oversight

Exposure of Naval Regional Medical Center Personnel to Toxic Substances

Published by the Government Accountability Office on 1977-07-05.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                           DOCUMENT RESUME
 02847 - [A1892948]
 [Exposure of Naval Regional Medical Center Personnel
                                                       to Toxic
 Substances]. HRD-77-117; B-163375. Jujy 5, 1977. 6
                                                     pp.
Report to Secretary, Department of Health, Education,
                                                         and
Welfare; by Gregory J. Ahart, Director, Human Resources
                                                           Div.
Issue Area: Consumer and Worker Protection: Standards,
                                                          Laws, and
     Regulations Enforcement (903).
Contact: Human Resources Div.
Budget Function: Health: Prevention and Control of
                                                    Health
     Problems (553).
Organization Concerned: Department of Defense; Department
     Labor; National Inst. for Occupational Safety and       of
Congressional Pelevance: House Committee on Education   Health.
                                                        and Labor;
     Senate Committee on Human Resources.
Authority: Occupational Safety and Health Act of 1970
                                                         (29 U.S.C..
    668). 29 C.F.R. 1910.1000.

          The deaths from leukemia of two employees
the powerhouse of the Naval Regional Medical Center who worked in
                                                     in
Portsmouth, Virginia, could have been work-induced.
Findings/Conclusions: The powerhouse uses "number
containing benzene and other contaminants. While a 6" fuel     il
                                                    cause and
effect relationship was not posited, Danzeno has been
cause leukemia. Number 6 fuel is used by several Federalknown to
agencies, and probably by private industry, in power
and steam-heating plants. Use of this fuel could causegeneration
exposure o employees if appropriate safeguards are       dangerous
Recommendations: The Department of Defense should    not  taken.
                                                   investigate
this hazard with the assistance of the National Institute
Occupational Safety and Health (ICSH).                      for
                                         NIOSH should also assess
the potential for exposure to toxic substances in
                                                   residual
oils at other Federal agencies and in private industries. fuel
                                                             (DJM)
                         UNITED STATES GENERAL ACCOUNTING OFFICE
          r"
           t~Tiij--~             WASHINGTON, D.C.   20548

      HUMAN MESOURCS
          DIVISICN


coa       B-163375                                                 JUL 0 5 1977

          The Honorable
          The Secretary of Health, Education,
            and Welfare

          Dear Mr. Secretary:

              We have been evaluating whether selected Federal
         lian and military installations provide adeauate         civi-
         to workers exposed to toxic substances. During      protection
         of our evaluation we visited several installations,the course
         the Naval Regional Medical Cente; in                   including
                                                ,rtsmo%-h, Virginia.
         Our evaluation included work area        tvans with an indus-
         trial hygienist from the Departmer.       ''rt's Occupational
         Safety and Health Administration (        -isclssions with
         installation officials, superviso          ,"J.oyees; and re-
         views of records.

              Through discussions with Medical Center personnel
         became aware of the leukemia-induced deaths             we
                                                      cf two Medical
         Center employees who had worked in the Center's
         which uses "nmber 6" fuel oil.                   powerhouse,
                                           Officials from the National
         Institute for Occupational Safety and Health
                                                       (NIOSH) said
         that benzene and other toxic substances are contaminants
                                                                    in
         residual fuel oils, including number 6 fuel.
                                                        Officials from
         the Defense Logistics Agency (DLA) said that
         these substances will vary among batches and the  amounts of
                                                       the benzene in
         the fuel oil could amount to as much as 1/2 of
                                                         one percent
         by weight.  NIOSH officials said that benzene has been known
         to cause leukemia.

             Although we are not concluding that there
        relationship between exposure to benzene or the was a direct
                                                         other toxic
        substances which may be found in number 6 fuel
        ┬▒eukemia-induced deaths, we believe the evidenceand  the two
                                                          on the ad-
        verse effects of benzene alone is enough to
                                                    warrant prompt
        attention to this matter.  DLA officials said that the De-
        partment of Defense (DOD) and several Federal
        agencies use significant amounts of number 6 civilian
                                                      fuel at various
        locations. Use of this fel could cause dangerous
        of employees if appropriate safeguards are not      exposure
                                                        taken.


                                                               HRD-77-117
 B-163375



        This matter has been brought to the attention
                                                        of the
  s;ecretary of Defense. We recommended that
 of Defense, with NIOSH'S assistance, look     the  Secretary
 health hazards created by handling and       into the potential
                                          using residual fuel
 oils which may contain benzene or other
                                           toxic
 We are bringing this matter to your attention substances.
 can take appropriate action to help DOD           so that you
                                           determine the scope
 of the problem and minimize exposure of
                                           DOD employees to
 this hazard.    Also, similar hazards may exist in other
 eral agencies and private industry.                        Fad-
                                        NIOSH
 that they would be interested in following    official.  said
                                               up on this matter.
 BACKGROUND

      The powerhouse uses three oil-fired boilers
steam heat for the Naval Regional Medical           to produce
                                            C .ter. Number 6
fuel is stired in tanks adjacent
taken from thes3 tanks, heated to to the powerhouse.    Fuel is
                                   140 degrees Fahrenheit,
pumped through filters, and heated to
                                       210 degrees Fahrenheit
before being sprayed into the firebox.
very thick and must be heated before it (Number 6 fuel is
                                         can be used effec-
tively.)   Twelve employees currently work in the
which operates 24 hours a day, 7 days a            powerhouse,
employees said that the physical plant week. Poworhouse
                                        and operation at
the powerhouse have been basically the
                                        same for the past
30 years, and that number 6 fuel has been
                                           used for more
than 20 years.
     Both deceased employees worked in the Medical
                                                    Center's
powerhouse for over 20 years. The first
                                          employee died in
July 1972 at age 66, a few weeks after
service. Medical Center personnel said retiring from Federal
was being treated by the Medical Center that this employee
death. The autopsy report snows the causeat the time of his
                                            of death to be
an acute intracerebral hemorrhage due to
mia. Regional Medical Center and Federal myelogenous leuke-
(St. Louis) officials said they had no     Record Center
                                       medical records on
this employee.

