT)
57 (HE)
9 (CT)
28 (HE)
5 (CT)
14 (HE)
2,247
Miscellaneous Non-Aerosol Commercial Uses
(crafting glues and cements, novelty items)
Miscellaneous Non-Aerosol Industrial Uses
(solvents and degreasers)
Bin 4-
Industrial
1.0
60 (CT)
180 (HE)
12 (CT)
36 (HE)
6 (CT)
18 (HE)
3 (CT)
9 (HE)
2,247
Commercial Aerosol Products
Bin 5 -
Commercial
1.0
94 (CT)
280 (HE)
19 (CT)
57 (HE)
9 (CT)
28 (HE)
5 (CT)
14 (HE)
N/A-
occlusion not
expected
CT - Central Tendency; HE - High End
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4 Discussion of Uncertainties and Limitations
4.1 Variability
EPA addressed variability in models by identifying key model parameters to apply a statistical
distribution that mathematically defines the parameter's variability. EPA defined statistical
distributions for parameters using documented statistical variations where available. Where the
statistical variation is not known, assumptions are made to estimate the parameter distribution
using available literature data.
4.2 Uncertainties and Limitations
Uncertainty is "the lack of knowledge about specific variables, parameters, models, or other
factors" and can be described qualitatively or quantitatively (U.S. EPA, 2001; HERO 201612).
The following sections discuss uncertainties in each of the assessed methylene chloride use
scenarios.
4.2.1 Number of Workers
There are a number of uncertainties surrounding the estimated number of workers potentially
exposed to methylene chloride, as outlined below. Most are unlikely to result in a systematic
underestimate or overestimate but could result in an inaccurate estimate.
CDR data are used to estimate the number of workers associated with manufacturing. There are
inherent limitations to the use of CDR data as they are reported by manufacturers and importers
of methylene chloride. Manufacturers and importers are only required to report if they
manufactured or imported methylene chloride in excess of 25,000 pounds at a single site during
any calendar from 2012 to 2015; as such, CDR may not capture all sites and workers associated
with any given chemical.
There are also uncertainties with BLS data, which are used to estimate the number of workers for
the remaining conditions of use. First, BLS' OES employment data for each industry/occupation
combination are only available at the 3-, 4-, or 5-digitNAICS level, rather than the full 6-digit
NAICS level. This lack of granularity could result in an overestimate of the number of exposed
workers if some 6-digit NAICS are included in the less granular BLS estimates but are not, in
reality, likely to use methylene chloride for the assessed applications. EPA addressed this issue
by refining the OES estimates using total employment data from the U.S. Census' SUSB.
However, this approach assumes that the distribution of occupation types (SOC codes) in each 6-
digit NAICS is equal to the distribution of occupation types at the parent 5-digit NAICS level. If
the distribution of workers in occupations with methylene chloride exposure differs from the
overall distribution of workers in each NAICS, then this approach will result in inaccuracy.
Second, EPA's judgments about which industries (represented by NAICS codes) and
occupations (represented by SOC codes) are associated with the uses assessed in this report are
based on EPA's understanding of how methylene chloride is used in each industry. Designations
of which industries and occupations have potential exposures is nevertheless subjective, and
some industries/occupations with few exposures might erroneously be included, or some
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industries/occupations with exposures might erroneously be excluded. This would result in
inaccuracy but would be unlikely to systematically either overestimate or underestimate the
count of exposed workers.
4.2,2 Analysis of Exposure Monitoring Data
In most scenarios where data were available, EPA did not find enough data to determine
complete statistical distributions of actual air concentrations for the workers exposed to
methylene chloride. Ideally, EPA would like to know 50th and 95th percentiles for each exposed
population. In the absence of percentile data for monitoring, the air concentration means and
medians (means are preferred over medians) of the data sets served as substitutes for 50th
percentiles (central tendencies) of the actual distributions, whereas high ends of ranges served as
substitutes for 95th percentiles of the actual distributions. However, these substitutes are
uncertain and are weak substitutes for the ideal percentiles. For instance, in the few cases where
enough data were found to determine statistical means and 95th percentiles, the associated
substitutes (i.e., medians and high ends of ranges) were shown to overestimate exposures,
sometimes significantly. While it is clear that most air concentration data represent real exposure
levels, EPA cannot determine whether these concentrations are representative of the statistical
distributions of actual air concentrations to which workers are exposed. It is unknown whether
these uncertainties overestimate or underestimate exposures.
This report uses existing worker exposure monitoring data to assess exposure to methylene
chloride during all conditions of use. To analyze the exposure data, EPA categorized each PBZ
and area data point as either "worker" or "occupational non-user". The categorizations are based
on descriptions of worker job activity as provided in literature and EPA's judgment. In general,
PBZ samples are categorized as "worker" and area samples are categorized as "occupational
non-user".
Exposures for occupational non-users can vary substantially. Most data sources do not
sufficiently describe the proximity of these employees to the exposure source. As such, exposure
levels for the "occupational non-user" category will have high variability depending on the
specific work activity performed. It is possible that some employees categorized as
"occupational non-user" have exposures similar to those in the "worker" category depending on
their specific work activity pattern.
Some data sources may be inherently biased. For example, bias may be present if exposure
monitoring was conducted to address concerns regarding adverse human health effects reported
following exposures during use. Similarly, OSHA CEHD are obtained from OSHA inspections,
which may be the result of worker complaints, and may provide exposure results that are
generally more conservative than the industry average.
Some air concentration data comes from sources pre-dating the most recent PEL update for
methylene chloride in 1997. PEL changes can drive improvements in engineering controls or
other efforts to reduce ambient exposure to meet the PEL. Use of pre-PEL data may overestimate
some exposures in some OESs.
Due to data limitations in most OESs, EPA combined inhalation data from two or more data sets
when metadata were not available to distinguish between OES subcategories. These
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combinations introduce uncertainties as to whether data from disparate worker populations had
been combined into one OES or OES subcategory. This same uncertainty applies to mixing data
collected pre-PEL change with data collected post-PEL change.
Some scenarios have limited exposure monitoring data in literature, if any. Where there are few
data points available, it is unlikely the results will be representative of worker exposure across
the industry.
Where data were not available, the modeling approaches used to estimate air concentrations also
have uncertainties. Parameter values used in models did not all have distributions known to
represent the modeled scenario. It is also uncertain whether the model equations generate results
that represent actual workplace air concentrations. It is unknown whether these uncertainties
overestimate or underestimate exposures. Additional model-specific uncertainties are included
below.
EPA calculated ADC values assuming a high-end exposure duration of 250 days per year over
40 years and LADC values assuming a high-end exposure duration of 250 days per year over 78
years. This assumes the workers and occupational non-users are regularly exposed during their
entire working lifetime, which likely results in an overestimate. Individuals may change jobs
during the course of their career such that they are no longer exposed to methylene chloride, and
that actual ADC and LADC values become lower than the estimates presented.
4.2.3 Near-Field/Far-Field Model Framework
The near-field/far-field approach is used as a framework to model inhalation exposure for many
conditions of use. The following describe uncertainties and simplifying assumptions generally
associated with this modeling approach:
• There is some degree of uncertainty associated with each model input parameter. In
general, the model inputs were determined based on review of available literature. Where
the distribution of the input parameter is known, a distribution is assigned to capture
uncertainty in the Monte Carlo analysis. Where the distribution is unknown, a uniform
distribution is often used. The use of a uniform distribution will capture the low-end and
high-end values but may not accurately reflect actual distribution of the input parameters.
• The model assumes the near-field and far-field are well mixed, such that each zone can
be approximated by a single, average concentration.
• All emissions from the facility are assumed to enter the near-field. This assumption will
overestimate exposures and risks in facilities where some emissions do not enter the
airspaces relevant to worker exposure modeling.
• The exposure models estimate airborne concentrations. Exposures are calculated by
assuming workers spend the entire activity duration in their respective exposure zones
(i.e., the worker in the near-field and the occupational non-user in the far-field). Since
vapor degreasing and cold cleaning involve automated processes, a worker may actually
walk away from the near-field during part of the process and return when it is time to
unload the degreaser. As such, assuming the worker is exposed at the near-field
concentration for the entire activity duration may overestimate exposure.
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• For certain applications (e.g. vapor degreasing), methylene chloride vapor is assumed to
emit continuously while the equipment operates (i.e. constant vapor generation rate).
Actual vapor generation rate may vary with time. However, small time variability in
vapor generation is unlikely to have a large impact in the exposure estimates as exposures
are calculated as a time-weighted average.
• The exposure models represent model workplace settings for each methylene chloride
condition of use. The models have not been regressed or fitted with monitoring data.
Each subsequent section below discusses uncertainties associated with the individual model.
4.2.3.1 Vapor Degreasing Models
The OTVD and conveyorized vapor degreasing assessments use a near-field/far-field approach
to model worker exposure. In addition to the uncertainties described above, the vapor degreasing
models have the following uncertainties:
• To estimate vapor generation rate for each equipment type, EPA used a distribution of the
emission rates reported in the 2014 NEI for each degreasing equipment type. NEI only
contains information on major sources not area sources. Therefore, the emission rate
distribution used in modeling may not be representative of degreasing equipment
emission rates at area sources.
• The emission rate for conveyorized vapor degreasing is based on equipment at a single
site and the emission rates for web degreasing are based on equipment from two sites. It
is uncertain how representative these data are of a "typical" site.
• EPA assumes workers and occupational non-users remove themselves from the
contaminated near- and far-field zones at the conclusion of the task, such that they are no
longer exposed to any residual methylene chloride in air.
4.2.3.2 Brake Servicing Model
The aerosol degreasing assessment also uses a near-field/far-field approach to model worker
exposure. Specific uncertainties associated with the aerosol degreasing scenario are presented
below:
• The model references a CARB study (citation) on brake servicing to estimate use rate and
application frequency of the degreasing product. The brake servicing scenario may not be
representative of the use rates for other aerosol degreasing applications involving
methylene chloride
• Because market penetration data were not available for methylene chloride-containing
products, EPA assumed the market penetration for PCE as an upper bound, because PCE
comprises the majority of the chlorinated solvent-based degreaser volume ( MOO).
• EPA found 10 different aerosol degreasing formulations containing methylene chloride.
For each Monte Carlo iteration, the model determines the methylene chloride
concentration in product by selecting one of 10 possible formulations, assuming the
distribution for each formulation is equal. It is uncertain if this distribution is
representative of all sites in the U.S.
• Aerosol formulations were taken from available safety data sheets, and most were
provided as ranges. For each Monte Carlo iteration the model selects a methylene
chloride concentration within the range of concentrations using a uniform distribution. In
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reality, the methylene chloride concentration in the formulation may be more consistent
than the range provided.
4.2.4 Modeling Dermal Exposures
The Dermal Exposure to Volatile Liquids Model used for modeling occupational dermal
exposures offers an improvement over the existing EPA/OPPT 2-HandDermal Exposure model
by accounting for the effect of evaporation on dermal absorption for volatile chemicals and the
potential exposure reduction due to glove use. The model assumes an infinite dose scenario and
does not account for the transient exposure and exposure duration effect, which likely
overestimates exposures. The model assumes one exposure event per day, which likely
underestimates exposure as workers often come into repeat contact with the chemical throughout
their work day. Surface areas of skin exposure are based on skin surface area of hands from
EPA's Exposure Factors Handbook, but actual surface areas with liquid contact are unknown and
uncertain for all OESs. For many OESs, the high end assumption of contact over the full area of
two hands likely overestimates exposures. Weight fractions are usually reported to CDR and
shown in other literature sources as ranges, and EPA assessed only upper ends of ranges. The
glove protection factors are "what-if' assumptions and are highly uncertain. EPA does not know
the actual frequency, type, and effectiveness of glove use in specific workplaces of the OESs.
Except where specified above, it is unknown whether most of these uncertainties overestimate or
underestimate exposures. The representativeness of the modeling results toward the true
distribution of dermal doses for the OESs is uncertain.
4.2.5 Release Estimates
EPA used 2016 TRI and 2016 DMR data to estimate releases. However, both data sources have
reporting requirements that limit the number of reporters. Due to these limitations, some sites
that manufacture, process, or use methylene chloride may not report to these datasets and are
therefore not included:
• Facilities are only required to report to TRI if the facility has 10 or more full-time
employees, is included in an applicable NAICS code, and manufactures, processes, or
uses the chemical in quantities greater than a certain threshold (25,000 pounds for
manufacturers and processors and 10,000 pounds for users).
• DMR data are submitted by National Pollutant Discharge Elimination System (NPDES)
permit holders to states or directly to the EPA according to the monitoring requirements
of the facility's permit. States are only required to load major discharger data into DMR
and may or may not load minor discharger data. The definition of major vs. minor
discharger is set by each state and could be based on discharge volume or facility size.
Due to these limitations, some sites that discharge methylene chloride may not be
included in the DMR dataset.
When possible for each condition of use, EPA/OPPT also estimated average daily releases and
number of release days per year. Because operational data were typically not available, EPA
typically assumed 350 days/yr for manufacturing and processing as a reactant because of
potentially large-scale operations. EPA assumed 300 days/yr for processing into formulation
based on an EU SpERC, and 250 days for all other operations (5 days/yr week, 50 weeks/yr)(see
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Section 1.4.6 for additional details). Actual release days may various across and between
industries and may not be accurately represented by these assumed default values.
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APPENDICES
APPENDIX A INHALATION MONITORING DATA
This appendix summarizes the personal monitoring data EPA found for each life cycle stage, as
well as EPA's rationale for inclusion or exclusion in the risk evaluation.
A.l Manufacturing
TableApx A-l lists the results of full-shift monitoring for manufacturing sites:
• Rows 1 through 136 were full-shift monitoring data provided by the Halogenated
Solvents Industry Alliance (HSIA), with sampling dates between 2005 and 2017, for
various worker activities during manufacturing (Halogenated Solvents Industry Alliance.
2018V
• Rows 137 through 140 contain data from the 1999 EC report (TNI |9). In
this report, a number of previous risk evaluations were re-examined for facilities that
manufacture methylene chloride. The data reflect sampling of plant workers and
maintenance personal at one of these facilities.
Table Apx A-2 presents short-term data:
• Rows 1 through 159 contain monitoring data provided by HSIA, with sampling dates
between 2005 and 2017, with various sample times and worker activities (Halogenated
Solvents Industry Alliance. 2018).
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Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
1
Manufacturing
Personal
Loaded and sampled 2 methyl
railcars, 1 methyl trailer, 2
chloroform railcars and 1
carbon tetrachloride railcar.
Unloaded 2 methanol railcars
and unhooked a spent sulfuric
railcar.
2.7
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
2
Manufacturing
Personal
Loaded a spent sulfuric railcar,
loaded and sampled a
methylene railcar, a methyl
trailer, prepped for what needed
loaded next week, and unloaded
2 methanol cars.
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
3
Manufacturing
Personal
Loaded 1 methyl chloride
trailer, 2 chloroform cars, and
unloaded a methanol trailer.
0.9
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
4
Manufacturing
Personal
Full-Shift - made and shot
standards.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
5
Manufacturing
Personal
Full-Shift - helped run organic
sample rounds and worked on
lab instruments.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
6
Manufacturing
Personal
Full-Shift - Loaded tank cars all
day off loaded one Carbon
Tetrachloride tank car. Loaded
perchloroethylene tank car.
Dried one methylene chloride
tank car.
11.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
7
Manufacturing
Personal
Load product/locomotive and
rail activities
0.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
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Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
8
Manufacturing
Personal
Routine lab samples - 2
methylene, 5 chloroform, 2
carbon tetrachloride, 5 methyl
chloride, 6 crude gas, 1 sulfuric
and 2 mallinckrodt samples,
and washed solvent bottles.
3.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
9
Manufacturing
Personal
Shot 20 GC samples, retrieved
ajar of carbon tetrachloride
from CLM2, and helped hook
up a cylinder of methyl chloride
to VCRU.
1.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
10
Manufacturing
Personal
Shot 12 samples on the GCs,
some carbon tetrachloride,
some chloroform and some
methylene; performed 20 wet
tests on methyl chloride.
2.1
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
11
Manufacturing
Personal
Shot 14 methyl shots on GCs,
paperwork, shot 6 GC shots,
and went to CLM2 to pick up
an empty cylinder from the
previous day.
1.2
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
12
Manufacturing
Personal
Paperwork, shot 12 methyl
shots, and 1 GC shot.
1.0
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
13
Manufacturing
Personal
Worked on aquastar analyzer,
shot 2 methylene, 3 chloroform
and 4 carbon tet samples, 2
crudes and 3 methyls on GCs.
2.2
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
14
Manufacturing
Personal
Full-Shift - loaded two methyl
chloride tank cars and loaded
one methyl chloride tank truck.
Disconnected all 3.
0.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
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Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
15
Manufacturing
Personal
Full-Shift - loaded two methyl
chloride tank cars and loaded
one methyl chloride tank truck.
Disconnected all 3.
0.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
16
Manufacturing
Personal
Full-Shift - loaded two methyl
chloride tank cars and loaded
one methyl chloride tank truck.
Disconnected all 3.
0.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
17
Manufacturing
Personal
Full-Shift - worked on
Electrical Systems on EDC
reactors and compressors.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
18
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
19
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
20
Manufacturing
Personal
Full-Shift - worked on monitor
on F-l deck, worked in the 230
yard in the CL2 unit.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
21
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
22
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
23
Manufacturing
Personal
Full-Shift - worked in the
chlorine unit on electrical
problems.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
24
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
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Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
25
Manufacturing
Personal
Loaded and sampled 2
chloroform railcars and 1
methyl railcar. Drained a
methylene line to prep for
maintenance. Unloaded a
methanol car and hooked up a
methyl car to sniff.
3.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
26
Manufacturing
Personal
Sniff tested ST-8 for
maintenance and loaded a
methyl trailer and sampled.
0.6
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
27
Manufacturing
Personal
Perfomed environmental
sampling - composited the
deepwell samples, shot 4
trichlor samples, 1 carbon tet, 7
methylene and 1 chloroform.
Shot 2 methyl chloride samples.
Made a purge and trap standard
using the organic mix.
0.9
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
28
Manufacturing
Personal
Shot 12 methyl chloride
samples, picked up 1 methylene
chloride sample at CLM2 and
shot it on the GC; ran 5 purge
and trap samples; weighed out
chloroform, methyl chloride,
and methylene chloride to make
a bottoms
standard and shot it 6 times.
1.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
29
Manufacturing
Personal
Shot 17 methyl chloride shots,
1 methylene chloride, 1
chloroform, 1 carbon
tetrachloride, and 2 purge and
trap shots.
0.6
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
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Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
30
Manufacturing
Personal
Load product/locomotive and
rail activities
3.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
31
Manufacturing
Personal
Full-Shift - Ran samples
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
32
Manufacturing
Personal
Full-Shift - Worked in the
environmental lab and helped in
the inorganic area.
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
33
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
34
Manufacturing
Personal
Perform maintenance on
instrumentation - worked on
analyzers in the chlorine
diaphragm unit and in shop.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
35
Manufacturing
Personal
Full-Shift - worked in the
membrane chopper room and
on the top of TK1801.
3.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
36
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
37
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
38
Manufacturing
Personal
Full-Shift - worked on electrical
systems in MCI unit and
worked in the old MCFII unit.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
39
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 131 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
40
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
41
Manufacturing
Personal
Full-Shift - loaded two methyl
chloride tank cars and loaded
one methyl chloride tank truck.
Disconnected all 3.
0.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
42
Manufacturing
Personal
Full-Shift - Loaded one methyl
chloride tank car. Disconnected
tank cars and collected methyl
chloride samples.
0.9
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
43
Manufacturing
Personal
Full-Shift - Loaded 3 methyl
chloride tank trucks and on tank
car. Caught product quality
samples.
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
44
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
45
Manufacturing
Personal
Loaded and sampled 1 methyl
trailer; loaded and sampled 2
chloroform railcars; unloaded 1
methanol railcar.
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
46
Manufacturing
Personal
Loaded and sampled 3
chloroform railcars; loaded and
sampled a methyl chloride car;
hooked up another methyl car
to prep for loading; loaded a
methyl trailer and sampled it;
unloaded a methanol railcar.
0.4
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
47
Manufacturing
Personal
Full-Shift - ran organic
samples; ran wets and RCLs.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 132 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
48
Manufacturing
Personal
Full-Shift - helped run organic
samples most of the day.
Helped with caustic samples.
Dumped organic retains.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
49
Manufacturing
Personal
Full-Shift - ran organic samples
and dumped sample retains.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
50
Manufacturing
Personal
Full-Shift - ran organic
samples, doing RCL and wet
test analysis. Dumped days
process retains under hood.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
51
Manufacturing
Personal
Load product/locomotive and
rail activities
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
52
Manufacturing
Personal
Full-Shift - worked the 8 lir day
job loading tank cars. Loaded
perc and carbon tetrachloride.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
53
Manufacturing
Personal
Load product/locomotive and
rail activities
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
54
Manufacturing
Personal
Loaded and sampled 1 methyl
chloride railcar, 1 methyl
chloride trailer; loaded and
sampled a chloroform railcar,
unloaded a methanol railcar;
loaded 12 drums of chloroform.
0.8
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
55
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
56
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 133 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
57
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
1.0
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
58
Manufacturing
Personal
Full-Shift - Blocked tank car on
the west methyl chloride
loading rack, prepped PSV558-
2 for maintenance, hooked up
methyl tank truck, prepped
PSV573A for
maintenance, loaded tank truck,
disconnected East/West methyl
tank car spots and
disconnect truck.
1.0
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
59
Manufacturing
Personal
Full-Shift - gave maintenance
the PSVs on CP542 and off
loaded a methyl chloride tank
car on the east gate.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
60
Manufacturing
Personal
Full-Shift - prepped and gave to
maintenance PSV's on ST500,
501, 502, CP542 and P573A.
Loaded methyl chloride truck,
stopped loading methyl
chloride tank car on west spot,
sample a new rental tank.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
61
Manufacturing
Personal
Full-Shift - worked in the
utilities F1 area, worked in the
5CP unit and in the electrical
shop.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
62
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 134 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
63
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
64
Manufacturing
Personal
Full-Shift - worked all day
installing heaters on the perc
reactor.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
65
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
66
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
67
Manufacturing
Personal
Full-Shift - worked electrical
problems in the caustic unit and
in the chlorine unit.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
68
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
69
Manufacturing
Personal
Perform maintenance on
instrumentation
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
70
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.6
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
71
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.6
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
72
Manufacturing
Personal
Loaded 1 methyl chloride
trailer, offloaded a methanol
railcar; shipped a chloroform
order.
0.2
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 135 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Industry
Type of
Sample
Worker Activity or Sampling
Location
Methylene Chloride
Airborne Concentration
(mg/m3) a'b
Number of
Samples
Type of
Measurement
Source
Score
Rationale for
Inclusion /
Exclusion
73
Manufacturing
Personal
Vented a methyl railcar to
VCRU; shipped a drain of
chloroform.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
74
Manufacturing
Personal
Sampled TK11, sampled 1
chloroform dram; filled 40
chloroform drums.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
75
Manufacturing
Personal
Loaded and sampled 2
chloroform and 1 methylene
railcar. Hooked up 1 methyl, 2
chloroform, and 1 methylene
railcar. Sampled 1 chloroform
and 1 methylene railcar.
4.5
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
76
Manufacturing
Personal
Prepared some drams to ship.
0.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
77
Manufacturing
Personal
Hooked up a methyl railcar;
unloaded and unhooked 2
methanol railcars; hooked up 2
methanol railcars; hooked up,
sampled, and unhooked 1
carbon tet railcar and 2
chloroform railcars.
3.3
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
78
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
1.7
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
79
Manufacturing
Personal
Dramming chloroform most of
shift; drammed 40 chloroform
drums, sampled 1 dram, and
dumped excess to waste
solvents dram.
4.9
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
80
Manufacturing
Personal
Unloaded 2 methanol railcars,
topped off a methylene railcar,
and vented 1 each methylene
5.9
1
8-hr TWA
Halosenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 136 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siiinplinii
Locution
Mcllnlcnc Chloride
Airborne Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilion;ilc lor
Inclusion /
r.xclusion
and chloroform cars; shipped 2
drum orders.
81
Manufacturing
Personal
Loaded/filled 40 drums of
chloroform.
0.4
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
82
Manufacturing
Personal
Drummed 40 drums of
chloroform, helped on 2
chloroform cars, 1 methanol
car, 1 methyl car and sampled
drums of chloroform.
0.4
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
83
Manufacturing
Personal
Filled 24 drums of carbon
tetrachloride.
0.5
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
84
Manufacturing
Personal
Loaded a methyl chloride
railcar and sampled it.
Unloaded and disconnected a
methanol railcar. Loaded,
sampled, and disconnected a
methyl chloride ISO container.
0.3
1
8-hr TWA
Haloeenated
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
85
Manufacturing
Personal
Loaded and sampled a methyl
railcar and an ISO container.
Loaded 2 carbon tet railcars and
sampled 1. Loaded and sampled
1 methylene chloride railcar.
Unloaded 2 methanol railcars
and unhooked 1.
3.8
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
86
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.5
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
87
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
1.9
1
8-hr TWA
Haloeenated
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 137 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siiinplinii
Locution
Mcllnlcnc Chloride
Airhornc Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilion;ilc lor
Inclusion /
r.xclusion
88
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
10.4
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
89
Manufacturing
Personal
Drummed 40 drums of carbon
tetrachloride and collected 4
samples from drums.
7.3
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
90
Manufacturing
Personal
Unloaded 1 methanol railcar;
loaded and sampled 1
chloroform railcar; loaded and
sampled 1 methyl chloride
trailer; hooked up a methyl
chloride trailer to air; hooked
up methyl railcar to vent;
hooked up 3 solvent railcars to
vent.
2.5
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
91
Manufacturing
Personal
Sampled methyl chloride
railcar; evacuated lines and
disconnected methyl railcar;
unloaded a methanol railcar;
unloaded 2 chloroform railcars
and sampled one; unloaded 1
carbon tetrachloride railcar and
sampled it.
0.7
1
8-hr TWA
Halogenated
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
92
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.4
1
8-hr TWA
Halogenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
93
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.4
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
94
Manufacturing
Personal
Load product/locomotive and
rail activities
0.2
1
8-hr TWA
Halogenated
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 138 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siiinplinii
Locution
Mcllnlcnc Chloride
Airhornc Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilion;ilc for
Inclusion /
r.xclusion
95
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.6
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
96
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.7
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
97
Manufacturing
Personal
Hooked up and offloaded a
methanol railcar; hooked up
and loaded a methyl trailer;
hooked up and loaded a carbon
tet railcar; sampled both railcars
that were loaded and then
worked on the methyl evac
rack.
0.4
1
8-hr TWA
Halogenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
98
Manufacturing
Personal
Offloaded a methanol railcar;
loaded a methylene railcar;
sampled methylene railcar;
sealed methylene railcar;
hooked up a carbon tet railcar
to air; hooked up a methylene
railcar to air.
9.7
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
99
Manufacturing
Personal
Loaded 1 methylene and 1
chloroform trailer, 1 methyl
trailer and offloaded a methanol
railcar.
1.5
1
8-hr TWA
Halogenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
100
Manufacturing
Personal
Loaded 1 chloroform railcar
and 1 methyl railcar; offloaded
1 methanol railcar.
0.5
1
8-hr TWA
Halogenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
101
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.4
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 139 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siimplin^
Locution
Mcllnlcnc Chloride
Airhornc Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilion;ilc for
Inclusion /
r.xclusion
102
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
0.8
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
103
Manufacturing
Personal
Transfer waste/Filter
Changes/Trap Changes
10.4
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
104
Manufacturing
Personal
Full-Shift - routine supervision
duties.
0.4
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
105
Manufacturing
Personal
Full-Shift - routine supervision
duties.
0.4
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
106
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
107
Manufacturing
Personal
General 8-hour exposure
0.0
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
108
Manufacturing
Personal
Analytical work
2.5
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
109
Manufacturing
Personal
General 8-hour exposure
0.5
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
110
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
111
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
112
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 140 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siimplin^
Locution
Mcllnlcnc Chloride
Airhornc Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilion;ilc for
Inclusion /
r.xclusion
113
Manufacturing
Personal
General 8-hour exposure
0.3
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
114
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
115
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
116
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
117
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
118
Manufacturing
Personal
General 8-hour exposure
0.0
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
119
Manufacturing
Personal
General 8-hour exposure
3.2
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
120
Manufacturing
Personal
General 8-hour exposure
2.3
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
121
Manufacturing
Personal
General 8-hour exposure
0.7
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
122
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Haloeenated
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
123
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 141 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Da
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siimplin^
Locution
Mcllnlcnc Chloride
Airhornc Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilion;ilc for
Inclusion /
r.xclusion
124
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
125
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
126
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
127
Manufacturing
Personal
Analytical work
0.0
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
128
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
129
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
130
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
131
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
132
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
133
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industrv
1.6
Included-Full-
Shift TWA-
Worker
134
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
a for Manufacturing
Page 142 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-l. Summary of Full-Shift Inhalation Monitoring Data for Manufacturing
Row
Imliisln
Tj pc of
Siimplc
\\ orkcr Acli\ i(\ or Siimplin^
Locution
Mcllnlcnc Chloride
Airhornc Conccnlmlion
(in ii/iii ") •l h
Number of
Siimplos
Tj pi' of
Moiisiiivinonl
Soiiito
Score
K;ilinn;ilc for
Inclusion /
r.xclusion
135
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industry
Alliance (2018)
1.6
Included-Full-
Shift TWA-
Worker
136
Manufacturing
Personal
General 8-hour exposure
0.2
1
8-hr TWA
Solvents Industry
1.6
Included-Full-
Shift TWA-
Worker
137
Manufacturing
Personal
Plant and Packing Personnel
3.5
1
8-hr TWA
TOO fCIVO)
2.3
Excluded in favor
of direct
monitoring data
138
Manufacturing
Personal
Plant and Packing Personnel
35.0
1
8-hr TWA
TNO (CIVO)
2.3
Excluded in favor
of direct
monitoring data
139
Manufacturing
Personal
Plant and Packing Personnel-
Maintenance
219.0
1
8-hr TWA
TNO (CIVOl
(1999)
2.3
Excluded in favor
of direct
monitoring data
140
Manufacturing
Personal
Plant and Packing Personnel-
Maintenance
374.0
1
8-hr TWA
TNO (CIVOl
(1999)
2.3
Excluded in favor
of direct
monitoring data
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 143 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Row
Indusln
Tj pc of
Siimplo
\\ orkcr Acli\ ilj or
Siiinplin^ Locution
Mcllnlcnc Chloride
Airborne (onccnlnilion
(iiili/in3) •l h
Number of
Siimplos
Tj pc of
Mciisiircmcnl
Source
Score
K;ilion;ilc lor
Inclusion /
I'Aclusion
1
Distribution lab operator
Personal
Lab - analysis
6.1
1
STEL
Haloaenated
Solvents liidusfrv
1.6
Included 15-min
STEL - Worker
2
Distribution lab operator
Personal
Lab - analysis
6.1
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
3
Distribution lab operator
Personal
Lab - analysis
6.1
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
4
Distribution lab operator
Personal
Lab - analysis
6.1
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
5
Outside operator
Personal
Catch samples - other
5.4
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
6
Logistics distribution operator
Personal
Loading/unloading -
sampling and disconnect
loading hose
298.7
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
7
Outside operator
Personal
Lab - analysis
5.4
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
8
Outside operator
Personal
Catch samples - other
4.9
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
9
Outside operator
Personal
Catch samples - other
4.9
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
10
Logistics distribution operator
Personal
Loading/unloading -
sampling and connect
loading hose
4.7
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 144 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
11
Outside operator
Personal
Lab - analysis
4.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
12
Logistics distribution operator
Personal
Loading/unloading -
sampling and connect
loading hose
2.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
13
Logistics distribution operator
Personal
Loading/unloading -
sampling and connect
loading hose
1.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
14
Logistics distribution operator
Personal
Loading/unloading -
sampling and disconnect
loading hose
16.0
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
15
Logistics distribution operator
Personal
Loading/unloading -
sampling and disconnect
loading hose
6.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
16
Machinist
Personal
Line and equipment
opening
1.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
17
VCRU Technician
Personal
Change D530 Filters
0.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
18
VCRU Technician
Personal
Change D530 Filters
0.3
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
19
VCRU Technician
Personal
Change D530 Filters
0.3
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
20
VCRU Technician
Personal
Sample D517, stabilized
D518
0.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 145 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
21
CLM2 Thermal Technician
Personal
Sample Round
9.3
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
22
Control Lab Technician
Personal
Special Samples
11.8
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
23
Drum Fill Loader
Personal
Sample Methylene
Chloride Drum
6.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
24
Drum Fill Loader
Personal
Sample Methylene
Chloride Drum
6.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
25
Drum Fill Loader
Personal
Sample Methylene
Chloride Drum
14.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
26
Chloromethanes II Thermal
Technician
Personal
Sample rounds
4.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
27
Chloromethanes II Thermal
Technician
Personal
Sample rounds
20.8
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
28
VCRU Technician
Personal
Change D530 Filters
0.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
29
VCRU Technician
Personal
Change D530 Filters
0.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
30
VCRU Technician
Personal
Change D530 Filters
3.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 146 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi l.ociilion
Mcllnlcnc Chloride
Airhornc C oiicont r;ilion
(iiiii/inJ);i h
Number ol'
Siimpk's
Tj |H' of
Moiisiiivinonl
Source
Score
K;ilion;ilc lor
Inclusion /
I'Aclusion
31
VCRU Technician
Personal
D530 Filter Change
2.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
32
VCRU Technician
Personal
D530 Filter Change
27.4
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
33
VCRU Technician
Personal
D530 Filter Change
2.6
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
34
VCRU Technician
Personal
D530 Filter Change
3.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
35
Tank Area
Personal
Sample Collection
170.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
36
VCRU Technician
Personal
Special Samples
59.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
37
Chloromethanes II Thermal
Technician
Personal
Sample rounds
3.5
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
38
Chloromethanes II Thermal
Technician
Personal
Sample rounds
4.5
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
39
Chloromethanes II Thermal
Technician
Personal
Sample rounds
6.9
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
40
Drum Fill Loader
Personal
Sample Methylene
Chloride Railcar
215.4
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 147 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Cnnccnlr;ilinn
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisiircmcnl
Source
Score
K;ilion;ilc lor
Inclusion /
r.xclusion
41
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
298.7
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
42
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
152.8
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
43
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
104.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
44
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
45.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
45
Control Lab Technician
Personal
Dumping Jugs
79.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
46
Control Lab Technician
Personal
Dumping Jugs
125.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
47
Dram Fill Loader
Personal
Sample Methylene
Chloride Dram
125.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
48
Dram Fill Loader
Personal
Sample Methylene
Chloride Dram
132.0
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
49
Dram Fill Loader
Personal
Sample Methylene
Chloride Dram
145.9
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
50
Dram Fill Loader
Personal
Sample Methylene
Chloride Dram
159.8
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 148 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(niii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
51
Control Lab Technician
Personal
Dumping Jugs
138.9
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
52
Tank Area
Personal
Sample Collection
21.2
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
53
Tank Area
Personal
Sample Collection
111.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
54
Drum Fill Loader
Personal
Sample Methylene
Chloride Drum
72.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
55
Drum Fill Loader
Personal
Sample Methylene
Chloride Drum
86.8
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
56
Control Lab Technician
Personal
Dumping Jugs
90.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
57
VCRU Technician
Personal
D530 Filter Change
0.4
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
58
Chloromethanes II Thermal
Technician
Personal
Sample Collection
6.3
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
59
Chloromethanes II Thermal
Technician
Personal
Sample Collection
12.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
60
Tank Area
Personal
Sample Collection
62.5
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 149 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(niii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
61
VCRU Technician
Personal
D530 Filter Change
5.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
62
VCRU Technician
Personal
D530 Filter Change
8.3
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
63
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
45.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
64
Control Lab Technician
Personal
Dumping Jugs
180.6
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
65
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
100.7
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
66
Tank Area
Personal
Sample Collection
17.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
67
Control Lab Technician
Personal
Dumping Jugs
86.8
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
68
Chloromethanes II Thermal
Technician
Personal
Sample Collection
24.7
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
69
Chloromethanes II Thermal
Technician
Personal
Sample Collection
2.1
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
70
Chloromethanes II Thermal
Technician
Personal
Sample Collection
2.4
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 150 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(niii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
71
Control Lab Technician
Personal
Dumping Jugs
486.3
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
72
Control Lab Technician
Personal
Dumping Jugs
184.1
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
73
Drum Fill Loader
Personal
Sample Methylene
Chloride Railcar
104.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
74
VCRU Technician
Personal
D530 Filter Change
2.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
75
Control Lab Technician
Personal
Dumping Jugs
198.0
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
76
Drum Fill Loader
Personal
Sample Methylene
Chloride Railcar
18.4
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
77
VCRU Technician
Personal
D530 Filter Change
1.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
78
Chloromethanes II Thermal
Technician
Personal
Sample Collection
15.3
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
79
Control Lab Technician
Personal
Dumping Jugs
125.1
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
80
Chloromethanes II Thermal
Technician
Personal
Sample Collection
10.4
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 151 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(niii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
81
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
184.1
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
82
Chloromethanes II Thermal
Technician
Personal
Sample Collection
9.4
1
STEL
Haloaenated
Solvents Iiidustrv
1.6
Included 15-min
STEL - Worker
83
VCRU Technician
Personal
D530 Filter Change
11.5
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
84
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
18.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
85
Control Lab Technician
Personal
Dumping Jugs
253.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
86
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
24.0
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
87
Chloromethanes II Thermal
Technician
Personal
Sample Collection
1.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
88
Control Lab Technician
Personal
Dumping Jugs
41.7
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
89
VCRU Technician
Personal
D530 Filter Change
1.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
90
Tank Area
Personal
Sample Collection
59.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 152 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
91
VCRU Technician
Personal
D530 Filter Change
1.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
92
Chloromethanes II Thermal
Technician
Personal
Sample Collection
121.6
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
93
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
24.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
94
VCRU Technician
Personal
D530 Filter Change
3.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
95
Control Lab Technician
Personal
Dumping Jugs
128.5
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
96
Tank Area
Personal
Sample Collection
11.8
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
97
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
41.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
98
VCRU Technician
Personal
D530 Filter Change
4.5
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
99
Control Lab Technician
Personal
Purged sample line into
waste jug; filled 2 sample
bottles, then drained
sample line into waste
jug.
