- Record Type:OSHA Instruction
- Current Directive Number:CPL 02-02-031
- Old Directive Number:CPL 2-2.31 CH-1
- Title:Removal of Obsolete Sections
- Information Date:
OSHA Instruction CPL 2-2.31 CH-1 JUN 3 1985 Office of General Industry Compliance Assistance
Subject: Removal of Obsolete Sections
A. Purpose. This notice transmits page changes which remove sections that contain policies and procedures superseded by guidelines set forth in the Field Operations Manual (FOM), OSHA Instruction CPL 2.45A.
B. Scope. This notice applies OSHA-wide.
C. Action. Replace existing pages with the attached CH-1 pages as
- listed below:
D. Significant Changes. The instruction will be totally revised and reprinted at a later date. In the interim, the following sections are removed:
- CPL 2-2.311, January 16, 1981: Chapter I, paragraph H.
Citations, pages I-13 and -14; Chapter III, Guidance for Citing Permissible
Exposure Violations, pages III-1 through III-6; and Chapter IV, Recommended
Grouping and Classification of Violations, pages IV-1 through
IV-15.
E. Background. A decision was made at the time the FOM was revised to incorporate all policies and procedures of a nontechnical nature into that manual. When FOM was published, numerous changes were made to existing health policy. These changes made the procedural sections of the instruction obsolete. To avoid confusion for directives users, it has become
OSHA Instruction CPL 2-2.31 CH-1 JUN 3 1985 Office of General Industry Compliance Assistance
- necessary to remove inapplicable sections from the instruction. The
remainder of the instruction is still in effect until the directive has been
totally revised and reprinted at a later date.
John B. Miles, Jr., Director Directorate of Field Operations
DISTRIBUTION: National, Regional and Area Offices Compliance Officers State Designees NIOSH Regional Program Directors 7 (c) (1) Project Managers
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
A. Purpose. This chapter supplements Chapter 1, E., of this manual by showing an example of the sort of information which may be obtained during the walkaround.
B. Scope.
- 1. This chapter presents the information obtained and the plant
layout sketch made during a hypothetical walkaround to evaluate an employer's
monitoring program in a picking area. The layout sketch is Figure V-1 of
this manual, and frequent references will be made to it in this
chapter.
- 2. This information will also serve to develop an OSHA sampling
strategy, if necessary, and to evaluate the employer's compliance
program.
- 3. The information content obtained during an actual walkaround
may vary greatly from that.shown here. The professional opinion of the OSHA
industrial hygienist conducting the inspection will thus play an important
role.
- NOTE: An industrial hygienist who is very familiar with textile
operations may not need to document this information during the walkaround,
hut may wish to do it during the sampling portion of the
inspection.
C. Picking Area. The hypothetical picking room is located on the west end of the second floor of the building. It is separated by a wall from the carding room, but the doorway between the two rooms is usually open. The floor space of the room is approximately 40 feet by 55 feet. (See Figure V-1.)
D. Picking Personnel.
- 1. A single supervisor has responsibility for both the picking and
carding areas. The supervisor spends about 2 hours per day in the picking
room.
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- 2. Four employees work in the picking room:
- a. Two of these employees function as picker
operators.
E. Picking Operations. There are five different types of machinery operations that go on in the picking room.
- 1. The Fiber Collection Hopper and Picker-Feeder Conveyer. Fibers
are blown pneumatically through ducts from the opening room and into a
feeder-hopper located in the picker room.
- a. Normally, according to both a management representative and
the picker operator, the feeder-hopper and picker-feeder conveyer do not
require operator attention.
- b. Occasionally fibers will become clogged or trapped at
various locations along this process flow, and it is necessary for one of the
picker operators or other employees to work on the feeder line to free the
clogged fibers. These intermittent work operations may occur 5 to 10 times
during each work shift.
- c. Tending to the feeder line is usually done by one or both
of the picker operators, unless the problem is major and they require
assistance. About 5 minutes per day per operator is spent at this
task.
- 2. Pickers.
- a. There are six pickers in this area- Since the pickers are
fed automatically by the feeder conveyer system, the operator's primary
responsibility is to doff the pickers.
- b. The two picker operators usually work as a team and remove
the laps from the end of the pickers, weigh them on a balance, and then place
them onto racks for intermediate storage and transport to the card
room.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- c. The picker operators have some free time when they are not
required to be involved in the actual doffing operation. During this time
the operators usually position themselves out in front of the pickers where
they can observe their operation. This is illustrated as "X1" and "X2" on
Figure V-1.