     The second employee died in August 1975
The autopsy report shows hat this employee     at age 55.
cerebral hemorrhage due to thrombocytopenia  died  of a
subacute myelogenous lukemia. His widow       resulting from
                                           has filed a
workmen's compensation claim, alleging
                                        work-related death
due to exposure to a toxic substance.
                                        In August 1973 a
private physician, after examining this
                                         employee and re-
viewing his medical history, reported
                                       the possibility of
bone marrow injury from a toxin such as
                                         benzene and the

                               2
B-163375


possibility f exposure to hydrocar- .ns. Medical records
show that leukemia was suspected at that time. Traces of
benzene had been found in the employ e's blood. In January
1975, the private physician diagnose  the illness as leukemia.

     At the foreman's request, the second employee's work
area was checked in 1973 by two Medical Center industrial
hygienists. The foreman said that he had informed the hy-
gienists that benzene had been found in the second employee's
blood and that the hygienists were to survey the powerhouse
for possible benzene exposure. The hygienists observed the
work area and examined some of the substances used, and con-
cluded that the second employee's problem was not due to
exposure to chemical vapors in the work environment.

     The hygienists' report makes no mention of testing for
benzene and we found no evidence tha- air samples had been
taken during the survey. One ,yrgienist said that the fuel
oil being used at that time was not tested.  The oil was
not suspected as a possible problem.

HAZARDS OBSERVED BY OUR
OFFICE AND OSHA HYGIENIST

     The OSHA standard for occupational exposure to benzene
is 10 parts per million (ppm) as an 8-hour time-weighted
average with a ceiling of 25 ppii (29 C.F.R. 1910.1000).
The standard does not include required work practices or
other measures to protect workers. In May 1977 an emergency
tempcary standard for occupational exposure to benzene was
to reduce the permissible workplace exposure to benzene
from 10 ppm to 1 ppm, with a ceiling of 5 ppm for any 15-
minute period during an 8-hour day. The emergency standard
includes required work practices and other measures to
protect workers. However, a court order temporarily stayed
the effective date of the proposed emergency standard. As
of June 29, 1977, the court order was still in ffect.

     Section 19 of the Occupational Safety and Health Act
of 1970 (29 U.S.C. 668) requires that Federal agencies
have an occupational safety and health program which is
consistent with OSHA standards.

     In January 1977,  t our request, an OSHA industrial
hygienist surveyed the powerhouse and took ir samples in
the work areas. Also, a sample of the number 6 fuel was
taken and analyzed for benzene. The air samples taken
in the general working areas of the powerhouse showed ..at
concentrations of benzene vapors in the air were less than



                              3
B-163375


1 ppm. The OSHA hygienist said this low level was due to
the ventilation produced by the boiler's air intake fans.

     The air samples from inside the storage tanks showed
concentrations of 60 ppm or more. The samples taken at
the fuel filters inside the powerhouse showed concentra-
tions exceeding 60 ppm--that is, the detection device be-
came saturated immediately, indicating that the concen-
tration exceeded 60 ppm, the maximum reading possible with
the testing device used. These samples were taken to
determine if benzene vapors were being emitted from the
fuel oil. The fuel oil sample showed a concentration of
about 1/10 of one percent by weight. The OSHA hygienist
seid such an amount, if released into the atmosphere,
would far exceed the OSHA-established level for benzene
e::posure.
     During our survey we observed a powerhouse employee
cleaning the fuel filters used in the system. Cleaning
waF accomplished by filling a metal bucket with fuel oil
and cleaning the filter by hand in the bucket. The em-
ployee wore no gloves or other protective clothing. He
had oil on his hands, arms, face, and clothing.
      Powerhouse employees said that they wore no gloves
or only cloth gloves in this cleaning operation. They
stated that the filters are cleaned weekly, the process
takes about 20 minutes per filter, and they frequently
get fuel on their hands, arms, and clothing. OSHA and
Medical Center health officials said that benzene can
be, absorbed through the skin. The foreman at the power-
house said that powerhouse employees were not participat-
ing in any medical surveillance program.
     The results of our survey were discussed with Medical
Cent-r officials. The OSHA industrial hygienist suggested
(1) mandatory use of synthetic-material gloves, (2) re-
engineering the fuel filtration system, and (3) prohibiting
open buckets of fuel oil in the powerhouse.
CORIECTIVE ACTION
BY MEDICAL CENTER

     In January 1977, after our air sampling was complete,
an industrial hygienist from the Medical Center surveyed
the powerhouse for benzene vapors and took air samples.
In a memorandum to the safety manager, the hygienist re-




                              4
 B-163375
 ported that the samples showed benzene
                                           concentrations of
 less than 1 ppm for seven samples taken
 tions in the powerhouse. The hygienist at various loca-
                                            recommended, however,
 that the employees "* * * should not breath
 vapors given off by No. 6 fuel oil which        hydrocarbon
  lie recommended also that respirators be   has  been heated."
                                            worn by employees
 cleaning up oil spills, skin contact
 oil be avoided, and protective gloves with number 6 fuel
                                         be worn when clean-
 ing filters, burners, and spills.