1.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
100
Control Lab Technician
Personal
Lab tech had jugs loaded
onto a cart, he pushed the
cart outside, dumped 7
18.8
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 153 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;iin|>lillvi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
jugs into the solvent for
recovery tote, put empty
jugs back on the cart and
rolled it back into the lab.
101
Tank Area
Personal
Sample Collection
10.1
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
102
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
2.0
1
STEL
Haloeenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
103
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
41.7
1
STEL
Haloeenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
104
Chloromethanes II Thermal
Technician
Personal
Collected 0600 samples -
T503 bottoms, T503
reflux, T504 bottoms,
T505 bottoms, T505
after, T506 after, Trap.
32.0
1
STEL
Haloeenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
105
Solvent Loader
Personal
Connected air line to
blow the load line out.
disconnected load hose,
connected air line to
pressure up railcar.
connected sampling
apparatus to railcar.
started purging sample
line into a waste bucket,
filled sample bottle and
rinsed it. dumped that
into a waste bucket, filled
sample bottle and capped
it. disconnected sampling
9.0
1
STEL
Haloeenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
Page 154 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;iin|>lillvi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
apparatus, closed air line
and finished
disconnecting railcar and
sealed it up.
106
VCRU Technician
Personal
Drained filter casing into
a waste bucket, removed
filter casing lid. scraped
excess carbon into filter,
pulled filter from casing
and put it over a waste
bucket, transferred to
D530 filter satellite drum,
placed a new filter in the
casing and re-bolted the
lid on. repeated this
process for the 2nd filter
casing.
9.0
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
107
Methanes Distillation Technician
Personal
Collected process sample
from DR-520
3.5
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
108
Methanes Distillation Technician
Personal
Collected process sample
fromDR-517. Open
bleed sampling station.
3.8
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
109
Methanes Distillation Technician
Personal
Collected process sample
from DR-503.
3.8
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
110
Methanes Distillation Technician
Personal
Collected process sample
from DR-503.
3.8
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
111
Methanes Distillation Technician
Personal
Collected process sample
from DR-520. Open
bleed sampling station.
4.2
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 155 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
112
Methanes Distillation Technician
Personal
Collected process sample
from DR-517.
4.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
113
Methanes Distillation Technician
Personal
Collected process sample
from DR-517. Closed
loop sampling station.
4.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
114
Methanes Hydrochlor Technician
Personal
Collected process sample
from DR-503.
4.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
115
Methanes Distillation Technician
Personal
Collected process sample
from T- 504 OH.
4.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
116
Methanes Distillation Technician
Personal
Collected process sample
from DR-520.
4.9
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
117
Methanes Distillation Technician
Personal
Collected process sample
from DR-503.
6.6
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
118
Methanes Distillation Technician
Personal
Collected process sample
from T- 504 OH.
8.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
119
Methanes Distillation Technician
Personal
Collected process sample
from DR-520.
11.5
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
120
Control Lab Technician
Personal
Took sample bottles to
Chlorine plant to sample
trailer, went with chlorine
plant operator to trailer,
filled 2 sample bottles,
after
purging sample line into
a waste jug. took samples
4.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 156 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;iin|>lillvi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
and waste jug back to lab.
dumped contents of waste
jug into solvent for
recovery tote, placed
sample bottles on
magnetic stirrer.
121
Control Lab Technician
Personal
Screwed on the funnel for
the solvent for recovery
tote. Dumped 7 jugs into
the tote, closed the
funnel, unscewed funnel
from tote and capped the
tote.
22.2
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
122
Dram Fill Loader
Personal
Sample Methylene
Chloride Dram
16.3
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
123
Dram Fill Loader
Personal
Sample Methylene
Chloride Dram
48.6
1
STEL
Haloeenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
124
Dram Fill Loader
Personal
Sample Methylene
Chloride Railcar
48.6
1
STEL
Haloeenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
125
Solvent Loader
Personal
Opened dram, inserted
tube into drum, filled
sample bottle and capped
it. Sealed drum back up.
14.6
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
126
Solvent Loader
Personal
Opened dram, inserted
sample tube into dram,
filled sample bottle, then
sealed drum.
3.2
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 157 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;iin|>lillvi Locution
Mcllnlcnc Chloride
Airhornc Cnnccnlr;ilinn
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisiircmcnl
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
127
Solvent Loader
Personal
Connected sampling
apparatus to railcar.
turned on air to pressure
up railcar. purged sample
line into a waste bucket,
filled sample bottle,
rinsed it into a waste
bucket, filled sample
bottle again and capped
it. disconnected sampling
apparatus and sealed up
railcar.
19.1
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
128
Control Lab Technician
Personal
Sampled pre-cooler
trailer, with the assistance
of the chlorine plant
operator, purged sample
line into a waste jug, then
filled 2 sample bottles,
purged excess from
sample line into waste
jug and then took jug
back to lab and put into
the solvent for recovery
tote.
14.2
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
129
VCRU Technician
Personal
D530 Filter Change
6.3
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
130
Chloromethanes II Thermal
Technician
Personal
Sample Collection
10.4
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
131
VCRU Technician
Personal
Blocked in filter. Drained
filter casing into waste
jugs from bleed valves.
41.7
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
Page 158 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;iin|>lillvi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(iiiii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
l-Acliisioii
removed filter casing lid.
removed carbon and filter
from filter casing, put a
new filter in. poured
carbon tet from waste
buckets into the filter
casing, replaced the lid of
the filter casing, repeated
this process for 2nd filter.
132
Control Lab Technician
Personal
Special Samples
10.4
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
133
Chloromethanes II Thermal
Technician
Personal
Sample Collection
8.3
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
134
VCRU Technician
Personal
D530 Filter Change
26.1
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
135
Control Lab Technician
Personal
Dumping Jugs
26.7
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
136
Solvent Loader
Personal
Special Samples
8.3
1
STEL
Haloaenated
Solvents Industry
1.6
Included 15-min
STEL - Worker
137
Solvent Loader
Personal
Special Samples
32.7
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
138
Chloromethanes II Thermal
Technician
Personal
Sample Collection
1.8
1
STEL
Haloaenated
Solvents Industry
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 159 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orkcr Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(niii/inJ);i h
Number of
Siimpk's
Tj pc of
Mciisu mucin
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
139
Control Lab Technician
Personal
Dumping Jugs
3.8
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
140
VCRU Technician
Personal
D530 Filter Change
194.5
1
STEL
Haloaenated
Solvents liidustrv
1.6
Included 15-min
STEL - Worker
141
Chloromethanes II Thermal
Technician
Personal
Sample Collection
7.3
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
142
Control Lab Technician
Personal
Special Samples
4.9
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
143
Solvent Loader
Personal
Special Samples
1.6
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
144
Control Lab Technician
Personal
Dumping Jugs
9.7
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
145
VCRU Technician
Personal
D530 Filter Change
48.6
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
146
Solvent Loader
Personal
Special Samples
3.2
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
147
Control Lab Technician
Personal
Special Samples
1.0
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
148
VCRU Technician
Personal
D530 Filter Change
3.1
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
Page 160 of 294
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TableApx A-2. Summary of Short-Term Inhalation Monitoring Data for Manufacturing
Uow
Indusln
Tj |H' of
Siimplo
\\ orker Acli\ il\ or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airhornc Concent nil inn
(iiiii/inJ);i h
Number ol'
Samples
Tj |H' of
\lc;isiircnicn(
Source
Scoiv
K;ilion;ik' lor
Inclusion /
l-Acliision
149
Control Lab Technician
Personal
Special Samples
6.6
1
STEL
Haloaenated
Solvents Iiidustrv
1.6
Included 15-min
STEL - Worker
150
Chloromethanes II Thermal
Technician
Personal
Sample Collection
8.3
1
STEL
Haloaenated
Solvents Iiidustrv
1.6
Included 15-min
STEL - Worker
151
Control Lab Technician
Personal
Dumping Jugs
22.2
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
152
Solvent Loader
Personal
Special Samples
5.6
1
STEL
Haloaenated
Solvents Industrv
Alliance (2018)
1.6
Included 15-min
STEL - Worker
153
Solvent Loader
Personal
Special Samples
3.3
1
STEL
Haloaenated
Solvents Industrv
1.6
Included 15-min
STEL - Worker
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 161 of 294
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A.2
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Processing as a Reactant
TableApx A-3 presents full-shift monitoring data for processing as a reactant.
• Rows 1 through 19 include TWA monitoring data provided by HSIA from a facility that
uses methylene chloride in the manufacturing process of fluorochemicals, with sampling
dates between 2010 and 2017 (Halogenated Solvents Industry Alliance. 2018).
• Row 20 provided a range of samples from "closed industrial applications" but was not
specific to processing as a reactant and therefore was excluded from the dataset (TNO
(Crvoi 19991
• Rows 21 through 24 present monitoring data provided by Olin Corporation for operators
and assistant operators during the production process (Olin Corp. 1979).
• Row 25 presents data provided by Arkema Inc. for a fluorochemicals manufacturing
facility. The data were claimed as Confidential Business Information and are not included
in this assessment. Higher quality data from HSIA were used instead (Bernstein. 2017).
Table Apx A-4 present short-term monitoring data:
• Row 1 provides a range of samples from "closed industrial applications" and is used as
surrogate data (TN< >9).
• Row 2 presents a 30-minute STEL provided by Olin Corporation during drumming
operations (Olin Corp. 1979)
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Table Apx A-3. Summary of Full-Shift Inhalation Monitoring Data for Processing as a Reactant
Row
Indusln
Tj po of
Siimplo
\\ nrkcr Acli\ ilj or
Siiinplin^ Locution
Mcllnlcnc Chloride
Airborne (oiktii trillion
(niii/ni1);|
Nil ill hoi' of
Siimplos
Tj po of
Mciisurcmcnl
Sourco
Score
Kiilioiiiilc lor
Inclusion /
r.xclnsion
1
Fluorochemicals Production
Personal
Maintenance
0.2
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
2
Fluorochemicals Production
Personal
Maintenance
0.2
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
3
Fluorochemicals Production
Personal
Maintenance
ND
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
4
Fluorochemicals Production
Personal
Chemical operator
ND
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
5
Fluorochemicals Production
Personal
Chemical operator
13.9
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
6
Fluorochemicals Production
Personal
Chemical operator
5.2
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
7
Fluorochemicals Production
Personal
Chemical operator
ND
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
8
Fluorochemicals Production
Personal
Laboratory technician
1.2
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
9
Fluorochemicals Production
Personal
Laboratory technician
8.9
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
10
Fluorochemicals Production
Personal
Maintenance
1.0
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
11
Fluorochemicals Production
Personal
Chemical operator
1.6
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-3. Summary of Full-Shift Inhalation Monitoring Data for Processing as a Reactant
Row
Indusln
Tj po of
Siimplo
\\ nrkcr Acli\ ilj or
Siiinplin^ Locution
Mcllnlcnc Chloride
Airborne (oiktii trillion
(niii/ni1);|
Nil ill hoi' of
Siimplos
Tj po of
Mciisurcmcnl
Sourco
Score
Kiilioiiiilc lor
Inclusion /
r.xclnsion
12
Fluorochemicals Production
Personal
Chemical operator
1.6
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
13
Fluorochemicals Production
Personal
Chemical operator
1.7
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
14
Fluorochemicals Production
Personal
Chemical operator
8.7
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
15
Fluorochemicals Production
Personal
Chemical operator
3.1
1
8-hr TWA
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Included-Worker
Full-Shift TWA
16
Fluorochemicals Production
Area
Chemical operator
0.3
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Excluded - used
personal samples
17
Fluorochemicals Production
Area
Chemical operator
2.0
1
8-hr TWA
Solvents Industrv
Alliance (2018)
1.6
Excluded - used
personal samples
18
Fluorochemicals Production
Area
Chemical operator
1.3
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Excluded - used
personal samples
19
Fluorochemicals Production
Area
Chemical operator
ND
1
8-hr TWA
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Excluded - used
personal samples
20
Other Chemical Industry
Personal
Closed Industrial
Applications
0-160
20 (mean)
unknown
8-hr TWA
TOO (CIVO)
(1999)
2.3
Excluded - used
direct monitoring
data instead
21
Olin Corporation - Crop
Protection
Personal
Operator
10.16
1
6.5-hr TWA
Olin Con) (1979)
2.2
Excluded - used
higher quality data
22
Olin Corporation - Crop
Protection
Personal
Operator
0.15
1
6.5-hr TWA
Olin Corn (1979)
2.2
Excluded - used
higher quality data
23
Olin Corporation - Crop
Protection
Personal
Asst Operator
21.77
1
6.5-hr TWA
Olin Corn (1979)
2.2
Excluded - used
higher quality data
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-3. Summary of Full-Shift Inhalation Monitoring Data for Processing as a Reactant
Row
Induslrj
Tj pc of
Siimplc
\\ orkcr Acli\ ilj or
Siiinplin^ Locution
Mclhjlcnc Chloride
Airborne ( 'onccn I ml ion
(niii/ni1);|
Nil ill hoi' of
Siimplos
Tj po of
Mciisiiicnicnl
Sou rco
Score
Riilioiiiile lor
Inclusion /
I'Aclusion
24
Olin Corporation - Crop
Protection
Personal
Asst Operator
0.27
1
6.5-hr TWA
Olin Con) (1979)
2.2
Excluded - used
higher quality data
25
Fluorochemicals Production
Personal
Not specified
CBI
Unknown
8-hr TWA
Bernstein (2017)
1.8
Excluded - used
higher quality data
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Table Apx A-4. Summary of Short-Term Inhalation Monitoring Data for Processing as a Reactant
Row
Indusln
Tj |K' of
Siimplc
Worker Acli\ ilj or
Siiniplin^ l.ocnlion
Mclhjlcnc Chloride
Airborne Conccnlr;ilion
(niii/ni1) •'
Nil in her of
Siimplcs
1 j pe of
Mciisiiicnicnl
Sou rco
Score
Riilioiiiile lor
Inclusion /
Lxclusion
1
Other Chemical Industry
Personal
Filter changing, charging,
discharging
350
1
10-min TWA
(1999)
2.3
Included - 10-min
STEL
2
Olin Corporation - Crop
Protection
Personal
Drumming
1,692.7
1
30-min TWA
Olin Com
(1979)
2.2
Included - 30-min
STEL
Page 165 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A.3 Processing - Incorporation into Formulation, Mixture, or
Reaction Product
TableApx A-5 presents full-shift data for processing methylene chloride into formulation,
mixtures, or reaction products.
• Row 1 presents 8-hr TWA concentrations ranging from 3.5 to 17.7 mg/m3 during filling
containers of methylene chloride-containing products (aerosols), as reported in a 1999
European Commission report (T> 99).
• Row 2 presents 8-hr TWA concentrations ranging from 95 to 628 mg/m3 during aerosol
product filling ((IPCS). 1996). The exposure data provided by IPCS is consolidated from
various health and environmental evaluations presented in other published literature.
Therefore, information about the specific facilities and other details corresponding to the
exposure data is not provided.
• Rows 3 through 12 contain 8-hr TWA exposure data compiled in EPA's 1985 exposure
and release assessment for processing into formulation. Exposure concentrations for
various workers ranged from 52 to l,260mg/m3, mainly during packing operations (US
EPA. 1985).
Table Apx A-6 presents short-term data for processing methylene chloride into formulation,
mixtures, or reaction products.
• Row 1 presents a peak exposure of 180 mg/m3 during filling containers of methylene
chloride-containing products (aerosols), as reported in a 1999 European Commission
report (TNC ?).
Page 166 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-5. Summary of Full-Shift Inhalation Monitoring Data for Processing - Incorporation into Formulation, Mixture, or Reaction Product
Row
Indusln
Tj po of
Siimplo
\\ nrkcr Acli\ ilj or
Siiinplin^ Locution
Mcllnlcnc Chloride
Airborne (oiktii trillion
(niii/ni1);i h
Nil ill hoi' of
Siimplos
Tj po of
Mciisurcmcnl
Sourco
Score
Kiilioiiiilc lor
Inclusion /
r.xclnsion
1
Formulation of DCM containing
products (aerosols)
Personal
Filling
3.5-17.7
Unknown
8-hr TWA
TOO (CIVO)
(1999)
2.3
Not used in favor
of individual data
points
2
Aerosol Products Manufacturing
Personal
Aerosol Filling
95 - 628
Unknown
8-hr TWA
(IPCS) (1996)
2.3
Not used in favor
of individual data
points
3
Paint Manufacture
Personal
Aerosol Line Filler
101
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
4
Specialty Cleaning
Personal
Line Operator
101
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
5
Specialty Cleaning
Personal
Line Operator
349
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
6
Specialty Cleaning
Personal
Valve Dropper
171
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
7
Specialty Cleaning
Personal
Valve Dropper
454
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
8
Paint, Varnish, Etc.
Personal
Batch Mixer
52
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
9
Paint, Varnish, Etc.
Personal
Package Grinding
464
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
10
Paint, Varnish, Etc.
Personal
Tipper Operator
1260
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
11
Paint, Varnish, Etc.
Personal
Valve Dropper
2223
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
12
Paint, Varnish, Etc.
Personal
Tub Cleaner
529
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
Full-Shift TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methy
ene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 167 of 294
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Table Apx A-6. Summary of Short-Term Inhalation Monitoring Data for Processing - Incorporation into Formulation, Mixture, or Reaction Product
Row
Indusln
Tj pc of
Siimplo
Worker Acli\ilj or
Siiinplin^ Locution
Mcllnlcnc ( hloriric
Airhornc Conccnlnilion
(inii/in1) •l h
NiiiiiIht of
Samples
Tj pc of
Moiisuivinonl
Sourer
Score
Kiilioiiiilo for
Inclusion /
Kxcliision
1
Formulation of DCM
containing products
(aerosols)
Personal
Filling
180
Unknown
Peak
(1999)
2.3
Not included -
duration not
provided.
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 168 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A.4 Import and Repackaging
TableApx A-7 presents the results of full-shift monitoring during distribution:
• Rows 1 through 5 contain full-shift exposure data at a distribution site during filling
drums, loading trucks, and transfer loading, ranging between 6.0 and 137.8 mg/m3
(Unocal Corporation. 1986).
Table Apx A-8 presents the results of short-term monitoring:
• Rows 1 through 4 contain short-term exposure data for the same site and activities as
presented for the full-shift data (Unocal Corporation. 1986).
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Table Apx A-7. Summary of Full-Shift Inhalation Monitoring Data for Import and Repackaging
Kow
111 (III si r>
Tj |K' of
Siimplo
Worker Acli\ ilj or
Siimpliiiii locution
Mclhjlcnc Chloride
Airborne Concent nil inn
img/nr');|
Number of
Samples
Tj pc of
Measurement
Sou rcc
Score
Kiilioiiiilo lor
Inclusion /
r.xclusion
1
Distribution
Personal
Filling drums / loading
trucks
39.64
1
Full-shift
Unocal Corooration
(1986)
2.0
Included - Full-
Shift TWA -
Worker
2
Distribution
Personal
Filling drums / loading
trucks
2.54
1
Full-shift
Unocal Corooration
(1986)
2.0
Included - Full-
Shift TWA -
Worker
3
Distribution
Personal
Filling drums / loading
trucks
2.54
1
Full-shift
Unocal Corooration
(1986)
2.0
Included - Full-
Shift TWA -
Worker
4
Distribution
Personal
Truck loading &
unloading
1.74
1
Full-shift
Unocal Corooration
2.0
Included - Full-
Shift TWA -
Worker
5
Distribution
Personal
Drumming solvent
14.47
1
Full-shift
Unocal Corooration
(1986)
2.0
Included - Full-
Shift TWA -
Worker
Table Apx A-8. Summary of Short-Term Inhalation Monitoring Data for
Row
Indnsln
Tj pc of
S;implc
W orkcr Acli\ ilj or
Siiniplin^ Locution
Mclhjlcnc Chloride
Airborne Concent nil ion
(niii/ni1) •'
Number of
Siimples
Tj pe of
Measurement
Source
Scoiv
Kiilioiiiile for
Inclusion /
I'Aclusion
1
Distribution
Personal
Transfer loading from
truck to storage tank
(4,100 gallons)
0.1
1
0.5-hr TWA
Corooration
6)
2.0
Included SIkh'I-
Term TWA -
Worker
2
Distribution
Personal
Truck loading (2,000 gal)
94
1
1-hr TWA
Unocal
Corooration
61
2.0
Included - Short-
Term TWA -
Worker
3
Distribution
Personal
Truck loading (800 gal)
10
1
0.5-hr TWA
Unocal
(1986)
2.0
Included - Short-
Term TWA -
Worker
mport and Repackaging
Page 170 of 294
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Table Apx A-8. Summary of Short-Term Inhalation Monitoring Data for
Row
Indusln
Tj po or
Siimpk*
W orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc ( hloriric
Airborne (nnccnlnilion
Number ol
S;i in pies
1 j pc of
McilMircillCIII
Sou itc
Score
Kiilioiiiilo lor
Inclusion /
l-Acliisioii
4
Distribution
Personal
Truck loading (250 gal)
8.6
1
1-hr TWA
Unocal
(1986)
2.0
Included - Short-
Term TWA -
Worker
mport and Repackaging
Page 171 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A.5 Cold Cleaning
Table Apx A-9 presents shows the full shift data available for cold cleaning:
• Row 1 provides a summary of a search of data from the UK Health and Safety
Executive's (HSE's) database, giving a range of exposures during cold degreasing
between 14-1,000 mg/m3 and a mean value if 280 mg/m3 for cold degreasing activities
(TNO (CIVOI 19991
• Row 2 indicates that exposure levels can be kept below 124 mg/m3 if stringent controls
are applied; however, the specific type of degreasing is not specified for this exposures;
nor was any sample duration for this data. Therefore, this data point was not used in the
analysis (H >99).
• Row 3 contains the results of EPA Monte Carlo modeling for cold degreasing for both
workers and ONUs (see Appendix F.2).
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Table Apx A-9. Summary of Full-Shift Inhalation Monitoring Data for Cold Cleaning
Row
liulusln
Tj pc of
Siimplo
\\ orker Adi\ il\ or
Siiniplin^ Locution
Mcllnlcnc Chloride Airborne
( oncciilr;ilion (niii/nv1)
Nil in hoi* or
Siimplos
Tj pe of
Mciisiiivinoiil
Sou IYO
Score
Kiilioiiiile loi* Inclusion /
r.xclnsion
1
Unknown
unknown
Cold degreasing
14 - 1,000
280 (mean)
Unknown
Unknown
TNO (CIVO)
(.1.999)
2.3
Included - Worker Full-Shift
TWA
2
Unknown
unknown
Degreasing
124
Unknown
Unknown
TNO (CIVO)
(.1.999)
2.3
Excluded - type of degreasing
not specified
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 173 of 294
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A.6
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Adhesives and Sealants
Full-shift data are summarized in TableApx A-10:
• Rows 1 through 12 contain personal 8-hr TWA sample data from a NIOSH Health
Hazard Evaluation in 1984 at the Sheldahl, Inc. facility in Northfield, MN (NIOSH.
1985). The facility manufactured flexible printed circuitry and employed approximately
650 workers, including 300 administrative personnel, 340 production workers, and 12
maintenance workers. NIOSH took various personal and area samples in the lamination
departments, where methylene chloride was used as a major component of the
adhesives/sealants and as a cleaning agent for the laminating machine and parts (non-
spray). Sample times ranged from 192 to 477 minutes.
• Row 13 presents full-shift spraying data included a 1999 European Commission report
(TNO (CIVOl. 1999). In the EC report, a number of previous risk evaluations were re-
examined for facilities where workers apply adhesives/sealants. Data were available from
sampling the plant workers and maintenance personal at one of these facilities where
spray adhesives/sealants were used.
• Row 14 provides a range of exposure data from glue spraying in the foam industry, using
local exhaust ventilation ( ?S). 1996)
• Rows 15 through 111 contain data from EPA's 1985 Occupational Exposure and
Environmental Release Assessment of Methylene Chloride, which compiled 8-hr TWA
adhesive/sealant use data (spray and non-spray ( >)
• Rows 112 and 113 contain area sample data that were not used; personal sampling data
were prioritized.
Short-term data are summarized in Table Apx A-l 1:
• Rows 1 through 10 contain provided monitoring data from OSHA for adhesive/sealant
sprayers from various inspections occurring between 2011 and 2016 (OS" 19)
• Rows 11 through 17 contain short-term personal monitoring data from the 1984 NIOSH
study discussed above. Rows 13 through 17 are excluded from the dataset, however,
because they are representative of a cleaning scenario and not relevant to
adhesives/sealants use (NIOSH. 1985).
• Rows 18 and 19 contain data from a 2016 NIOSH HHE that summarized
adhesive/sealant use at a federal crime lab between 2012-2014, for activities such as
transferring methylene chloride and bonding plastics. These data were excluded from the
dataset because the activities are relatively small scale, and likely not applicable to full-
scale industrial and commercial use (Beaucham et at.. 2016).