- d. Both operators also spend some time cleaning around the
machine.. The areas covered by the picker operators are designated by
crosshatching on Figure V-1.
- 3. Garnetting of Drawing and Roving Waste.
- a. One operator is responsible for the operation of the
garnett. (Note that this plant is unusual in that it has a garnett in the
yarn manufacturing area.) The operator spends most of the time taking sliver
or roving out of transport baskets and loading it onto the input conveyer to
the garnett. This is illustrated as "X3" in Figure V-1.
- b. The garnett operator is also responsible for sending the
garnetted fibers back to the opening room via a vacuum tube located in the
opening room.
- (1) The garnett operator wheels a large box, in which the
garnetted fibers are collected, over to the area of the card room where this
vacuum tube opening is located.
- (2) He then removes one side of the large box so that the
fibers either fall or can be raked onto the floor.
- (3) Using the broomstick-like pole, the fibers are then
poked up to the entrance of the vacuum tube, where they are sucked back to
the opening room.
- c. The garnett operator thus spends about 4 to 6 hours of his
work shift feeding the garnetted fibers back to the opening room, and the
rest of the time cleaning up the general area of the garnett
machine.
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- 4. Reworkable Card Waste Hopper.
- a. The card room employee responsible for card stripping
usually brings baskets of reworkable card waste into the picker room and
dumps it into the feed hopper.
- b. The picker operators then turn the hopper mechanism on and
off to feed various amounts of reworkable waste into the picker process feed
line.
- c. This reworkable waste feed hopper does not have an employee
tending it on a continuous basis. It may, however, be a source of dust in the
picking room.
- 5. Dust Control. Despite enclosures and hoods that have been
instituted, the picking area is visibly dusty. Along the feed conveyer, the
doors of the enclosure are often left open. The dust control system is
installed on the pickers as follows:
- a. Various hoods and collection devices over the pickers and
the garnett collect dust and blow it into a filter room.
- b. The air cleansing system contains a large cylindrical
filter through which the air from the local ventilation system must pass,
filtering out the dust before the air is returned to the room.
- c. Two or three times a day the picker room mechanic sweeps up
air cleaner waste that is dumped onto the floor, puts it into a basket, and
transports it to the vacuum collection tube (located in the carding room)
leading to the opening room.
- d. At the vacuum collection tube the waste materials are
dumped on the floor and swept into the vacuum tube inlet to send the waste
particles and fibers back to the opening room.
- e. This waste fiber is used in the batting that is used for
mattress manufacturing. The mechanic has a high potential for dust exposure
while
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- gathering this waste and sending it back to the opening room
by sweeping it into the vacuum tube opening.
F. Shift Work. The picking room normally works only one full shift, although it occasionally works 4 hours on the second shift. Normal work shift hours are 7:30 a.m. until 3:50 p.m. The pickers are often shut down for 30 to 60 minutes for lunch, which starts at about 10:30 or 11:00 a.m. Generally, the garnett is shut down while the operator goes to lunch.
G. Electrical Outlets. There are six electrical outlets located in the picker room, which are adequate to allow sampling of this area.
H. Employer's Measurement Results. The employer used six vertical elutricators at the locations shown in Figure V-1 by . Employee exposure was determined by averaging six measurements, and assuming that all persons in the packing room had the same exposure. The following narrative need not accompany the case file, but is included here for the sake of example. The case file should contain copies of the employer's records.
- 1. Results of the employer's exposure data were as follows:
- April 22, 1980 Micrograms/Cubic Meter
- (Name), picker operator 1 377
- (Name), picker operator 2 377
- (Name), picker mechanic 377
- (Name), garnett operator 377
- (Name), foreman, picker/card 328
- October 30, 1980
- (Name), picker operator 1 331
- (Name), picker operator 2 331
- (Name), picker mechanic 331
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- October 30, 1980 Micrograms/Cubic Meter
- (Name), garnett operator 331
- (Name), foreman, picker/card 280
- 2. Because it did not seem reasonable that four workers should
have the same exposure, the industrial hygienist obtained a copy of the raw
data as follows:
- DATE Sample Location Concentration
- 4/22/80 A 522
- 4/22/80 B 296
- 4/22/80 C 40
- 4/22/80 C 406
- 4/22/80 D 353
- 4/22/80 E 300
- 4/22/80 F 389
- 10/30/80 A 497
- 10/30/80 B 315
- 10/30/80 C 425
- 10/30/80 D 324
- 10/30/80 E 205
- 10/30/80 F 225
- 3. Analysis of the employer's data would show the following:
- (a) The values of the raw data are reasonable for a poorly
controlled picking room. The range of values is also
reasonable.