     On a subsequent visit ea:ly in February
seoved that signs had been posted in the      1977, we ob-
tioning employees to avoid skin contact   powerhouse cau-
products in use and informing them       with the petroleum
                                   of mandatory require-
ments for protective gloves and respirators.

     We understand that the safety manager
port to the commander of the Medical Center made a full re-
stances surrounding the deaths of the two    on the circum-
                                           former employees.
CONCLUSIONS

      Because  f the seriousness of exposure to benzene
other toxic substances which may be found                 or
                                           in number 6 fuel,
and the possible implication of the recent
deaths o. two Medical Center employees,     leukemia-induced
                                         we believe efforts
should be made to determine the scope of
propriate action can be taken to prevent the problem so ap-
exposure to this hazard. Number 6 fuel or minimize worker
                                         is used by several
Federal agencies ad likely by private
                                        industry.
stand it is used extensively by power generation We under-
                                                   and steam-
heating plants.   Use of this fuel could cause dangerous
exposure of employees if appropriate safeguards
taken.                                            are not

     Our report to the Secretary of Defense
that DOD look into this problem with        recommended
                                     NIOSH's assistance.
RECOMMENDATIONS

      We recommend that the Secretary of HEW
                                              make appropriate
arrangements for NIOSH to assist DOD in
                                         its
 into the health hazards which may be created efforts to look
                                               by exposure
to number 6 fuel.   Since the potential for exposure also
exists for workers outside DOD we recommend
NIOSH be directed t determine whether         also that
                                        occupational expo-
sure to residual fuel oils which may contain
other toxic substances creates health problemsbenzene or
Federal and private industry workplaces.         at othez




                               5
B-163375


     Because of OSHA's responsibilities for worker protec-
tion, we are sending a similar letter to the Secretary of
Labor and recommending that OSHA (!  inform other Federal
agencies and private industry of this hazard and (2) include
residual fuels as a potential hazard to be checked for dur-
ing OSHA inspections and surveys of workplaces.

     As you know, section 236 of the Legislative Reorgani-
zation Act of 1970 requires the head of a Federal agency
to submit a written statement on action taken on our recom-
mendations to the House Committee on Government Operations
and the Senate Committee on Governmental Affairs not later
than 60 days after the date of the report and to te House
and Senate Committees on Appropriations with the agency's
first request for appropriations made more than 60 days
efter the dat- of the report.

     Copies of this report are being sent today to the
House Committee on Government Operations; the Senate Com-
mittee on Governmental Affairs; the House Committee on
Education and Labor; the Senate Committee on Human Re-
sources; te ouse Committee on Appropriations; the Senate
Appropriations Subcommittee on Labor, Health, Education,
and Welfare and related agencies; the House Subcommittee
on Manpower and Housing; and the Director, Office of Man-
agement and Budget.

     We would appreciate receiving your comments on any ac-
tions you take or plan on the recommendations made in this
report.

     We appreciate the courtesy and cooperation extended
by your staff to our representatives during the review.

                                 Sincerely yours,




                                 Dgo'           t




                             6
    eJ~i~\
     Q   )         UNITED STATES GENERAL ACCOUNTING OFFICE
                            WASHINGTON, D.C. 20548

HUMAN RIESOURCES
    ODVISION

     B-163375


     The Honorable
     The Secretary of Defense

     Dear Mr. Secretary:

         We have been evaluating whether selected Federal
    civilian and military installations provide adequate pro-
    tection to workers exposed to toxic substances. During the
    course of our evaluation we visited several installations,
    including the Naval Regional Medical Center in Portsmouth,
    Virginia. Our evaluation included work area inspections
    with an industrial hygienist from the Department of Labor's
    Occupational Safety and Health Administration (OSHA);
    discussions with installation officials, supervisors, and
    employees; and reviews of records.

         Through discussions with Medical Center personnel we -
    became aware of the leukemia-induced deaths of two Medical
    Center employees who had worked in the Center's powerhouse,
    which uses "number 6" fuel oil. Officials from the National
    Institute for Occupational Safety and Health (NIOSH) said
    that benzene and other toxic substances are contaminants in
    residual fuel oils, including number 6 fuel oil.  Officials
    from the Defense Logistics Agency (DLA) said that the amounts
    of these substances will vary among batches and the benzene
    in the fuel oil could amount to as much as 1/2 of one
    percent by weight. NIOSH officials said that benzene has
    been known to cause leukemia.

         Although we are not concluding that there was a direct
    relationship between exposure to benzene or the other toxic
    substances which may be found in number 6 fuel and the two
    leukemia-induced deaths, we believe the evidence on the
    adverse effects of benzene alone is enough to warrant
    prompt attention to this matter. DLA officials said that
    the Department of Defense (DOD) uses a significant amount
    of number 6 fuel at various locations. Use of this fuel
    could cause dangerous exposure of employees if appropriate
    safeguards are not taken.

         We are bringing this matter to your attention so that
    you may take appropriate action to determine the scope of
    the problem and initiate whatever orrective measures may

                                                             HRD-77-118
                                 I
B-163375



be necessary to prevent or minimize employee exposure to
this hazard.  We plan to issue, at a later date, a full re-
port on our work at all installations included in our review
and will request your comments on a draft of the full report
when it is completed.

BACKGROUND

     The powerhouse uses three oil-fired boilers to produce
steam heat for the Naval Regional Medical Center.   Number 6
fuel is stored in tanks adjacent to the powerhouse.   Fuel
is taken from these tanks, heated to 140 degrees Fahrenheit,
pumped through filters, and heated to 210 degrees Fahrenheit
before being sprayed into the firebox.   (Number 6 fuel is
very thick and must be heated before it can be used effec-
tively.)  Twelve employees currently work in the powerhouse,
which operates 24 hours a day, 7 days a week.   Powerhouse
employees said tnat the physical plant and operation at the
powerhouse have been basically the same for the past 30
years, and that number 6 fuel has been used for more than
20 years.