Page 174 of 294
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Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
Siimpk*
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Samples
Tj pc of
Mciisurcmcnl
Source
Score
Kiilioiiiilc lor Inclusion
/ I'Aclusion
1
Flexible Circuit Board
Manufacturing
Personal
Operator, Laminator #1
295.3
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
2
Flexible Circuit Board
Manufacturing
Personal
Operator, Laminator #4
250.1
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
3
Flexible Circuit Board
Manufacturing
Personal
Tape Machine, Dept. 12
458.5
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
4
Flexible Circuit Board
Manufacturing
Personal
Laminator #1, Dept. 14
218.8
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
5
Flexible Circuit Board
Manufacturing
Personal
Laminator #3 & 4, Dept. 14
225.8
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
6
Flexible Circuit Board
Manufacturing
Personal
Laminator #1, Dept. 14
132.0
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
7
Flexible Circuit Board
Manufacturing
Personal
Adhesive mixer, Dept. 14
90.3
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
8
Flexible Circuit Board
Manufacturing
Personal
Tape Machine, Dept. 12
204.9
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
9
Flexible Circuit Board
Manufacturing
Personal
Laminator #4, Dept. 14
114.6
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
10
Flexible Circuit Board
Manufacturing
Personal
Mixing room employee,
Dept. 14
302.2
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
11
Flexible Circuit Board
Manufacturing
Personal
Laminator #1, Dept. 14
86.8
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
12
Flexible Circuit Board
Manufacturing
Personal
36" Laminator, Dept. 12
364.7
1
8-hr TWA
NIOSH (1985)
1.6
Included - full-shift
TWA (non-spray)
13
Adhesives
Personal
Spray application
3.5-1,500
200 (average)
unknown
8-hr TWA
TNO (CIVO)
(1999)
2.3
Included - full-shift
TWA (spray)
14
Foam Industry
Personal
Glue spraying
85 - 244
unknown
8-hr TWA
K
h
to
i
2.3
Included - full-shift
TWA (spray)
15
Fiberglass Boats
Personal
Deck Lamination
10.47
1
TWA
|5}
1.4
Included - full-shift
TWA (non-spray)
16
Fiberglass Boats
Personal
Deck Lamination
10.47
1
TWA
|5}
1.4
Included - full-shift
TWA (non-spray)
Page 175 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
Siimpk*
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Samples
Tj pc of
Mciisurcmcnl
Source
Score
Kiilioiiiilc lor Inclusion
/ I'Aclusion
17
Fiberglass Boats
Personal
Deck Lamination
10.47
1
TWA
US EPA (1985)
1.4
Included - full-shift
TWA (non-spray)
18
Fiberglass Boats
Personal
Deck Lamination
6.98
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
19
Fiberglass Boats
Personal
Gel Kote
17.45
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
20
Fiberglass Boats
Personal
Lamination
3.49
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
21
Fiberglass Boats
Personal
Lamination
1.745
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
22
Fiberglass Boats
Personal
Lamination
6.98
1
TWA
si
1.4
Included - full-shift
TWA (non-spray)
23
Fiberglass Boats
Personal
Lamination
10.47
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
24
Fiberglass Boats
Personal
Gel Kote
10.47
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
25
Fiberglass Boats
Personal
Hull Lamination
20.94
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
26
Fiberglass Boats
Personal
Hull Lamination
17.45
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
27
Fiberglass Boats
Personal
Hull Lamination
28.94
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
28
Fiberglass Boats
Personal
Hull Lamination
53.84
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
29
Fiberglass Boats
Personal
Lam Stiffening
17.45
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
30
Fiberglass Boats
Personal
Hull Lamination
17.45
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
31
Fiberglass Boats
Personal
Gel Kote
6.98
1
TWA
m
1.4
Included - full-shift
TWA (non-spray)
32
Fiberglass Boats
Personal
Mold Repair
10.47
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
Page 176 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
Siimpk*
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Samples
Tj pc of
Mciisurcmcnl
Source
Score
Kiilioiiiilc lor Inclusion
/ I'Aclusion
33
Fiberglass Boats
Personal
Deck Lamination
26.94
1
TWA
US EPA (1985)
1.4
Included - full-shift
TWA (non-spray)
34
Fiberglass Boats
Personal
Hull Lamination
27.92
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
35
Fiberglass Boats
Personal
Deck Lamination
6.98
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
36
Fiberglass Boats
Personal
Deck Lamination
3.49
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
37
Fiberglass Boats
Personal
Deck Lamination
10.47
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
38
Fiberglass Boats
Personal
Stiffening
13.96
1
TWA
si
1.4
Included - full-shift
TWA (non-spray)
39
Fiberglass Boats
Personal
Gel Kote
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
40
Fiberglass Boats
Personal
Hull Lamination
10.47
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
41
Fiberglass Boats
Personal
Hull Lamination
6.98
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
42
Fiberglass Boats
Personal
Hull Lamination
10.47
1
TWA
m
1.4
Included - full-shift
TWA (non-spray)
43
Fiberglass Boats
Personal
Hull Lamination
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
44
Fiberglass Boats
Personal
Hull Lamination
6.98
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
45
Fiberglass Boats
Personal
Hull Lamination
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
46
Fiberglass Boats
Personal
Stiffening
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
47
Fiberglass Boats
Personal
Stiffening
6.98
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
48
Fiberglass Boats
Personal
Gel Kote
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
Page 177 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
Siimpk*
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Samples
Tj pc of
Mciisurcmcnl
Source
Score
Kiilioiiiilc lor Inclusion
/ I'Aclusion
49
Fiberglass Boats
Personal
Lamination
3.49
1
TWA
US EPA (1985)
1.4
Included - full-shift
TWA (non-spray)
50
Fiberglass Boats
Personal
Lamination
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
51
Fiberglass Boats
Personal
Lamination
13.96
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
52
Fiberglass Boats
Personal
Gel Kote
6.98
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
53
Fiberglass Boats
Personal
Lamination
3.49
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
54
Fiberglass Boats
Personal
Lamination
30.39
1
TWA
si
1.4
Included - full-shift
TWA (non-spray)
55
Fiberglass Boats
Personal
Lamination
6.98
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
56
Fiberglass Boats
Personal
Stringer
3.49
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
57
Plastics Materials
Personal
Laminator Helper
0.073
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
58
Plastics Materials
Personal
Laminator Helper
87.25
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
59
Plastics Materials
Personal
Laminator Helper
87.25
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
60
Plastics Materials
Personal
Mold Controller
87.25
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
61
Plastics Materials
Personal
PM Laminator
48.86
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
62
Building Paper
Personal
Laborer
223.36
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
63
Building Paper
Personal
Laminator
177.99
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
64
Building Paper
Personal
Laminator Laborer
87.25
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
Page 178 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
S;implc
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Methylene Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Samples
Tj pc of
Mc;iMircmcnl
Source
Score
Kiilioiiiile lor Inclusion
/ I'Aclusion
65
Misc. Plastic Products
Personal
Laminator
0
1
TWA
US EPA (1985)
1.4
Included - full-shift
TWA (non-spray)
66
Misc. Plastic Products
Personal
Lead Man
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
67
Misc. Plastic Products
Personal
Lead Man
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
68
Misc. Plastic Products
Personal
Laminator
0
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
69
Wood Household
Furniture
Personal
Laminator
79.118
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
70
Boat Building
Personal
Sprayer
60.028
1
TWA
si
1.4
Included - full-shift
TWA (spray)
71
Boat Building
Personal
Foreman
72.941
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
72
Boat Building
Personal
Foreman/Sprayer
60.796
1
TWA
in
1.4
Included - full-shift
TWA (spray)
73
Boat Building
Personal
Roller/Sprayer
86.23
1
TWA
in
1.4
Included - full-shift
TWA (spray)
74
Boat Building
Personal
Sprayer
43.555
1
TWA
in
1.4
Included - full-shift
TWA (spray)
75
Boat Building
Personal
Gel Coat Sprayer
34.481
1
TWA
in
1.4
Included - full-shift
TWA (spray)
76
Boat Building
Personal
Sprayer Helper
93.637
1
TWA
in
1.4
Included - full-shift
TWA (spray)
77
Boat Building
Personal
Layup Sprayer
0
1
TWA
m
1.4
Included - full-shift
TWA (spray)
78
Boat Building
Personal
Layup Sprayer
0
1
TWA
in
1.4
Included - full-shift
TWA (spray)
79
Boat Building
Personal
Sprayer
0
1
TWA
in
1.4
Included - full-shift
TWA (spray)
80
Boat Building
Personal
Layup Sprayer
0
1
TWA
in
1.4
Included - full-shift
TWA (spray)
Page 179 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
Siimpk*
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Samples
Tj pc of
Mciisurcmcnl
Source
Score
Kiilioiiiilc lor Inclusion
/ I'Aclusion
81
Boat Building
Personal
Layup Sprayer
0
1
TWA
US EPA (1985)
1.4
Included - full-shift
TWA (spray)
82
Boat Building
Personal
Layup
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
83
Boat Building
Personal
Layup
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
84
Boat Building
Personal
Layup
0
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
85
Boat Building
Personal
Layup
0.14
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
86
Boat Building
Personal
Layup
4.18
1
TWA
si
1.4
Included - full-shift
TWA (non-spray)
87
Air Brake Manufacture
Personal
Gluer
205.918
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
88
Foam Products
Personal
Glue Mixing
0.007
1
TWA
m
1.4
Included - full-shift
TWA (non-spray)
89
Abrasive Products
Personal
Gluer
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
90
Abrasive Products
Personal
Gluer
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
91
Abrasive Products
Personal
Gluer
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
92
Abrasive Products
Personal
Portable Belt Gluer
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
93
Public Bldg. Furniture
Personal
Glue Gun Operator
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
94
Public Bldg. Furniture
Personal
Glue Gun Operator
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
95
Foam Products
Personal
Hot Wire Cutting
0.698
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
96
Foam Products
Personal
Hot Wire Cutting
0.698
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
Page 180 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
S;implc
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
( onccnlr;ilion (niii/ni1) 1 h
Number ol°
Samples
Tj pc of
Mciisurcmcnl
Source
Score
Kiilioiiiile lor Inclusion
/ I'Acliision
97
Foam Products
Personal
Hot Wire Cutting
0.349
1
TWA
US EPA (1985)
1.4
Included - full-shift
TWA (non-spray)
98
Foam Products
Personal
Foam Processing
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
99
Foam Products
Personal
Foam Processing
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
100
Foam Products
Personal
Adhesive Storage
0
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
101
Foam Products
Personal
Adhesive Storage
0.044
1
TWA
Ml
1.4
Included - full-shift
TWA (non-spray)
102
Abrasive Products
Personal
Presser
0
1
TWA
si
1.4
Included - full-shift
TWA (non-spray)
103
Plastic Materials
Personal
Medical Device Ass.
575.05
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
104
Plastic Materials
Personal
Micro Flush Assembly
206.1
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
105
Plastic Materials
Personal
Assembler
20.94
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
106
Plastic Materials
Personal
Micro Flush Assembly
397.162
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
107
Rubber & Plastic
Footwear
Personal
Sock Liner
145.917
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
108
Rubber & Plastic
Footwear
Personal
Lacer
77.827
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
109
Rubber & Plastic
Footwear
Personal
Sock Liner
120.405
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
110
Rubber & Plastic
Footwear
Personal
Sock Liner
187.364
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
111
Public Bldg. Furniture
Personal
Upholsterer
0
1
TWA
in
1.4
Included - full-shift
TWA (non-spray)
112
Flexible Circuit Board
Manufacturing
Area
Area Sample, Laminator #4
284.8
1
TWA
NIOSH (1985)
1.6
Excluded - prioritized
personal samples
Page 181 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-10. Summary of Full-Shift Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
Indusln
Tj pc of
Siimplc
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
C onceii 1 r;ilion inig/iir') 1 h
Number ol°
Siimples
Tj pc of
Mciisurcmcnl
Soiiivo
Scoiv
Kiilioiiiilo lor Inclusion
/ I'Aclusion
113
Cabinet Manufacturing
Area
Spray contact cement
1,042- 1,736
unknown
TWA
Mahmiid and
2.3
Excluded - prioritized
personal samples
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 182 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-ll. Summary of Short-Term Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
1 ihIii Mn
Tj |>c of
Siimplc
Worker Aclit il> or
Siiinplin^ Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(ing/iir¦') 1 h
Number ol°
S;i in pies
Tj pi* of
Moiisiiivinonl
Soiiivo
Score
Kiilioiiiilc lor Inclusion / l-Aclusion
1
Metal Window and Door
Manufacturing
Personal
Adhesive Sprayer
719.0
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
2
Metal Window and Door
Manufacturing
Personal
Adhesive Sprayer
576.6
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
3
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
142.4
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
4
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
225.8
1
6-min-STEL
OSHA (2019)
1.3
Excluded in favor of 15 -minute
sample times
5
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
479.4
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
6
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
159.8
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
7
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
361.3
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
8
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
100.7
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
9
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
284.8
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
10
Wood Kitchen Cabinet and
Countertop Manufacturing
Personal
Adhesive Sprayer
12.2
1
15-min-STEL
OSHA (2019)
1.3
Included - Industrial 15-min STEL -
Spray
11
Flexible Circuit Board
Manufacturing
Personal
Operator, laminator #3 & #4,
cleaning
423.8
1
15-min-STEL
NIOSH (1985)
1.6
Included - Industrial 15-min STEL -
Non-Spray
12
Flexible Circuit Board
Manufacturing
Personal
Employee mixing adhesives,
Dept 12
569.7
1
15-min-STEL
NIOSH (1.985)
1.6
Included - Industrial 15-min STEL -
Non-Spray
13
Flexible Circuit Board
Manufacturing
Personal
Employee cleaning parts in
room with no ventilation
6085.8
1
Short Term
NIOSH (1.985)
1.6
Excluded - cleaning operations
14
Flexible Circuit Board
Manufacturing
Personal
Operator cleaning 39 inch
laminator, Dept 12
2539.2
1
Short Term
NIOSH (1.985)
1.6
Excluded - cleaning operations
15
Flexible Circuit Board
Manufacturing
Personal
Operator cleaning tape
machine, Dept 12
1754.2
1
Short Term
NIOSH (1.985)
1.6
Excluded - cleaning operations
16
Flexible Circuit Board
Manufacturing
Personal
Employee cleaning "tunnel"
of laminator #10, Dept 14
1545.8
1
Short Term
NIOSH (.1.985)
1.6
Excluded - cleaning operations
Page 183 of 294
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Table Apx A-ll. Summary of Short-Term Inhalation Monitoring Data for Application of Adhesives and Sealants
Row
1 ihIii Mn
Tj |>c of
Siimplc
Worker Aclit il> or
Siiinplin^ Locution
Mcllnlcnc Chloride
Airhornc Conccnlr;ilion
(ing/iir¦') 1 h
Number ol°
S;i in pies
Tj pi* of
MciiMircmcnl
Soiiivo
Score
Kiilioiiiilc lor Inclusion / l-Aclusion
17
Flexible Circuit Board
Manufacturing
Personal
Employee cleaning "tunnel"
of laminator#10, Dept 14
930.9
1
Short Term
NIOSH (.1.985)
1.6
Excluded - cleaning operations
18
Federal Crime Lab
Personal
Pouring MeCl into secondary
container (2 min)
ND (<69.5)
1
Short Term
Beaucham et
2.3
Excluded - Not typical scale of
industrial/commercial applications.
13
Federal Crime Lab
Personal
Using MeCl to connect
pieces of plastic in the shop
(few seconds)
ND (<69.5)
1
Short Term
Beaucham et
at (20.1.6)
2.3
Excluded - Not typical scale of
industrial/commercial applications.
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 184 of 294
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A.7
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Paints and Coatings
Full-shift monitoring data for paints and coatings are presented in TableApx A-12:
• Rows 1 and 2 contain 8-hr TWA data points for paint sprayers in unknown industries,
ranging from 14.2 to 222.3 mg/m3, from OSHA inspections (OSHA. 2019)
• Rows 2 through 27 contain data from EPA's 1985 exposure and release assessment,
which compiled full-shift TWA data for spray painters in various industries. These
exposure concentrations ranged from ND to 439.7 mg/m3 (US EPA. 1985)
• Rows 28 through 32 contain exposure data compiled by DOD in 2016 during structural
repair and painting. DOD indicated that typical operation duration times are zero to 15
minutes, although samples were taken over ~2 hrs. EPA assumed that no other exposure
to workers occurs over the remaining 6 hour period and averaged the exposures over an
8-hr period to calculate 8-hr TWAs ((DOEHRS-IH). 2018).
Short-term monitoring data are presented in Table Apx A-13:
• Rows 1 and 2 contain short-term data from a NIOSH Health Hazard Evaluation in 1981
at a Metro Bus Maintenance Shop in Washington D.C. The HHE reported ND exposure
concentrations over 40-50 minute sample durations (Love and Kern. 1981).
• Rows 3 through 10 contain short-term data from a NIOSH Health Hazard Evaluation in
1973 at a metal fabrication plant. The HHE reported exposures from 1.0 - 74.0 mg/m3
during spray painting activities (Vandervort and Polakoff. 1973).
• Rows 11 through 19 contain 15-min exposure data compiled by DOD during painting and
coating operations. Only one data point indicated spray coating ((DOEHRS-IH). 2018).
Page 185 of 294
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Table Apx A-12. Summary of Full-Shift Inhalation Monitoring Data for Application of Paints and Coatings
Row
1 ndii sin
Tj |>c of
S;i in pie
\\ orkcr Acli\ i(\ or Siiinplin^
Locution
Mcllnlcnc Chloride Airborne
( onccnlriilion (iii^/ni1) >h
NiiiiiIht of
Siimplcs
T\pc of
Mc;isiircmcnl
Source
Score
Kiilioiiiilc for Inclusion /
r.xclnsion
1
Unknown
Personal
Paint Sprayer
14.2
1
8-hr TWA
OSHA (2019)
1.3
Included - full-shift TWA
2
Unknown
Personal
Paint Sprayer
222.3
1
8-hr TWA
OSHA (2019)
1.3
Included - full-shift TWA
3
Sporting Goods
Personal
Spray Painter
ND
1
8-hr TWA
US EPA(
1985)
1.4
Included - full-shift TWA
4
Sporting Goods
Personal
Spray Painter
76.0
1
8-hr TWA
US EPA(
1985)
1.4
Included - full-shift TWA
5
Sporting Goods
Personal
Spray Painter
270.0
1
8-hr TWA
US EPA i"
1985)
1.4
Included - full-shift TWA
6
Sporting Goods
Personal
Spray Painter
35.0
1
8-hr TWA
US EPAf
1985)
1.4
Included - full-shift TWA
7
Metal Products
Personal
Spray Painter
22.5
1
6-hr TWA
US EPAf
1985)
1.4
Included - full-shift TWA
8
Metal Products
Personal
Spray Painter
377.3
1
6-hr TWA
US EPAC
1985)
1.4
Included - full-shift TWA
9
Metal Products
Personal
Spray Painter
313.5
1
6-hr TWA
US EPA i"
1985)
1.4
Included - full-shift TWA
10
A/C Equipment
Personal
Spray Painter
64.0
1
8-hr TWA
US EPAf
1985)
1.4
Included - full-shift TWA
11
A/C Equipment
Personal
Spray Painter
54.0
1
8-hr TWA
US EPAf
1985)
1.4
Included - full-shift TWA
12
A/C Equipment
Personal
Spray Painter
63.0
1
8-hr TWA
US EPAC
1985)
1.4
Included - full-shift TWA
13
A/C Equipment
Personal
Spray Painter
36.0
1
8-hr TWA
US EPA i"
1985)
1.4
Included - full-shift TWA
14
A/C Equipment
Personal
Spray Painter
74.0
1
8-hr TWA
US EPAf
1985)
1.4
Included - full-shift TWA
15
A/C Equipment
Personal
Spray Painter
0.5
1
8-hr TWA
US EPAf
1985)
1.4
Included - full-shift TWA
16
A/C Equipment
Personal
Spray Painter
3.0
1
8-hr TWA
US EPAC
1985)
1.4
Included - full-shift TWA
17
A/C Equipment
Personal
Spray Painter
4.0
1
8-hr TWA
US EPA(
1985)
1.4
Included - full-shift TWA
18
Fabr. Rubber
Products NEC
Personal
Spray Painter
ND
1
8-hr TWA
US I iS\
1.4
Included - full-shift TWA
19
Public Bldg.
Furniture
Personal
Spray Painter
65.6
1
8-hr TWA
US I iS\
1.4
Included - full-shift TWA
20
A/C & Heating
Equipment
Personal
Spray Painter
87.3
1
8-hr TWA
US I iS\
1.4
Included - full-shift TWA
21
A/C & Heating
Equipment
Personal
Spray Painter
87.3
1
8-hr TWA
US I i5)
1.4
Included - full-shift TWA
22
Airports
Personal
Spray Painter
69.8
1
8-hr TWA
US I iS)
1.4
Included - full-shift TWA
23
Surgical
Instruments
Personal
Spray Painter
42.2
1
8-hr TWA
US I i5)
1.4
Included - full-shift TWA
Page 186 of 294
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Table Apx A-12. Summary of Full-Shift Inhalation Monitoring Data for Application of Paints and Coatings
Row
1 ndii sin
Tj |>c of
S;i in pie
\\ orkcr Acli\ i(\ or Siiinplin^
Locution
Mcllnlcnc Chloride Airborne
( onccnlriilion (iii^/ni1) >h
NiiiiiIht of
Siimplcs
T\pc of
Mc;isiircmcnl
Source
Score
Kiilioiiiilc for Inclusion /
r.xclnsion
24
Misc. Plastic
Products
Personal
Spray Painter
156.7
1
8-hr TWA
US I iS\
1.4
Included - full-shift TWA
25
Misc. Plastic
Products
Personal
Spray Painter
439.7
1
8-hr TWA
US I $5)
1.4
Included - full-shift TWA
26
Misc. Plastic
Products
Personal
Spray Painter
255.0
1
8-hr TWA
US I $5)
1.4
Included - full-shift TWA
27
Misc. Plastic
Products
Personal
Spray Painter
264.5
1
8-hr TWA
US I $5)
1.4
Included - full-shift TWA
28
DOD
Personal
009A-5, STRUCTURAL
REPAIR, PAINTING OPS
0.9
1
2-hr TWA
((DOEHRS-IH).
2018)
1.3
Included - full-shift TWA
(averaged over 8-hr)
29
DOD
Personal
009A-5, STRUCTURAL
REPAIR, PAINTING OPS
10.7
1
2-hr TWA
((DOEHRS-IH).
2018)
1.3
Included - full-shift TWA
(averaged over 8-hr)
30
DOD
Personal
009A-5, STRUCTURAL
REPAIR, PAINTING OPS
10.6
1
2-hr TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - full-shift TWA
(averaged over 8-hr)
31
DOD
Personal
009A-5, STRUCTURAL
REPAIR, PAINTING OPS
7.1
1
2-hr TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - full-shift TWA
(averaged over 8-hr)
32
DOD
Personal
009A-5, STRUCTURAL
REPAIR, PAINTING OPS
2.8
1
2-hr TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - full-shift TWA
(averaged over 8-hr)
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 187 of 294
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Table Apx A-13. Summary of Short-Term Inhalation Monitoring Data for A
Uow
liulusln
Tj |K' of
Siimplo
\\ orkcr Acli\ il\ or Siimpliii^
Locution
Mcllnlcnc Chloride Airborne
( onccnlr;ilion nng/iiv') •lh
Number of
Samples
Tj pc of
Mciisu miicul
Soiiito
Score
K:ilion;ilc for
Inclusion / I'.xclnsion
1
Mcli'o 1 ills
maintenance shop
Personal
Painting
ND (MJ.Ul;
1
STEL
(1981)
1.8
Worker 1-hr S TEL
2
Metro Bus
maintenance shop
Personal
Painting
ND (<0.01)
1
STEL
Love and Kern
(l"
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-13. Summary of Short-Term Inhalation Monitoring Data for Application of Paints and Coatings
Row
liulusln
Tj pc of
Siimplc
\\ nrkcr Acli\ il\ or S;implin^
Locution
Mcllnlcnc Chloride Airborne
( onccn(r;ilion (niii/ni1) >h
Number of
Siimplcs
Tj pc of
Moiisuivinonl
Sourcc
Score
Kiilioiiiilo for
Inclusion / r.xclnsion
16
DOD
Personal
IND-002-00 Chemical cleaning
multi ops.
1.7
1
STEL
((DOEHRS-IH).
2018)
1.3
Worker 15-min STEL
17
DOD
Personal
IND-006-00 Coating
Operations, Multiple Operations
1.9
1
STEL
((DOEHRS-IH).
20.1.8)
1.3
Worker 15-min STEL
18
DOD
Personal
IND-006-00 Coating
Operations, Multiple Operations
1.9
1
STEL
((DOEHRS-IH).
20.1.8)
1.3
Worker 15-min STEL
19
DOD
Personal
NPS ECE aerosol can painting
13.5
1
STEL
((DOEHRS-IH).
20.1.8)
1.3
Worker 15-min STEL
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 189 of 294
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AJ8 Adhesive and Caulk Removers
Note that this section was extracted from the 2014 Risk Assessment on Methylene Chloride
(U.S. EPA, i ), as data from paint stripping by professional contractors was used as a
surrogate scenario for adhesive and caulk remover use.
Inhalation exposure monitoring data of methylene chloride during paint stripping, specifically
full-shift 8-hr TWA breathing zone or personal samples, were used for risk analyses. Data
monitoring of over 5 hour duration are assumed adequate to represent full shift exposure levels.
Methylene chloride exposure data for paint stripping conducted by professional contractors
were not identified in the literature search. However, TNO (CIVO) (1999) reported some
methylene chloride exposure data for consumer use of methylene chloride -based paint
strippers/ The EU report states that there is "probably ...no fundamental difference between the
application ofpaint removers by professional painters and consumers'' and goes on to further
state that, in regard to the cited consumer exposure studies, "the test situations and data
described/are assumed validfor occupational exposure during professional use as weir (TNO
There are differences between the consumer and occupational use of methylene chloride -based
paint strippers by professional contractors. For instance, professional contractors are expected
to have higher frequencies and durations of exposure, and a likely higher prevalence of
respirator use, as compared to consumers. It is also not clear whether overall activity patterns
and practices of contractors match those of consumers or whether the overall distributions of
exposures of contractors and consumers have any semblance to one another. Despite these
uncertainties, EPA/OPPT considered some of the literature data for consumers in the
occupational exposure assessment of paint strippers.
The EU report conducted a literature review and identified the following consumer exposures
to methylene chloride during paint stripping (T> j99):
• A 1990 EPA investigation estimated consumer exposure levels ranging from 35 mg/m3
(10 ppm) to a few short-term exposures of over 14,100 mg/m3 (4,063 ppm)2. The
majority of the exposures were below 1,770 mg/m3 (510 ppm) (TI ).
• A separate study conducted by a solvent manufacturer measured methylene chloride
exposures during testing in a small room. One test conducted with ventilation measured a
2-hr TWA exposure of 289 mg/m3 (83.3 ppm), but the ventilation rate or air change rate
was not specified. The peak exposure during application was 460 mg/m3 (133 ppm). The
peak exposure during scrape-off ranged from 710 to 1,410 mg/m3 (205 to 406 ppm), and
the observed maximum during the study was 3,530 mg/m3 (1,017 ppm). When no
ventilation was used, the worst-case exposure exceeded 14,000 mg/m3 (4,035 ppm).
Based on the solvent manufacturer, 8-hr TWA exposures under supplier-recommended
ventilation would be 187 to 226 mg/m3 (54 to 65 ppm) (TP; >99).
• A literature review conducted by the United Kingdom (UK) in 1998 identified 1-hr TWA
exposures of 840 to 2,765 mg/m3 (240 to 790 ppm) in an unventilated room, and 129.5 to
948 mg/m3 (37 to 270 ppm) with the door open (Th 99).
• An older study from 1981 found 8-hr TWA exposures of 460 to 2,980 mg/m3 (133 to 859
ppm)3 in unventilated rooms and 60 to 400 mg/m3 (17 to 115 ppm) ventilated rooms
(TNO fCIYOI 1999).
2 The short-term exposure of over 14,100 mg/m3 (4,063 ppm) was selected to represent the high end of the range of
short-term and other non-8-hr TWA values for professional contractors in TableApx A-14 (TNO (CIVO). 1999).
EPA/OPPT calculated the midpoint values from the high-end values reported by the study authors.
3 The methylene chloride air concentrations of 60 mg/m3 (17 ppm) and 2,980 mg/m3 (859 ppm) were selected to
represent the low and high ends of the range of 8-hr TWA values, respectively, for professional contractors in
Table Apx A-14 (TNO (CIVO). .1.999). EPA/OPPT calculated midpoint values from the high and low values
reported by the study authors.
Page 190 of 294
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Another EU report described a 2004 study that cited several case studies of methylene chloride
monitoring during paint stripping of buildings in the UK (ELI. 2007).
An average personal methylene chloride exposure of 182 mg/m3 (52 ppm), ranging from 21 to
318 mg/m3 (6 to 92 ppm), was reported for "paint stripping at a block of flats" (EU. 2007).
• A case study of paint stripping in a building stairway reported an average personal
methylene chloride exposure of 86 mg/m3 (25 ppm) (EU. 2007).
• Another case study observed an average personal methylene chloride exposure of 710
mg/m3 (205 ppm) while paint stripping a ceiling. The methylene chloride air
concentration was measured during brush application and stripping over approximately
40 minutes (EU. 2007).
• A 2003 case study of the paint stripping of an external fa9ade observed personal
monitoring methylene chloride concentrations with a maximum of 400 mg/m3 (115 ppm)
and a minimum of zero mg/m3.4 The average of all of the reported means was
approximately 62 mg/m3 (18 ppm) (EU. 2007).
Midwest Research Institute (MRI) prepared a report for EPA in 1994 that documented an
experimental investigation of consumer exposures to solvents used in paint stripping products
with eliminated or reduced methylene chloride content. MRI investigated five paint strippers,
two of which contained methylene chloride (along with other solvents, but the concentrations
were not specified). The paint stripping was conducted in a laboratory-based, environment-
controlled, room-sized test chamber. The paint strippers were used on a plywood panel coated
with a primer coat and two finish coats. The air exchange rate for the experiments ranged from
0.54 to 0.76 air changes per hr (ACH), with an average of 0.58 ACH. The air exchange rate of
approximately 0.5 ACH was intended to replicate the ventilation rate of an enclosed room in a
typical residence as a worst-case scenario (U.S. EPA. 2014).
During each experiment, the following samples were taken for the spray and brush applications:
a personal breathing zone sample of the test subject using the paint stripper; two stationary air
samples for the duration of the paint stripping task; and one stationary air sample beginning at
the start of the paint stripping and lasting for 8 hrs (U.S. EPA. 2014). The results are summarized
below.
• For the spray application of the methylene chloride -based paint stripper, MRI reported
breathing zone methylene chloride concentrations of 3,000 and 3,400 mg/m3 (865 and
980 ppm) over 1.7-and 1.5-hour sampling times, respectively. The stationary length-of-
task concentrations ranged from 2,900 to 3,600 mg/m3 (836 to 1,037 ppm). The
stationary, 8-hr TWA concentration ranged from 1,700 to 2,000 mg/m3 (490 to 576
PPm) (U.S. EPA. 2014).
• MRI reported breathing zone concentrations of 380 and 430 mg/m3 (110 and 124 ppm)
over sampling times of approximately 2 hours for the brush application. The stationary
length-of task concentrations ranged from 300 to 490 mg/m3 (86 to 141 ppm). The
stationary, 8-hr TWA concentration ranged from 230 to 270 mg/m3 (66 to 78 ppm) (U.S.
EPA. 2014).
TableApx A-14 and TableApx A-15 present a summary of exposure data.
4 The short-term exposure of 0 mg/m3 was selected to represent the low end of the range of short-term and other non-
8-hr TWA values for professional contractors in Table Apx A-14 (TNO(CIVO). 1999).
Page 191 of 294
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Table Apx A-14. Summary of Full-Shift Inhalation Monitoring Data for Paint Stripping by Professional Contractors
Row
Indusln
Tj pc of
Siimplo
\\ orkcr Acli\ il\ or
Siiinplin^ Locution
Lslim;ilcd Mcllnlcnc Chloride Airborne
( onccnlr;ilion (iiiii/mM •'
Number ol°
Samples
Tj pc of
Measurement
Source
Score
Kalionalc lor Inclusion /
Lxclusion
Mean
Ili»h
Midpoint
Low
1
Professional
Contractors
Personal
-
-
2,980
1,520
60
>4
8-hr TWA
U.S. EPA
(2014)
1.1
Included as best available
data source (surrogate)
Table Apx A-15. Summary of Short-Term Inhalation Monitoring Data for Paint Stripping by Professional Contractors
Row
Indusln
Tj pc of
Siimplc
\\ orkcr Acli\ il\ or
Sampling Location
Lslimalcd Mclhjlcnc ( hloridc Airborne
Conccnlralion (mti/niM 1 h
Number
ol'
Siimples
Tjpe of
Meiisiireinenl
Sou rce
Score
Kalionalc for
Inclusion /
Lxclusion
Mean
Ili»h
Midpoim
Low
1
Professional Contractors
Personal
-
-
14,100
7,050
0
>38
STEL
U.S. EPA (20.1.4)
1.1
Included as best
available data
source (surrogate)
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A.9 Fabric Finishing
Table Apx A-16 presents full-shift monitoring data for fabric finishing.
• Row 1 contains data from a 1999 European Commission report that cited an HSE study
on methylene chloride use for caffeine extraction, but noted that other exposure of other
open industrial applications, such as printing, gauze coating and fabric coating, are in the
same range as those known for extraction processes (T| ).
• Rows 2 through 15 contain OSHA data submitted in a public comment (Finkel. 2017).
The exposure data come from textile and fabric industries, such as "Men's and Boys' Cut
and Sew Apparel Mfg," "Apparel Accessories and Other Apparel Mfg," and "All Other
Misc. Textile Product Mills." However, worker activities for these exposure data points
are not known. Sample times vary - however, exposures were adjusted to 8-hr TWAs.
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Table Apx A-16. Summary of Full-Shift Inhalation Monitoring Data for Fabric Finishing
Row
Indusln
Tj pi* of
Siimplo
\\ orkcr Acli\ ilj or
S;i in pi in vi Locution
Mcllnlcnc Chloride
Airborne (onccnlr;ilion
(niii/m M
Number of
Siimplos
Tj pc «l'
Mi'iiMimiH'iil
Source
Score
K;ilion;ilc for
Inclusion /
r.xclusion
1
Caffeine Extraction (surrogate
data)
Personal
Caffeine Extraction
(surrogate)
110.0
1
Unknown
TNO (CIVO)
(1999)
2.3
Excluded - Used
direct monitoring
data
2
Men's and Boys' Cut and Sew
Apparel Mfg.
Personal
unknown
162.4
1
Worker 8-hr TWA
FmMilMIl
2.0
Included - full-
shift TWA
3
Men's and Boys' Cut and Sew
Apparel Mfg.
Personal
unknown
162.8
1
Worker 8-hr TWA
FmMilMIl
2.0
Included - full-
shift TWA
4
Men's and Boys' Cut and Sew
Apparel Mfg.
Personal
unknown
164.6
1
ONU 8-hr TWA
FmMilMIl
2.0
Included - full-
shift TWA
5
Men's and Boys' Cut and Sew
Apparel Mfg.
Personal
unknown
157.8
1
ONU 8-hr TWA
Finkel (2017)
2.0
Included - full-
shift TWA
6
Women's, Misses', and Juniors'
Outerwear, Not Elsewhere
Classified
Personal
unknown
42.6
1
Worker 8-hr TWA
Finkel (2017)
2.0
Included - full-
shift TWA
7
Women's, Misses', and Juniors'
Outerwear, Not Elsewhere
Classified
Personal
unknown
42.0
1
Worker 8-hr TWA
2.0
Included - full-
shift TWA
8
Pleating, Decorative and Novelty
Stitching, and Tucking for the
Trade
Personal
unknown
55.9
1
Worker 8-hr TWA
2.0
Included - full-
shift TWA
9
Pleating, Decorative and Novelty
Stitching, and Tucking for the
Trade
Personal
unknown
53.4
1
Worker 8-hr TWA
Finkel (2017)
2.0
Included - full-
shift TWA
10
Pleating, Decorative and Novelty
Stitching, and Tucking for the
Trade
Personal
unknown
53.4
1
Worker 8-hr TWA
Mselflom
2.0
Included - full-
shift TWA
11
Apparel Accessories and Other
Apparel Mfg.
Personal
unknown
86.8
1
Worker 8-hr TWA
F'°te"2"'7)
2.0
Included - full-
shift TWA
12
Apparel Accessories and Other
Apparel Mfg.
