In February 2012, a worker using a product containing methylene chloride to refinish a bathtub was found dead, slumped over a bathtub in an unventilated bathroom.
In September 2011, a worker using a product containing methylene chloride to strip the glaze from a bathtub collapsed in the bathtub and later died.
The cases described above are just two of many similar cases. The Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH)-supported Fatality Assessment and Control Evaluation (FACE) Program have identified at least 14 worker deaths since 2000 related to bathtub refinishing with stripping agents containing methylene chloride.
These types of deaths can be prevented by using alternative, less hazardous chemicals or methods that eliminate the use of methylene chloride. If this is not possible, employers can still prevent deaths and illnesses by using safe work practices, such as using adequate ventilation, supplying workers with respiratory protection as well as protective clothing and equipment, and providing workers with training in accord with OSHA's Methylene Chloride standard (29 CFR 1910.1052) and other applicable standards, such as the Hazard Communication standard (29 CFR 1910.1200) and the Personal Protective Equipment standard (29 CFR 1910.132).
Bathtub refinishing is the process of restoring the surface of an old bathtub to improve the bathtub's appearance and repair surface damage. The process commonly involves removing the bathtub's existing finish before applying a new coating, usually a synthetic finish such as polyurethane or epoxy. Refinishing a bathtub is a less costly alternative to full replacement of the fixture; however, the process often involves the use of hazardous chemicals including methylene chloride, acids and isocyanates.
Methylene chloride, a chlorinated solvent, is a volatile, colorless liquid with a sweet-smelling odor. It is often referred to as dichloromethane. Methylene chloride has many industrial uses, such as paint stripping, metal cleaning and degreasing.
Workers are exposed to methylene chloride by breathing it in and by absorbing it through their skin. If workers smell methylene chloride, they are being overexposed because methylene chloride cannot be smelled until the level in the air is higher than OSHA's permissible exposure limits (PELs). However, the human body can quickly become desensitized to the smell of methylene chloride, and a worker may be overexposed even if he or she can no longer smell it.
When workers use methylene chloride to strip coatings from bathtubs, they often spray or pour a bathtub stripping product into the basin of the bathtub and then brush the product onto the tub surface. Many stripping products (including those that may also be available to consumers), such as the one shown in the picture at right, contain high percentages of methylene chloride. Use of these chemicals in bathrooms is extremely dangerous, particularly because bathrooms are often small, enclosed spaces with little or no ventilation. Since methylene chloride is a volatile organic compound that will evaporate faster when sprayed, brushed, or poured, the chemical vapors can quickly build up in small spaces. Moreover, because methylene chloride evaporates quickly (it has a high vapor pressure), vapors can collect in the bottom of a bathtub and in the worker's breathing zone when working in the bathtub. This situation creates dangerously high concentrations of methylene chloride and even replaces the breathable air. Exposure to as little as six ounces of methylene chloride-based material has been enough to cause death.
Investigations of bathroom refinisher fatalities by Federal OSHA, OSHA-approved State plans,1 and the NIOSH supported FACE program revealed common elements that led to dangerous working conditions. Workers were:
When methylene chloride enters the human body, it affects brain function, such as not being able to concentrate. At high enough levels, it can stop breathing. At lower levels, methylene chloride exposure causes dizziness, fatigue, headaches, and nausea. Methylene chloride breaks down into other chemicals in the body, such as carbon monoxide. In addition, methylene chloride can displace the oxygen in a worker's environment because of its high vapor pressure.
The specific effects of methylene chloride exposure will vary depending on several factors, such as the amount of methylene chloride the worker is exposed to, how long the exposure lasts, and whether the worker has a higher susceptibility (for example, having a pre-existing heart condition).
In workers with heart disease, an increase in carbon monoxide may lead to early onset heart attacks and arrhythmias (irregular heartbeats). Heart attacks may occur even before any other symptoms of methylene chloride exposure occur.
WARNING: Methylene Chloride and Stripping Products
Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthy working conditions for their workers.
OSHA's Methylene Chloride standard (29 CFR 1910.1052) requires employers using methylene chloride to protect and train workers exposed to its hazards. States that operate their own occupational safety and health programs approved by Federal OSHA enforce similar standards but may have different or additional requirements. A list of state plans is available at OSHA's State Occupational Safety and Health Plans web page.
Work Practice Controls:
OSHA's Methylene Chloride standard (29 CFR 1910.1052) requires employers to test the air to determine the concentration of methylene chloride present in the air when a product containing methylene chloride is used (29 CFR 1910.1052(d)). Employers must ensure that workers are not exposed to levels above OSHA's permissible exposure limits (PELs) of 25 parts per million (ppm) over an 8-hour time-weighted average (TWA) and 125 ppm over any 15-minute period (short-term exposure limit or STEL) (29 CFR 1910.1052(c)). The standard also sets a 12.5 ppm action level (AL) which triggers periodic monitoring and medical surveillance provisions. Lowering exposures, even below the permissible exposure limit (PEL), is considered to be good industrial hygiene practice.
