OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
May 28, 1996
The Honorable David L. Hobson
House of Representatives
Washington, D.C. 20515
Dear Congressman Hobson:
This is in response to your letter of February 7, addressed to Geri D. Palast, Assistant Secretary for Congressional and Intergovernmental Affairs, on behalf of your constituent, Dr. Manoj Desai, who is concerned with the dangers of carbon dioxide exposure. We agree that all workers need to be made aware of the potential hazards of carbon dioxide displacement of oxygen.
OSHA has a process for disseminating information on hazardous substances which includes specific hazard bulletins. A hazard bulletin is currently being developed on the hazards of carbon dioxide displacement of oxygen that covers the protective measures your constituent has suggested.
Any questions regarding the bulletin on the hazards of carbon dioxide can be addressed to Mr. Steve Mallinger, Acting Director for the Directorate of Technical Support at (202) 219-7031. Once the hazard bulletin has been completed, a copy can be obtained from Mr. Mallinger's office.
We appreciate your constituent's interest in worker safety and health.
Joseph A. Dear
February 7, 1996
The Hon. Geri D. Palast
Assistant Secretary for Congressional
and Intergovernmental Affairs
U.S. Department of Labor
Frances Perkins Building
Third Street and Constitution Avenue, N.W.
Washington, D.C. 20210
Dear Ms. Palast:
Enclosed is correspondence from my constituent, Dr. Manoj R. Desai, Coroner of Greene County, Ohio.
I would appreciate it if you would look into the matter discussed and provide a report.
Thanks for your help.
DAVID L. HOBSON
Member of Congress
January 9, 1996
Honorable David L. Hobson
150 N. Limestone St.
Springfield, Ohio 45501
Dear Representative Dave Hobson,
In the early morning of September 26, 1995 a 58-year-old male delivery driver collapsed and died shortly after arrival at Greene Memorial Hospital. The investigation revealed the driver had delivered Carbon Dioxide from his semi-tractor trailer to a local fast food restaurant and was found approximately 20 minutes later at the bottom of a darkened stairwell. The driver was found sitting upright in the corner of the stairwell, still wearing his face shield required by OSHA in delivery of carbon dioxide. The autopsy revealed no apparent reason for death with the exception of the blood work drawn at the hospital that disclosed an extremely high level of carbon dioxide in his blood at the time of death. I ruled the death an accident resulting from carbon dioxide intoxication. I discovered the carbon dioxide system utilized is a common system used to operate the carbonated drink dispensers in numerous restaurants and businesses. High concentrations of carbon dioxide, which displaces oxygen, can result in death in less than fifteen minutes.
I would like your assistance in alerting those that work with or come in contact with carbon dioxide, of the dangers associated with exposure to the carbon dioxide gas. Having completed the medical aspects of this investigation, I am making the following suggestions and recommendations for public and private workers' safety. These recommendations are for prevention of further accidents or fatalities involving Carbon Dioxide Intoxication.
1) All new Carbon Dioxide receptacles are installed at ground level in an open area.
2) The remaining underground receptacles have an adequate ventilation system installed.
3) If any detection system for Carbon Dioxide is available, it be installed near the receptacle to alert workers if the concentration reaches a dangerous level.
4) Periodic inspections and if needed, replacement of the delivery and receiving system in all of the facilities that utilize a detrimental gas distribution system.
5) General safety inspections to replace inoperable lights, and to correct identified safety hazards
The dangers involved with Carbon Monoxide (CO) have been well documented and publicized. Some publicity has been afforded to Carbon Dioxide (CO2) dangers in confined spaces associated with agricultural settings and underground settings where gas can accumulate naturally. This death and associated dangers don't apply to the agricultural or confined space hazards, as the stairwell wasn't enclosed and the driver introduced (delivered) the Carbon Dioxide to the atmosphere. Although this death may appear isolated, this is a common carbon dioxide system utilized to operate carbonated drink dispensers, and there is potential for further accidents and fatalities. With your assistance maybe we can alert workers and the general public of the dangers associated with exposure to concentrations of Carbon Dioxide. If you can use these recommendations or have others and I can be of assistance to help promote them, please let me know.
Manoj R. Desai, M.D.
Greene County Coroner