Personal
unknown
86.8
1
Worker 8-hr TWA
F'"te"2"'7)
2.0
Included - full-
shift TWA
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-16. Summary of Full-Shift Inhalation Monitoring Data for Fabric Finishing
Row
Indusln
Tj pe of
Siimplo
\\ orkcr Acli\ ilj or
Siiinplin^ Locution
Mcllnk-nc Chloride
Airborne (oiktii trillion
(niti/m M
Nil ill hoi' of
Siimplos
Tj pe of
Moiisiiiviiicnl
Souivo
Score
Kiilioiiiik' I'or
1 Delusion /
I'Ai'liisinn
13
Apparel Accessories and Other
Apparel Mfg.
Personal
unknown
86.8
1
Worker 8-hr TWA
Finkel (2017)
2.0
Included - full-
shift TWA
14
Apparel Accessories and Other
Apparel Mfg.
Personal
unknown
86.8
1
Worker 8-hr TWA
Finkel (2017)
2.0
Included - full-
shift TWA
15
All Other Misc. Textile Product
Mills
Personal
unknown
86.1
1
Worker 8-hr TWA
Finkel (2017)
2.0
Included - full-
shift TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 195 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A, 10 Spot Cleaning
TableApx A-17 presents full-shift inhalation monitoring data for the use of methylene chloride
for at industrial launderers:
• The monitoring data shown is taken from one source, which provided exposure data for
workers in drycleaning, laundry services, and industrial launderers fFinkel. 2017). The
specific worker activities corresponding to the exposure data is not provided . The
exposure data presented is for sample times ranging from 252 to 270 minutes, and is thus
adjusted to 8-hr TWA data.
Table Apx A-18 shows short-term data for the use of methylene chloride for industrial
launderer:
• The monitoring data shown is taken from the same source as the data in Table Apx A-17,
and is for industrial launderers (Finkel. 2017). The specific worker activities correspond
to the exposure data is not provided. The exposure data presented is for sample times
ranging from 173 to 225 minutes.
Page 196 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-17. Summary of Full-Shift Inhalation Monitoring Data for Spot Cleaning
Row
Inriusln
Tj pc of
Siimplo
Worker Acli\ it\ or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
('onccnlr;ilion (infi/niV'1"
Nil 111 her of
Siimples
1 Ape of
Measurement
Sou ree
Score
Kiilioiiiile for Inclusion /
I'Aclusion
1
Drycleaning and Laundry
Services (Except Coin-Operated)
Personal
unknown
0.0
1
TWA
Finkel
(2017)
2.0
Included - no other data
available. Data adjusted to 8-hr
TWA
2
Industrial Launderers
Personal
unknown
83.7
1
TWA
Finkel
(2017)
2.0
Included - no other data
available. Data adjusted to 8-hr
TWA
3
Industrial Launderers
Personal
unknown
3.0
1
TWA
Finkel
1.8
Included - no other data
available. Data adjusted to 8-hr
TWA
4
Industrial Launderers
Personal
unknown
2.7
1
TWA
Finkel
1.8
Included - no other data
available. Data adjusted to 8-hr
TWA
5
Industrial Launderers
Personal
unknown
2.4
1
TWA
Finkel
(201.7)
1.8
Included - no other data
available. Data adjusted to 8-hr
TWA
6
Industrial Launderers
Personal
unknown
2.4
1
TWA
Finkel
1.8
Included - no other data
available. Data adjusted to 8-hr
TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
c -EPA/OPPT converted data to 8-hr TWAs assuming zero concentrations outside sampling time.
Page 197 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-18. Summary of Short-Term Inhalation Monitoring Data for Spot Cleaning
Row
111 (III si r>
Tj pc of
S;i in pie
\\ orkcr Acli\ il\ or
S;iin|>lillvi Locution
Mcllnlcnc Chloride Airborne
( onccnlriilion (niii/in1) '1'
Nilmher of
Siimples
Tj pc of
Measurement
Source
Score
Kiilioiiiile for Inclusion /1'\clusion
1
Industrial
Launderers
Personal
unknown
o7.4
1
TWA
(2017)
2.0
Included - im oilier dala a\ ailahlc
Data adjusted to 4-hr TWA
2
Industrial
Launderers
Personal
unknown
234.5
1
TWA
Finkel
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
3
Industrial
Launderers
Personal
unknown
159.4
1
TWA
Finkel
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
4
Industrial
Launderers
Personal
unknown
8.7
1
TWA
Finkel
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
5
Industrial
Launderers
Personal
unknown
11.5
1
TWA
Finkel
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
6
Industrial
Launderers
Personal
unknown
975.1
1
TWA
Finkel
(2017)
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
7
Industrial
Launderers
Personal
unknown
975.1
1
TWA
Finkel
(2017)
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
8
Industrial
Launderers
Personal
unknown
0.3
1
TWA
Finkel
(2017)
2.0
Included - no other data available.
Data adjusted to 4-hr TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 198 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A, 11 Cellulose Triacetate Film Production
Table Apx A-19 shows full-shift personal monitoring data for settings involved with the use or
production of cellulose triacetate (CTA) film:
• Rows 1 through 4 present data for a CTA fiber production facility in Rock Hill, SC,
where methylene chloride was the major component of the solvent system for CTA
production. The study provided measured full-shift exposures from 208 to 1,216 mg/m3
(Oft et ai. 1983).
• Rows 5 through 25 present personal monitoring data compiled for various facilities
involved with CTA film production. Exposures ranged from 6.9 to 5,905 mg/m3 (Dell et
ai.1999V
• Row 26 contains data for CTA production summarized from two studies (TN
o UK HSEs reported 8-hr TWA exposures between 0 and 60 mg/m3; 20 mg/m3
(mean).
o An IPCS study reported 8-hr TWA exposures up to 350 mg/m3
Page 199 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-19. Summary of Full-Shift Inhalation Monitoring Data for Cellulose Triacetate Film Manufacturing
Uo«
Indusln
T\pc of
S;i in pie
\\ orkcr Acli\ il\ or Siimpliii^
Locution
Mcllnlcnc Chloride Airborne
( onccnlr;ilion (mti/niM 'h
Nil m her
ol'
S;i in pies
1 Ape of
Measurement
Sou rcc
Score
Kiilioiiiile lor Inclusion /
r.xclusion
Min
M;i\
Moiin/
Median
1
CTA Film
Manufacturing
Personal
Cellulose Triacetate Block I
Extrusion And Preparation (Low
Mecl)
208.42
1,215.77
486.31
84
8-hr TWA
Off ef al. (1983)
2.2
Included - full-shift TWA
2
CTA Film
Manufacturing
Personal
Cellulose Triacetate Tow
Extrusion And Service (Moderate
Mecl)
173.68
1,632.60
972.61
19
8-hr TWA
Off ef al. (1983)
2.2
Included - full-shift TWA
3
CTA Film
Manufacturing
Personal
Cellulose Triacetate - Block II
Extrusion And Preparation (High
Mecl)
729.46
2,396.80
1,649.97
63
8-hr TWA
Off ef al (1983)
2.2
Included - full-shift TWA
4
CTA Film
Manufacturing
Personal
Cellulose Triacetate - Preparation
Area
17.37
1,319.98
-
26
8-hr TWA
Off ef al (1983)
2.2
Included - full-shift TWA
5
CTA Film
Manufacturing
Personal
CTA film-base production /
Group Leader
34.74
1,389.45
395.99
168
8-hr TWA
De"aa'-"'JW>
2.1
Included - full-shift TWA
6
CTA Film
Manufacturing
Personal
CTA film-base production /
Coater and swing crew aide
17.37
1,042.09
166.73
61
8-hr TWA
De"aa'-"'JW>
2.1
Included - full-shift TWA
7
CTA Film
Manufacturing
Personal
CTA film-base production /
Coater's Assistant
10.42
1,042.09
138.94
60
8-hr TWA
Dell ef al. (1999)
2.1
Included - full-shift TWA
8
CTA Film
Manufacturing
Personal
CTA film-base production /
Cleaner, mechanic, pipe fitter,
chemical worker
10.42
694.72
79.89
339
8-hr TWA
Dell ef al. (1999)
2.1
Included - full-shift TWA
9
CTA Film
Manufacturing
Personal
CTA film-base production /
Instrument mechanic, quality-
control tech
6.95
347.36
48.63
191
8-hr TWA
DMLitiUmi
2.1
Included - full-shift TWA
10
CTA Film
Manufacturing
Personal
CTA film-base production / Film
inspector, head dispatcher, office
worker
6.95
173.68
34.74
44
8-hr TWA
Dellelal-
2.1
Included - full-shift TWA
11
CTA Film
Manufacturing
Personal
CTA film-base production / MeCl
work area, not otherwise spec
0.00
868.40
138.94
57
8-hr TWA
Dell ef al. (1999)
2.1
Included - full-shift TWA
12
CTA Film
Manufacturing
Personal
CTA film-base production / MeCl
work area, not otherwise spec
142.42
653.04
316.10
28
8-hr TWA
DMLiUUmi
2.1
Included - full-shift TWA
Page 200 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-19. Summary of Full-Shift Inhalation Monitoring Data for Cellulose Triacetate Film Manufacturing
Uo«
Indusln
T\pc of
S;i in pie
\\ orkcr Acli\ il\ or Siimpliii^
Locution
Mcllnlcnc Chloride Airborne
( onccnlr;ilion (mti/niM 'h
Nil m her
ol'
S;i in pies
1 Ape of
Measurement
Sou rcc
Score
Kiilioiiiile lor Inclusion /
r.xclusion
Min
M;i\
Moiin/
Median
13
CTA Film
Manufacturing
Personal
CTA film-base production / MeCl
work area, not otherwise spec
347.36
521.04
413.36
4
8-hr TWA
De'";'°"'TO>
2.1
Included - full-shift TWA
14
CTA Film
Manufacturing
Personal
CTA film-base production / MeCl
work area, not otherwise spec
31.26
1215.77
274.42
188
8-hr TWA
De'";"""TO>
2.1
Included - full-shift TWA
15
CTA Film
Manufacturing
Personal
CTA film-base production /
extrusion & preparation areas
DL
5905.15
-
-
8-hr TWA
De'""a'-"')99>
2.1
Included - full-shift TWA
16
CTA Film
Manufacturing
Personal
CTA film-base production /
Extrusion & spinning areas, or
employed as jet wipers
1,042.09
4342.02
-
-
8-hr TWA
Dell ef al. (1999)
2.1
Included - full-shift TWA
17
CTA Film
Manufacturing
Personal
CTA film-base production / Dope
section
-
-
253.57
47
8-hr TWA
De'";'i""TO>
2.1
Included - full-shift TWA
18
CTA Film
Manufacturing
Personal
CTA film-base production /
Operator (D block)
-
-
305.68
47
8-hr TWA
D'"""i"-"')99>
2.1
Included - full-shift TWA
19
CTA Film
Manufacturing
Personal
CTA film-base production /
Operator (B/C blocks)
-
-
111.16
47
8-hr TWA
Dell et al. (1999)
2.1
Included - full-shift TWA
20
CTA Film
Manufacturing
Personal
CTA film-base production /
Solvent Recovery
-
-
93.79
47
8-hr TWA
Dell et al. (1999)
2.1
Included - full-shift TWA
21
CTA Film
Manufacturing
Personal
CTA film-base production /
Cleaning
-
-
86.84
47
8-hr TWA
Dell et al. (1999)
2.1
Included - full-shift TWA
22
CTA Film
Manufacturing
Personal
CTA film-base production /
Subwash operator
-
-
34.74
47
8-hr TWA
Dell et al. (1999)
2.1
Included - full-shift TWA
23
CTA Film
Manufacturing
Personal
CTA film-base production /
Laboratory
-
-
24.32
47
8-hr TWA
De"a!""w>
2.1
Included - full-shift TWA
24
CTA Film
Manufacturing
Personal
CTA film-base production /
Polyester film worker and
electroplater
21
DMLitiUmi
2.1
Included - full-shift TWA
25
CTA Film
Manufacturing
Personal
CTA film-base production / MeCl
work area, not otherwise spec
30
Dell ef al. (1999)
2.1
Included - full-shift TWA
26
CTA Film
Manufacturing
Personal
CTA production
0
60
3650
20
unknown
TOO (CIVO)
(1999)
2.3
Included - full-shift TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
Page 201 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 202 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A. 12 Flexible Polyurethane Foam Manufacturing
TableApx A-20 shows full-shift monitoring data available in published literature for the
polyurethane (PU) foam manufacturing industry:
• Rows 1 and 2 present 8-hr TWA methylene chloride exposure for workers utilizing
methylene chloride as a blowing agent (13 - 570 mg/m3) and during miscellaneous tasks
in PU foam production (7 - 700 mg/m3, mean 231 mg/m3) (T> >99).
• Row 3 presents an 8-hr TWA data exposure concentration of 27.8 mg/m3 over a sample
time of approximately 9 hours. The OSHA evaluation came after a complaint by an
employee of six employees being exposed to chemicals involved with heating and mixing
of ingredients in an oven with no exhaust ventilation (I ARC. 2016)
• Rows 4 through 8 present data from a 1987 NIOSH HHE at the Trailmobile Inc. in
Charleston, Illinois. The facility manufactured tractor trailers used widely in the trucking
industry. Personal 8-hr TWA monitoring data for workers in foaming areas ranged from
4.5 to 27.8 mg/m3 (Kch andLushniak. 1990).
• Rows 9 through 12 present 8-hr TWA occupational exposure data for workers exposed to
methylene chloride during activities in PU manufacturing, including glue spraying and
moulding, ranging from 7.1 to 1,090 mg/m3. The exposure data provided by IPCS is
consolidated from various health and environmental evaluations presented in other
published literature. Therefore, information about the specific facilities and procedures
corresponding to the exposure data is not provided ((IPCS). 1996).
• Rows 13 through 15 present results from a 1983 monitoring study at the Cone Mills
Corporation, for 6-hr exposures during mold release spray coating, ranging from 86.8
through 114.6 mg/m3 (Cone Mills Cc la)
• Rows 16 through 28 present results from a 1981 monitoring study at the Cone Mills
Corporation, for 4-6-hr exposures during PU foam production, ranging from 13.9 through
972.6 mg/m3 (Cone Mills Corp. 1981b).
• Rows 29 through 31 present exposures from a 1989 monitoring study a Vulcan
Chemicals facility, which used MeCl as an auxiliary blowing agent in PU foam
production. Full-shift TWA exposures for a saw operator, quality control operator, and
flat top operator ranged from 654.5 to 773.1 mg/m3 (Vulcan Chemica [).
• Rows 32 through 49 present exposures from a 1977 monitoring study an Olin Chemicals
facility, for various workers during PU foam production. Full-shift TWA exposures
ranged from 0.3 to 2,200.9 mg/m3 (Olin Chemicals. 1977).
• Rows 50 through 77 contain 8-hr TWA exposure data compiled in EPA's 1985 exposure
and release assessment for PU foam production. Exposure concentrations for various
workers ranged from ND to l,001.9mg/m3 (US EPA. 1985). EPA assumed zero for the
ND value because the limit of detection was not provided and the relative magnitude of
the other data points.
Table Apx A-21 presents the short-term data:
• Rows 1 through 8 contain 0.5 and 3-hr TWA exposure data compiled in EPA's 1985
exposure and release assessment for PU foam production. Exposure concentrations for
various workers were 54.5 mg/mg3 (0.5-hr TWA) and 5.5 to 38.0 mg/m3 (3-hr TWA) (US
EPA. 1985).
Page 203 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-20. Summary of Full-Shift Inhalation Monitoring Data
Row
liulusln
Tj po of
Siimplo
Worker Aiii\ il\ or
Siiinplin^ Locution
Mcllijlcnc Chloride Airborne
( oiui'iKiiilion (niii/nv1)
NiiiiiIht of
Siimplos
Tj |K' III'
Mciisuivnionl
Sou rce
Sen iv
Kiilimiiilo lor Inclusion /
I'Acliision
1
Foam Industry
Personal
Blowing Agent
13 - 570
1
8-hr TWA
TNO (CIVO)
2.3
Included min and max
values - full-shift TWA
2
Foam Industry
Personal
Other Tasks in PUR
Production
7-700
231 (mean)
1
8-hr TWA
TNO (CIVO)
2.3
Included min and max
values - full-shift TWA
3
Polyurethane Manufacture
Personal
Mix and Heat Ingredients
in Oven
27.8
1
8-hr TWA
lARCiMMl
1.9
Included - full-shift TWA
4
Tractor Trailer Construction
Personal
Foam Operator
4.5
1
8-hr TWA
Reh and
Lushniak (1990)
1.7
Included - full-shift TWA
5
Tractor Trailer Construction
Personal
Foam Operator
17.4
1
8-hr TWA
Reh and
Lushniak: (1990)
1.7
Included - full-shift TWA
6
Tractor Trailer Construction
Personal
Foam Operator
10.8
1
8-hr TWA
Reh and
Lushniak: (1990)
1.7
Included - full-shift TWA
7
Tractor Trailer Construction
Personal
Foam Operator
17.7
1
8-hr TWA
Reh and
Lushniak (1990)
1.7
Included - full-shift TWA
8
Tractor Trailer Construction
Personal
Foam Operator
15.6
1
8-hr TWA
Reh and
Lushniak (1990)
1.7
Included - full-shift TWA
9
Foam industry
Personal
Moulding
88-1,090
unknown
8-hr TWA
(IPCS) (1996)
2.3
Included - full-shift TWA
10
Foam industry
Personal
Moulding
<247
unknown
8-hr TWA
(IPCS) (1996)
2.3
Included - full-shift TWA
11
Foam industry
Personal
Unknown
7.1-251
unknown
8-hr TWA
(IPCS) (1996)
2.3
Included - full-shift TWA
12
Foam industry
Personal
Various jobs
18 - 580
unknown
8-hr TWA
(IPCS) (1996)
2.3
Included - full-shift TWA
13
Cone Mills Corporation-
Corporate Medical Department
Personal
Spraying
111.2
1
8-hr TWA
Cone Mills Coro
ill
1.7
Included - full-shift TWA
14
Cone Mills Corporation-
Corporate Medical Department
Personal
Spraying
114.6
1
8-hr TWA
Cone Mills Coro
ill
1.7
Included - full-shift TWA
15
Cone Mills Corporation-
Corporate Medical Department
Personal
Spraying
86.8
1
8-hr TWA
Cone Mills Coro
ill
1.7
Included - full-shift TWA
16
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Line Operator
13.9
1
8-hr TWA
Cone Mills Coro
ill
1.7
Included - full-shift TWA
17
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Line Operator
38.2
1
8-hr TWA
Cone Mills Coro
1.7
Included - full-shift TWA
18
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Line Operator
243.2
1
8-hr TWA
Cone Mills Coro
1.7
Included - full-shift TWA
'or Flexible Polyurethane Foam Manufacturing
Page 204 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-20. Summary of Full-Shift Inhalation Monitoring Data
Row
liulusln
Tj po of
Siimplo
Worker Aiii\ il\ or
Siiinplin^ Locution
Mcllijlcnc Chloride Airborne
( oiui'iKiiilion (niii/nv1)
NiiiiiIht of
Siimplos
Tj pi* of
Mciisuivnionl
Sou rce
Sen iv
Kiilimiiilo lor Inclusion /
I'Acliision
19
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Line Operator
625.3
1
8-hr TWA
Cone Mills Con)
1.7
Included - full-shift TWA
20
Cone Mills Corporation-
Corporate Medical Department
Personal
Crane Operator in Foam
Storage Removal
833.7
1
8-hr TWA
Cone Mills Con)
1.7
Included - full-shift TWA
21
Cone Mills Corporation-
Corporate Medical Department
Personal
Cut-Off Saw Operator in
Foam Storage Removal
521.0
1
8-hr TWA
Cone Mills Con)
1.7
Included - full-shift TWA
22
Cone Mills Corporation-
Corporate Medical Department
Personal
Overhead Crane Operator -
Cured Foam Storage
173.7
1
8-hr TWA
Cone Mills Con)
la)
1.7
Included - full-shift TWA
23
Cone Mills Corporation-
Corporate Medical Department
Personal
Crane Operator in Foam
Storage
208.4
1
8-hr TWA
Cone Mills Com
la)
1.7
Included - full-shift TWA
24
Cone Mills Corporation-
Corporate Medical Department
Personal
Crane Operator in Foam
Storage Removal
104.2
1
8-hr TWA
Cone Mills Com
la)
1.7
Included - full-shift TWA
25
Cone Mills Corporation-
Corporate Medical Department
Personal
Cut-Off Saw Operator in
Foam Storage Removal
138.9
1
8-hr TWA
Cone Mills Con)
1.7
Included - full-shift TWA
26
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Storage Crane
Operators
486.3
1
8-hr TWA
Cone Mills Con)
1.7
Included - full-shift TWA
27
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Storage Removal
Crane Operator
972.6
1
8-hr TWA
Cone Mills Con)
1.7
Included - full-shift TWA
28
Cone Mills Corporation-
Corporate Medical Department
Personal
Foam Storage Crane
Operators
521.0
1
8-hr TWA
Cone Mills Con)
ill
1.7
Included - full-shift TWA
29
Vulcan Chemicals
Personal
Saw Operator
654.5
1
8-hr TWA
Vulcan
Chemicals
(1991)
1.9
Included - full-shift TWA
30
Vulcan Chemicals
Personal
Quality Control Operator
773.1
1
8-hr TWA
Vulcan
Chemicals
1.9
Included - full-shift TWA
31
Vulcan Chemicals
Personal
Flat Top Operator
682.9
1
8-hr TWA
Vulcan
Chemicals
(1991)
1.9
Included - full-shift TWA
32
Olin Chemicals
Personal
Batch operations
91.0
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
33
Olin Chemicals
Personal
Batch operations
167.1
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
'or Flexible Polyurethane Foam Manufacturing
Page 205 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-20. Summary of Full-Shift Inhalation Monitoring Data
Row
liulusln
Tj po of
Siimplo
Worker Aiii\ il\ or
Siiinplin^ Locution
Mcllijlcnc Chloride Airborne
( oiui'iKiiilion (niii/nv1)
NiiiiiIht of
Siimplos
Tj pi* of
Mciisuivnionl
Sou rce
Sen iv
Kiilimiiilo lor Inclusion /
I'Acliision
34
Olin Chemicals
Personal
Drumming
94.1
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
35
Olin Chemicals
Personal
Drumming
377.2
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
36
Olin Chemicals
Personal
Purge Operations
110.8
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
37
Olin Chemicals
Personal
Purge Operations
0.3
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
38
Olin Chemicals
Personal
Cylinder cleaning
620.0
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
39
Olin Chemicals
Personal
Cylinder cleaning
515.1
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
40
Olin Chemicals
Personal
Blending
112.9
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
41
Olin Chemicals
Personal
Blending
38.9
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
42
Olin Chemicals
Personal
Blending
225.1
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
43
Olin Chemicals
Personal
Laboratory Operations
2200.9
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
44
Olin Chemicals
Personal
Laboratory Operations
1039.3
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
45
Olin Chemicals
Personal
Batch operations
336.2
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
46
Olin Chemicals
Personal
Batch operations
242.1
1
8-hr TWA
Olin Chemicals
(1977)
1.9
Included - full-shift TWA
47
Olin Chemicals
Personal
Laboratory Operations
266.1
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
48
Olin Chemicals
Personal
Laboratory Operations
323.0
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
49
Olin Chemicals
Personal
Filter cleaning, MDA tank
1400.6
1
8-hr TWA
Olin Chemicals
1.9
Included - full-shift TWA
'or Flexible Polyurethane Foam Manufacturing
Page 206 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-20. Summary of Full-Shift Inhalation Monitoring Data
Row
liulusln
Tj po of
Siimplo
Worker Aiii\ il\ or
Siiinplin^ Locution
Mcllijlcnc Chloride Airborne
( oiui'iKiiilion (niii/nv1)
NiiiiiIht of
Siimplos
Tj pi* of
Mciisuivnionl
Sou rce
Sen iv
Kiilimiiilo lor Inclusion /
I'Acliision
50
Plastic Products
Personal
Foam Gun Operator
558.4
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
51
Plastic Products
Personal
Foam Gun Operator
942.3
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
52
Plastic Products
Personal
Foam Gun Operator
767.8
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
53
Plastic Products
Personal
Foam Gun Operator
698
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
54
Plastic Products
Personal
Inj. Mold Operator
24.43
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
55
Plastic Products
Personal
Inj. Mold Operator
34.98
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
56
Household Refrigerators
Personal
Foam Operator
173.104
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
57
Household Refrigerators
Personal
Foam Operator
169.265
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
58
Household Refrigerators
Personal
Foam Operator
87.25
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
59
Prefab Metal Buildings
Personal
Foamline Operator
ND
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift
TWA; assumed zero
value
60
Food Product Machinery
Personal
Foam Injecting
111.331
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
61
Plastic Products
Personal
Crusher
296.63
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
62
Plastic Products
Personal
Crusher
17.45
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
63
Plastic Products
Personal
Crusher
146.58
1
8-hr TWA
US EPA {
1985)
1.4
Included - full-shift TWA
64
Plastic Products
Personal
Skin Layer
523.58
1
8-hr TWA
US EPA (
1985)
1.4
Included - full-shift TWA
65
Plastic Products
Personal
Skin Layer
272.22
1
8-hr TWA
US EPA {
1985
)
1.4
Included - full-shift TWA
66
Plastic Products
Personal
Skin Layer
122.15
1
8-hr TWA
US EPA (
1985
)
1.4
Included - full-shift TWA
67
Plastic Products
Personal
Beader
1001.9
1
8-hr TWA
US EPA {
1985
)
1.4
Included - full-shift TWA
68
Plastic Products
Personal
Beader
418.88
1
8-hr TWA
US EPA C
1985
)
1.4
Included - full-shift TWA
69
Plastic Products
Personal
Beader
383.9
1
8-hr TWA
US EPA{
1985
)
1.4
Included - full-shift TWA
70
Plastic Products
Personal
Beader
97.72
1
8-hr TWA
US EPA C
1985
)
1.4
Included - full-shift TWA
71
Plastic Products
Personal
Waxer
558.4
1
8-hr TWA
US EPA
1985
)
1.4
Included - full-shift TWA
72
Plastic Products
Personal
Waxer
872.5
1
8-hr TWA
us epa
1985
)
1.4
Included - full-shift TWA
73
Plastic Products
Personal
Vacuum Former
216.3
1
8-hr TWA
US EPA c
1985
)
1.4
Included - full-shift TWA
74
Plastic Products
Personal
Crimper
6.9
1
8-hr TWA
US EPA C
1985
)
1.4
Included - full-shift TWA
75
Plastic Products
Personal
Mold Opener
254.77
1
8-hr TWA
US EPA (
1985
)
1.4
Included - full-shift TWA
'or Flexible Polyurethane Foam Manufacturing
Page 207 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-20. Summary of Full-Shift Inhalation Monitoring Data for Flexible Polyurethane Foam Manufacturing
Row
liulusln
Tj po of
Siimplo
Worker Aiii\ il\ or
Siiinplin^ Locution
Mcllijlcnc Chloride Airborne
( oiui'iKiiilion (niii/nv1)
NiiiiiIht of
Siimplos
Tj pi* of
Mciisuivnionl
Sou rce
Sen iv
Kiilimiiilo lor Inclusion /
I'Acliision
76
Plastic Products
Personal
Mold Opener
167.52
1
8-hr TWA
US EPA (1985)
1.4
Included - full-shift TWA
77
Plastic Products
Personal
Shearing Machine
17.45
1
8-hr TWA
ill
1.4
Included - full-shift TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 208 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-21. Summary of Short-Term Inhalation Monitoring Data for Flexible Polyurethane Foam Manufacturing
Row
1 ihIii Mn
Tj pc of
Siimplo
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc ( hloridc Airborne
( onccnlr;ilion (in^/niJ) >h
Number itl"
Siimplos
Tjpe of
\lc;isiircnicn(
Sou rcc
Score
K;ilion;ilc lor Inclusion /
r.xclnsion
1
Appliance
Manufacturing
Personal
Foam Blowing
5.2
1
STEL
US EPA
(1985)
1.4
4-hr TWA
2
Appliance
Manufacturing
Personal
Foam Blowing
13.1
1
STEL
US EPA
(1985)
1.4
4-hr TWA
3
Appliance
Manufacturing
Personal
Foam Blowing
18.5
1
STEL
US EPA
(1985)
1.4
4-hr TWA
4
Appliance
Manufacturing
Personal
Foam Blowing
17.0
1
STEL
US EPA
(1985)
1.4
4-hr TWA
5
Appliance
Manufacturing
Personal
Foam Blowing
5.2
1
STEL
US EPA
(1985)
1.4
4-hr TWA
6
Appliance
Manufacturing
Personal
Foam Blowing
38.0
1
STEL
US EPA
(1985)
1.4
4-hr TWA
7
Appliance
Manufacturing
Personal
Foam Blowing
10.5
1
STEL
(1985)
1.4
4-hr TWA
8
Toys
Personal
Nozzle Cleaning
54.5
1
STEL
(1985)
1.4
0.5-hr TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 209 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A.13 Laboratory Use
TableApx A-22 presents full-shift data for laboratory use.
• Rows 1 through 3 contain data from a NIOSH Health Hazard Evaluation in 1989 of the
Standards Preparation and Organic Extraction areas at the Rocky Mountain Analytical
Laboratory, a division of Enesco, Inc. Samples longer than 4 hours long were adjusted to
8-hr TWAs, and resulted in 8-hr TWA exposures from 2.8 to 3.5 nig/m3 (Mccammon.
1990V
• Rows 4 through 6 contain monitoring data from a study at Texaco for research laboratory
staff. Full-shift exposures for methylene chloride were less than detectable (3.5 mg/m3)
(Texaco Inc. 1993).
• Row 7 included data from another Texaco monitoring study, but contained data that were
already provided in Rows 4 through 6 (Texaco I |3).
• Rows 8 through 11 contain 8-hr TWA exposure data compiled by DOD during laboratory
sample preparation and instrument analysis. Exposure concentrations for various workers
ranged from 4.9 to 16.6mg/m3 ((DOEHRS-IH). 2018).
•
Table Apx A-23 presents short-term data for laboratory use.
• Rows 1 through 12 include shorter-term monitoring data from the 1989 NIOSH HHE
described in the full-shift data (Mccammon. 1990)
• Row 13 presents a data point from IARC that indicated short-term exposures less than 3.5
mg/m3, but did not provide additional details; therefore, this data point was excluded in
favor of higher quality data (IARC. 2.016).
• Rows 14 through 44 contain short-term exposure data compiled by DOD during
laboratory operations. Exposure concentrations for various workers ranged from 0.7 to
1,830 mg/m3 (various sample times) ((DOEHRS-IH). 2018).
Page 210 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-22. Summary of Full-Shift Inhalation Monitoring Data for Laboratory Use
Row
Indusln
Ttpcof S;implc
Worker Acli\ il\ or
S;iinpliiivi l.ociilion
Mcllnlcnc ( hloriric
Airhornc Conccnlmlion
(iiiu/in i)lh
Number ol°
Siimplos
Tj pi* of
MoilSIIIVIlK'lll
Source
Score
K;ilion;ilc lor
Inclusion /
Kxcliision
1
Analytical Laboratory
Personal
Sample prep, transfer of
meel from separatory
funnels
3.5a
1
TWA
Reh and
Lushniak (1990)
1.8
Included - full-
shift TWA
2
Analytical Laboratory
Personal
Transferring sample from
250-ml beakers, load on
steam bath
3.3a
1
TWA
Reh and
1.8
Included - full-
shift TWA
3
Analytical Laboratory
Personal
Sample concentrating
2.8a
1
TWA
Reh and
Lushniak (1990)
1.8
Included - full-
shift TWA
4
Laboratory
Personal
Research lab staff
3.5
1
TWA
TexacoInc
1.9
Included - full-
shift TWA
5
Laboratory
Personal
Research lab staff
3.5
1
TWA
TexacoInc
(1993)
1.9
Included - full-
shift TWA
6
Laboratory
Personal
Pro lab Staff
3.5
1
TWA
TexacoInc
(1993)
1.9
Included - full-
shift TWA
7
Laboratory
Personal
Research lab staff
3.5
1
TWA
TexacoInc
(1993)
1.9
Excluded - repeat
of above data
8
DOD Laboratory
Personal
INSTRUMENT
ANALYSIS
4.9
1
TWA
((DOEHRS-IH).
2018).
1.3
Included - full-
shift TWA
9
DOD Laboratory
Personal
LAB SAMPLE
PREPARATION
6.4
1
TWA
((DOEHRS-IH).
20.1.8).
1.3
Included - full-
shift TWA
10
DOD Laboratory
Personal
LAB SAMPLE
PREPARATION
3.3
1
TWA
((DOEHRS-IH).
20.1.8).
1.3
Included - full-
shift TWA
11
DOD Laboratory
Personal
LAB SAMPLE
PREPARATION
16.6
1
TWA
((DOEHRS-IH).
20.1.8).