      Both deceased employees worked in the Medical Center's
powerhouse for over 20 years. The first employee died in
July 1972 at age 66, a few weks after retiring from Federal
service. Medical Center personnel said that this employee
was being treated by the Medical Center at the tinge of his
death. The autopsy report shows the cause of death to be an
acute intracerebral hemorrhage due to myelogenous leu;emia.
Regional Medical Center and Federal Record Center (St. Louis)
officials said that they had no medical records or this
employee.

     The second employee died in August 1975 at age 55.  The
autopsy report shows that this employee died of a cerebral
hemorrhage due to thrombocytopenia resulting from subacute
myelogenous leukemia. His widow has filed a workmen's com-
pensation claim, alleging work-related death due to exposure
to a toxic substance.  In August 1973 a private physician,
after examining this employee and reviewing his medical
history, reported the possibility of bone marrow injury from
a toxin such as benzene and the possibility of exposure to
hydrocarbons.  Medical records show that leukemia was sus-
pected at that time. Traces of benzene had been found in
the employee's blood.  In January 1975 the private physician
diagnosed the illness as leukemia.


                              2
B-163375



     At the foreman's request, the second employee's work
area was checked in 1973 by two Medical Center industrial
hygienists.  The foreman said that he had informed the
hygienists that benzene had been found in the second em-
ployee's blood and that the hygienists were to survey the
powerhouse for possible benzene exposure. The hygienists
observed the work area and examined some of the substances
used, and concluded that the second employee's problem
was not due to exposure to chemical vaprts in the work
environment.

     The hygienists' report makes no mention of testing for
benzene, and we found no evidence that air samples had been
taken during the survey. One ygienist said that the fuel
oil being used at that time w_s not tested. The oil was
not suspected as a possible problem.

HAZARDS OBSERVED BY OUR
OFFICE AND OSHA HYGIENIST

     The OSHA standard for occupational exposure to benzene
4s 10 parts per million (ppm) as an 8-hour time-weighted
average with a ceiling of 25 ppm (29 C.F.R. 1910.1000).
The standard does not include required work practices or
other measures to protect workers. In May 1977 an emergency
temperary standarc for occupational exposure to benzene was
to reduce the permissible workplace exposure to benzene from
10 ppm to 1 ppm, with a ceiling of 5 ppm for any 15-minute
period during an 8-hour day. The emergency standard in-
cludes required work practices and other measures to protect
workers. However, a court order temporarily stayed the
effective date of the proposed emergency standard.

     Section 19 of the Occupational Safety and Health Act
of 1970 (29 U.S.C. 668) requires that Federal agencies have
an occupational safety and health program which is consis-
tent with OSHA standards.

     In January 1977, at our request, an OSHA industrial
hygienist surveyed the powerhouse and took air samples in
the work areas. Also, a sample of number 6 fuel was taken
and analyzed for benzene. The air samples taken in the
general working areas of the powerhouse showed that concen-
trations of benzene vapors in the air were less than 1 ppm.
The OSHA hygienist said this low level was due to the ven-
tilation produced by the boiler's air intake fans.


                              3
B-163375



      The air samples from inside the storage tanks showed
concentrations of 60 ppm or more. The samples taken at
the fuel filters inside the powerhouse showed concentrations
exceeding 60 ppm--that is, the detection device became
saturated immediately, indicating that the concentration
exceeded 60 ppm, the maximum readiuig possible with the
testing device used.  These samples were taken to determine
if benzene vapors were being emitted from the fuel oil.
The fuel oil sample showed a concentration of about 1/10
of one percent by weight.  The OSHA hygienist said such
an amount, if released into the atmosphere, would far exceed
the OSHA-established level for benzene exposure.

      During our survey we observed a owerhouse employee
cleaning fuel filters used in the syst.em. Cleaning was
accomplished by filling a metal bucket with fuel oil and
cleaning the filter by hanc in the bucket. The employee
wore no gloves or other protective clothing.  He had oi.
on his hands, arms, face, and clothing.

      Powerhouse employees said that they wore no gloves
or only cloth gloves in this cleaning operation. They
stated that the filters are cleaned weekly, the process
takes about 20 minutes per filter, and they frequently
get fuel on their hands, arms, and clothing. OSHA and
Medical Center health offic als said that benzene can be
absorbed through the skin. The foreman at the powerhouse
said that powerhouse employees were not participating in
any medical surveillance program.

      The results of our survey were discussed with Medical
Center officials.   The OSHA industrial hygienist suggested
(1) mandatory  use of synthetic-material gloves, (2) re-
engineering  the fuel filtration system, and (3) prohibiting
open buckets  of fuel oil in the powerhouse.

CORRECTIVE ACTION
BY MEDICAL CENTER

      In January 1977, after our air samplina survey was
complete, an industrial hygienist from the Medical Center
surveyed the powerhouse for benzene vapors and took air
samples.  In a memorandum to the safety manager, the hygien-
ist reported that the samples showed benzene concentrations
of less than 1 ppm for seven samples taken at various loca-
tions in the powerhouse. The hygienist recommended, however,

                               4
B-163375



that the employees "    * should not breath hydrocarbon
vapors given off by No. 5 fuel oil which has been heated."
He recommended also that respirators be worn by employees
cleaning up oil spills, skin contact with number 6 fuel be
avoided, and protective gloves e worn when cleaning fil-
ters, burners, and spills.