- (b) Since some of the employees do not spend any time where
some of the samplers are located,
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- (1) For the picker operators, locations B, C and D should be
averaged. The picker operator's exposure would thus be:
- 4/22/80 352
- 10/30/80 354
- (2) Location E is not useful. It should be moved to the vacuum
opening.
- (3) For the garnett operator, the exposure should be
time-weighted: 7 hours at location A, and 1 hour at the new location E (near
the vacuum opening).
- (4) The mechanic's exposure should be calculated from all six
locations. /
- (5) The foreman's exposure should be time-weighted for time
spent in the card room. The exposure for the picking room would be 2 hours
at the average of all six locations.
I. Air Currents. The only air currents detected were inward movements from the cleaner card room. Arrows on Figure V-1 show the air flow. Additional ventilation information would be obtained during the sampling portion of the inspection.
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
A. Purpose. This chapter presents several examples of sampling strategies developed for an inspection of a hypothetical textile mill.
B. Scope. These examples are only intended to demonstrate possible OSHA sampling strategies that will make the best use of OSHA resources while accomplishing the inspection goals. Other strategies that may be equally effective could be chosen. In any case, the examples will give only an idea of the strategy to develop. Professional judgment will be necessary to develop strategies for actual field situations. NOTE: It should be emphasized that these strategies are developed for OSHA compliance purposes only, and do not necessarily reflect the employer's sampling strategy.
C. Picking Area. This is the sampling strategy for the hypothetical situation described in Chapter V of this manual.
- 1. The two picker operators can easily be sampled with five
vertical elutriators, located within the cross-hatched section of Figure V-1.
The duties of these employees meet all the sampling criteria found in
Chapter I of this manual.
- 2. Unlike most picking operations, these picking operators work as
a team. Their exposure would therefore be the same. The sample results
are:
- Concentration Location Micrograms/Cubic
Meter
- #1 296 #2 372 #4
315 #5 355
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- 3. To calculate the exposure during the time spent in the picking
area, find the arithmetic average of the five sample results. The exposure
would be 296 + 372 + 406 + 315 or 349 micrograms per cubic meter.
______________________
- 5 4. To calculate the 8-hour TWA exposure, the time spent away
from the picking area must be considered. In this example, the only time
spent away from the area is one-half hour spent eating lunch in a lunch room
equipped with an air filtration system. Hence, we assume no exposure to
cotton dust during this period. Also in this example the sampling duration
was 6 1/2 hours, which, based upon professional judgment, provided results
that were representative of the 7 1/2 hour TWA exposure in the picking area.
Thus, taking into account the above facts, the 8-hour exposure would be
(349)(7.5) + (0)(0.5) _____________________ = 327 micrograms/cubic
meter.
- 8
- 5. This compares reasonably with the employer's values of 352 and
354 as calculated on page V-8 of this manual.
D. Carding Area.
- 1. Description. The carding area is located on the west end of
the second floor of the old spinning building adjacent to the picker room.
The east end of that same large area is devoted to drawing and roving. The
drawing and roving area is not physically separated from the carding area,
but from a supervisory standpoint the two areas are operated separately and
are served by two different ventilation systems. The dimensions of the room
are approximately 68 feet by 50 feet. Figure VI-1 is a sketch of the carding
area.
- 2. Carding Personnel. Thirteen employees work in the carding
area, in addition to the supervisor, who also has responsibility for
picking.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- a. Two of these 13 employees actually work in and adjacent
room operating a Hollingsworth threadmaster. The threadmaster reworks waste
yarn, separating it into fibers so that it may be utilized in the mattress
manufacturing operation.
- b. Four carding area employees work as card tenders.
- c. Two carding area employees work as card mechanics.
- d. Two carding area employees serve as utility men, filling in
on any jobs where they are needed.
- e. Two carding area employees work as card strippers.
- f. One carding area employee works as a porter, doing clean-up
work.
- 3. Carding Operations.