1.3
Included - full-
shift TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
a - Adjusted to 8-hr TWA
Page 211 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-23. Summary of Short-Term Inhalation Monitoring Data for Laboratory Use
Row
1 ihIii Mn
Tj |>c of
Siimplo
\\ orkcr Acli\ilj or Sampling l ocution
Mcllnlcnc Chloride
Airborne Concent nil ion
(inii/inJ) •l h
Number of
Siimplos
Tj pc of
MciisnrcmciH
Sou rcc
Score
Kiilioiiiilc lor Inclusion /
r.xcliision
1
Analytical
Laboratory
Personal
sample concentrating
2.7
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
2
Analytical
Laboratory
Personal
sample sonification
3.9
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
3
Analytical
Laboratory
Personal
sample sonification
4.5
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
4
Analytical
Laboratory
Personal
washing separtory funnels in sink near
CLLE
113.0
1
STEL
Mccammon (1990)
1.8
Included - Worker 15-min
STEL
5
Analytical
Laboratory
Personal
column cleaning
10.0
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
6
Analytical
Laboratory
Personal
sample concentrating
30.0
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
7
Analytical
Laboratory
Personal
sample concentrating
4.2
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
8
Analytical
Laboratory
Personal
sample concentrating
6.8
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
9
Analytical
Laboratory
Personal
transfering 100 ml MeCl into soil samples
9.8
1
STEL
Mccammon (1990)
1.8
Included - Worker 4-hr TWA
10
Analytical
Laboratory
Personal
collecting waste chemicals & dumping
into waste chemical storage
995.0
1
STEL
Mccammon (1990)
1.8
Included - Worker 30-min
TWA
11
Analytical
Laboratory
Personal
above refrigerator #G in organic lab
storage
17.0
1
STEL
Mccammon (1990)
1.8
Excluded - Personal Samples
Prioritized
12
Analytical
Laboratory
Personal
on top of refrigerator #F in organics lab
storage
11.0
1
STEL
Mccammon (1990)
1.8
Excluded - Personal Samples
Prioritized
13
Analytical
Laboratory
Personal
Laboratory worker
3.5
1
STEL
I ARC (20.1.6)
2.2
Excluded - no info on type of
sampling
14
DOD
Laboratory
Personal
Miscellaneous lab operations
3.1
1
4-hr TWA
(T.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 4-hr TWA
15
DOD
Laboratory
Personal
Miscellaneous lab operations
3.1
1
4-hr TWA
(TDOEH
20.1
RS-IH).
I)
1.3
Included - Worker 4-hr TWA
16
DOD
Laboratory
Personal
Sample extraction and analysis (3809,
OCD)
34.7
1
3-hr TWA
(TDOEH
20J
RS-IH).
1)
1.3
No health comparisons for 2-
or 3-hr TWA. Presented data
Page 212 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-23. Summary of Short-Term Inhalation Monitoring Data for Laboratory Use
Row
1 ihIii Mn
Tj |>c of
Siimplo
\\ orkcr Acli\ilj or Sampling l ocution
Mcllnlcnc Chloride
Airborne (onccnlnilion
(inii/inJ) •l h
Number of
Samples
Tj pc of
Mc;iMircmcnl
Sou rcc
Score
Kiilioiiiilc lor Inclusion /
r.xcliision
point, but not used to calculate
risk.
17
DOD
Laboratory
Personal
(3)GC Extraction
0.7
1
2.5-hr TWA
((.DOEHRS-IH).
20.1.8)
1.3
No health comparisons for 2-
or 3-hr TWA. Presented data
point, but not used to calculate
risk.
18
DOD
Laboratory
Personal
134: Extraction of PCB in water samples
(Rm 221 - Prep & Rm 227 - GC)
22.5
1
2-hr TWA
(fDOEHRS-IH),
20.1.8)
1.3
No health comparisons for 2-
or 3-hr TWA. Presented data
point, but not used to calculate
risk.
19
DOD
Laboratory
Personal
134: Extraction of total volatiles
(TCLP)(Rm 227)
64.7
1
2-hr TWA
(I'DOEHRS-IH).
20.1.8)
1.3
No health comparisons for 2-
or 3-hr TWA. Presented data
point, but not used to calculate
risk.
20
DOD
Laboratory
Personal
Analysis, chemical (Laboratory
Operations)
1.7
1
1-hr TWA
((.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 1-hr TWA
21
DOD
Laboratory
Personal
Analysis, chemical (Laboratory
Operations)
2.4
1
30-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
22
DOD
Laboratory
Personal
LAB ACTIVITIES
3.3
1
30-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
23
DOD
Laboratory
Personal
LAB ACTIVITIES
6.4
1
30-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
24
DOD
Laboratory
Personal
LAB ACTIVITIES
16.6
1
30-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
25
DOD
Laboratory
Personal
LAB ACTIVITIES
3.4
1
30-min TWA
((.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
26
DOD
Laboratory
Personal
LAB ACTIVITIES
3.4
1
30-min TWA
((.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
27
DOD
Laboratory
Personal
LAB ACTIVITIES
3.4
1
30-min TWA
((.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
28
DOD
Laboratory
Personal
LAB ACTIVITIES
3.4
1
30-min TWA
((.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
Page 213 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-23. Summary of Short-Term Inhalation Monitoring Data for Laboratory Use
Row
1 ihIii Mn
Tj |>c of
Siimplo
\\ orkcr Acli\ilj or Sampling l ocution
Mcllnlcnc Chloride
Airborne (onccnlnilion
(inii/inJ) •l h
Number of
Samples
Tj pc of
Mc;iMircmcnl
Sou rcc
Score
Kiilioiiiilc lor Inclusion /
r.xcliision
29
DOD
Laboratory
Personal
PRO-OOl-Ol LABORATORY
CHEMICAL ANALYSIS/SAMPLING
5.4
1
30-min TWA
((.DOEHRS-IH).
2018)
1.3
Included - Worker 30-min
TWA
30
DOD
Laboratory
Personal
514A Using Solvents
1830.0
1
15-min TWA
((.DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
31
DOD
Laboratory
Personal
EXTRACTION OP
3.6
1
15-min TWA
(t'DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
32
DOD
Laboratory
Personal
EXTRACTION OP
24.8
1
15-min TWA
(t'DOEHRS-IH).
20.1.8)
1.3
Included - Worker 30-min
TWA
33
DOD
Laboratory
Personal
(3)GC Extraction
10.4
1
15-min TWA
(t'DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
34
DOD
Laboratory
Personal
(3)GC Extraction
10.4
1
15-min TWA
(t'DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
35
DOD
Laboratory
Personal
Sample extraction and analysis (3809,
OCD)
62.5
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
36
DOD
Laboratory
Personal
Miscellaneous lab operations
6.7
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
37
DOD
Laboratory
Personal
EXTRACTION OP
4.6
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
38
DOD
Laboratory
Personal
EXTRACTION OP
4.6
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
39
DOD
Laboratory
Personal
134: Extraction of PCB in water samples
(Rm 221 - Prep & Rm 227 - GC)
5.3
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
40
DOD
Laboratory
Personal
134: Extraction of total volatiles
(TCLP)(Rm 227)
5.0
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
41
DOD
Laboratory
Personal
PRO-OOl-Ol LABORATORY
CHEMICAL ANALYSIS/SAMPLING
5.4
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
42
DOD
Laboratory
Personal
IND-025-10 HM/HW HANDLING
CLEANUP, CONTAINER
SAMPLE/OPEN
6.1
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
43
DOD
Laboratory
Personal
PRO-001-01 LABORATORY
CHEMICAL ANALYSIS/SAMPLING
10.9
1
15-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 15-min
TWA
Page 214 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
TableApx A-23. Summary of Short-Term Inhalation Monitoring Data for Laboratory Use
Row
1 ihIii Mn
Tj |>c of
Siimplo
\\ orkcr Acli\ilj or Sampling l ocution
Mcllnlcnc Chloride
Airhornc Conccnlnilion
(inii/inJ) l h
Number of
Siimplos
Tj pc of
Mi'iiMimiK'iil
S(»i ito
Scoiv
Kiilioiiiilo lor Inclusion /
r.xcliision
44
DOD
Laboratory
Personal
PRO-OOl-Ol LABORATORY
CHEMICAL ANALYSIS/SAMPLING
13.2
1
15-min TWA
((DOEHRS-IBX
2018)
1.3
Included - Worker 15-min
TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 215 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A.14 Plastic Product Manufacturing
TableApx A-24 presents full-shift monitoring data for plastics product manufacturing.
• Rows 1 through 5 contain 8-hr TWA data from various OSHA inspections at a number of
plastic product supply and manufacturing companies that were conducted between 2012
and 2016. Exposure concentrations ranged from 9 to 2,685.1 mg/m3. Specific worker
activities were not specified (OS] 19).
• Row 6 presents an 8-hr TWA of 28.5 mg/m3 during mixing and heating ingredients from
polyurethane part manufacturing (casting) (Fairfax and Porter. 2006).
• Row 7 present an exposure concentration of 208 to 304 mg/m3 from fabrication of rubber
products ((IPCS). 1996).
• Rows 8 through 27 contain monitoring data provided by the Halogenated Solvents
Industry Alliance (HSIA), with sampling dates between 2005 and 2017, for production
technicians during plastic product manufacturing. Exposure concentrations ranged from
3.9 to 134.1 mg/m3 (Halogenated Solvents Indu liance. 2018).
• Rows 28 through 30 present exposure concentration for operators, maintenance, shift
leaders, and lab technicians at a General Electric plastic polymer plant, ranging from 11.5
to 170.2 mg/m3 (GE. 1989).
Table Apx A-25 presents short-term monitoring data for plastics product manufacturing.
• Rows 1 through 3 contain short-term exposure data from various OSHA inspections at
plastic product manufacturing companies that were conducted between 2012 and 2016.
Exposure concentrations ranged from ND to 27.8 mg/m3. Specific worker activities were
not specified. (OS1 19).
• Rows 4 through 24 contain monitoring data provided by the Halogenated Solvents
Industry Alliance (HSIA), with sampling dates between 2005 and 2017, for operators and
production technicians during plastic product manufacturing. Exposure concentrations
ranged from 50.7 to 166.7mg/m3 (Halogenated Solvents Indusl ance. 2018).
Page 216 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Ta
)le Apx A-24. Summary of Full-Shift Inhalation Monitoring Data for Plasl
tic Product Manufacturing
Row
Indusln
Tj pc ol'
S;implc
\\ orkcr Acli\ il\ or
Siiinplin^ locution
Mcllnlcnc Chloride
Airborne Coiutmtrillion
diiii/m M •l h
NiiihIht ol°
Siimplos
Tj pc of
Mciisu mucin
Source
Score
Kiilioiiiilc lor
Inclusion /
I'Aclusion
1
All Other Plastics Product
Manufacturing
Personal
Ada Area
9.0
1
8-hrTWA
OSHA (20.1.9)
1.3
Included - full-shift
TWA
2
All Other Plastics Product
Manufacturing
Personal
Hop Area Operator
11.5
1
8-hrTWA
OSHA (20.1.9)
1.3
Included - full-shift
TWA
3
All Other Plastics Product
Manufacturing
Personal
Hop Area Operator
2674.7
1
8-hrTWA
OSHA (20.1.9)
1.3
Included - full-shift
TWA
4
All Other Plastics Product
Manufacturing
Personal
Injection Molding
Operator
35.8
1
8-hrTWA
OSHA (20.1.9)
1.3
Included - full-shift
TWA
5
All Other Plastics Product
Manufacturing
Personal
Injection Molding
Operator
32.7
1
8-hrTWA
OSHA (20.1.9)
1.3
Included - full-shift
TWA
6
Polyurethane Part Manufacturing
(Casting)
Personal
Mix and heat ingredients
in oven
28.5
1
8-hr TWA
Fairfax and
Porter (2006)
1.6
Included - full-shift
TWA
7
Rubber Products
Personal
Fabrication
208 - 304
Unknown
8-hr TWA
(IPCS1119961
2.3
Included - full-shift
TWA
8
Plastics material and resin
manufacturing
Personal
Production technician
5.2
1
8-hr TWA
Haloeenated
Solvents
Industrv Alliance
(20.1.8)
1.6
Included - full-shift
TWA
9
Plastics material and resin
manufacturing
Personal
Production technician
5.2
1
8-hr TWA
Haloeenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
10
Plastics material and resin
manufacturing
Personal
Production technician
25.5
1
8-hr TWA
Haloeenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
11
Plastics material and resin
manufacturing
Personal
Production technician
31.9
1
8-hr TWA
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
12
Plastics material and resin
manufacturing
Personal
Production technician
4.9
1
8-hr TWA
Haloeenated
Solvents
1.6
Included - full-shift
TWA
Page 217 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Ta
)le Apx A-24. Summary of Full-Shift Inhalation Monitoring Data for Plasl
tic Product Manufacturing
Row
Indusln
Tj pc ol'
S;implc
\\ orkcr Acli\ il\ or
Siiinplin^ locution
Mcllnlcnc Chloride
Airborne Coiutmtrillion
diiii/m M •l h
NiiihIht ol°
Siimplos
Tj pc of
Mciisu mucin
Source
Score
Kiilioiiiilc lor
Inclusion /
I'Aclusion
Industry Alliance
(20.1.8)
13
Plastics material and resin
manufacturing
Personal
Production technician
7.3
1
8-hr TWA
Halo seriated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
14
Plastics material and resin
manufacturing
Personal
Production technician
3.7
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
15
Plastics material and resin
manufacturing
Personal
Production technician
3.7
1
8-hr TWA
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
16
Plastics material and resin
manufacturing
Personal
Production technician
6.9
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
1.6
Included - full-shift
TWA
17
Plastics material and resin
manufacturing
Personal
Production technician
3.9
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
18
Plastics material and resin
manufacturing
Personal
Production technician
3.7
1
8-hr TWA
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
19
Plastics material and resin
manufacturing
Personal
Production technician
14.9
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
20
Plastics material and resin
manufacturing
Personal
Production technician
134.1
1
8-hr TWA
Halogenated
Solvents
1.6
Included - full-shift
TWA
Page 218 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Ta
)le Apx A-24. Summary of Full-Shift Inhalation Monitoring Data for Plasl
tic Product Manufacturing
Row
Indusln
Tj pc ol'
S;implc
\\ orkcr Acli\ il\ or
Siiinplin^ locution
Mcllnlcnc Chloride
Airborne Coiutmtrillion
diiii/m M •l h
NiiiiiIht ol°
Siimplos
Tj pc of
Mciisu mucin
Source
Score
Kiilioiiiilc lor
Inclusion /
I'Aclusion
Industry Alliance
(20.1.8)
21
Plastics material and resin
manufacturing
Personal
Production technician
16.3
1
8-hr TWA
Halo seriated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
22
Plastics material and resin
manufacturing
Personal
Production technician
7.7
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
23
Plastics material and resin
manufacturing
Personal
Production technician
20.3
1
8-hr TWA
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
24
Plastics material and resin
manufacturing
Personal
Production technician
11.4
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
1.6
Included - full-shift
TWA
25
Plastics material and resin
manufacturing
Personal
Production technician
12.8
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
26
Plastics material and resin
manufacturing
Personal
Production technician
5.1
1
8-hr TWA
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
27
Plastics material and resin
manufacturing
Personal
Production technician
17.1
1
8-hr TWA
Halogenated
Solvents
Industry Alliance
(20.1.8)
1.6
Included - full-shift
TWA
28
Plastic Polymer Plant
Personal
Operators
170.2
1
8-hr TWA
GE (.1.989)
2.0
Included - full-shift
TWA
Page 219 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Ta
)le Apx A-24. Summary of Full-Shift Inhalation Monitoring Data for Plasl
tic Product Manufacturing
Row
Indusln
Tj pc ol'
S;implc
\\ orkcr Acli\ il\ or
Siiinplin^ locution
Mcllnlcnc Chloride
Airborne Coiutmtrillion
diiii/m M •l h
NiiihIht ol°
Siimplos
Tj pc of
Mciisu mucin
Source
Score
Kiilioiiiilc lor
Inclusion /
I'Aclusion
29
Plastic Polymer Plant
Personal
Operators/Maintenance/
Lab technicians
37.9
1
8-hr TWA
GE (1989)
2.0
Included - full-shift
TWA
30
Plastic Polymer Plant
Personal
Shift leaders/lab
technicians
11.5
1
8-hr TWA
GE (1989)
2.0
Included - full-shift
TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 220 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-25. Summary of Short-Term Inhalation Monitoring Data for Plastic Product Manufacturing
Uow
liulusln
Tj pc of
Siimplo
Worker Acli\ ilj or
Siiinplin^ Locution
Mcllnlcnc Chloride Airborne
(nnccnlr;ilion (niii/ni1);ih
Nil ill hoi' of
Siimpk's
Tj pc of
Mc;iMircmcnl
Source
Score
Kiilioiiiile for
Inclusion / l-'\clnsi«ui
1
All Other Plastics Product
Manufacturing
Personal
Plastics Manufacturer
ND
1
STEL
OSHA (2019)
1.3
Excluded - Did not
include ND from
OSHA data.0
2
All Other Plastics Product
Manufacturing
Personal
Plastics Manufacturer
27.8
1
STEL
OSHA (2019)
1.3
Worker - 15-min STEL
3
All Other Plastics Product
Manufacturing
Personal
Plastics Manufacturer
20.8
1
STEL
OSHA (2019)
1.3
Worker - 15-min STEL
4
Plastics material and resin
manufacturing
Personal
Operator
102.1
1
STEL
Solvents Industry
Alliance (2018)
1.6
Worker - 15-min STEL
5
Plastics material and resin
manufacturing
Personal
Operator
73.5
1
STEL
Solvents Industry
Alliance (2018)
1.6
Worker - 15-min STEL
6
Plastics material and resin
manufacturing
Personal
Operator
94.3
1
STEL
Haloeenated
Solvents Industry
Alliance (2018)
1.6
Worker - 15-min STEL
7
Plastics material and resin
manufacturing
Personal
Operator
65.8
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
8
Plastics material and resin
manufacturing
Personal
Operator
65.8
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
9
Plastics material and resin
manufacturing
Personal
Operator
60.2
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
10
Plastics material and resin
manufacturing
Personal
Operator
131.6
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
11
Plastics material and resin
manufacturing
Personal
Operator
65.8
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
Page 221 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-25. Summary of Short-Term Inhalation Monitoring Data for Plastic Product Manufacturing
Row
liulusln
Tj pc of
S;iin pie
Worker Acli\il\ or
Siiinplin^ l.ociilion
Mcllnlcnc Chloride Airborne
( OIKTHll'illioil (lllli/lll1)
Nil in her of
Siimplcs
Tj pc of
Moiisuivnioiil
Source
Score
K:ilion;ilc lor
Inclusion /1'\cliision
12
Plastics material and resin
manufacturing
Personal
Operator
102.1
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
13
Plastics material and resin
manufacturing
Personal
Operator
166.7
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
14
Plastics material and resin
manufacturing
Personal
Operator
111.1
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
15
Plastics material and resin
manufacturing
Personal
Operator
83.3
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
16
Plastics material and resin
manufacturing
Personal
Product technician
119.9
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
17
Plastics material and resin
manufacturing
Personal
Product technician
69.4
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
18
Plastics material and resin
manufacturing
Personal
Product technician
82.5
1
STEL
Haloeenated
Solvents Industrv
Alliance {2018)
1.6
Worker - 15-min STEL
29
Plastics material and resin
manufacturing
Personal
Product technician
62.8
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
20
Plastics material and resin
manufacturing
Personal
Product technician
88.0
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
21
Plastics material and resin
manufacturing
Personal
Product technician
82.5
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
22
Plastics material and resin
manufacturing
Personal
Product technician
101.5
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
Page 222 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-25. Summary of Short-Term Inhalation Monitoring Data for Plastic Product Manufacturing
Row
liulusln
Tj pc of
S;iin pie
Worker Acli\il\ or
Siiinplin^ l.ociilion
Mcllnlcnc Chloride Airborne
( OIKTHll'illioil (lllli/lll1)
Nil in her of
Siimplcs
Tj pc of
Moiisuivnioiil
Source
Score
K:ilion;ilc lor
Inclusion / l-Aclusion
23
Plastics material and resin
manufacturing
Personal
Product technician
109.9
1
STEL
Haloeenated
Solvents Industrv
Alliance (2018)
1.6
Worker - 15-min STEL
24
Plastics material and resin
manufacturing
Personal
Product technician
50.7
1
STEL
Solvents Industrv
Alliance (2018)
1.6
Worker - 30-min STEL
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
c - OSHA indicated that Non-detect samples may be the result of many different inspector intentions when deciding to sample; therefore, ND values from OSHA were excluded.
Page 223 of 294
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A.15
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Lithographic Printing Plate Cleaning
TableApx A-26 presents full-shift monitoring data for lithographic printing plate cleaning.
• Row 1 presents 8-hr TWA data for 61 workers with occupational exposure to methylene
chloride through 8-hr shifts cleaning up printing rolls with methylene chloride or using
methylene chloride as a solvent in production. The monitoring data was split up into 4-hr
TWA samples, as the workers' 8-hr days were split into 4-hr morning and afternoon
shifts. The full 8-hr exposures ranged from 3.5 to 625.3 mg/m3, with a mean of 34.4
mg/m3 (TJkai et at.. 1998).
• Rows 2 and 3 present data from a NIOSH HHE performed in 1980 at Looart Press
Incorporated, Colorado Springs, Colorado. The evaluation was requested over concerns
about the platemaking and pressroom areas. Two personal TWA exposure samples were
determined for methylene chloride exposure, resulting in ND and 17 mg/m3 (Ahrenholz.
1980V
• Row 4 presents a data point from IARC (2016) that indicated exposure of 24.3 mg/m3
during cleaning presses, but did not indicate whether the exposure was an 8-hr TWA;
therefore, this data point was excluded in favor of higher quality data (IARC. 2016).
• Rows 5 and 6 present modeled exposure concentrations from printing and ink cleaning,
ranging from 0 to 1,632 mg/m3; these data points were excluded for actual monitoring
data (Yamada et at.. 2014); (Yamada et at.. 2015)
• Rows 7 through 50 contain 8-hr TWA exposure data compiled in EPA's 1985 exposure
and release assessment for printing operations. Exposure concentrations for various
workers ranged from ND to 547.9mg/m3 (US EPA. 1985).
Table Apx A-27 presents short-term data.
• Row 1 presents the 4-hr TWA exposure concentrations as described in Row 1 of
Table Apx A-26. Worker exposures ranged from 3.5 to 937.9 mg/m3 Ukai (1998).
Page 224 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-26. Summary of Full-Shift Inhalation Monitoring I
Row
Indusln
Tj pc of
Siimplo
Worker Adi\ ilj or
Siiniplin^ l.ncnlion
Mcllnlcnc Chloride
Airborne ('onccnlr;ilion
(niii/m M •l h
Number ol°
Samples
Tjpe of
Mciisurcmcnl
Soiiito
Score
K;ilion;ilc lor
Inclusion /
I'Aclnsion
1
Printing
Personal
Cleaning of printing rolls /
solvent in production
3.5-625.3
34.3 (mean)
61
8-hrTWA
Ukai et al. (1998)
2.1
Included - 8-hr
TW A-Monitoring
Study
2
Printing
Personal
Platemaking Employees -
Cleaning step and repeat
machine
ND
1
Full-Shift
Ahrenholz (1980)
1.7
Included - full-
shift TWA-
NIOSH HHE
3
Printing
Personal
Platemaking Employees -
Cleaning step and repeat
machine
17
1
Full-Shift
Ahrenholz (1980)
1.7
Included - full-
shift TWA-
NIOSH HHE
4
Printing
Personal
Cleaning Presses
24.31
1
Full-Shift
1.9
Excluded-Used
actual monitoring
data
5
Printing
Personal
Printing/Ink Cleaning
(modeled)
0-521.04
n/a
Full-Shift
(modeled)
Yamada et al.
(2015)
4.0
Excluded-Used
actual monitoring
data
6
Printing
Personal
Printing/Ink Cleaning
(modeled)
69.47- 1,632.6
n/a
Full-Shift
(modeled)
Yamada et al.
4.0
Excluded-Used
actual monitoring
data
7
Graphic Arts
Personal
Multilith Operator
62.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
8
Screen Printing
Personal
Printing
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
9
Screen Printing
Personal
Printing
10.5
1
8-hr TWA
US EPA (19851
1.4
Included - Worker
8-hr TWA
10
Screen Printing
Personal
Printing
ND
1
8-hr TWA
US EPA (19851
1.4
Included - Worker
8-hr TWA
11
Screen Printing
Personal
Printing
17.5
1
8-hr TWA
US EPA (19851
1.4
Included - Worker
8-hr TWA
12
Department Stores
Personal
Asst. Printer
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
13
Department Stores
Personal
Sign Maker
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
ata for Lithographic Printing Plate Cleaning
Page 225 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-26. Summary of Full-Shift
Inhalation Monitoring I
Row
Indusln
Tj pc of
Siimplo
Worker Adi\ ilj or
Siiniplin^ l.ncnlion
Mcllnlcnc Chloride
Airborne Conccnlnilion
(niii/m M •l h
Number ol°
Samples
Tjpe of
Mciisurcmcnl
Soiiito
Score
K;ilion;ilc lor
Inclusion /
I'Aclnsion
14
Department Stores
Personal
Printing Shop
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
15
Department Stores
Personal
Printer
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
16
Department Stores
Personal
Printer
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
17
Direct Selling Est.
Personal
Virkotype Printer
3.5
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
18
Direct Selling Est.
Personal
Offset Printer
3.5
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
19
Government
Personal
Printer
ND
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
20
Newspapers
Personal
Pressman
77.4
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
21
Newspapers
Personal
Pressman
152.9
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
22
Newspapers
Personal
Pressman
76.4
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
23
Newspapers
Personal
Pressman
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
24
Lithographic Printing
Personal
Pressman
3.7
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
25
Lithographic Printing
Personal
Printing Press
ND
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
26
Lithographic Printing
Personal
First Feeder
ND
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
27
Lithographic Printing
Personal
Printing Press
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
28
Lithographic Printing
Personal
Pressman
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
29
Lithographic Platemaking
Personal
Proof Press Operator
139.7
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
ata for Lithographic Printing Plate Cleaning
Page 226 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-26. Summary of Full-Shift
Inhalation Monitoring I
Row
Indusln
Tj pc of
Siimplo
Worker Adi\ ilj or
Siiniplin^ l.ncnlion
Mcllnlcnc Chloride
Airborne ('onccnlr;ilion
(niii/m M •l h
Number ol°
Samples
Tjpe of
Mciisurcmcnl
Soiiito
Score
K;ilion;ilc lor
Inclusion /
I'Aclnsion
30
Industrial Controls
Personal
Screen Washer
76.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
31
Industrial Controls
Personal
Silk Screen Oper.
179.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
32
Fabr. Textile Products NEW
Personal
Screen Washer
36.9
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
33
Fabr. Textile Products NEW
Personal
Screen Washer
18.0
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
34
Stationery Products
Personal
Platemaker
17.0
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
35
Stationery Products
Personal
Platemaker
ND
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
36
Graphic Arts
Personal
Platemaker
19.2
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
37
Graphic Arts
Personal
Platemaker
30.7
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
38
Graphic Arts
Personal
Plate Cleaner
221.3
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
39
Lithographic Printing
Personal
Helper
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
40
Lithographic Platemaking
Personal
Etcher Operator
296.7
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
41
Graphic Arts
Personal
Mat Preparation
62.8
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
42
Graphic Arts
Personal
Film Processor
22.7
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
43
Screen Printing
Personal
Image Making
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
44
Screen Printing
Personal
Chopping
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
45
Screen Printing
Personal
Trimming
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
ata for Lithographic Printing Plate Cleaning
Page 227 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-26. Summary of Full-Shift Inhalation Monitoring Data for Lithographic Printing Plate Cleaning
Row
Indusln
Tj pc of
Siimplo
Worker Adi\ il\ or
Siiniplin^ Locution
Methylene Chloride
Airborne ('onccnlr;ilion
(mii/m M •l h
Nil ill hoi'of
Siimplos
1 Ape of
Measurement
Souree
Score
Riitiomile for
Inclusion /
I'Aclusion
46
Screen Printing
Personal
Cutting
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
47
Screen Printing
Personal
Sewing
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
48
Graphic Arts
Personal
Stripper
24.4
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker
8-hr TWA
49
Commercial Letterpress
Personal
Clean-up Man
157.1
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
50
Commercial Letterpress
Personal
Screen Maker
547.9
1
8-hr TWA
US EPA (1985}
1.4
Included - Worker
8-hr TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Table Apx A-27. Summary of Short-Term Inhalation Monitoring Data for Lithographic Printing Plate Cleaning
Row
Indusln
Tj pc of
Siimplc
W orkcr Acti\ il\ or
Siiniplin^ Locution
Methylene Chloride
Airborne Conccn trillion
diiii/m M
Nil in her of
Siimples
1 Ape of
Measurement
Souree
Score
Riitioiiiile for
Inclusion /
Lxclusion
1
Printing
Personal
( leaiiiim of pi'iiiiiim rolls
solvent in production
; 5.. >r.s
35.4 (mean)
o 1
4-hrTWA
"ImsT
2.1
I sod as 4-hr 1 \\ \
data
2
Printing
Personal
Platemaking Employees -
Cleaning step and repeat
machine
3.5-476
25 (mean)
61
4-hrTWA
Ukai et al.
2.1
Used as 4-hr TWA
data
0.938)
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 228 of 294
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A.16
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Pharmaceutical Manufacturing
Table Apx A-28 presents full-shift data for pharmaceutical manufacturing.
• Rows 1 through 3 includes various data points from a 1999 European Commission report.
One reference reported that in the pharmaceutical industry, sealed processes, high
recovery rates and careful handling of discharges can bring exposure rates to around 106
mg/m3. Alternate data from the UK HSE's (1998) occupational exposure database
showed that for process operators in pharmacy the values can in practice be much lower,
in the range of 3.5 to 10 mg/m3. Finally, according to a feasibility study, workers in
production facilities without adequate control measurements could be exposed to levels
between 7 and 3,750 mg/m3 (TNO (CIVOl 19991
• Rows 4 through 15 contain 8-hr TWA exposure data compiled in EPA's 1985 exposure
and release assessment for production workers during pharmaceutical manufacturing.
Exposure concentrations for various workers ranged from ND to 4,628 mg/m3 (US EPA.
1985V
Page 229 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-28. Summary of Full-Shift Inhalation Monitoring Data for Pharmaceutical IV
Row
Indusln
Tj |K' of
Siimplo
\\ orker Adi\ il\ or
Siiinplin^ l ocution
Mcllnlcnc ( hloriric
Airborne (onccnlnilion
(iiiii/iii4) 1 h
Number of
Samples
Tj pe of
Mc;iMircmcnl
Source
Score
Kiilioiiiile lor
Inclusion /
I'Aclnsion
1
Pharmaceuticals
Personal
unknown
106
unknown
8-hr TWA
TNO (CIVO)
2.3
Included- Worker
8-hr TWA
2
Pharmaceuticals
Personal
Unknown
3.5-10
Unknown
8-hr TWA
TNO (CIVO)
2.3
Included- Worker
8-hr TWA
3
Pharmaceuticals
Personal
unknown
7-3,750
Unknown
8-hr TWA
TNO (CIVO)
2.3
Excluded - used
more recent data
(consistent with
EC, 1999)
4
Pharmaceuticals
Personal
Operator
1
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
5
Pharmaceuticals
Personal
Operator
587
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
6
Pharmaceuticals
Personal
Film Coater
ND
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
7
Pharmaceuticals
Personal
Film Coater
142
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
8
Pharmaceuticals
Personal
Operator
230
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
9
Pharmaceuticals
Personal
Operator
467
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
10
Pharmaceuticals
Personal
Production
2003
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
11
Pharmaceuticals
Personal
Production
2865
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
12
Pharmaceuticals
Personal
Production
4628
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
13
Pharmaceuticals
Personal
Lead
ND
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
14
Pharmaceuticals
Personal
Chemical Operator
315
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
15
Pharmaceuticals
Personal
Chemical Operator
192
1
8-hr TWA
US EPA (.1.985)
1.4
Included- Worker
8-hr TWA
anufacturing
Page 230 of 294
-------
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 231 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
A,17 Non-Aerosol Industrial and Commercial Use
Table Apx A-29 presents full-shift data for non-aerosol industrial and commercial use.
• Rows 1 through 108 contain 8-hr TWA exposure data compiled in EPA's 1985 exposure
and release assessment for production workers during general cleaning uses. Exposure
concentrations for various workers ranged from ND to 1,294.8 mg/m3 ( 35).
Page 232 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
Row
1 ndii sin
T\|HM»rS;ini|)k'
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc Chloride Airborne
Conccnlriilion (iii^/ni1)¦lh
Nilmher of
Siimples
Tj |)C of
Mc;isiircmcnl
Sou rcc
Score
Kiilioiiiile lor
Inclusion /
r.xclnsion
1
Air Transport
Personal
Maintenance Utility
423.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
2
Air Transport
Personal
Maintenance Utility
313.4
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
3
Air Transport
Personal
Maintenance Utility
491.0
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
4
Air Transport
Personal
Maintenance Utility
197.2
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
5
Alkalies & Chlorine
Personal
Maintenance Man
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
6
Colleges
Personal
Janitorial
ND
1
8-hr TWA
USEPA'1985'
1.4
Included - Worker 8-
hr TWA
7
Colleges
Personal
Janitorial
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
8
Consulting Services
Personal
Maintenance Man
65.3
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
9
Consulting Services
Personal
Maintenance Man
39.5
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
10
Sporting Goods
Personal
Paint Operator
65.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
11
Totalizing Fluid Meters
Personal
Painter
70.5
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
12
Nonferrous Foundies NEC
Personal
Painter
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
13
Nonferrous Foundies NEC
Personal
Painter
ND
1
8-hr TWA
USEPA('',85)
1.4
Included - Worker 8-
hr TWA
14
Electronic Components
Personal
Pour Head Operator
101.2
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
15
Electronic Components
Personal
Pour Head Operator
167.5
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
16
Sporting Goods
Personal
Rim Operator
43.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
Page 233 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
Row
1 ndii sin
T\|HM»rS;ini|)k'
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc Chloride Airborne
Conccnlriilion (iii^/ni1)¦lh
Nilmher of
Siimples
Tj |)C of
Mc;isiircmcnl
Sou rcc
Score
Kiilioiiiile lor
Inclusion /
r.xclnsion
17
Sporting Goods
Personal
Rim Operator
59.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
18
Sporting Goods
Personal
Rim Operator
31.0
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
19
Sporting Goods
Personal
Rim Operator
2.0
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
20
Sporting Goods
Personal
Rim Operator
2.0
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
21
Sporting Goods
Personal
Sole Operator
72.0
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
22
Sporting Goods
Personal
Sole Operator
104.0
1
8-hr TWA
USEPA'1985'
1.4
Included - Worker 8-
hr TWA
23
Sporting Goods
Personal
Glue Operator
12.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
24
Sporting Goods
Personal
Glue Operator
62.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
25
Sporting Goods
Personal
Clean-Up Operator
64.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
26
Sporting Goods
Personal
Glue Operator
69.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
27
Sporting Goods
Personal
Glue Operator
131.0
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
28
Sporting Goods
Personal
Glue Operator
28.0
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
29
Sporting Goods
Personal
Tongue Ass. Oper
15.0
1
8-hr TWA
USEPA('',85)
1.4
Included - Worker 8-
hr TWA
30
Sporting Goods
Personal
Tongue Ass. Oper
16.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
31
Sporting Goods
Personal
Cuff Glue Oper.