      On a subsequent visit early in February 1977, we
observed that signs had been posted in the powerhouse
cautioning employees to avoid skin contact with the petro-
leum products in use and informing them of mandatory re-
quirements for protective gloves and respirators.

      We understand that the safety manager made a full re-
port to the commander of the Medical Center on the circum-
stances surrounding the deaths of the two former employees.
We requested a copy of this report, but we have not yet
received one.

REVISIONS IN STANDARD
FOR BENZENE EXPOSURE

      NIOSH is responsible, under section 20(a)(3) of the
Occupational Sdfety and Health Act of 1970, to develop
criteria for toxic substance exposure levels at which
employees will not suffer impaired health or functional
capacities because of their work experience.

      In July 1974 NIOSH issued a criteria document recom-
mending that OSHA revise the standard for occupational
exposure to benzene. At that time, NIOSH recommended an
exposure limit of 10 ppm as a time-weighted average for
a 10-hour workday, with a 25-ppm ceiling determined by
a 10-minute sampling time.

      In addition to the exposure limit, NIOSH recommended
that, under certain conditions, employees "subject to expo-
sure to benzene" be (1) provided periodic medical examina-
tions and bioligical monitoring; (2) informed and educated
on benzene hazards; and (3) provided with, and instructed
in the use of, protective clothing and equipment. NIOSH
recommended also that employers be required to maintain
exposure records and medical histories for each exposed
employee, post signs at entrances to areas where exposure
is likely to occur, and establish several work practices
to protect workers.



                              5
B-163375


                                                 eidenc3
     In August 1976, after reviewing additional
                                               data indic-
accumulated from clinical and epidemiological
                                      NIOSH recommended  a
ating that benzene was leukemogeic,
                                      limit for benzene:
more stringent occupational exposure          NIOSH recom-
1 ppm as determined by a 2-hour air sample. benzene be con-
mended also that, for regulatory purposesc
sidered carcinogenic to man.   In a memorandum to OSHA, the
director of NIOSH said
                                                to
      "Because it is not possible at presenta  car-
      establish a safe exposure level  for
                                         is to
      cinogen, the NIOSH recommendation       that
      restrict exposure to very low  levels
                                      in the   work-
      can still be reliably measured
      place."
                                               over the need
      In October 1976 NIOSH expressed concern
                                  process and strongly
to accelerate the OSHA rulemaking     action to revise the
recommended that OSHA take emergency
                                      to OSHA, NIOSH stated
                   In its memorandum made
benzene standard. had recently been       between oenzene
that a connection
and chronic leukemia.
                                that NIOSH considered and  recent
       The memorandum states benzene is  leukemogenic          pro-
 evidence conclusive   that
                                              the blood-forming
 duces progressive, malignant disease of the time to estab-
 organs. Because it was     not possible  at
                                                 recommended that
 lish a safe benzene exposure level, NIOSH
                                          possible--I ppm in the
 the exposure level be kept as low as this is Che lowest
 air.   According to a NIOSH official
                                          with devices currently
 level which can feasibly be detected
 in use.
                                                   NIOSH, in January
        Based on the information supplied by
                                            for the control of
 1977 OSHA issued voluntary guidelines  The guidelines recommend-
 occupational exposure to benzene.                         average
 ed an exposure limit cf 1 ppm as a time-weighted
  for any 8-hour day.
                                                          additional
         In January and April 1977 NIOSH submitted
                           the adverse effects of       benzene. OSHA
  information to OSHA onan emergency  temporary    standard   for
  subsequently issued                          was   to  become  effec-
  occupational exposure to benzene, which         the   permissible
  tive May 21, 1977. This standard reduced to 1 ppm, with a
                                             ppm
  workplace exposure to benzene from 10
                                     period   during an 8-hour day.
  5-ppm ceiling for any 15-minute

                                    6
B-163375



On May 20, 1977, a Federal court issued a restraining order
staying the effective date of the emergency standard. As
of June 29, 1977, the restraining order was still in effect.

      The emergency standard will require that employers
notify OSdA of the location of all workplaces where benzene
is used, the condition of use, and the protective measures
in effect.  In additioa, under certain conditions employers
will have to maintain exposure records and medical histories
on exposed employees, establish medical surveillance pro-
grams, require use of protective clothing and equipment,
prcvide education and training programs, and establish other
work practices to minimize or prevent employee exposure to
benzene.

      The emergency standard will apply to all employers
and establishments in which benzene is present, except
for two general groups:

      -- Those operations involving the storage, transpor-
         tation, distribution, dispensing, or sale f gaso-
         line as a fuel subsequent to discharge of such
         gasoline from bulk terminals.

      -- Those operations using liquid mixtures cont ining
         1 percent or less benzene.

The exempted groups will continue to be subject to the old
OSHA standard. OSHA says that employees working in the
exempted groups are generally exposed to concentrations of
less than 1 ppm.  In its press release on the emergency
standard, OSHA said these operations will be considered for
inclusion in a permanent standard to be developed within 6
months.

      Although the emergency standard reduced permissible
exposure to a very low level, supplementary information
provided by OSHA with the emergency standard states

      "The best available scientific vidence indi-
      cates that no safe level for exposure to a
      carcinogen, including benzene, can be estab-
      lished or assumed to exist."

OSHA concluded that "* * * a single exposure episode may
be sufficient to cause cancer."


                              7
B-163375



CONCLUSIONS

      OSHA and NIOSH believe it is currently impossible to
determine whether a safe exposure level exists for carcino-
gens.  Leukemia is a cancer and benzene has been known to
cause leukemia. We believe, therefore, that until a deter-
mination can be made on a sfe exposure level, any eposure
to benzene should be reduced to the lowest level feasible.

