EPA DEVELOPED A LIST OF SAFETY PRECAUTIONS FOR DEALING WITH BIOSOLIDS
EPA has told the Centers for Disease Control it developed a list of safety recommendations for people when dealing with sludge/biosolids. However, it has refused to pass those recommendations to the farmers who handle Class B sludge or the public who handles unlabelled Class A sludge/biosolids contaminated by pathogen regrowth.
It is clear from the CDC document that this information is meant for sludge contractors and their employees who might be covered by OSHA rules.
It would appear that EPA gave CDC misinformed the CDC who believes Class B sludge sites are restricted for one year.
EPA would never agree to CDC recommendations which are much like those recommended in MSDS sheets for those handled pathogens.
"Periodic training on standard hygiene practices for biosolids workers should be conducted by qualified safety and health professionals that covers issues such as:
• the proper use of appropriate PPE, such as coveralls, boots, gloves, goggles, respirators, and face shields;
• the removal of contaminated PPE and the use of available on-site showers, lockers, and laundry services;
• proper storage, cleaning, or disposal of contaminated PPE;"
Guidance For Controlling Potential Risks To Workers Exposed to Class B Biosolids
Excerpts: Whereas EPA rules (40 CFR Part 503) restrict public access to lands treated with Class B biosolids in order to protect public health, these rules do not apply to workers involved with Class B biosolids handling and land application. Workers may come in contact with Class B biosolids during the course of their work. Workers and employers may be well aware of the need for precautions when contacting untreated sewage, but less aware of the need for basic precautions when using Class B biosolids. This document provides information, guidance, and recommendations to employers and employees working with Class B biosolids to minimize occupational risks from pathogens. It does not address other potential safety and health issues such as injuries or exposures to chemicals.
To protect public health, the EPA’s 40 CFR Part 503 rule prescribes a restricted period of up to one year to limit public access to lands where Class B biosolids have been applied. These EPA restrictions do not apply to occupational access. EPA does recognize that occupational exposure can occur, and states that workers exposed to Class B biosolids might benefit from several additional precautions such as use of dust masks when spreading dry materials, the use of gloves when touching biosolids, and routine hand washing before eating, drinking, smoking, or using the restroom.
NIOSH interviewed employees who worked in all phases of the biosolids operation. Some employees reported repeated episodes of gastrointestinal illness after working with the biosolids, either at the treatment plant or during land application. • NIOSH observed among workers an inconsistent awareness, provision, and use of protective equipment and hygiene practices appropriate for handling Class B biosolids (or biosolids that do not comply with EPA standards). • NIOSH collected bulk samples from different locations within the biosolids storage site and found measurable concentrations of fecal coliforms. Fecal coliforms are used as an indicator for the presence of other enteric microorganisms. Enteric bacteria were detected in air samples collected at the land applications site. • The local department of environmental services recently informed NIOSH that biosolids applied at this site intermittently exceeded (by up to 4.5-times) the EPA fecal coliform upper limit for Class B biosolids prior to the NIOSH survey. • The sub-standard biosolids were applied at the agricultural site before the monitoring results were received from the laboratory.
EPA reports that high-pressure spray applications may result in some aerosolization of pathogens, and that application or incorporation of dewatered biosolids may cause very localized fine particulate/dusty conditions. Also, farm workers may be exposed to biosolids after application and during the restricted period. Ancillary workers, for example laborers hired to clean trucks that were used to haul biosolids, can be exposed to biosolids. Exposures to sub-standard biosolids can occur when these materials are loaded and hauled to approved landfills or incinerators for disposal.
Basic hygiene precautions are important for workers handling biosolids. The following list, originally developed by EPA, provides a good set of hygiene recommendations. 1) Wash hands thoroughly with soap and water after contact with biosolids. 2) Avoid touching face, mouth, eyes, nose, genitalia, or open sores and cuts while working with biosolids. 3) Wash your hands before you eat, drink, smoke, and before and after using the bathroom. 4) Eat in designated areas away from biosolids handling activities. 5) Do not smoke or chew tobacco or gum while working with biosolids. 6) Use barriers between skin and surfaces exposed to biosolids. 7) Remove excess biosolids from footgear prior to entering a vehicle or a building. 8) Keep wounds covered with clean, dry bandages. 9) Flush eyes thoroughly, but gently, if biosolids contact eyes. 10) Change into clean work clothing on a daily basis and reserve footgear for use at work site or during biosolids transport. 11) Do not wear work clothes home or outside the work environment. 12) Use gloves to prevent skin abrasion.
Additionally, NIOSH recommends the following steps to provide a more comprehensive set of precautions for use by employers and employees:
Provide appropriate protective equipment, hygiene stations, and training
Personal Protective Equipment (PPE) - Appropriate PPE should be provided for all workers likely to have exposure to biosolids. The choices of PPE include goggles, splash-proof face shields, respirators, liquid-repellant coveralls, and gloves.
Face shields should be made available for all jobs where there is a potential for exposure to spray or high-pressure leaks, or aerosolized biosolids during land application.
Management and employee representatives should work together to determine which job duties are likely to result in this type of exposure, to conduct appropriate on-site monitoring, and to determine which type of PPE is needed in conjunction with a qualified health and safety professional. If respirators are needed, a comprehensive program would include respirator fit testing and training or retraining. Preprint, June 12, 2002 DHHS (NIOSH) Publication Number 2002-149
Hygiene and Sanitation - Hand-washing stations with clean water and mild soap should be readily available whenever contact with biosolids occurs. In the case of workers in the field, portable sanitation equipment including clean water and soap should be provided. Cabs should be wiped down and cleaned of residual mud (or settled dust) frequently to reduce potential exposure to biosolids.
Training - Periodic training on standard hygiene practices for biosolids workers should be conducted by qualified safety and health professionals that covers issues such as:
• frequent and routine hand washing (the most valuable safeguard in preventing infection by agents present in biosolids), especially before eating or smoking;
• the proper use of appropriate PPE, such as coveralls, boots, gloves, goggles, respirators, and face shields;
• the removal of contaminated PPE and the use of available on-site showers, lockers, and laundry services;
• proper storage, cleaning, or disposal of contaminated PPE;
• instructions that work clothes and boots should not be worn home or outside the immediate work environment.
• prohibition of eating, drinking, or smoking while working in or around biosolids.
• procedures for controlling exposures to chemical agents that may be in biosolids.
Reporting - Workers should be trained to report potentially work-related illnesses or symptoms to the appropriate supervisory or healthcare staff. This may aid in the early detection of workrelated health effects. Immunizations - Ensure that all employees are up- to-date on tetanus-diphtheria immunizations, since employees are at risk of soil- contaminated injuries. Current CDC recommendations do not support hepatitis A vaccination for sewage workers.