29.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
32
Sporting Goods
Personal
Hot Max Oper.
22.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
Page 234 of 294
-------
Row
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
I ndii sin
T\|H'ol'S;ini|>k'
\\ orker Aiii\ ilj or
Siiinplin^ locution
Mi l In lone Chloride Airborne
('onconli'iilion (in^/in1) ¦lh
Number of
Siimplos
Tj pi* of
Mciisiiivnionl
S((ll ITC
Sporting Goods
Personal
Hot Max Oper.
11.0
8-hr TWA
US EPA (.1.985)
Mineral Wool
Personal
Utility Operator
84.5
8-hr TWA
US EPA (.1.985)
Mineral Wool
Personal
Pt. Applicator
94.9
8-hr TWA
US EPA (.1.985)
Mineral Wool
Personal
Dyken Operator
84.5
8-hr TWA
Mineral Wool
Personal
Pt. Operator
84.3
8-hr TWA
Aluminum Foundries
Personal
Core Machine
Operator
ND
8-hr TWA
Brass Foundries
Personal
Griner
0.6
8-hr TWA
US EPA (.1.985)
Misc Plastic Products
Personal
Equipment Operator
ND
8-hr TWA
US EPA (.1.985)
Misc Plastic Products
Personal
Equipment Operator
ND
8-hr TWA
US EPA (.1.985)
Pumping Equipment
Personal
Inpres. Operator
83.*
8-hr TWA
US EPA (.1.985)
Wholesale Comm. Machines
Personal
DCR Operator
127.7
8-hr TWA
Motor Vehicle Parts
Personal
Micell. Mach. Oper.
20.5
8-hr TWA
Motor Vehicle Parts
Personal
Micell. Mach. Oper.
41.2
8-hr TWA
Special Dies & Tools
Personal
Press Operator
87.3
8-hr TWA
US EPA (.1.985)
A/C & Heatig
Personal
Machine Operator
174.5
8-hr TWA
US EPA (.1.985)
U.S. Postal Service
Personal
Mail Process Eqpt.
ND
8-hr TWA
US EPA (.1.985)
Page 235 of 294
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PEER REVIEW DRAFT, DO NOT CITE OR QUOTE
Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
Row
1 ndii sin
T\|HM»rS;ini|)k'
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc Chloride Airborne
Conccnlriilion (iii^/ni1)¦lh
Nilmher of
Siimples
Tj |)C of
Mc;isiircmcnl
Sou rcc
Score
Kiilioiiiile lor
Inclusion /
r.xclnsion
49
U.S. Postal Service
Personal
Mail Process Eqpt.
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
50
Hand & Edge Tools
Personal
Induction Machine
ND
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
51
Hand & Edge Tools
Personal
Unassigned Machine
ND
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
52
Coating & Engraving
Personal
Machine Operator
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
53
Coating & Engraving
Personal
Asst. Machine Oper.
232.4
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
54
Industrial Controls
Personal
Machine Operator
966.7
1
8-hr TWA
USEPA'1985'
1.4
Included - Worker 8-
hr TWA
55
Petroleum Refining
Personal
Machinist
10.5
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
56
Electric Repair
Personal
Assembler
1294.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
57
Electric Repair
Personal
Assembler
621.2
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
58
Electric Repair
Personal
Assembler
1294.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
59
Electric Repair
Personal
Assembler
621.2
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
60
Service Ind. Machines NEC
Personal
Assembler
1017.3
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
61
Service Ind. Machines NEC
Personal
Assembler
205.9
1
8-hr TWA
USEPA('',85)
1.4
Included - Worker 8-
hr TWA
62
Service Ind. Machines NEC
Personal
Assembler
764.3
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
63
Service Ind. Machines NEC
Personal
Assembler
862.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
64
Sporting Goods
Personal
Mold Cleaner
40.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
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Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
Row
1 ndii sin
T\|HM»rS;ini|)k'
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc Chloride Airborne
Conccnlriilion (iii^/ni1)¦lh
Nilmher of
Siimples
Tj |)C of
Mc;isiircmcnl
Sou rcc
Score
Kiilioiiiile lor
Inclusion /
r.xclnsion
65
Sporting Goods
Personal
Mold Cleaner
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
66
Sporting Goods
Personal
Mold Cleaner
ND
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
67
Plastic Products
Personal
Fabricator
ND
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
68
Plastic Products
Personal
Fabricator
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
69
Plastic Products
Personal
Fabricator
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
70
Plastic Products
Personal
Fabricator
ND
1
8-hr TWA
USEPA'1985'
1.4
Included - Worker 8-
hr TWA
71
Plastic Products
Personal
Fabricator
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
72
Plastic Products
Personal
Fabricator
59.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
73
Plastic Products
Personal
Fabricator
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
74
Plastic Products
Personal
Helper
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
75
Plastic Products
Personal
Helper
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
76
Plastic Products
Personal
Helper
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
77
Sporting Goods
Personal
Lead Lady
81.0
1
8-hr TWA
USEPA('',85)
1.4
Included - Worker 8-
hr TWA
78
Sporting Goods
Personal
Lead Lady
319.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
79
Sporting Goods
Personal
Riveter
15.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
80
Soaps & Detergents
Personal
Supervisor
376.9
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
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Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
Row
1 ndii sin
Ttpcof Siimplc
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc Chloride Airborne
Conccnlriilion (iii^/ni1)¦lh
Nilmher of
Siimples
Tj |R' of
Mc;isiircmcnl
Sou rcc
Score
Kiilioiiiile for
Inclusion /
I'.xclnsion
81
Soaps & Detergents
Personal
Mixer
150.9
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
82
Aluminum Products
Personal
Inspector
54.3
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
83
Brass Foundries
Personal
Art Chase
2.3
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
84
U.S. Postal Service
Personal
Electronics
Technician
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
85
Cleaning Services
Personal
Asst. Supervisor
468.7
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
86
Misc. Plastic Products
Personal
Mixer
137.9
1
8-hr TWA
USEPA'1985'
1.4
Included - Worker 8-
hr TWA
87
Transportation Eqpt. NEC
Personal
Mechanic
311.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
88
Oil Field Machinery
Personal
Helper
188.2
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
89
Machine Tools
Personal
Snipper
90.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
90
A/C & Heating Eqpt.
Personal
Disassembler Steam
323.0
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
91
Metal Doors
Personal
Sealer
87.3
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
92
Auto Repair
Personal
Installer
51.1
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
93
Metal Household Furniture
Personal
Set-up Man
1129.5
1
8-hr TWA
USEPA('',85)
1.4
Included - Worker 8-
hr TWA
94
Measurement Instruments
Personal
Washer
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
95
Photographic Equipment
Personal
Transport Cleaner
76.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
96
Photographic Equipment
Personal
Transport Cleaner
76.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
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Table Apx A-29. Summary of Full-Shift Inhalation Monitoring Data for Non-Aerosol Commercial Use
Row
1 ndii sin
Ttpcof Siimplc
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Mcllnlcnc Chloride Airborne
Conccnlriilion (iii^/ni1)¦lh
Number of
Siimples
Tj |H' of
Mc;isiircmcnl
Sou rcc
Score
Kiilioiiiile for
Inclusion /
I'.xclnsion
97
Photographic Equipment
Personal
Transport Cleaner
76.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
98
Electroplating
Personal
Watch Band Cleaner
61.6
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
99
Electroplating
Personal
Compounder
1092.4
1
8-hr TWA
5\
1.4
Included - Worker 8-
hr TWA
100
Coating & Engraving
Personal
Line Helper
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
101
Small Arms Ammo
Personal
Applier
59.3
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
102
Small Arms Ammo
Personal
Applier
247.8
1
8-hr TWA
USEPA'1985'
1.4
Included - Worker 8-
hr TWA
103
Motors & Generators
Personal
Grinder Washer
23.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
104
Petroleum Refining
Personal
Ketone Operator
46.8
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
105
Refuse Systems
Personal
Foreman
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
106
Refuse Systems
Personal
Drum Cutter
ND
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
107
Refuse Systems
Personal
Operator
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
108
Refuse Systems
Personal
General Laborer
ND
1
8-hr TWA
liSEPAll985)
1.4
Included - Worker 8-
hr TWA
a - Statistics provided by the cited source and are presented here as they were presented in the source.
b - Values provided in ppm were converted to mg/m3 by multiplying the measurement in ppm by the molecular weight of methylene chloride (84.93 g/mol) and dividing by molar volume (24.45 L)
Page 239 of 294
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A, 18 Waste Handling, Disposal, Treatment, and Recycling
TableApx A-30 presents full-shift data for from waste handling, disposal, treatment, and
recycling.
• Rows 1 through 3 contain 8-hr TWA exposure data compiled in EPA's 1985 exposure
and release assessment for solvent reclaimers during solvent recovery. Exposure
concentrations for various workers ranged from 10.5 to 19.2 mg/m3 (US EPA. 1985).
• Rows 4 through 7 contain full-shift exposure data compiled by DOD from 2015 and 2017
during waste disposal and sludge operations. Exposure concentrations for various
workers ranged from 0.4 to 2.3 mg/m3 (various sample times) ((DOEHRS-IH). 2018).
Note that the data were provided over various sample times that corresponded with the
process durations; therefore, EPA averaged the exposures over an 8-hr period to calculate
8-hr TWAs.
Table Apx A-31 presents short-term data for from waste handling, disposal, treatment, and
recycling.
• Rows 1 through 8 contain short-term exposure data compiled by DOD from 2014 and
2015 during waste transfer. Exposure concentrations for various workers ranged from 1.8
to 5.8 mg/m3 (various sample times) ((DOEHRS-IH). 20.1.8).
Page 240 of 294
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Table Apx A-30. Summary of Full-Shift Inhalation Monitoring Data for Waste Handling, Disposal, Treatment, and Recycling
Row
1 ndii sin
Ttpeof S;imple
\\ orkcr Acli\ ilj or
Siiinplin^ l ocution
Methylene Chloride Airborne
Concenlriilion (iii^/ni1)¦lh
Number of
Samples
Tj pe of
Measurement
Source
Score
Kiilioiiiile for
Inclusion /
l'l\cliision
1
Solvent Recovery
Personal
Solvent Reclaimer
19.2
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
2
Solvent Recovery
Personal
Solvent Reclaimer
18.5
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
3
Solvent Recovery
Personal
Solvent Reclaimer
10.5
1
8-hr TWA
US EPA (1985)
1.4
Included - Worker 8-
hr TWA
4
DOD Waste Disposal and
Sludge Handling
Personal
Waste Disposal
0.4
1
8-hr TWA
((DOEHRS-IH).
2018)
1.3
Included - Worker 8-
hr TWA
5
DOD Waste Disposal and
Sludge Handling
Personal
313 A Sludge
Operations
2.3
1
8-hr TWA
((DOEHRS-IH).
2018)
1.3
Included - Worker 8-
hr TWA
6
DOD Waste Disposal and
Sludge Handling
Personal
313 A Sludge
Operations
2.3
1
8-hr TWA
((DOEHRS-IH).
2018)
1.3
Included - Worker 8-
hr TWA
7
DOD Waste Disposal and
Sludge Handling
Personal
313 A Sludge
Operations
2.3
1
8-hr TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker 8-
hr TWA
Table Apx A-31. Summary of Short-Term Inhalation Monitoring Data for Waste Handling, Disposal, Treatment, and Recycling
Row
1 mlu sin
T\pcof Siimple
\\orkcr Acli\ il\ or Siimplin^
l.ociilion
\lelh\lenc
Chloride
Airborne
( onccnlmlion
(niii/ni1) •l h
Number of
Siimples
Tj pe of
Measurement
Source
Score
Kiiliomile for
Inclusion /
I'Aclusion
1
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
from the bowser and storage tanks,
addition of chemicals to tanks
2.9
1
30-min TWA
((DOEHRS-IH).
20.1.8)
1.3
Included - Worker
30-min TWA
2
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
from the bowser and storage tanks,
addition of chemicals to tanks
2.9
1
30-min TWA
((DOEHRS-IH),
20.1.8)
1.3
Included - Worker
30-min TWA
3
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
1.8
1
2.5-hr TWA
((DOEHRS-IH).
20.1.8)
1.3
No health
comparisons for 2-
Page 241 of 294
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Table Apx A-31. Summary of Short-Term Inhalation Monitoring Data for Waste Handling, Disposal, Treatment, and Recycling
Row
1 ihIii sin
T\ pool'S;i mp lc
\\orkcr Acli\ il\ or Siiniplin^
Locution
Mclhjlcnc
Chloride
Airborne
( onccnlr;ilion
(inii/in1) •l h
Nil in her of
Siimpk-s
Tj pc of
MciiMircmcnl
Source
Score
Kiilioiiiile lor
Inclusion /
r.xclusion
from the bowser and storage tanks,
addition of chemicals to tanks
or 3-hr TWA.
Presented data point,
but not used to
calculate risk.
4
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
from the bowser and storage tanks,
addition of chemicals to tanks
5.8
1
2.5-hr TWA
O'DOEHRS-IH).
2018)
1.3
No health
comparisons for 2-
or3-hrTWA.
Presented data point,
but not used to
calculate risk.
5
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
from the bowser and storage tanks,
addition of chemicals to tanks
2.7
1
2.5-hr TWA
(TDOEHRS-IH).
2018)
1.3
No health
comparisons for 2-
or3-hrTWA.
Presented data point,
but not used to
calculate risk.
6
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
from the bowser and storage tanks,
addition of chemicals to tanks
2.8
1
2.5-hr TWA
(TDOEHRS-IH).
20.1.8)
1.3
No health
comparisons for 2-
or3-hrTWA.
Presented data point,
but not used to
calculate risk.
7
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
from the bowser and storage tanks,
addition of chemicals to tanks
0.8
1
3-hr TWA
(TDOEHRS-IH).
20.1.8)
1.3
No health
comparisons for 2-
or3-hrTWA.
Presented data point,
but not used to
calculate risk.
8
DOD Waste Disposal and
Sludge Handling
Personal
IND-025-00 Hazardous Waste
Disposers: Transfer chemical to and
3.4
1
2.5-hr TWA
(TDOEHRS-IH).
20.1.8)
1.3
No health
comparisons for 2-
or3-hrTWA.
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Table Apx A-31. Summary of Short-Term Inhalation Monitoring Data for Waste Handling, Disposal, Treatment, and Recycling
Row
1 ihIii sin
T\|K'ol'S;un|)k'
\\orker Acli\ il\ or Siiniplin^
Locution
\lclh\lcnc
Chloride
Airborne
( onccnlr;ilion
(inii/in1) •l h
Nil in her of
Siimpk-s
Tj |>c of
Mciisiircmcnl
Soiiivo
Score
Kiilioiiiilc lor
Inclusion /
r.xclusion
from the bowser and storage tanks,
addition of chemicals to tanks
Presented data point,
but not used to
calculate risk.
Page 243 of 294
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APPENDIX B APPROACH FOR ESTIMATING NUMBER OF
WORKERS
This appendix summarizes the methods that EPA/OPPT used to estimate the number of workers who are
potentially exposed to methylene chloride in each of its conditions of use. The method consists of the
following steps:
1. Identify the North American Industry Classification System (NAICS) codes for the industry
sectors associated with each condition of use.
2. Estimate total employment by industry/occupation combination using the Bureau of Labor
Statistics' Occupational Employment Statistics (OES) data (U.S. BLS. 2016).
3. Refine the OES estimates where they are not sufficiently granular by using the U.S. Census'
Statistics of U.S. Businesses (SUSB) data ( isus Bureau. 2015) on total employment by
6-digit NAICS.
4. Estimate the percentage of employees likely to be using methylene chloride instead of other
chemicals (i.e., the market penetration of methylene chloride in the condition of use).
5. Estimate the number of sites and number of potentially exposed employees per site.
6. Estimate the number of potentially exposed employees within the condition of use.
Step 1: Identifying Affected NAICS Codes
As a first step, EPA/OPPT identified NAICS industry codes associated with each condition of use.
EPA/OPPT generally identified NAICS industry codes for a condition of use by:
• Querying the U.S. Census Bureau's NAICS Search tool using keywords associated with each
condition of use to identify NAICS codes with descriptions that match the condition of use.
• Referencing EPA/OPPT Generic Scenarios (GS's) and Organisation for Economic Co-operation
and Development (OECD) Emission Scenario Documents (ESDs) for a condition of use to
identify NAICS codes cited by the GS or ESD.
• Reviewing Chemical Data Reporting (CDR) data for the chemical, identifying the industrial
sector codes reported for downstream industrial uses, and matching those industrial sector codes
to NAICS codes using Table D-2 provided in the CDR reporting instructions.
Each condition of use section in the main body of this report identifies the NAICS codes EPA/OPPT
identified for the respective condition of use.
Step 2: Estimating Total Employment by Industry and Occupation
BLS's (U.S. BLS. 2016) OES data provide employment data for workers in specific industries and
occupations. The industries are classified by NAICS codes (identified previously), and occupations are
classified by Standard Occupational Classification (SOC) codes.
Among the relevant NAICS codes (identified previously), EPA/OPPT reviewed the occupation
description and identified those occupations (SOC codes) where workers are potentially exposed to
methylene chloride. Table Apx B-l shows the SOC codes EPA/OPPT classified as occupations
potentially exposed to methylene chloride. These occupations are classified into workers (W) and
Page 244 of 294
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occupational non-users (O). All other SOC codes are assumed to represent occupations where exposure
is unlikely.
TableApx B-l. SOCs with Worker and ONU Designations for All Conditions of Use Except Dry
Cleaning
S()<
Occii pillion
Dcsi^iiiilion
1 1 -9020
Construction Managers
O
17-2000
Engineers
O
17-3000
Drafters, Engineering Technicians, and Mapping Technicians
0
19-2031
Chemists
0
19-4000
Life, Physical, and Social Science Technicians
0
47-1000
Supervisors of Construction and Extraction Workers
0
47-2000
Construction Trades Workers
w
49-1000
Supervisors of Installation, Maintenance, and Repair Workers
0
49-2000
Electrical and Electronic Equipment Mechanics, Installers, and
Repairers
w
49-3000
Vehicle and Mobile Equipment Mechanics, Installers, and Repairers
w
49-9010
Control and Valve Installers and Repairers
w
49-9020
Heating, Air Conditioning, and Refrigeration Mechanics and Installers
w
49-9040
Industrial Machinery Installation, Repair, and Maintenance Workers
w
49-9060
Precision Instrument and Equipment Repairers
w
49-9070
Maintenance and Repair Workers, General
w
49-9090
Miscellaneous Installation, Maintenance, and Repair Workers
w
51-1000
Supervisors of Production Workers
0
51-2000
Assemblers and Fabricators
w
51-4020
Forming Machine Setters, Operators, and Tenders, Metal and Plastic
w
51-6010
Laundry and Dry-Cleaning Workers
w
51-6020
Pressers, Textile, Garment, and Related Materials
w
51-6030
Sewing Machine Operators
0
51-6040
Shoe and Leather Workers
0
51-6050
Tailors, Dressmakers, and Sewers
0
51-6090
Miscellaneous Textile, Apparel, and Furnishings Workers
0
51-8020
Stationary Engineers and Boiler Operators
w
51-8090
Miscellaneous Plant and System Operators
w
51-9000
Other Production Occupations
w
W = worker designation
O = ONU designation
For dry cleaning facilities, due to the unique nature of work expected at these facilities and that different
workers may be expected to share among activities with higher exposure potential (e.g., unloading the
dry cleaning machine, pressing/finishing a dry cleaned load), EPA/OPPT made different SOC code
worker and ONU assignments for this condition of use. Table Apx B-2 summarizes the SOC codes with
worker and ONU designations used for dry cleaning facilities.
)le Apx B-2. SOCs with Worker and ONU Designations for Dry Cleaning Facilil
SOC
Occii pillion
Dcsiuiiiilion
41-2000
Rclail Sales Workers
O
49-9040
Industrial Machinery Installation, Repair, and Maintenance Workers
w
49-9070
Maintenance and Repair Workers, General
w
49-9090
Miscellaneous Installation, Maintenance, and Repair Workers
w
51-6010
Laundry and Dry-Cleaning Workers
w
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SOC
Occu pillion
IH'siuiiiilinn
51-6020
Pressers, Textile, Garment, and Related Materials
W
51-6030
Sewing Machine Operators
O
51-6040
Shoe and Leather Workers
O
51-6050
Tailors, Dressmakers, and Sewers
O
51-6090
Miscellaneous Textile, Apparel, and Furnishings Workers
O
W = worker designation
O = ONU designation
After identifying relevant NAICS and SOC codes, EPA/OPPT used BLS data to determine total
employment by industry and by occupation based on the NAICS and SOC combinations. For example,
there are 110,640 employees associated with 4-digit NAICS 8123 {Dry cleaning and Laundry Services)
and SOC 51-6010 (Laundry andDry-Cleaning Workers).
Using a combination of NAICS and SOC codes to estimate total employment provides more accurate
estimates for the number of workers than using NAICS codes alone. Using only NAICS codes to
estimate number of workers typically result in an overestimate, because not all workers employed in that
industry sector will be exposed. However, in some cases, BLS only provide employment data at the 4-
digit or 5-digit NAICS level; therefore, further refinement of this approach may be needed (see next
step).
Step 3: Refining Employment Estimates to Account for lack of NAICS Granularity
The third step in EPA/OPPT's methodology was to further refine the employment estimates by using
total employment data in the U.S. Census Bureau's (U.S. Census Bureau. 2015) SUSB. In some cases,
BLS OES's occupation-specific data are only available at the 4-digit or 5-digit NAICS level, whereas
the SUSB data are available at the 6-digit level (but are not occupation-specific). Identifying specific 6-
digit NAICS will ensure that only industries with potential methylene chloride exposure are included.
As an example, OES data are available for the 4-digit NAICS 8123 Dry cleaning and Laundry Services,
which includes the following 6-digit NAICS:
• NAICS 812310 Coin-Operated Laundries and Drycleaners;
• NAICS 812320 Drycleaning and Laundry Services (except Coin-Operated);
• NAICS 812331 Linen Supply; and
• NAICS 812332 Industrial Launderers.
In this example, only NAICS 812320 is of interest. The Census data allow EPA/OPPT to calculate
employment in the specific 6-digit NAICS of interest as a percentage of employment in the BLS 4-digit
NAICS.
The 6-digit NAICS 812320 comprises 46 percent of total employment under the 4-digit NAICS 8123.
This percentage can be multiplied by the occupation-specific employment estimates given in the BLS
OES data to further refine our estimates of the number of employees with potential exposure.
Table_Apx B-3 illustrates this granularity adjustment for NAICS 812320.
Table Apx B-3. Estimated Number of Potentially Exposed Workers and ONUs under NAICS
812320
NAICS
SOC
com-:
SOC Description
Occn p:il i«ui
Dosi^iiiilion
Kmpltmm-nl
In SOC ill 4-
V-'ii (if Tolill
Kmpltmiicnl
I-: Mi m ill c(l
l-'.mpltmiH-iil
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diiiil NAICS
le\ el
In SOC al (>-
diiiil NAICS
le\ el
8123
41-2000
Retail Sales Workers
O
44,500
46.0%
20,459
8123
49-9040
Industrial Machinery
Installation, Repair, and
Maintenance Workers
w
1,790
46.0%
823
8123
49-9070
Maintenance and Repair
Workers, General
w
3,260
46.0%
1,499
8123
49-9090
Miscellaneous Installation,
Maintenance, and Repair
Workers
w
1,080
46.0%
497
8123
51-6010
Laundry and Dry-Cleaning
Workers
w
110,640
46.0%
50,867
8123
51-6020
Pressers, Textile, Garment,
and Related Materials
w
40,250
46.0%
18,505
8123
51-6030
Sewing Machine Operators
0
1,660
46.0%
763
8123
51-6040
Shoe and Leather Workers
0
Not Reported for this NAICS Code
8123
51-6050
Tailors, Dressmakers, and
Sewers
0
2,890
46.0%
1,329
8123
51-6090
Miscellaneous Textile,
Apparel, and Furnishings
Workers
0
0
46.0%
0
Total Potentially Exposed Employees
206,070
94,740
Total Workers
72,190
Total Occupational Non-Users
22,551
Note: numbers may not sum exactly due to rounding.
W = worker
O = occupational non-user
Source: U.S. BLS (20.1.6): U.S. Census Bureau (20.1.5)
Step 4: Estimating the Percentage of Workers Using Methylene Chloride Instead of Other
Chemicals
In the final step, EPA/OPPT accounted for the market share by applying a factor to the number of
workers determined in Step 3. This accounts for the fact that methylene chloride may be only one of
multiple chemicals used for the applications of interest. EPA/OPPT did not identify market penetration
data for any number of conditions of use. In the absence of market penetration data for a given condition
of use, EPA/OPPT assumed methylene chloride may be used at up to all sites and by up to all workers
calculated in this method as a bounding estimate. This assumes a market penetration of 100%. Market
penetration is discussed for each condition of use in the main body of this report.
Step 5: Estimating the Number of Workers per Site
EPA/OPPT calculated the number of workers and occupational non-users in each industry/occupation
combination using the formula below (granularity adjustment is only applicable where SOC data are not
available at the 6-digitNAICS level):
Number of Workers or ONUs in NAICS/SOC (Step 2) x Granularity Adjustment Percentage (Step 3) =
Number of Workers or ONUs in the Industry/Occupation Combination
EPA/OPPT then estimated the total number of establishments by obtaining the number of establishments
reported in the U.S. Census Bureau's SUSB (U.S. Census Bureau. 2015) data at the 6-digit NAICS
level.
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EPA/OPPT then summed the number of workers and occupational non-users over all occupations within
a NAICS code and divided these sums by the number of establishments in the NAICS code to calculate
the average number of workers and occupational non-users per site.
Step 6: Estimating the Number of Workers and Sites for a Condition of Use
EPA/OPPT estimated the number of workers and occupational non-users potentially exposed to
methylene chloride and the number of sites that use methylene chloride in a given condition of use
through the following steps:
6. A. Obtaining the total number of establishments by:
i. Obtaining the number of establishments from SUSB (U.S. Census Bureau. 2.015) at the 6-
digit NAICS level (Step 5) for each NAICS code in the condition of use and summing
these values; or
ii. Obtaining the number of establishments from the Toxics Release Inventory (TRI),
Discharge Monitoring Report (DMR) data, National Emissions Inventory (NEI), or
literature for the condition of use.
6.B. Estimating the number of establishments that use methylene chloride by taking the total
number of establishments from Step 6. A and multiplying it by the market penetration factor
from Step 4.
6.C. Estimating the number of workers and occupational non-users potentially exposed to
methylene chloride by taking the number of establishments calculated in Step 6.B and
multiplying it by the average number of workers and occupational non-users per site from
Step 5.
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APPENDIX C EQUATIONS FOR CALCULATING ACUTE AND
CHRONIC EXPOSURES FOR NON-CANCER AND
CANCER
This report assesses exposures to methylene chloride for workers in occupational settings, presented as
8-hr time weighted averages (TWA). The 8-hr TWA exposures are then used to calculate acute
exposure, average daily concentration (ADC) for chronic, non-cancer risks, and lifetime average daily
concentration (LADC) for chronic, cancer risks.
Acute workplace exposures are assumed to be equal to the contaminant concentration in air (8-hr TWA),
per Equation C-l.
Equation C-l
AEC =
CxED
ATn,
Where:
AEC
C
ED
ATacute
= acute exposure concentration
= contaminant concentration in air (TWA)
= exposure duration (8 hr/day)
= acute averaging time (8 hr)
ADC and LADC are used to estimate workplace chronic exposures for non-cancer and cancer risks,
respectively. These exposures are estimated as follows:
Equation C-2
C x ED x EF x WY
ADC or LADC =
AT or ATC
Where:
ADC = average daily concentration (8-hr TWA) used for chronic non-cancer risk calculations
LADC = lifetime average daily concentration (8-hr TWA) used for chronic cancer risk calculations
C = contaminant concentration in air (8-hr TWA)
ED = exposure duration (8 hr/day)
EF = exposure frequency (250 days/yr)
WY = exposed working years per lifetime (50th percentile = 31; 95th percentile = 40)
AT = averaging time, non-cancer risks (WY x 365 days/yr x 24 hr/day)
ATc = averaging time, cancer risks (lifetime (LT) x 250 days/year x 8 hr/day; where LT = 78
years); this averaging time corresponds to the cancer benchmark
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Table Apx C-l. Parameter Values for Calculating Inhalation Exposure Estimates
Parameter Name
Sv ill hoi
Value
1 nil
Exposure Duration
ED
8
hr/day
Exposure Frequency
EF
250
days/year
Working Years
WY
31 (50th percentile)
40 (95th percentile)
years
Lifetime, cancer
LT
78
years
Averaging Time, non-cancer
AT
271,560 (CT)a
350,400 (HE)b
hr
Averaging Time, cancer
ATC
156,000
hr
" Calculated using the 50th percentile value for working years (WY)
b Calculated using the 95th percentile value for working years (WY)
Exposure Duration (ED)
EPA uses an exposure duration of 8 hours per day for averaging full-shift exposures.
Exposure Frequency (EF)
EPA uses an exposure frequency of 250 days per year. Exposure frequency (EF) is expressed as the
number of days per year a worker is exposed to the chemical being assessed. In some cases, it may be
reasonable to assume a worker is exposed to the chemical on each working day. In other cases, it may be
more appropriate to estimate a worker's exposure to the chemical occurs during a subset of the worker's
annual working days. The relationship between exposure frequency and annual working days can be
described mathematically as follows:
EF = fx AWD
Where:
EF = exposure frequency, the number of days per year a worker is exposed to the chemical
(day/yr)
f = fractional number of annual working days during which a worker is exposed to the
chemical (unitless)
AWD = annual working days, the number of days per year a worker works (day/yr)
U.S. BLS (2015) provides data on the total number of hours worked and total number of employees by
each industry NAICS code. These data are available from the 3- to 6-digitNAICS level (where 3-digit
NAICS are less granular and 6-digitNAICS are the most granular). Dividing the total, annual hours
worked by the number of employees yields the average number of hours worked per employee per year
for each NAICS.
EPA has identified approximately 140 NAICS codes applicable to the multiple conditions of use for the
ten chemicals undergoing risk evaluation. For each NAICS code of interest, EPA looked up the average
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hours worked per employee per year at the most granular NAICS level available (i.e., 4-digit, 5-digit, or
6-digit). EPA converted the working hours per employee to working days per year per employee
assuming employees work an average of eight hours per day. The average number of days per year
worked, or AWD, ranges from 169 to 282 days per year, with a 50th percentile value of 250 days per
year. EPA repeated this analysis for all NAICS codes at the 4-digit level. The average AWD for all 4-
digit NAICS codes ranges from 111 to 282 days per year, with a 50th percentile value of 228 days per
year. 250 days per year is approximately the 75th percentile.
In the absence of industry- and methylene chloride-specific data, EPA assumes the parameter/is equal
to one for all conditions of use.
Working Years (WY)
EPA has developed a triangular distribution for working years. EPA has defined the parameters of the
triangular distribution as follows:
• Minimum value: BLS CPS tenure data with current employer as a low-end estimate of the
number of lifetime working years: 10.4 years;
• Mode value: The 50th percentile tenure data with all employers from SIPP as a mode value for
the number of lifetime working years: 36 years; and
• Maximum value: The maximum average tenure data with all employers from SIPP as a high-end
estimate on the number of lifetime working years: 44 years.
This triangular distribution has a 50th percentile value of 31 years and a 95th percentile value of 40 years.
EPA uses these values for central tendency and high-end ADC and LADC calculations, respectively.
The U.S. BLS (2014) provides information on employee tenure with current employer obtained from the
Current Population Survey (CPS). CPS is a monthly sample survey of about 60,000 households that
provides information on the labor force status of the civilian non-institutional population age 16 and
over; CPS data are released every two years. The data are available by demographics and by generic
industry sectors but are not available by NAICS codes.
The U.S. Census Bureau (2019a) Survey of Income and Program Participation (SIPP) provides
information on lifetime tenure with all employers. SIPP is a household survey that collects data on
income, labor force participation, social program participation and eligibility, and general demographic
characteristics through a continuous series of national panel surveys of between 14,000 and 52,000
households (U.S. Census Bureau. 2019b). EPA analyzed the 2008 SIPP Panel Wave 1, a panel that
began in 2008 and covers the interview months of September 2008 through December 2008 (U.S.