      Because of the seriousness of exposure to benzeie ad
the possible implication of the recent leukemia-induced
deaths of to Medical CenteL employees, we believe DOD
should take whatever actioi, may be necessary to provide
maximum protection to its employees who are or have been
exposed to benzene at the Medical Center and other loca-
tons. We believe the recommendations made by NIOSH in its
criteria document, subsequent correspondence with OSHA,
and the requireiaerts of the emergency standard should
guide such action. We believe also that the residual fuel
oil used by the various DCD installations should be fully
analyzed to determine whether it contains other toxic
substances.

      NIOSH officials said that they would be interested
in following up on this matter to obtain more data on the
effects of contaminated fuel oil on workers' health.

RECOMMENDATION

      We recommend that the Secretary of Defense, with the
assistance of NIOSH, look into the health hazards created
by handling and using residual fuel oils which may contain
benzene or other toxic substances. As part of this effort,
appropriate ac:ion should be taken to:

     -- Identify which DOD installations use residual fuels,
        particularly number 6 fuel oil; and, using the latest
        NIOSE recommendations and OSHA standards, determine
        whether these fuel oils are used in a manner which
        assures worker protection from exposure to benzene.

     -- Analyze the fuel oil to ascertain whether it con-
        tains other toxic substances so appropriate action
        can be taken to assure worker protection.

     -- Establish a comprehensive medical surveillance
        program for powerhouse and other COD employees who

                              8
B-163375



           may be or may have been exposed to benzena or other
           toxic substances which may be found in residual
           fuel oil.

DOD COMMENTS

      Officials from the Office of the Secretary of Defense
(OSD) did not agree that benzene could be a problem in the
powerhouse. They said routine DOD analyses had never shown
be-zene was present in number 6 fuel oil. They said the
dLstillation process used to refine crude oil should remove
benzene from the residual fuels.

      We discussed this matter with DLA officials and a
representative of the oil company which produced the fuel
oil used at the Medical Center's powerhouse. They said that
number 6 fuel oil usually has a small amount of benzene
since the refining process will not remove all of it. They
said the same generally holds true for other toxic substances
which can be found in residual fuels, including number 6
fuel oil. DLA officials stated that they did not routinely
check esidual fuels for benzene. They said the type of
testing they do would not detect a benzene level lower than
about 2 percent.

      The officials from OSD questioned the reliability of
the benzene detector tubes used by the OSHA industrial
hygienist. We discussed this matter with DLA and NIOSH
officials who said that although detector tubes are not
completely reliable, such tubes are adequate to detect
the presence of a toxic substance. They said that sub-
stances other than the one being tested for can interfere
with the reaction of the detector tube, causing it to
produce an erroneous reading. They said that the manufac-
turers of the detector tubes generally identify the inter-
fering substances so that users have some indication of the
tube's reliability and whether further testing might be
warranted. They stated that detector tubes are able to
detect the presence of toxic substances although they are
not reliable to show exactly how much.



       Because NIOSH officials are interested in this matter
 we are sending the Secretary of Health, Education, and Wel-



                                  9
B-163375
fare a similar letter and recommending that he make arrange-
inents for NIOSH to assist you.

      As you know, section 236 of the Legislative Reorgani-
zation Act of 1970 requires the head of a Federal agency to
submit a written statement on action taken on our recommen-
dations to the House Committee on Government Operations and
the Senate Committee on Governmental Affairs not later than
60 days after the date of the report and to the House and
Senate Committees on Appropriations with the agency's first
request tor appropriations made more than 60 days after
the date of the report.

      Copies of this report are being sent today to the House
Committee on Government Operations; the Senate Committee on
Governmental Affairs; the House and Senate Committees on
Armed Services; the House Committee on Appropriations; the
Senate Appropriations Subcommittee on Defense; the House
Subcommittee on Manpower and Housing; and the Director,
Office Management and Budget.

      We would appreciate your comments on the findings and
recommendations inr this report, including any actions you
take or plan to take on the recommendations.

      We appreciate the courtesy and cooperation extended
by DOD personnel to our representatives during this review.

                              Sincerely yours,




                                e          art
                              Direc




                            10
                        UNITED STATES GENERAL ACCOUNTING OFFICE
            am/~~~~   ~WASHINGTON, D.C. 20548

HUMAN RESOURCCS
    DIVISION

     B-163375                                                JUL   5 1977


     The Honorable
     The Secretary of Labor

     Dear Mr. Secretary:

          We have been evaluating whether selected Federal civilian
     and military installations provide adequate protection to
     workers exposed to'toxic substances. During the course of our
     evaluation we visited several installations, including the
     Naval Regional Medical Center in Portsmouth, Virginia. Our
     evaluation included work area inspections with an industrial
     hygienist from the Dpartment of Labor's Occupa- onal Safety
     and Health Administration (OSHA!; discussions w h installa-
     tion officials, supervisors, and employees; and reviews of
     records.

          Through discussions with Medical Center personnel we
     became aware of the leukemia-induced deaths of two Medical
     Center employees who had worked in the Center's powerhouse,
     which uses "number 6" fue2 oil.  Officials from the National
     Institute for Occupational Safety and Health (NIOSH) said tt
     ben ene and other toxic substances are contaminants in resi-
     dual fuel oils, including number 6 fuel. Officials from the
     Defense Logistics Agency (DLA) said that the amounts of these
     substances will vary among batches and the benzene in the fuel
     oil could amount to as much as 1/2 of one percent by weight.
     NIOSH officials said that benzene has been known to cause
     leukemia.