- a. Card Tenders. There are 134 cards in the carding area. Each
card tender tends approximately 34 cards, which amount to two rows of
cards.
- (1) The card tender places the laps from the picker room on
the feed end of the card and doffs the cans of sliver from the doffer's side
of the cards.
- (2) Each card must be doffer about every 3 hours. The
doffing operation takes just a few minutes, but the 34 cards in the card
tender's control are ramdomly doffed as required.
- (3) The card tender has time between the doffing operations
to clean around the machines and to blow-down the machines, a process which
is done once each shift. Typically, the blow-down operation is done shortly
after lunch break.
- (4) The card tender is responsible for blowing down the
machines and leaning up on the doffer side of the machines. The hatchmarks
on Figure VI-1 indicate the working area of one card
tender.
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- b. Card Strippers. Dust and lint collection systems are
installed on all of the cards, and the collected dust and lint from each row
of cards goes to Pneumafil collection houses.
- (1) One of the two card strippers is responsible for
cleaning these Pneumafil collection houses. This operation is done once each
shift, and usually is done the first thing in the
morning.
- (2) The other card stripper is responsible for cleaning the
waste out from under the cards. The waste from the front of the card usually
is cleaned once each shift. Usually, this operation is done the first thing
in the morning, and completed by 10:00 to 10:30 a.m. The card stripper uses
a rake-like device to rake the waste out from under the cards, puts it into a
basket, and later in the day, sends the waste through vacuum collection ducts
back to the opening room.
- (3) During the rest of the day both card strippers do
cleaning on the cards. Both card strippers have the possibility of very high
dust exposure when they are cleaning the waste or collecting the waste from
the cards, or when they are sweeping it into the vacuum collection duct for
transport to the opening room.
- c. Card Mechanics and Utility Operators. The card mechanics
and utility operators work throughout the card room and have no special
station assignment. Their exposure varies dramatically from day to
day.
- d. Porter. The porter is responsible for cleaning the
bathrooms and the back aisles of the card room. Exposure varies considerably
depending on personal work practices.
- e. Electrical Outlets. There are only eight electrical
outlets in the card room. It may prove to be quite time-consuming to install
temporary wiring cords from these outlets to
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- the areas where cotton dust sampling should be done to
properly evaluate employee exposure. Because of the large size of the room,
and the large area over which the employees move during their work shift, it
will be necessary to run some temporary wiring more than 100 feet depending
upon the sampling location. The location of the electrical outlets are shown
as E Figure VI-1.
- 4. Sampling Strategy.
- a. Employee Selection.
- (1) Out of 11 employees in the carding area, only 4 have
designated work areas. For areas cover large sections of the area. Most of
the other employees duties that take them throughout the
area.
- (2) It will be most advantageous to sample the card tender.
Because the carding area is large, only one tender could be sampled with
five vertical elutriators.
- b. Location Selection. The location selected is adjacent to
the drawing area and near the electrical outlets. The vertical elutriators
are scattered in the carding area worked by one card tender. The sampling
locations are shown on Figure VI-1.
- c. Exposure Calculations. The card tender's exposure is
calculated by arithmetically averaging the five vertical elutriator sample
results.
- d. Other Employees.
- (1) Often, it will be difficult for OSHA to the exposure of
employees who throughout large areas of the plant. The employer, however,
could easily move
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- the vertical elutriators throughout the plant from day
to day to measure these employees' exposure.
- (2) However, it has been noted that the card stripper
mechanics and porter could have high exposure levels that depend upon their
duties and work practices. To ensure protection for these
workers:
- (a) Review the employer's data to determine
exposures.
- (b) If the written work practice program required under
29 CFR 1910.1043(e) (3) (ii)(f) has been prepared, review it carefully. It
must be prepared no later than March 27, 1981.
- (c) While sampling, as one industrial hygienist
monitors the instruments and the carding area being sampled, another should
observe the duties and work practices of the
workers.
- (d) Evaluate this information to determine if there is
compliance with the work practices required under 29 CFR
1910.1043(g).
- (e) Based upon the observations, determine if the
written work practice program is adequate.
E. Drawing and Roving Areas.
- 1. Description. The drawing and roving areas are located adjacent
to the card room. The drawing frames are separated from the carding machines
by an aisleway, but there is no physical barrier. Neither is there a
physical barrier, other than an aisleway, separating drawing frames from the
roving frames. These areas are approximately 70 feet by 76 feet in extent.