Census Bureau. , b). For this panel, lifetime tenure data are available by Census Industry Codes,
which can be cross-walked with NAICS codes.
SIPP data include fields for the industry in which each surveyed, employed individual works
(TJBIND1), worker age (TAGE), and years of work experience with all employers over the surveyed
individual's lifetime.5 Census household surveys use different industry codes than the NAICS codes
5 To calculate the number of years of work experience we took the difference between the year first worked (TMAKMNYR)
and the current data year (i.e., 2008). We then subtracted any intervening months when not working (ETIMEOFF).
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used in its firm surveys, so these were converted to NAICS using a published crosswalk (U.S. Census
Bureau. 2013). EPA calculated the average tenure for the following age groups: 1) workers age 50 and
older; 2) workers age 60 and older; and 3) workers of all ages employed at time of survey. EPA used
tenure data for age group "50 and older" to determine the high-end lifetime working years, because the
sample size in this age group is often substantially higher than the sample size for age group "60 and
older". For some industries, the number of workers surveyed, or the sample size, was too small to
provide a reliable representation of the worker tenure in that industry. Therefore, EPA excluded data
where the sample size is less than five from our analysis.
TableApx C-2 summarizes the average tenure for workers age 50 and older from SIPP data. Although
the tenure may differ for any given industry sector, there is no significant variability between the 50th
and 95th percentile values of average tenure across manufacturing and non-manufacturing sectors.
Table Apx C-2. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)
Industry Sectors
Working Years
Average
50th
Percentile
95th
Percentile
Maximum
All industry sectors relevant to the 10
chemicals undergoing risk evaluation
35.9
36
39
44
Manufacturing sectors (NAICS 31-33)
35.7
36
39
40
Non-manufacturing sectors (NAICS
42-81)
36.1
36
39
44
Source: Census Bureau (2019a).
Note: Industries where sample size is less than five are excluded from this analysis.
BLS CPS data provides the median years of tenure that wage and salary workers had been with their
current employer. Table Apx C-3 presents CPS data for all demographics (men and women) by age
group from 2008 to 2012. To estimate the low-end value on number of working years, EPA uses the
most recent (2014) CPS data for workers age 55 to 64 years, which indicates a median tenure of 10.4
years with their current employer. The use of this low-end value represents a scenario where workers are
only exposed to the chemical of interest for a portion of their lifetime working years, as they may
change jobs or move from one industry to another throughout their career.
Table Apx C-3. Median Years of Tenure with Current Employer by Age Group
Age
January 2008
January 2010
January 2012
January 2014
16 years and over
4.1
4.4
4.6
4.6
16 to 17 years
0.7
0.7
0.7
0.7
18 to 19 years
0.8
1.0
0.8
0.8
20 to 24 years
1.3
1.5
1.3
1.3
25 years and over
5.1
5.2
5.4
5.5
25 to 34 years
2.7
3.1
3.2
3.0
35 to 44 years
4.9
5.1
5.3
5.2
45 to 54 years
7.6
7.8
7.8
7.9
55 to 64 years
9.9
10.0
10.3
10.4
65 years and over
10.2
9.9
10.3
10.3
Source: U.S. BLS (2014)
Lifetime Years (LT)
EPA assumes a lifetime of 78 years for all worker demographics.
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APPENDIX D SAMPLE CALCULATIONS FOR CALCULATING
ACUTE AND CHRONIC (NON-CANCER AND
CANCER) INHALATION EXPOSURES
Sample calculations for high-end and central tendency chronic exposure concentrations for one setting,
Manufacturing, are demonstrated below. The explanation of the equations and parameters used is
provided in Appendix B. Example High-End ADC and LADC
Calculate ADChe:
_ CHE x ED x EF x WYhe
HE ~ A The
4.6 ^fx 8^— x 250^^x 40years mn
m3 day year 7 mg
HE 350,400 hours ' m3
Calculate L ADChe:
CHE x ED x EF x WYhe
LADChe = — — —
HE ATC
4.6 ^fx 8-^x 250^^x40 years mn
m3 day year * _ n Amd
HE 156,000 hours ' m3
D.2 Example Central Tendency ADC and LADC
Calculate ADCct:
Cct x ED x EF x WYct
ADCct = — — —
AT
ni CT
0.36^fx x 250^£ x 31 years mn
m3 day year J n*m9
CT 271,560 hours ' m3
Calculate LADCct:
Cct x ED x EF x WYct
LADCct = — —
CT ATC
0.36 x 8^x 250^2Hx 31 years mn
LADCct = ^ dZ ^ = 0.14—y
156,000 hours m3
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APPENDIX E DERMAL EXPOSURE ASSESSMENT METHOD
This method was developed through review of relevant literature and consideration of existing exposure
models, such as EPA/OPPT models, and the European Centre for Ecotoxicology and Toxicology of
Chemicals Targeted Risk Assessment (ECETOC TRA).
E.l Incorporating the Effects of Evaporation
E.l.l Modification of EPA/OPPT Models
Current EPA/OPPT dermal models do not incorporate the evaporation of material from the dermis. The
dermal potential dose rate, Dexp (mg/day), is calculated as (U.S. EPA. ):
Equation E-l
Dexp — S x Qu x Yderm x FT
Where:
S is the surface area of contact (cm2; defaults: 535 cm2 (central tendency); 1,070 cm2 (high end) =
full area of one hand (central tendency) or two hands (high end), a mean value for men > 21 yr
(U.S. EPA. 201 I). the highest exposed population)
Qu is the quantity remaining on the skin (mg/cm2-event; defaults: 1.4 mg/cm2-event (central
tendency); 2.1 mg/cm2-event (high end))
Yderm is the weight fraction of the chemical of interest in the liquid (0 < Yderm < 1)
FT is the frequency of events (integer number per day).
Here Qu does not represent the quantity remaining after evaporation, but represents the quantity
remaining after the bulk liquid has fallen from the hand that cannot be removed by wiping the skin (e.g.,
the film that remains on the skin).
One way to account for evaporation of a volatile solvent would be to add a multiplicative factor to the
EPA/OPPT model to represent the proportion of chemical that remains on the skin after evaporation,/abs
(0
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Equation E-3
P MW3A
X = 3.4 X 10~3u° 78 „
|/0.76c
Oct
Where:
u is the air velocity (m/s)
Koctis the octanol:water partition coefficient
MW is the molecular weight
Sw is the water solubility (|ag/cm3)
Pvp is the vapor pressure (torr)
Chemicals for which % » 1 will largely evaporate from the skin surface, while chemicals for which x
« 1 will be largely absorbed; x = 1 represents a balance between evaporation and absorption. Equation
E-3Equation is applicable to chemicals having a log octanol/water partition coefficient less than or
equal to three (log Kow < 3)6. The equations that describe the fraction of the initial mass that is absorbed
(or evaporated) are rather complex (Equations 20 and 21 of Kasting and Miller (2006)) but can be
solved.
E.2.1 Small Doses (Case 1: Mo < Msat)
In the small dose scenario, the initial dose (Mo) is less than that required to saturate the upper layers of
the stratum corneum (Mo < Msat), and the chemical is assumed to evaporate from the skin surface at a
rate proportional to its local concentration.
For this scenario, FH. (2012) calculated the fraction of applied mass that is absorbed, based on the
infinite limit of time (i.e. infinite amount of time available for absorption after exposure):
Equation E-4
mabsi™) 2 + fx
fabs ~
M0 2 + 2/
Where:
mabs is the mass absorbed
Mo is the initial mass applied
/is the relative depth of penetration in the stratum corneum (f= 0.1 can be assumed)
X is as previously defined
Note the simple algebraic solution in Equation E-4 provides a theoretical framework for the total mass
that is systemically absorbed after exposure to a small finite dose (mass/area) of chemical, which
depends on the relative rates of evaporation, permeation, and the initial load. At "infinite time", the
applied dose is either absorbed or evaporated (FH. 2012). The finite dose is a good model for splash-
type exposure in the workplace (Frasch and Bunge. 2015).
6 For simplification, Kasting and Miller (2006) does not consider the resistance of viable tissue layers underlying the stratum,
corneum, and the analysis is applicable to hydrophilic-to-moderately lipophilic chemicals. For small molecules, this
limitation is equivalent to restricting the analysis to compounds where Log Kow < 3.
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The fraction of the applied mass that evaporates is simply the complement of that absorbed:
Equation E-5
mevap(co) _ 2x~fX
M0 ~ 'abs ~ 2 + 2/
Where:
mevap is the mass evaporated
The fraction absorbed can also be represented as a function of dimensionless time t (Dt/h2), as shown in
Equation E-6:
Equation E-6
00 i 7
mabs ^ V 1 1+4 \ (C05(l ~f)K~ cosln\
M0 ~ 2Lxn{1 e " \2+AJ+x) ¦{ f.K J
where the eigenvalues An are the positive roots of the equation:
Equation E-7
ln ¦ cot(2n) + X = 0
Equation E-6 and Equation E-7must be solved analytically. It should be noted that the dimensionless
time t is not a representation of exposure duration for a work activity; rather, it represents the amount of
time available for absorption after the initial exposure dose is applied. Since most dermal risk
assessments are typically more concerned with the quantity absorbed, rather than the time course of
absorption, the simple algebraic solution is recommended over the analytical solution.
E.2.2 Large Doses (Case 2: Mo > Msat)
For large doses (Mo > Msat), the chemical saturates the upper layers of the stratum corneum, and any
remaining amount forms a residual layer (or pool) on top of the skin. The pool acts as a reservoir to
replenish the top layers of the membrane as the chemical permeates into the lower layer. In this case,
absorption and evaporation approach steady-state values as the dose is increased, similar to an infinite
dose scenario.
The steady-state fraction absorbed can be approximated by Equation E-8:
Equation E-8
1
fabsi.00) — _j_
Table Apx E-l presents the estimated absorbed fraction calculated using the steady-state approximation
for large doses (Equation E-8) for methylene chloride.
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Table Apx E-l. Estimated Fraction Evaporated and Absorbed (fabs) using Equation E 8
( hcmiciil Niimo
Mo(h\k'iK' Chloride
CASUS
"75-0')-2
Moloculiii' l-'oi'iniilii
CILCI:
Molecular Wcmlil (u mol)
84.93
\' (lorn
435
I iii\eisal uas ainsiaiil. k
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Chemicals trapped in the glove may be broadly distributed over the skin (increasing S in Equation E-l),
or if not distributed within the glove, the chemical mass concentration on the skin at the site of
contamination may be maintained for prolonged periods of time (increasing Qu in Equation E-l
Equation ). Conceptually, occlusion is similar to the "infinite dose" study design used in in vitro and ex
vivo dermal penetration studies, in which the dermis is exposed to a large, continuous reservoir of
chemical.
The impact of occlusion on dermal uptake is complex: continuous contact with the chemical may
degrade skin tissues, increasing the rate of uptake, but continuous contact may also saturate the skin,
slowing uptake (Dancik et at... ). These phenomena are dependent upon the chemical, the vehicle
and environmental conditions. It is probably not feasible to incorporate these sources of variability in a
screening-level population model of dermal exposure without chemical-specific studies.
Existing EPA/OPPT dermal models (Equation E-l) could theoretically be modified to account for the
increased surface area and/or increased chemical mass in the glove. This could be achieved through a
multiplicative variable (such as used in Equation E-2 to account for evaporative loss) or a change in the
default values of S and/or Qu. It may be reasonable to assume that the surface area of hand in contact
with the chemical, S, is the area of the whole hand owing to the distribution of chemical within the
glove. Since Qu reflects the film that remains on the skin (and cannot be wiped off), a larger value
should be used to reflect that the liquid volume is trapped in the glove, rather than falling from the hand.
Alternatively, the product S xQu (cm2 x mg/cm2-event) could be replaced by a single variable
representing the mass of chemical that deposits inside the glove per event, M (mg/event):
Equation E-9
Dexp — M x Yderm x FT
Garrod et al. (2001) surveyed contamination by involatile components of non-agricultural pesticide
products inside gloves across different job tasks and found that protective gloves were nearly always
contaminated inside. While the study does not describe the exact mechanism in which the contamination
occurs (e.g. via the cuff, permeation, or penetration through imperfections in glove materials), it
quantified inner glove exposure as "amount of product per unit time", with a median value of 1.36 mg
product per minute, a 75th percentile value of 4.21 mg/min, and a 95th percentile value of 71.9 mg/min. It
is possible to use these values to calculate the value of M, i.e. mass of chemical that deposits inside the
glove, if the work activity duration is known.
Assuming an activity duration of one hour, the 50th and 95th percentile values translate to 81.6 mg and
4,314 mg of inner glove exposure. While these values may be used as default for M in Equation E-10,
EPA notes the significant difference between the 50th and 95th percentile deposition, with the 95th
percentile value being two times more conservative than the defaults for the EPA/OPPT 2-Hand Dermal
Exposure Model (where the product S x Quis 2,247 mg/event). Given the significant variability in inner
glove exposure and lack of information on the specific mechanism in which the inner glove
contamination occurs, EPA addresses the occlusion scenario in combination with other glove
contamination and permeation factors through the use of a protection factor, as described in the next
section.
EPA does not expect occlusion scenarios to be a reasonable occurrence for all conditions of use.
Specifically, occlusion is not expected at sites using chemicals in closed systems where the only
potential of dermal exposure is during the connecting/disconnecting of hoses used for unloading/loading
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of bulk containers (e.g., tank trucks or rail cars) or while collecting quality control samples including
manufacturing sites, repackaging sites, sites processing the chemical as a reactant, formulation sites, and
other similar industrial sites. Occlusion is also not expected to occur at highly controlled sites, such as
electronics and pharmaceuticals manufacturing sites, where, due to purity requirements, the use of
engineering controls is expected to limit potential dermal exposures. EPA also does not expect occlusion
at sites where contact with bulk liquid chemical is not expected such as aerosol degreasing sites where
workers are only expected to handle the aerosol cans containing the chemical and not the actual bulk
liquid chemical.
EPA expects occlusion to be a reasonable occurrence at sites where workers may come in contact with
bulk liquid chemical and handle the chemical in open systems. This includes conditions of use such as
vapor degreasing, cold cleaning, and dry cleaning where workers are expected to handle bulk chemical
during cleanout of spent solvent and addition of fresh solvent to equipment. Similarly, occlusion may
occur at coating or adhesive application sites when workers replenish application equipment with liquid
coatings or adhesives.
E.5 Incorporating Glove Protection
Data about the frequency of effective glove use - that is, the proper use of effective gloves - is very
limited in industrial settings. Initial literature review suggests that there is unlikely to be sufficient data
to justify a specific probability distribution for effective glove use for a chemical or industry. Instead,
the impact of effective glove use is explored by considering different percentages of effectiveness.
Gloves only offer barrier protection until the chemical breaks through the glove material. Using a
conceptual model, Cherrie et al. (2004) proposed a glove workplace protection factor - the ratio of
estimated uptake through the hands without gloves to the estimated uptake though the hands while
wearing gloves: this protection factor is driven by flux, and thus varies with time. The ECETOC TRA
model represents the protection factor of gloves as a fixed, assigned protection factor equal to 5, 10, or
20 (Marquart et al.. 2.017). Where, similar to the APR for respiratory protection, the inverse of the
protection factor is the fraction of the chemical that penetrates the glove.
The protection afforded by gloves can be incorporated into the EPA/OPPT model (Equation E-l) by
modification of Qu with a protection factor, PF (unitless, PF > 1):
Equation E-10
Dexp = S x x Yderm x FT
Given the limited state of knowledge about the protection afforded by gloves in the workplace, it is
reasonable to utilize the PF values of the ECETOC TRA model (Marquart et al.. ), rather than
attempt to derive new values. Table Apx E-2 presents the PF values from ECETOC TRA model
(version 3). In the exposure data used to evaluate the ECETOC TRA model, (Marquart et al.. 2017)
reported that the observed glove protection factor was 34, compared to PF values of 5 or 10 used in the
model.
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TableApx E-2. Exposure Control Efficiencies and Protection Factors for Different Dermal
Protection Strategies from ECETOC TRA v3
Dorniiil Pmk'Clion ( h;ii ;iclc'i is(ics
AITcc led I scr Croup
Indiciilod
1.Hick-no ("")
Prnleclion
1 iicloi-. PI
a. Any glove / gauntlet without permeation data and without
employee training
Both industrial and
professional users
0
1
b. Gloves with available permeation data indicating that the
material of construction offers good protection for the
substance
80
5
c. Chemically resistant gloves (i.e., as b above) with "basic"
employee training
90
10
d. Chemically resistant gloves in combination with specific
activity training (e.g., procedure for glove removal and
disposal) for tasks where dermal exposure can be expected to
occur
Industrial users only
95
20
E.6 Proposed Dermal Dose Equation
Accounting for all parameters above, the proposed, overall equation for estimating dermal exposure is:
Equation E-ll
( Qu Xfabs)
n C v uusj y j-,j,
uexp pp ^ 1derm ^ 1 1
EPA presents exposure estimates for the following deterministic dermal exposure scenarios:
• Dermal exposure without the use of protective gloves (Equation E-l 1, PF = 1)
• Dermal exposure with the use of protective gloves (Equation E-l 1, PF = 5)
• Dermal exposure with the use of protective gloves and employee training (Equation E-l 1, PF =
20 for industrial users and PF = 10 for professional users)
• Dermal exposure with occlusion (Equation E-9)
EPA assumes the following parameter values for Equation E-l2 in addition to the parameter values
presented in Table E-l:
• S, the surface area of contact: 535 cm2 (central tendency) and 1,070 cm2 (high end), representing
the total surface area of one and two hands, repectively (note that EPA has no data on actual
surface area of contact for any OES).
• Qu, the quantity remaining on the skin: 1.4 mg/cm2-event (central tendency) and 2.1 mg/cm2-
event (high end). These are the midpoint value and high end of range default value, respectively,
used in the EPA/OPPT dermal contact with liquids models (EPA, 2013).
• Yderm, the weight fraction of the chemical of interest in the liquid: EPA will assess a unique value
of this parameter for each occupational scenario or group of similar occupational scenarios.
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• FT, the frequency of events: 1 event per day
For Equation E-10, EPA assumes the quantity of liquid occluded underneath the glove (M) is equal to
the product of the entire surface area of contact (S = 1,070 cm2) and the assumed quantity of liquid
remaining on the skin (Qu = 2.1 mg/cm2-event), which is equal to 2,247 mg/event. See discussion in
Section E.5.
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APPENDIX F DESCRIPTION OF MODELS USED TO ESTIMATE
WORKER AND ONU EXPOSURES
F.l Brake Servicing Near-Field/Far-Field Inhalation Exposure Model
Approach and Parameters
This appendix presents the modeling approach and model equations used in the Brake Servicing Near-
Field/Far-Field Inhalation Exposure Model. The model was developed through review of the literature
and consideration of existing EPA/OPPT exposure models. This model uses a near-field/far-field
approach ( 009). where an aerosol application located inside the near-field generates a mist of
droplets, and indoor air movements lead to the convection of the droplets between the near-field and far-
field. Workers are assumed to be exposed to methylene chloride droplet concentrations in the near-field,
while occupational non-users are exposed at concentrations in the far-field.
The model uses the following parameters to estimate exposure concentrations in the near-field and far-
field:
• Far-field size;
• Near-field size;
• Air exchange rate;
• Indoor air speed;
• Concentration of methylene chloride in the aerosol formulation;
• Amount of degreaser used per brake job;
• Number of degreaser applications per brake job;
• Time duration of brake j ob;
• Operating hours per week; and
• Number of j obs per work shift.
An individual model input parameter could either have a discrete value or a distribution of values. EPA
assigned statistical distributions based on available literature data. A Monte Carlo simulation (a type of
stochastic simulation) was conducted to capture variability in the model input parameters. The
simulation was conducted using the Latin hypercube sampling method in @Risk Industrial Edition,
Version 7.0.0. The Latin hypercube sampling method is a statistical method for generating a sample of
possible values from a multi-dimensional distribution. Latin hypercube sampling is a stratified method,
meaning it guarantees that its generated samples are representative of the probability density function
(variability) defined in the model. EPA performed the model at 100,000 iterations to capture the range of
possible input values (i.e., including values with low probability of occurrence).
Model results from the Monte Carlo simulation are presented as 95th and 50th percentile values. The
statistics were calculated directly in @Risk. The 95th percentile value was selected to represent high-end
exposure level, whereas the 50th percentile value was selected to represent central tendency exposure
level. The following subsections detail the model design equations and parameters for the brake
servicing model.
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F.l.l Model Design Equations
In brake servicing, the vehicle is raised on an automobile lift to a comfortable working height to allow
the worker (mechanic) to remove the wheel and access the brake system. Brake servicing can include
inspections, adjustments, brake pad replacements, and rotor resurfacing. These service types often
involve disassembly, replacement or repair, and reassembly of the brake system. Automotive brake
cleaners are used to remove oil, grease, brake fluid, brake pad dust, or dirt. Mechanics may occasionally
use brake cleaners, engine degreasers, carburetor cleaners, and general purpose degreasers
interchangeably (CARB, 2000). Automotive brake cleaners can come in aerosol or liquid form (CARB.
2000): this model estimates exposures from aerosol brake cleaners (degreasers).
FigureApx F-l illustrates the near-field/far-field modeling approach as it was applied by EPA to brake
servicing using an aerosol degreaser. The application of the aerosol degreaser immediately generates a
mist of droplets in the near-field, resulting in worker exposures at a methylene chloride concentration
Cnf. The concentration is directly proportional to the amount of aerosol degreaser applied by the worker,
who is standing in the near-field-zone (i.e., the working zone). The volume of this zone is denoted by
Vnf. The ventilation rate for the near-field zaone (Qnf) determines how quickly methylene chloride
dissipates into the far-field (i.e., the facility space surrounding the near-field), resulting in occupational
bystander exposures to methylene chloride at a concentration Cff. Vff denotes the volume of the far-
field space into which the methylene chloride dissipates out of the near-field. The ventilation rate for the
surroundings, denoted by Qff, determines how quickly methylene chloride dissipates out of the
surrounding space and into the outside air.
NF c ^ST<^
y5
Volatile Source X'Jr
Figure Apx F-l. The Near-Field/Far-Field Model as Applied to the Brake Servicing Near-
Field/Far-Field Inhalation Exposure Model
In brake servicing using an aerosol degreaser, aerosol degreaser droplets enter the near-field in non-
steady "bursts," where each burst results in a sudden rise in the near-field concentration. The near-field
and far-field concentrations then decay with time until the next burst causes a new rise in near-field
concentration. Based on site data from automotive maintenance and repair shops obtained by CARB
(2000) for brake cleaning activities and as explained in Sections F.l.2.5 and F. 1.2.9 below, the model
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assumes a worker will perform an average of 11 applications of the degreaser product per brake job with
five minutes between each application and that a worker may perform one to four brake jobs per day
each taking one hour to complete. EPA modeled two scenarios: one where the brake jobs occurred back-
to-back and one where brake jobs occurred one hour apart. In both scenarios, EPA assumed the worker
does not perform a brake job, and does not use the aerosol degreaser, during the first hour of the day.
EPA denoted the top of each five-minute period for each hour of the day (e.g., 8:00 am, 8:05 am, 8:10
am, etc.) as tm,n. Here, m has the values of 0, 1, 2, 3, 4, 5, 6, and 7 to indicate the top of each hour of the
day (e.g., 8 am, 9 am, etc.) and n has the values of 0, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11 to indicate the top
of each five-minute period within the hour. No aerosol degreaser is used, and no exposures occur, during
the first hour of the day, to,o to to,n (e.g., 8 am to 9 am). Then, in both scenarios, the worker begins the
first brake job during the second hour, ti,o (e.g., 9 am to 10 am). The worker applies the aerosol
degreaser at the top of the second 5-minute period and each subsequent 5-minute period during the hour-
long brake job (e.g., 9:05 am, 9:10 am,... 9:55 am). In the first scenario, the brake jobs are performed
back-to-back, if performing more than one brake job on the given day. Therefore, the second brake job
begins at the top of the third hour (e.g., 10 am), and the worker applies the aerosol degreaser at the top
of the second 5-minute period and each subsequent 5-minute period (e.g., 10:05 am, 10:10 am,... 10:55
am). In the second scenario, the brake jobs are performed every other hour, if performing more than one
brake job on the given day. Therefore, the second brake job begins at the top of the fourth hour (e.g., 11
am), and the worker applies the aerosol degreaser at the top of the second 5-minute period and each
subsequent 5-minute period (e.g., 11:05 am, 11:10 am,... 11:55 am).
In the first scenario, after the worker performs the last brake job, the workers and occupational non-users
(ONUs) continue to be exposed as the airborne concentrations decay during the final three to six hours
until the end of the day (e.g., 4 pm). In the second scenario, after the worker performs each brake job,
the workers and ONUs continue to be exposed as the airborne concentrations decay during the time in
which no brake jobs are occurring and then again when the next brake job is initiated. In both scenarios,
the workers and ONUs are no longer exposed once they leave work.
Based on data from CARB (2000). EPA assumes each brake job requires one 14.4-oz can of aerosol
brake cleaner as described in further detail below. The model determines the application rate of
methylene chloride using the weight fraction of methylene chloride in the aerosol product. EPA uses a
uniform distribution of weight fractions for methylene chloride based on facility data for the aerosol
products in use (CARB. 2000).
The model design equations are presented below in Equation F. 1-1 through Equation F.l-21.
Near-Field Mass Balance
Equation F.l-1
Far-Field Mass Balance
Equation F.l-2
Where:
Vnf
Vff
near-field volume;
far-field volume;
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Qnf =
near-field ventilation rate;
Qff =
far-field ventilation rate;
Cnf =
average near-field concentration;
Cff =
average far-field concentration; and
t
elapsed time.
Solving Equation F. 1-1 and Equation F. 1-2 in terms of the time-varying concentrations in the near-field
and far-field yields Equation F. 1-3 and Equation F. 1-4, which EPA applied to each of the 12 five-minute
increments during each hour of the day. For each five-minute increment, EPA calculated the initial near-
field concentration at the top of the period (tm,n), accounting for both the burst of methylene chloride
from the degreaser application (if the five-minute increment is during a brake job) and the residual near-
field concentration remaining after the previous five-minute increment (tm,n-i; except during the first
hour and tm,o of the first brake job, in which case there would be no residual methylene chloride from a
previous application). The initial far-field concentration is equal to the residual far-field concentration
remaining after the previous five-minute increment. EPA then calculated the decayed concentration in
the near-field and far-field at the end of the five-minute period, just before the degreaser application at
the top of the next period (tm,n+i). EPA then calculated a 5-minute TWA exposure for the near-field and
far-field, representative of the worker's and ONUs' exposures to the airborne concentrations during each
five-minute increment using Equation F. 1-13 and Equation F. 1-14. The k coefficients (Equation F. 1-5
through Equation F. 1-8) are a function of the initial near-field and far-field concentrations, and therefore
are re-calculated at the top of each five-minute period. In the equations below, where the subscript "m,
n-1" is used, if the value of n-1 is less than zero, the value at "m-1, 11" is used and where the subscript
"m, n+1" is used, if the value of n+1 is greater than 11, the value at "m+1, 0" is used.
Equation F.l-3
= (X
t e
Lm,n
Ai t
+ k2t e
*>Lm,n
Equation F.l-4
Cpp t + =(k3t eXlt-kAt eA2t)
rr>Lm,n+1 V s>lm,n ^>lm,n J
Where:
Equation F.l-5
/Cl £
1>Lm,n
QnF (CFF,o(tm,n) CWF0(tmn)^ A2VNFCNF,o(tm,n)
Vnf^i ^2)
Equation F.l-6
QnF (j-'NF.O (tm,n) ^FF, 0 (*771,71)) + ^l^NF^NF,o(^m,n)
2,t
m,n
Vnf^i ~ ^2)
Equation F.l-7
lo f
o.tn
(.QnF + ^iVnf)(.QnF (CFF,o(tm,n) CWF0(tmn)^ N
Qnf^nf 0^1 ^2)
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Equation F.l-8
(.Qnf + ^2^nf){Qnf (cWF0(tmn) — CFF 0(tmnj^ + ^-iVNFCNF 0(tmn))
4,tm,n Qnf^nf(^i ~ A2)
Equation F.l-9
Xx = 0.5
(Qnf^ff + Vnf(Qnf + Qff)\ \( Qnf^ff + Vnf(.Qnf + Qff)\ „ (QnfQffs
V KvfKfF J AI V KvF^FF
) _ 1 (VnfQff\
) \ VNFVFF )
Equation F.l-10
Ay = 0.5
(Qnf^ff + Vnf(Qnf + Qff)\ I /Qnf^ff + Vnf(.Qnf + Qff)\ _ . (QnfQff\
\ ^/VF^FF / J\ VnfVfF / \VNFVFF)
Equation F.l-11
( 0, m = 0
CNF,o{pm,n) — j —Z'1,000——"j + CWF(tmn_1) , n > 0 /or all m where brake job
V wVF ^ 9 '
Equation F.l-12
occurs
r 0, m = 0
FF,o\tm,n) — [CFF(tmn_x) , /or all n where m > 0
Equation F.l-13
(^1'tm,n-1 AU-, 1 ^Vn-l J,t,] _ /^l,tmn_1 Ai ti .
I Ai 6 + A2 6 j 1 Ax 6 + 12 6
c,
WF, 5-min TWA, tm „ f f
r2 rl
Equation F.l-14
/^3,tm,n-l cAit, | _ (^}tm,n-l cA1t1 | ^4tm,n-1
_ \ Ax 12 J \ h a2
^FF, 5-min TWA, tmn
^2 *1
After calculating all near-field/far-field 5-minute TWA exposures (i.e., C«f, 5-min twa, tm „ and
Cpp 5_min TWA tmn) for each five-minute period of the work day, EPA calculated the near-field/far-field
8-hour TWA concentration and 1-hour TWA concentrations following the equations below:
Equation F.l-15
n _ Sm=0 2n=o[^NF,5-min TWA,tmn X 0.0833 hr\
CNF,%-hrTWA ~ Q~hZ ^
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Equation F.l-16
C,
Hm=oHn=o[^FF,
NF, 8-hr TWA
5-min TWA,tm,n
x 0.0833 hr]
8 hr
Equation F.l-17
Cnf, i-
liiofa
NF,5-min TWA.tr,
x 0.0833 hr]
\wTWA
1 hr
Equation F.l-18
Cff, i-
liiofa
FF,5-min TWA,tr
x 0.0833 hr]
\wTWA
1 hr
EPA calculated rolling 1-hour TWA's throughout the workday and the model reports the maximum
calculated 1-hour TWA.
To calculate the mass transfer to and from the near-field, the free surface area (FSA) is defined to be the
surface area through which mass transfer can occur. The FSA is not equal to the surface area of the
entire near-field. EPA defined the near-field zone to be a hemisphere with its major axis oriented
vertically, against the vehicle, and aligned through the center of the wheel (see FigureApx F-l). The
top half of the circular cross-section rests against, and is blocked by, the vehicle and is not available for
mass transfer. The FSA is calculated as the entire surface area of the hemisphere's curved surface and
half of the hemisphere's circular surface per Equation F.l-19, below:
Equation F.l-19
FSA
— (2 X 47T/?ivf) + Q X n^NF^j
Where: Rnf is the radius of the near-field
The near-field ventilation rate, Qnf, is calculated in Equation F. 1-20 from the indoor wind speed, vnf,
and FSA, assuming half of the FSA is available for mass transfer into the near-field and half of the FSA
is available for mass transfer out of the near-field:
Equation F.l-20
1
Qnf ~ 2 vnfFSA
The far-field volume, Vff, and the air exchange rate, AER, is used to calculate the far-field ventilation
rate, Qff, as given by Equation F. 1-21:
Equation F.l-21
Qff = Vff^ER
Using the model inputs described in Appendix F.1.2, EPA estimated methylene chloride inhalation
exposures for workers in the near-field and for occupational non-users in the far-field. EPA then
conducted the Monte Carlo simulations using @Risk (Version 7.0.0). The simulations applied 100,000
iterations and the Latin Hypercube sampling method.
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F.1.2 Model Parameters
Table Apx F-l summarizes the model parameters and their values for the Brake Servicing Near-
Field/Far-Field Inhalation Exposure Model. Each parameter is discussed in detail in the following
subsections. Summary of Parameter Values and Distributions Used in the Brake Servicing Near-
Field/Far-Field Inhalation Exposure Model
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TableApx F-l. Summary of Parameter Values and Distributions Used in the Brake Servicing Near-Field/Far-Field Inhalation
Exposure Model
Input
Parameter
Symbol
Unit
Constant Model
Parameter Values
Variable Model Parameter Values
Comments
Value
Basis
Lower
Bound
Upper
Bound
Mode
Distributio
n Type
Far-field volume
Vff
m3
—
—
206
70,679
3,769
Triangular
Distribution based on data
collected by CARB (2006)
Air exchange
rate
AER
lir1
—
—
1
20
3.5
Triangular
Demou et al. (2009) identifies
typical AERs of 1 lir1 and 3 to 20
lir1 for occupational settings with
and without mechanical
ventilation systems, respectively.
Hellwee et al. (2009) identifies
average AERs for occupational
settings utilizing mechanical
ventilation systems to be between
3 and 20 lir1. Golsteijn et al.