          Although we re not concluding that there was a direct
     relationship between exposure to benzene or the other toxic
     substances which may be found in number 6 fuel and the two
     leukemia-induced deaths, we believe the evidence on the ad-
     verse effects of benzene alone is enough to warrant prompt
     attention to this matter. DLA officials said that the Depart-
     ment of Defense (DOD) uses a significant amount of number 6
     fuel at various locations. Use of this fuel could cause
     dangerous exposure of employees if appropriate safeguards
     are not taken.

          This matter has been brought to the attention of the
     Secretary of Defense and the Secretary of Health, Education,

                                                              HRD-77-116
B-163375

and Welfare. We recommended that they look into the hazards
created by handling and using residual fel oil,; which may
contain benzene or other toxic substances. We are bringing
this mattEr to your attention so that (1) other Federal
agencies and private industry can be informed of this hazard
and (2, OSHA inspectors may check for this hazard in their
workplace inspections.

BACKGROUND

    The powerhouse uses three oil-fired boilers to produce
steam heat for the Naval Regional Medical Center. Number 6
fuel is stored in tanks adjacent to the powerhouse. Fuel is
taken from these tanks, heated to 140 degrees Fahrenheit,
pumped through filters, and heated to 210 degrees Fahrenheit
before being sprayed into the firebox.  (Number 6 fuel is ve:y
thick and must be heated before it can be used effectively.)
Twelve employees currently work in the powerhouse, which oper-
ates 24 hours a day, 7 days a week.  Powerhouse employees said
that the physical plant and operation at the powerhouse have
been basically the same for the past 30 years, and that number
6 fuel has been used for more than 20 years.

    Both deceased employees worked in the Medical Center's
powerhouse for over 20 years. The first employee died in
July 1972 at age 66, a few weeks after retiring from Federal
service   Medical Center personnel said this employee was
be'ng treated by the Medical Center at the time of his death.
The autopsy report shows the cause of death to be an acute
intracerebral hemorrhage due to myelogennus leukemia. Regional
Medical Center and Federal Record Center (St. Louis) officials
said they had no medical records on this employee.

    The second employee died in August 1975 at age 55. The
autopsy report shows that this employee died of a cerebral
hemorrhage due to thrombocytopenia resulting from subacute
myelogenous leukemia. His widow has filed a workmen's com-
pensation claim, alleging work-related death due to exposure
to a toxic substance.  In August 1973 a private physician,
after examining this employee and reviewing his medical his-
tory, reported the possibility of bone marrow injury from a
toxin such as benzene and the possibility of exposure to
hydrocarbons. Medical records show that leukemia was sus-
pected at the time. Traces of benzene had been found in
the employee's blood.  In January 1975 the private physician
diagnosed the illness as leukemia.

    At the foreman's request, the second employee's work
area was checked in 1973 by two Medical Center industrial
hygienists.  The foreman said that he had informed the hy-
gienists that benzene had been found in the second employee's

                              2
B-163375

blood and that the hygienists were to iurvey the powerhouse
for possible benzene exposure.  The hygienists observed the
work area and examined some of the substances used, and con-
cluded that the second employee's problem was not due to ex-
posure to chemical vapors in te work environment.

     The hygienists' report makes no mention of testing for
benzene, and we found no evidence that air samples had been
taken during the survey. One hygienist said that the fuel
oil being used at that time was not tested.  The oil was not
suspected as a possible problem.

HAZARDS OBSERVED BY OUR
OFFICE AND-OSHA HYGIENIST

     In January 1977, at our request, an OSHA industrial hy-
gienist surveyed the powerhouse and took air samples in the
work areas. Also, a sample of the number 6 fuel was taken and
analyzed for benzene. The air samples taken in the general
working areas of the powerhouse showed that concentrations of
benzene vapors in the air were less than 1 part per million
(ppm). The OSHA hygienist said this low level was due to the
ventilation produced by the boiler's air intake fans.

     The air samples from inside the storage tanks showed con-
centrations of 60 ppm or more. The samples taken at the fuel
filters inside the powerhouse showed concentrations exceeding
60 ppm--that is, the detection device became saturated im-
mediately, indicating that the concentration exceeded 60 ppm,
the maximum reading possible with the testing device used.
These samples were taken to determine if benzene vapors were
being emitted from the fuel oil. The fuel oil sample showed
a concentration of about 1/10 of one percent by weight. The
OSHA hygienist said such an amount, if released into the at-
mosphere, would far exceed the OSHA-established level for
benzene exposure.

     During our survey we observed a powerhouse employee
cleaning fuel filters used in the system. Cleaning was ac-
complished by filling a metal bucket with fuel oil and clean-
ing the filter by hand in the bucket. The employee wore no
gloves or other protective clothing.  He had oil on his hands,
arms, face, and clothing.

     Powerhouse employees said that they wore no gloves or
only cloth gloves in cnis cleaning operation. They stated
that the filters are cleaned weekly, the process takes about
20 minutes per filter, and they frequently get fuel on their
hands, arms, and clothing. OSHA and Medical Center health
officials said that benzene can be absorbed through the skin.


                              3
B-163375

The foreman at the powerhouse said that powerhouse employees
were not participating in any medical surveillance program.

     The results of our survey were discussed with Medical
Center officials. The OSHA industrial hygienist suggested
(1) mandatory use of synthetic-material gloves, (2) re-engine-
ering the fuel filtration system, and (3) prohibiting open
buckets of fuel oil n the powerhouse.