They are illustrated in Figure VI-2.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- 2. Personnel and Operations.
- a. Drawing. The mill has 28 drawing frames, each with
two-position delivery. The frames are located in two long rows, extending
from one side of the room to the other.
- (1) Three employees work as frame tenders on these
machines. One employee tends 9 machines on the first row, another tends 10 on
the second row, and the third handles all of the remaining drawing
frames.
- (2) A second shift is conducted in the drawing area with
two employees, each running 9 or 10 frames. Most of the blow down and major
cleaning is conducted on the second shift.
- b. Roving. The mill has 12 roving machines (or slubbers).
One roving machine tender can operate two machines. A second shift is
conducted in the roving area, and most of the blow down and major cleaning is
conducted on the second shift.
- 3. Electrical Outlets. There are 14 electrical outlets in the
roving area, located on roof support pillars. These should prove sufficient
for OSHA purposes. However, some cords will have to be run for distances up
to 50 feet.
- 4. Sampling Strategy.
- a. Samplers are so arranged in the roving and drawing areas as
to permit detailed sampling that accurately establishes individual personal
exposure.
- b. Sampler locations are selected to sample in retail the
exposure of one drawing frame tender and one roving frame
tender.
- c. The layout drawing for these areas, Figure VI-2, shows the
vertical elutriator sampling locations. Employee exposure is determined for
the operators of the machines marked by cross-hatching.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- d. Five vertical elutriators are used to sample the
drawing machine operator, and five for the roving machine
operator.
- e. The inspection team consisting of two industrial
hygienists spends 2 days sampling, each day concentrating on an area of the
plant.
- 5. Exposure Calculations.
- a. Drawing. The exposure of the drawing machine operator
is calculated by averaging the five samples located in the employee working
area shown in Figure VI-2.
- b. Roving. The exposure of the roving machine operator is
calculated by averaging the five samples located in the employee working area
shown in Figure VI-2.
F. Spinning.
- 1. Description. The spinning room is one of the largest areas of
the textile mill.
- a. It includes the spinning machinery, and also winding
machinery which is located on one side of the room.
- b. The room contains 76 spinning frames, each with
approximately 200 spindles, and 15 semiautomatic winding
machines.
- c. The spinning and winding areas are separated by a fairly
wide aisleway, hut the same air handling and air conditioning system services
the entire area.
- d. One small area in the corner of this room is devoted to a
waste reworking area where waste roving and yarn is torn apart to reclaim the
fibers for reuse.
- e. Figure VI-3 is a sketch of the spinning and winding
areas.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- 2. Personnel and Operations.
- a. Approximately 35 people work in the spinning frame area of
the mill. The 76 spinning frames are divided into two areas, each managed by
a foreman, and each foreman has approximately 15 employees under his
direction.
- b. The employees are responsible for spinning, doffing
maintenance and cleaning.
- c. The mill produces three different size yarns: 7's cotton
count, 9.5's cotton count, and 11.5's cotton count.
- d. When producing the coarser yarn (7's cotton count), a
spinner usually is assigned to operate 6 spinning frames and a doffer to
handle 12 spinning frames. When producing this coarser yarn, the frames
generally must be doffed three times each shift.
- e. When producing the finer yarn (9.5's and 11.5's cotton
count), a spinner usually is assigned to operate 5 spinning frames and a
doffer to handle 10 spinning frames. In producing the finer yarns, the
frames typically must be doffed twice each shift.
- f. The hypothetical spinning mill is considerably short on
employees. Usually, a number of frames are not operating because of an
operator shortage for that particular day. Utility men and maintenance men
are often used as spinners or doffers to operate a full job or half a job, in
an effort to keep as many frames operating as possible.
- 3. Electrical Outlets. There are four 110 volt electrical outlets
in the spinning area, as shown in Figure VI-3.
- 4. Sampling Strategy.
- a. The emphasis in spinning area sampling will be on
attempting to collect a sufficient number of samples to evaluate the exposure
of two spinners and one doffer working on frames.
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- b. Vertical elutriators are placed in the aisles where the
workers spend their time. Since the operators move from one machine to the
next, it is necessary to use several vertical elutriators to define the
exposures. In this case, five elutriators are used.