(2014) indicates a characteristic
AER of 4 lir1. Peer reviewers of
EPA's 2013 TCE draft risk
assessment commented that
values around 2 to 5 lir1 may be
more likelv (SCG. 2013). in
agreement with Golsteijn et al.
(2014). A trianeular distribution
is used with the mode equal to the
midpoint of the range provided by
the peer reviewer (3.5 is the
midpoint of the range 2 to 5 lir1).
Near-field indoor
wind speed
Vkf
Mir
—
—
0
1,037
—
Lognonnal
Lognonnal distribution fit to
commercial-type workplace data
from Baldwin and Maynard
(1998).
cm/s
—
—
0
8.78
—
Lognonnal
Near-field radius
Rnf
m
1.5
—
—
—
—
Constant
Value
Constant.
Starting time for
each application
period
tl
lir
0
—
—
—
—
Constant
Value
Constant.
End time for
each application
period
t2
lir
0.0833
—
—
—
—
Constant
Value
Assumes aerosol degreaser is
applied in 5-minute increments
during brake job.
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Input
Symbol
Unit
Constant Model
Parameter Values
Variable Model Parameter Values
Comments
Parameter
Value
Basis
Lower
Bound
Upper
Bound
Mode
Distributio
n Type
Averaging Time
tavg
hr
8
—
—
—
—
Constant
Value
Constant.
Discrete distribution of
CHEMICAL-based aerosol
product formulations based on
products identified in Abt (2017).
Methylene
chloride weight
wtfrac
wt frac
0.10
0.80
Discrete
Where the weight fraction of
methylene chloride in the
fraction
formulation was given as a range,
EPA assumed a uniform
distribution within the reported
range for the methylene chloride
concentration in the product.
Degreaser Used
per Brake Job
wd
oz/job
14.4
—
—
—
—
Constant
Value
Based on data from
CARB (2000).
Number of
Applications per
Job
na
Applications/
job
11
—
—
—
—
Constant
Value
Calculated from the average of
the number of applications per
brake and number of brakes per
job.
Amount Used
Amt
g methylene
chloride/
application
3.7
29.7
Calculated
Calculated from wtfrac, Wd, and
per Application
Na.
Lognonnal distribution fit to the
Operating hours
per week
OHpW
hr/week
—
—
40
122.5
—
Lognonnal
operating hours per week
observed in CARB (2000) site
visits.
Calculated from the average
Number of
number of brake jobs per site per
Brake Jobs per
Work Shift
Nj
jobs/site-shift
1
4
year, OHpW, and assuming 52
operating weeks per year and 8
hours per work shift.
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F.l.2.1 Far-Field Volume
The far-field volume is based on information obtained from CARB (2000) from site visits of 137
automotive maintenance and repair shops in California. CARB (2000) indicated that shop volumes at the
visited sites ranged from 200 to 70,679 m3 with an average shop volume of 3,769 m3. Based on this data
EPA assumed a triangular distribution bound from 200 m3 to 70,679 m3 with a mode of 3,769 m3 (the
average of the data from CARB (2000)).
CARB measured the physical dimensions of the portion of the facility where brake service work was
performed at the visited facilities. CARB did not consider other areas of the facility, such as customer
waiting areas and adjacent storage rooms, if they were separated by a normally closed door. If the door
was normally open, then CARB did consider those areas as part of the measured portion where brake
servicing emissions could occur (CARB. 2000). CARB's methodology for measuring the physical
dimensions of the visited facilities provides the appropriate physical dimensions needed to represent the
far-field volume in EPA's model. Therefore, CARB's reported facility volume data are appropriate for
EPA's modeling purposes.
F. 1.2.2 Air Exchange Rate
The air exchange rate (AER) is based on data from Demou et al. (2009). Hellweg et al. (2009). Golsteijn
et al. (2014). and information received from a peer reviewer during the development of the 2014 TSCA
Work Plan Chemical Risk Assessment Trichloroethylene: Degreasing, Spot Cleaning and Arts & Crafts
Uses (SCG. ). Demou et al. (2.009) identifies typical AERs of 1 hr"1 and 3 to 20 hr"1 for
occupational settings with and without mechanical ventilation systems, respectively. Similarly, Hellweg
et al. (2009) identifies average AERs for occupational settings using mechanical ventilation systems to
vary from 3 to 20 hr"1. Golsteijn et al. (2014) indicates a characteristic AER of 4 hr"1. The risk
assessment peer reviewer comments indicated that values around 2 to 5 hr"1 are likely (SCG. 2013). in
agreement with Golsteijn et al. (2014) and the low end reported by Demou et al. (2009) and Hellweg et
al. (2009). Therefore, EPA used a triangular distribution with the mode equal to 3.5 hr"1, the midpoint of
the range provided by the risk assessment peer reviewer (3.5 is the midpoint of the range 2 to 5 hr"1),
with a minimum of 1 hr"1, per Demou et al. (2.009) and a maximum of 20 hr"1 per Demou et al. (2.009)
and Hellweg et al. (2009).
F.l.2.3 Near-Field Indoor Air Speed
Baldwin and Maynard (1998) measured indoor air speeds across a variety of occupational settings in the
United Kingdom. Fifty-five work areas were surveyed across a variety of workplaces.
EPA analyzed the air speed data from Baldwin and Maynard (1998) and categorized the air speed
surveys into settings representative of industrial facilities and representative of commercial facilities.
EPA fit separate distributions for these industrial and commercial settings and used the commercial
distribution for dry cleaners (including other textile cleaning facilities that conduct spot cleaning).
EPA fit a lognormal distribution for both data sets as consistent with the authors observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed. Since lognormal distributions are
bound by zero and positive infinity, EPA truncated the distribution at the largest observed value among
all of the survey mean air speeds from Baldwin and Maynard (1998).
EPA fit the air speed surveys representative of commercial facilities to a lognormal distribution with the
following parameter values: mean of 10.853 cm/s and standard deviation of 7.883 cm/s. In the model,
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the lognormal distribution is truncated at a maximum allowed value of 202.2 cm/s (largest surveyed
mean air speed observed in Baldwin and Maynard (1998) to prevent the model from sampling values
that approach infinity or are otherwise unrealistically large.
Baldwin and Maynard (1998) only presented the mean air speed of each survey. The authors did not
present the individual measurements within each survey. Therefore, these distributions represent a
distribution of mean air speeds and not a distribution of spatially-variable air speeds within a single
workplace setting. However, a mean air speed (averaged over a work area) is the required input for the
model.
F.l.2.4 Near-Field Volume
EPA defined the near-field zone to be a hemisphere with its major axis oriented vertically, against the
vehicle, and aligned through the center of the wheel (see FigureApx F-l). The near-field volume is
calculated per Equation F.l-22. EPA defined a near-field radius (Rnf) of 1.5 meters, approximately 4.9
feet, as an estimate of the working height of the wheel, as measured from the floor to the center of the
wheel.
Equation F.l-22
1 4
Vnf = 2 x 2n^F
F. 1.2.5 Application Time
EPA assumed an average of 11 brake cleaner applications per brake job (see Section F. 1.2.9). CARB
observed, from their site visits, that the visited facilities did not perform more than one brake job in any
given hour (CARB. 2000). Therefore, EPA assumed a brake job takes one hour to perform. Using an
assumed average of 11 brake cleaner applications per brake job and one hour to perform a brake job,
EPA calculates an average brake cleaner application frequency of once every five minutes (0.0833 hr).
EPA models an average brake job of having no brake cleaner application during its first five minutes
and then one brake cleaner application per each subsequent 5-minute period during the one-hour brake
job.
F.l.2.6 Averaging Time
EPA was interested in estimating 8-hr TWAs for use in risk calculations; therefore, a constant averaging
time of eight hours was used.
F. 1.2.7 Methylene Chloride Weight Fraction
EPA reviewed the Use and Market Profile for Methylene Chloride report (Abt. 2017) for aerosol
degreasers that contain methylene chloride. Abt (2.017) identifies nine aerosol automotive parts cleaners
that overall range in methylene chloride content from 10 to 80 weight percent. The identified aerosol
automotive parts cleaners are mostly brake cleaners but also include carburetor cleaners and a gasket
remover. EPA includes all of these aerosol automotive parts cleaners in the estimation of methylene
chloride content as: 1) automotive maintenance and repair facilities may use different degreaser products
interchangeably as observed by (CARB. 2000); and 2) EPA uses this brake servicing model as an
exposure scenario representative of all commercial-type aerosol degreaser applications.
EPA used a discrete distribution to model the methylene chloride weight fraction based on the number
of occurrences of each product type. For each product, the concentration of methylene chloride was
reported as a range. EPA used a uniform distribution to model the methylene chloride weight fraction
within the product type. Table Apx F-2 provides a summary of the reported methylene chloride content
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reported in the safety data sheets identified in Abt (2017). the number of occurrences of each product
type, and the fractional probability of each product type. Summary of Methylene Chloride-Based
Aerosol Degreaser Formulations
Table Apx F-2. Summary of Methylene Chloride-
3ased Aerosol Degreaser Formulations
Name of Aerosol Degreaser
Product Identified in Abt
(2017)
Methylene
Chloride Weight
Percent
Number of
Occurrences
Fractional
Probability
B-00002 BTS Brake Parts &
Metal Cleaner
25-35%
1
0.10
Berryman Brake Parts Cleaner
(1401, 1405, and 1455)
60-70%
1
0.10
Berryman Brake Parts Cleaner
(1420)
60-70%
1
0.10
Brake & Contact Cleaner (Bulk)
30-60%
1
0.10
High Performance Brake Clean
Free(80-928)
10-20%
1
0.10
Gunk Carburetor Parts Cleaner
- Chlorinated (M4814H)
20-<30%
1
0.10
Gunk Brake Parts Cleaner -
Chlorinated (M720)
40-<50%
1
0.10
Gunk Carb Medic Carburetor
Cleaner (M4814/M4824)
60-<70%
1
0.10
Sprayway Industrial Gasket
Remover No. 719
60-80%
1
0.10
American Industries, Inc.; Rapid
Solv (A)
45-55%
1
0.10
Total
10
1.00
F.l.2.8 Volume of Degreaser Used per Brake Job
CARB (2000) assumed that brake jobs require 14.4 oz of aerosol product. EPA did not identify other
information to estimate the volume of aerosol product per job; therefore, EPA used a constant volume of
14.4 oz per brake job based on CARB (2000).
F.l.2.9 Number of Applications per Brake Job
Workers typically apply the brake cleaner before, during, and after brake disassembly. Workers may
also apply the brake cleaner after brake reassembly as a final cleaning process (CARB. 2000).
Therefore, EPA assumed a worker applies a brake cleaner three or four times per wheel. Since a brake
job can be performed on either one axle or two axles (CARB. 2000). EPA assumed a brake job may
involve either two or four wheels. Therefore, the number of brake cleaner (aerosol degreaser)
applications per brake job can range from six (3 applications/brake x 2 brakes) to 16 (4
applications/brake x 4 brakes). EPA assumed a constant number of applications per brake job based on
the midpoint of this range of 11 applications per brake job.
F.l.2.10 Amount of Methylene Chloride Used per Application
EPA calculated the amount of methylene chloride used per application using Equation F. 1-23. The
calculated mass of methylene chloride used per application ranges from 3.7 to 29.7 grams.
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Equation F.l-23
Amt =
Wd x wtfrac x 28.3495^
Where:
Wtfrac
Na
Amt
Wd
Amount of methylene chloride used per application (g/application);
Weight of degreaser used per brake job (oz/job);
Weight fraction of methylene chloride in aerosol degreaser (unitless); and
Number of degreaser applications per brake job (applications/job).
F. 1.2.11 Operating Hours per Week
CARB (2000) collected weekly operating hour data for 54 automotive maintenance and repair facilities.
The surveyed facilities included service stations (fuel retail stations), general automotive shops, car
dealerships, brake repair shops, and vehicle fleet maintenance facilities. The weekly operating hours of
the surveyed facilities ranged from 40 to 122.5 hr/week. EPA fit a lognormal distribution to the surveyed
weekly operating hour data. The resulting lognormal distribution has a mean of 16.943 and standard
deviation of 13.813, which set the shape of the lognormal distribution. EPA shifted the distribution to
the right such that its minimum value is 40 hr/week and set a truncation of 122.5 hr/week (the truncation
is set as 82.5 hr/week relative to the left shift of 40 hr/week).
F.l.2.12 Number of Brake Jobs per Work Shift
CARB (2000) visited 137 automotive maintenance and repair shops and collected data on the number of
brake jobs performed annually at each facility. CARB calculated an average of 936 brake jobs
performed per facility per year. EPA calculated the number of brake jobs per work shift using the
average number of jobs per site per year, the operating hours per week, and assuming 52 weeks of
operation per year and eight hours per work shift using Equation F. 1-24 and rounding to the nearest
integer. The calculated number of brake jobs per work shift ranges from one to four.
Equation F.l-24
F.2 Occupational Exposures during Vapor Degreasing and Cold
Cleaning
This appendix presents the modeling approach and model equations used in the following models:
• Open-Top Vapor Degreasing Near-Field/Far-Field Inhalation Exposure Model;
• Conveyorized Degreasing Near-Field/Far-Field Inhalation Exposure Model;
• Cold Cleaning Near-Field/Far-Field Inhalation Exposure Model.
hours
weeks
x OHpW
Where:
Nj
OHpW
Number of brake jobs per work shift (jobs/site-shift); and
Operating hours per week (hr/week).
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The models were developed through review of the literature and consideration of existing EPA/OPPT
exposure models. These models use a near-field/far-field approach ( 009). where a vapor
generation source located inside the near-field diffuses into the surrounding environment. Workers are
assumed to be exposed to methylene chloride vapor concentrations in the near-field, while occupational
non-users are exposed at concentrations in the far-field.
The model uses the following parameters to estimate exposure concentrations in the near-field and far-
field:
• Far-field size;
• Near-field size;
• Air exchange rate;
• Indoor air speed;
• Exposure duration;
• Vapor generation rate; and
• Operating hours per day.
An individual model input parameter could either have a discrete value or a distribution of values. EPA
assigned statistical distributions based on available literature data. A Monte Carlo simulation (a type of
stochastic simulation) was conducted to capture variability in the model input parameters. The
simulation was conducted using the Latin hypercube sampling method in @Risk Industrial Edition,
Version 7.0.0. The Latin hypercube sampling method is a statistical method for generating a sample of
possible values from a multi-dimensional distribution. Latin hypercube sampling is a stratified method,
meaning it guarantees that its generated samples are representative of the probability density function
(variability) defined in the model. EPA performed the model at 100,000 iterations to capture the range of
possible input values (i.e., including values with low probability of occurrence).
Model results from the Monte Carlo simulation are presented as 95th and 50th percentile values. The
statistics were calculated directly in @Risk. The 95th percentile value was selected to represent high-end
exposure level, whereas the 50th percentile value was selected to represent typical exposure level. The
following subsections detail the model design equations and parameters for vapor degreasing and cold
cleaning models.
F.2.1 Model Design Equations
FigureApx F-2 and FigureApx F-3 illustrate the near-field/far-field modeling approach as it was
applied by EPA to each vapor degreasing and cold cleaning model. As the figures show, volatile
methylene chloride vapors evaporate into the near-field, resulting in worker exposures at a methylene
chloride concentration Cnf. The concentration is directly proportional to the evaporation rate of
methylene chloride, G, into the near-field, whose volume is denoted by Vnf. The ventilation rate for the
near-field zone (Qnf) determines how quickly methylene chloride dissipates into the far-field, resulting
in occupational non-user exposures to methylene chloride at a concentration Cff. Vff denotes the
volume of the far-field space into which the methylene chloride dissipates out of the near-field. The
ventilation rate for the surroundings, denoted by Qff, determines how quickly methylene chloride
dissipates out of the surrounding space and into the outside air.
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Far-Field
FigureApx F-2. The Near-Field/Far-Field Model as Applied to the Open-Top Vapor Degreasing
Near-Field/Far-Field Inhalation Exposure Model and the Cold Cleaning Near-Field/Far-Field
Inhalation Exposure Model
Far-Field
Figure Apx F-3. The Near-Field/Far-Field Model as Applied to the Conveyorized Degreasing
Near-Field/Far-Field Inhalation Exposure Model
The model design equations are presented below in Equation F.l-1 through Equation F.l-21. Note the
design equations are the same for each of the models discussed in this appendix.
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Near-Field Mass Balance
Equation F.2-25
Vnf ^ = CffQnf ~ CNFQNF + G
Far-Field Mass Balance
Equation F.2-26
dCFF
Vff ^ = CnfQnf ~ CffQnf ~ CFFQFF
Where:
Vnf =
near-field volume;
Vff =
far-field volume;
Qnf =
near-field ventilation rate;
Qff =
far-field ventilation rate;
Cnf =
average near-field concentration;
Cff =
average far-field concentration;
G
average vapor generation rate; and
t
elapsed time.
Both of the previous equations can be solved for the time-varying concentrations in the near-field and
far-field as follows (AIHA. 2009):
Equation F.2-27
CNF = G{k1 + k2eXlt - k3eX2t)
Equation F.2-28
CFF = G — + k4eXlt - kseX2t^j
Where:
Equation F.2-29
1
kl (_QnF__\q
\Qnf + Qpp)
Equation F.2-30
^ _ QnfQff + ^2 Vnf(.Qnf + Qff)
QnfQff^nf^i ~ ^2)
Equation F.2-31
^ _ QnfQff + ^i^vf(Qwf + Qff)
QnfQffVnf(.^i ~ ^2)
Equation F.2-32
M QNP )k2
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Equation F.2-33
_ M2Vnf + Qnf\
\ Qnf '
Xx = 0.5
Equation F.2-34
Qnf^ff + Vnf(Qnf + Qff)
VwV,
+
NFVFF
( Qnf^ff + Vnf(Qnf + Qff)\
V ^nf^ff J
^ (QnfQff\
\ VnfVff '
Equation F.2-35
X2 = 0.5
'QnF^FF + KvF (Q
NF
VmpVi
NFV FF
+ Qff)\ _ fQnf^ff + ^nf(Qnf + Qff)\
/ J\ VnfVff )
^ {QnfQff\
V VpjpVpF /
EPA calculated the hourly TWA concentrations in the near-field and far-field using Equation F.2-36 and
Equation F.2-37, respectively. Note that the numerator and denominator of Equation F.2-36 and
Equation F.2-37 use two different sets of time parameters. The numerator is based on operating times for
the scenario (e.g., two to eight hours for OTVDs, 4 to 8 hours for conveyorized degreasers, and 1 to 24
hours for cold cleaning, see Appendix F.1.2) while the denominator is fixed to an average time span,
t avg, of eight hours (since EPA is interested in calculating 8-hr TWA exposures). Mathematically, the
numerator and denominator must reflect the same amount of time. This is indeed the case since the
numerator assumes exposures are zero for any hours not within the operating time. Therefore,
mathematically speaking, both the numerator and the denominator reflect eight hours regardless of the
values selected for ti and t2.
Equation F.2-36
j^2 CNFdt J^2 G{kx + k2eXlt — k3eX2t)dt
^NF TWA = 17 = =
J0 Z^g
r(i + 1 k2ex^2 k3eX2t2\ r (1 + 1 k2eXltl k3ex^\
j - g (kltl +
tavg
Equation F.2-37
;t'2 cPPdt jt'; a (^-+k^'-1 - k5e^') dt
C,,JWA = = ^ =
n ( t2 , k4eXlt2 kseX2-t2\ n ( U , k4eXltl kseX2tl\
GWr + — —)-G\Q7r + — —)
tavg
To calculate the mass transfer to and from the near-field, the free surface area, FSA, is defined to be the
surface area through which mass transfer can occur. Note that the FSA is not equal to the surface area of
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the entire near-field. EPA defined the near-field zone to be a rectangular box resting on the floor;
therefore, no mass transfer can occur through the near-field box's floor. FSA is calculated in Equation
F.l-19, below:
Equation F.2-38
FSA = 2{LnfHnf) + 2 (WnfHnf) + (LnfWnf)
Where: Lnf, Wnf, and Hnf are the length, width, and height of the near-field, respectively. The near-
field ventilation rate, Qnf, is calculated in Equation F. 1-20 from the near-field indoor wind speed, vnf,
and FSA, assuming half of FSA is available for mass transfer into the near-field and half of FSA is
available for mass transfer out of the near-field:
Equation F.2-39
1
Qnf — — vnfFSA
The far-field volume, Vff, and the air exchange rate, AER, is used to calculate the far-field ventilation
rate, Qff, as given by Equation F. 1-21:
Equation F.2-40
Qff = Vff^ER
Using the model inputs described in Appendix F.1.2, EPA estimated methylene chloride inhalation
exposures for workers in the near-field and for occupational non-users in the far-field. EPA then
conducted the Monte Carlo simulations using @Risk (Version 7.0.0). The simulations applied 100,000
iterations and the Latin Hypercube sampling method for each model.
F.2.2 Model Parameters
TableApx F-3 through
TableApx F-5 summarize the model parameters and their values for each of the models discussed in
this Appendix. Each parameter is discussed in detail in the following subsections.
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TableApx F-3. Summary of Parameter Values and Distributions Used in the Open-Top Vapor Degreasing Near-Field/Far-Field
Inhalation Exposure Model
Input
Parameter
Symbol
Unit
Constant Model
Parameter Values
Variable Model Parameter Values
Comments
Value
Basis
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Far-field
volume
Vff
ft3
—
—
10,594
70,629
17,657
Triangular
See Section F.2.2.1
Air
exchange
rate
AER
hr"1
—
—
2
20
3.5
Triangular
See Section F.2.2.2
Near-field
indoor wind
speed
VNF
ft/hr
—
—
—
23,882
—
Lognormal
See Section F.2.2.3
cm/s
—
—
—
202.2
—
Lognormal
Near-field
length
Lnf
ft
10
—
—
—
—
Constant
Value
See Section F.2.2.4
Near-field
width
Wnf
ft
10
—
—
—
—
Constant
Value
Near-field
height
Hnf
ft
6
—
—
—
—
Constant
Value
Starting
time
ti
hr
0
—
—
—
—
Constant
Value
Constant.
Exposure
Duration
t2
hr
—
—
2
8
—
—
See Section F.2.2.5
Averaging
Time
tavg
hr
8
—
—
—
—
Constant
Value
See Section F.2.2.6
Vapor
generation
rate
G
mg/hr
—
—
6.99E+03
2.72E+06
—
Discrete
See Section F.2.2.7
lb/hr
—
—
0.015
6.00
—
Discrete
Operating
hours per
day
OH
hr/day
—
—
2
8
—
Discrete
See Section F.2.2.8
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TableApx F-4. Summary of Parameter Values and Distributions Used in the Conveyorized Degreasing Near-Field/Far-Field
Inhalation Exposure Model
Input
Parameter
Symbol
Unit
Constant Model
Parameter Values
Variable Model Parameter Values
Comments
Value
Basis
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Far-field
volume
Vff
ft3
—
—
10,594
70,629
17,657
Triangular
See Section F.2.2.1
Air exchange
rate
AER
hr"1
—
—
2
20
3.5
Triangular
See Section F.2.2.2
Near-field
indoor wind
speed
VNF
ft/hr
—
—
—
23,882
—
Lognormal
See Section F.2.2.3
cm/s
—
—
—
202.2
—
Lognormal
Near-field
length
Lnf
ft
10
—
—
—
—
Constant
Value
See Section F.2.2.4
Near-field
width
Wnf
ft
10
—
—
—
—
Constant
Value
Near-field
height
Hnf
ft
6
—
—
—
—
Constant
Value
Starting time
ti
hr
0
—
—
—
—
Constant
Value
Constant.
Exposure
Duration
t2
hr
—
—
4
8
—
Discrete
See Section F.2.2.5
Averaging
Time
tavg
hr
8
—
—
—
—
Constant
Value
See Section F.2.2.6
Vapor
generation
rate
G
mg/hr
—
—
2.20E+06
2.63E+06
—
Discrete
See Section F.2.2.7
lb/hr
—
—
4.86
5.81
—
Discrete
Operating
hours per day
OH
hr/day
—
—
4
8
—
Discrete
See Section F.2.2.8
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TableApx F-5. Summary of Parameter Values and Distributions Used in the Cold Cleaning Near-Field/Far-Field Inhalation
Exposure Model
Input
Parameter
Symbol
Unit
Constant Model
Parameter Values
Variable Model Parameter Values
Comments
Value
Basis
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Far-field
volume
Vff
ft3
—
—
10,594
70,629
17,657
Triangular
See Section F.2.2.1
Air exchange
rate
AER
hr"1
—
—
2
20
3.5
Triangular
See Section F.2.2.2
Near-field
indoor wind
speed
VNF
ft/hr
—
—
—
23,882
—
Lognormal
See Section F.2.2.3
cm/s
—
—
—
202.2
—
Lognormal
Near-field
length
Lnf
ft
10
—
—
—
—
Constant
Value
See Section F.2.2.4
Near-field
width
Wnf
ft
10
—
—
—
—
Constant
Value
Near-field
height
Hnf
ft
6
—
—
—
—
Constant
Value
Starting time
ti
hr
0
—
—
—
—
Constant
Value
Constant.
Exposure
Duration
t2
hr
—
—
1
8
—
Discrete
See Section F.2.2.5
Averaging Time
tavg
hr
8
—
—
—
—
Constant
Value
See Section F.2.2.6
Vapor
generation rate
G
mg/hr
—
—
3.08E-02
2.93E+05
—
Discrete
See Section F.2.2.7
lb/hr
—
—
6.79E-08
0.65
—
Discrete
Operating hours
per day
OH
hr/day
—
—
1
24
—
Discrete
See Section F.2.2.8
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F.2.2.1 Far-Field Volume
EPA used the same far-field volume distribution for each of the models discussed. The far-field volume
is based on information obtained from von Grote et al. (2003) that indicated volumes at German metal
degreasing facilities can vary from 300 to several thousand cubic meters. They noted that smaller
volumes are more typical and assumed 400 and 600 m3 (14,126 and 21,189 ft3) in their exposure models
(Von Grote et al.. 2.003). These are the highest and lowest values EPA identified in the literature;
therefore, EPA assumes a triangular distribution bound from 300 m3 (10,594 ft3) to 2,000 m3 (70,629 ft3)
with a mode of 500 m3 (the midpoint of 400 and 600 m3) (17,657 ft3).
F.2.2.2 Air Exchange Rate
EPA used the same air exchange rate distribution for each of the models discussed. The air exchange
rate is based on data from Hellweg et al. (2009) and information received from a peer reviewer during
the development of the 2014 TSCA Work Plan Chemical Risk Assessment Trichloroethylene:
Degreasing, Spot Cleaning and Arts & Crafts Uses (SCO.: ). Hellweg et al. (2009) reported that
average air exchange rates for occupational settings using mechanical ventilation systems vary from 3 to
20 hr"1. The risk assessment peer reviewer comments indicated that values around 2 to 5 hr"1 are likely
(SCG. 2013). in agreement with the low end reported by Hellweg et al. (2.009). Therefore, EPA used a
triangular distribution with the mode equal to 3.5 hr"1, the midpoint of the range provided by the risk
assessment peer reviewer (3.5 is the midpoint of the range 2 to 5 hr"1), with a minimum of 2 hr"1, per the
risk assessment peer reviewer (SCG. 2013) and a maximum of 20 hr"1 per Hellweg et al. (2009).
F.2.2.3 Near-Field Indoor Air Speed
Baldwin and Maynard (1998) measured indoor air speeds across a variety of occupational settings in the
United Kingdom. Fifty-five work areas were surveyed across a variety of workplaces.
EPA analyzed the air speed data from Baldwin and Maynard (1998) and categorized the air speed
surveys into settings representative of industrial facilities and representative of commercial facilities.
EPA fit separate distributions for these industrial and commercial settings and used the industrial
distribution for facilities performing vapor degreasing and/or cold cleaning.
EPA fit a lognormal distribution for both data sets as consistent with the authors observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed. Since lognormal distributions are
bound by zero and positive infinity, EPA truncated the distribution at the largest observed value among
all of the survey mean air speeds from Baldwin and Maynard (1998).
EPA fit the air speed surveys representative of industrial facilities to a lognormal distribution with the
following parameter values: mean of 22.414 cm/s and standard deviation of 19.958 cm/s. In the model,
the lognormal distribution is truncated at a maximum allowed value of 202.2 cm/s (largest surveyed
mean air speed observed in Baldwin and Maynard (1998) to prevent the model from sampling values
that approach infinity or are otherwise unrealistically large.
Baldwin and Maynard (1998) only presented the mean air speed of each survey. The authors did not
present the individual measurements within each survey. Therefore, these distributions represent a
distribution of mean air speeds and not a distribution of spatially variable air speeds within a single
workplace setting. However, a mean air speed (averaged over a work area) is the required input for the
model.
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F.2.2.4 Near-Field Volume
EPA assumed a near-field of constant dimensions of 10 ft x 10 ft x 6 ft resulting in a total volume of 600
ft3.
F.2.2.5 Exposure Duration
EPA assumed the maximum exposure duration for each model is equal to the entire work-shift (eight
hours). Therefore, if the degreaser/cold cleaning machine operating time was greater than eight hours,
then exposure duration was set equal to eight hours. If the operating time was less than eight hours, then
exposure duration was set equal to the degreaser/cold cleaning machine operating time (see Appendix
F.2.2.8 for discussion of operating hours).
F.2.2.6 Averaging Time
EPA was interested in estimating 8-hr TWAs for use in risk calculations; therefore, a constant averaging
time of eight hours was used for each of the models.
F.2.2.7 Vapor Generation Rate
For the vapor generation rate from each machine type (OTVD, conveyorized, web, and cold), EPA used
a discrete distribution based on the annual unit emission rates reported in the 2014 NEI (U.S. EPA.
2018a) . Annual unit emission rates were converted to hourly unit emission rates by dividing the annual
reported emissions by the reported annual operating hours (see Appendix F.2.2.8). Reported annual
emissions in NEI without accompanying reported annual operating hours were not included in the
analysis. Emission rates reported as zero were also excluded as it is unclear if this is before or after
vapor controls used by the site and if the vapor controls used would control emissions into the work area
(thus reducing exposure) or only control emissions to the environment (which would not affect worker
exposures). TableApx F-6 summarizes the data available in the 2014 NEI.
TableApx F-6. Summary of Methylene Chloride Vapor Degreasing and Cold Cleaning Data from
the 2014 NEI
Units with Zero
Emissions
Units without
Units Used
Unit Type
Total Units
Accompanying
Operating Hours
in
Analysis3
Open-Top Vapor Degreasers
18
1
9
8
Convey orized Degreasers
3
0
1
2
Cold Cleaning Machines
27
4
3
21
a - Some units with zero emissions also did not include accompanying operating hours; therefore, subtracting the units with
zero emissions and the units without operating hours from the total units does not equal the units in the analysis due to double
counting.
Source: U.S. EPA (2018a)
Table Apx F-7 through Table Apx F-9 summarize the distribution of hourly unit emissions for each
machine type calculated from the annual emission in the 2014 NEI.
Table Apx F-7. Distribution of Methy
ene Chloride Open-Top Vapor Degreasing Unit Emissions
Unit
Count
Emissions
Fractional
of Units
(lb/unit-hr)
Probability
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1
6.00
0.1250
1
4.73
0.1250
1
4.00
0.1250
1
3.69
0.1250
1
3.17
0.1250
1
3.17
0.1250
1
1.78
0.1250
1
0.02
0.1250
TableApx F-8. Distribution of Methylene Chloride Conveyorized Degreasing Unit Emissions
Unit
Count
Emissions
Fractional
of Units
(lb/unit-hr)
Probability
1
5.81
0.5000
1
4.86
0.5000
TableApx F-9. Distribution of Methylene Chloride Cold Cleaning Unit Emissions
Count
of Units
Unit
Emissions
(lb/unit-hr)
Fractional
Probability
1
0.65
0.0476
1
0.60
0.0476
1
0.58
0.0476
1
0.50
0.0476
1
0.09
0.0476
1
0.02
0.0476
1
0.02
0.0476
1
0.02
0.0476
1
0.01
0.0476
1
0.01
0.0476
1
0.01
0.0476
1
0.01
0.0476
1
0.01
0.0476
1
2.66E-04
0.0476
1
1.37E-04
0.0476
1
2.77E-05
0.0476
1
1.03E-05
0.0476
1
1.49E-06
0.0476
1
2.98E-07
0.0476
1
2.98E-07
0.0476
1
6.79E-08
0.0476
1
0.65
0.0476
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F.2.2.8 Operating Hours
For the operating hours of each machine type (OTVD, conveyorized, web, and cold), EPA used a
discrete distribution based on the daily operating hours reported in the 2014 NEI. It should be noted that
not all units had an accompanying reported daily operating hours; therefore, the distribution for the
operating hours per day is based on a subset of the reported units. TableApx F-10 through TableApx
F-12 summarize the distribution of operating hours per day for each machine type.
Table Apx F-10. Distribution of Methylene Chloride Open-Top Vapor Degreasing Operating
Hours
Operating
Hours
Fractional
(hr/day)
Probability
8
0.2000
4
0.4000
2
0.4000
Table Apx F-ll. Distribution of Methylene Chloride Conveyorized Degreasing Operating Hours
Operating
Hours
(hr/day)
Fractional
Probability
8
0.5000
4
0.5000
Table Apx F-12. Distribution of Methylene Chloride Cold Cleaning Operating Hours
Operating
Hours
(hr/day)
Fractional
Probability
24
0.4583
16
0.0417
10
0.1250
8
0.3333
1
0.0417
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