CORRECTIVE-ACTION
BY MEDICALCENTER

     In January 1977, after our air sampling survey was com-
plete, an industrial hygienist from the Medical Center surveyed
the powerhouse for benzene vapors and took air samples. In a
memorandum to the safety manager, the hygienist reported that
the samples showed benzene concentrations of less than 1 ppm
for seven samples taken at various locations in the powerhouse.
The hygienist recommended, however, that the employees
"* * * should not breath hydrocarbon vapors given off by no. 6
fuel oil which has been heated." He recommended also that re-
pirators be worn by employees cleaning up oil spills, skin
contact with number 6 fuel be avoided, and protective lo.ves
be worn when cleaning filters, burners, and spills.

     On a subsequent visit early in February 1977, we observed
that signs had been posted in the powerhouse cautioning
employees to avoid skin contact with the petroleum products
in use and informing them cf mandatory requirements for pro-
tective gloves and respirators.

REVISIONS-IN-STANDARD
FOR BENZENE EXPOSURE

     The OSHA standard for occupational exposure to benzene--
adopted is 1971--is 10 ppm as an 8-hour time-weighted average
with a ceiling of 25 ppm. The standard does not include re-
quired work practices or other measures to protect workers.
In May 1977 an emergency temporary standard for occupational
exposure to benzene was to reduce the permissible workplace
exposure to benzene from 10 ppm to 1 ppm, with a ceiling of 5
ppm for any 15-minute reriod during an 8-hour day. The emer-
gency standard includes required work practices and other
measures to protect workers. However, a court order has
temporarily stayed the effective date of the proposed emer-
gency standard.

      In July 1974 NIOSH issued a criteria document on oc-
 cupational exposure to benzene and recommended an exposure
 limit of 10 ppm as a time-weighted average for a 10-hour
 day, with a 25--ppm ceiling determined by a 10-minute sampling
                               4
B-163375

time. In addition, NIOSH recommended periodic medical ex-
aminations and biological mcnitoring for employees subject to
exposure to benzene. It recommended also that, under certain
conditions, various work practices be etablished and main-
tained to protect workers.

     In August 197C, after considering additional chemical
and epidemiological data, NIOSH recommended a more stringent
benzene exposure limit of 1 ppm. At the time, NIOSH recom-
mended also that, for regulatory purposes, benzene be considered
carcinogenic to man. In a memorandum to OSHA, the Director
of NIOSH said

     "Because it is not possible at present to establish
     a safe exposure level for a carcinogen, the NIOSH
     recommendation is to restrict exposure to very low
     levels that can still be reliably measured in the
     workplace."

     In October 1976 NIOSH expressed concern over the need
to accelerate OSHA's rulemaking process and strongly recom-
mended that emergency standards be established for benzene
and certain other toxic substances. NIOSH said that it con-
sidered recent evidence to be conclusive that benzene is
leukemogenic and produces progressive, malignant disease of
the blood-forming organs.

     In January and April 1977 NIOSH submitted additional
information to OSHA on the adverse effects of benzene. OSHA
subsequently issued an emergency temporary standard for oc-
cupational exposure to benzene, which was to become effective
May 21, 1977. On May 20, 1977, a Federal court issued a re-
straining order taying the effective date of the emergency
standard. As of June 29, 1977, the restraining order was
stil. in effect.

     Although the emergency standard will reduce permissible
exposure to a very low level, supplementary information pro-
vided by OSHA with the emergency standard states:

     "The best available scientific evidence indicates
     that no safe level for exposure to a carcinogen,
     including benzene, can be established or assumed to
     exist."

OSHA concluded that "* * a single exposure episode may be
sufficient to cause cancer."




                              5
B-163375

CONCLUSION

     OSHA and NIOSH believe it is currently impossible to
determine whether a safe exposure level exists for carci-
nogens. Leukemia is a cancer and benzene hs been known to
cause leukemia. We believe, therefore, that until a deter-
mination can be made on a safe exposure level, any exposure
to benzene should be reduced to the lowest level feasible.

     Because of the seriousness of occupational exposure to
benzene and other toxic substances which may be found in
number 6 fuel, and the possible implication of the leukemia-
induced deaths of the two Medical Center employees, we believe
OSHA should consider taking additional steps to protect
workers from unnecessary exposure to these hazards. Number 6
fuel is used by several Federal agencies and likely by private
industry. We understand it is used extensively by power gener-
ation and steam-heating plants. Usi   f this fuel could cause
dangerous exposure of employees if appropriate safeguards are
not taken.

RECOMMENDATIONS

     We recommend that the Secretary of Labor inform Federal
agencies and private industry of the health hazards which can
be created by handling and using residual fuel oils which may
contain benzene and other toxic substances. We recommend also
that residual fuels be included as a potential health hazard
which should be checked for during OSHA's inspections and sur-
veys of workplaces.


     As you know, section 236 of the Legislative Reorganization
Act of 1970 requires the head of a Federal agency to submit a
written statement on action taken on our recommendations to
the House Committee on Government Operations and the Senate
Committee on Governmental Affairs not later than 60 days after
the date of the report and to the House and Senate Committees
on Appropriations with the agency's first request for appro-
priations made more than 60 days after the date of the report.

     Copies of this report are being sent today to the House
Committtee on Government Operations; the Senate Committee on
Governmental Affairs; the House Committee on Education and
Labor; the Senate Committee on Human Resources; the House
Committee on AppropriaLions; the Senate Appropriations Sub-
committee on Labor, Health, Education, and Welfare and related
agencies; the House Subcommittee on Manpower and Housing; and
the Director, Office of Management and Budget.



                              6
B-163375

     We would appreciate your comments on the findings and
recommendations in this repor , including any actions you
take or plan to take on the recommendations.

     We appreciate the courtesy and cooperation extended by
your staff tc our representatives during this review.

                              Sincerely yours,




                              Direct'r




                              7