When engineering and work practice controls cannot decrease methylene chloride levels below OSHA's PELs (25 ppm over an 8-hour TWA or 125 ppm over a 15-minute period), employers must provide their workers with full-face atmosphere supplying respirators. Air-purifying respirators are not permitted due to the short service life of chemical cartridges when used for methylene chloride exposure. Halfmask respirators may NOT be used because methylene chloride may cause eye irritation or damage. Whenever respirators are required to be worn, the employer must establish and implement a complete respiratory protection program that meets the requirements of OSHA's Respiratory Protection standard (29 CFR 1910.134), including proper selection, usage, training and medical surveillance.
Protective Clothing, Gloves and Eyewear
Regardless of the airborne exposure levels of methylene chloride, the employer must provide each worker using methylene chloride with, and ensure the use of, appropriate PPE to protect the worker's eyes and skin from exposure to methylene chloride. This includes, but is not limited to:
METHYLENE CHLORIDE-RESISTANT GLOVES
METHYLENE CHLORIDE-RESISTANT CLOTHING
Both OSHA's Methylene Chloride and Hazard Communication standards2 require employers to provide health and safety information and training to their employees. Employers must provide training to workers in a manner and language that the worker understands. The training and information must include but is not limited to:
In addition, employers must:
Employers who produce, use, or store methylene chloride in such a way that employees of other employers may be exposed must:
OSHA Consultations: OSHA provides free On-Site Consultation safety and health services for small businesses with fewer than 250 workers at a site (and no more than 500 employees nationwide). This program provides on-site compliance assistance to help employers identify and correct job hazards as well as improve injury and illness prevention programs. On-site consultation services are separate from enforcement and do not result in penalties or citations. To locate the OSHA Consultation office nearest you, visit OSHA's On-site Consultation webpage or call 1-800-321-OSHA (6742).
OSHA Compliance Assistance: OSHA also has compliance assistance specialists throughout the nation who can provide general information about OSHA standards and compliance assistance resources. Contact your local OSHA office for more information by calling 1-800-321-OSHA (6742) or visit OSHA's webpage.
NIOSH FACE Program: Through the FACE Program, NIOSH and state partners investigate selected work-related fatalities to identify work situations at high risk for injury and then formulate and disseminate prevention strategies. NIOSH and state partner FACE investigation reports and related NIOSH worker safety and health documents can be accessed at the NIOSH FACE webpage.
NIOSH HHE Program: Employees, employee representatives, or employers can ask NIOSH to conduct Health Hazard Evaluations (HHEs) at their workplace. NIOSH may provide assistance and information by phone and in writing, or may visit the workplace to assess employee exposure and health. Based on their findings, NIOSH will recommend ways to reduce hazards and prevent work-related illness. The evaluation is done at no cost to the employees, employee representatives, or employers. For more information about the HHE Program, visit the NIOSH HHE webpage or contact the HHE program by phone at 513-841-4383. For general information or questions about any hazard or illness, call the NIOSH Toll-Free Information Service: 1-800-CDC-INFO (1-800-232-4636).
Workers have the right to:
For questions or to get information or advice, to report an emergency, fatality or catastrophe, to order publications, to file a confidential complaint, or to request OSHA's free on-site Consultation service, contact your nearest OSHA office, visit www.osha.gov, or call OSHA at 1-800-321-OSHA (6742), TTY 1-877-889-5627.
To receive documents or more information about occupational safety and health topics, please contact NIOSH at 1-800-CDC-INFO (1-800-232-4636), TTY 1-888-232-6348, email: firstname.lastname@example.org or visit the NIOSH website.
This Hazard Alert is not a standard or regulation, and it creates no new legal obligations. It contains recommendations as well as descriptions of mandatory safety and health standards. The recommendations are advisory in nature, informational in content, and are intended to assist employers in providing a safe and healthful workplace. The Occupational Safety and Health Act requires employers to comply with safety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, the Act's General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm.
1 Currently there are 27 OSHA-approved state occupational safety and health plans. Twenty-one states and Puerto Rico operate complete state plans covering the private sector and state and local government employers and employees. Four states and the Virgin Islands operate state plans which cover only state and local government employers and employees. For additional information about state plans, see OSHA's State Occupational Safety and Health Plans web page.
2OSHA revised its Hazard Communication standard on March 26, 2012 (see 77 FR 17574). Although this Hazard Alert references the revised standard (for example, by referring to "safety data sheets" instead of "material safety data sheets"), the regulated community should refer to the revised standard to determine the effective dates of the revised standard.
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