- 5. Exposure Calculations. The exposure of one spinner is
calculated by averaging samples from locations A, B and C, as shown on Figure
VI-3. The exposure of the second spinner is calculated by the average of C,
D and E. The exposure of the doffer is calculated by averaging all five
samples.
G. Winding.
- 1. Description. This is the same as for the spinning area, given
in paragraph F.1.
- 2. Personnel and Operations.
- a. The winding area has approximately 15 winding frames and 20
employees. One foreman is responsible for all of the work in the winding
area.
- b. Each winding machine requires almost constant attention of
an operator. The winding machines are semiautomatic, and the operator sits
at a fixed location, places yarn bobbins in a magazine and removes yarn
packages from a traveling conveyer.
- c. The operator spends approximately 7 1/2 hours at this fixed
location, and one-half hour correcting problems up and down the winding frame
line.
- 3. Waste Reclaiming Area. The small waste reclaiming area located
on the corner of this large room is actually an operation which is the
responsibility of the card room supervisor.
- a. The equipment in this area consists of feeder hoppers and
two specially equipped cards.
- b. Employees manually feed roving and yarn waste into the
hoppers, remove the stock, and put it
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- in boxes for transport back into the process line. Two
employees typically work in this area.
- 4. Sampling Strategy.
- a. In the winding area, the operators remain relatively
stationary. Vertical elutriators are placed near the job
location.
- b. For this example, three positions are measured at the
locations shown on Figure VI-3 as "F", "G" and "H".
- c. To measure the concentration while the operator tends to
correcting problems down the line, two elutriators are placed in the
aisleways near the machine at "I" and "J" on Figure VI-3.
- d. It was decided that no samples would be collected in the
waste reclaiming area during this hypothetical inspection, because the
winding area seemed more important.
- NOTE: A different sampling strategy could have been
developed, using only three vertical elutriators in the winding area and two
elutriators in the waste reclaiming area.
- 5. Exposure Calculations. For the winding operators, exposure
would be time-weighted, as follows:
Exposure of 1st winder =
- (7.0)(Sample F) + (O.5)(Sample I) + (0.5 lunchtime)(O)
______________________________________________________
Exposure of 2nd winder =
- (7.0)(Sample H) + (O.5)(Sample I + J) + (0.5 lunchtime)(O)
__________________________________________________________
- __________________________________________________________
Exposure of 3rd winder=
- (7.0)(Sample G) + (O.5)(Sample J) + (0.5 lunchtime)(O)
______________________________________________________
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
A. General Operation Procedures. In general, follow the procedures for sampling with the vertical elutriator, and the procedures for analyzing the samples, which are given in Appendix A of 29 CFR 1910.1043. Specific exceptions and additions are presented in this chapter. In the interest of continuity, a few of the sampling and analytical procedures described Appendix A are repeated.
B. Use of Professional Judgment. These procedures are good operating practices, but not the only procedures that will provide correct results. Minor deviations may not substantially affect the sampling results.
C. Instrumentation. Compliance samples shall be collected with the vertical elutriators (VE's), as provided in 29 CFR 1910.1043(d)(1)(ii) and elsewhere in the standard. OSHA has two types of vertical elutriators: one has a constant flow regulating device; the other maintains constant flow by an orifice. Both are equipped with rotameters. Most of the instruments are electrically powered, but battery powered ones are available.
D. Flow Rate. Collect samples at 7.4 + G.2 liters per minute.
E. Filter Cassettes. The filter cassettes for vertical elutriator sampling are 3-piece and 37 mm diameter. The filters are 5 micron pore size, 37 mm diameter, and made of polyvinyl chloride.
F. Preparing for Sampling.
- 1. Obtaining Instruments. Not all Area Offices will be equipped
with vertical elutriators. It may be necessary to borrow elutriators,
through the Regional Office, from another Area Office.
- 2. Number of Instruments. For a typical textile mill, plan on
taking seven vertical elutriators and four personal pumps on an
inspection.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- 3. Transportation. Four vertical elutriators will fit into a
compact size station wagon.
- 4. Preweighed Cassettes. Approximately 20 cassettes containing
preweighed filters must be brought to the inspection for each sampling day.
This will provide a sufficient number of cassettes and filters for operating
5 VE's and 2 personal pumps, and will supply the necessary blanks. Use the
following procedures:
- a. Weigh the filters according to the IHFOM, Chapter X, page
6. Do not, however, desiccate the filters. Report three significant
figures.
- b. The same person who preweighs the filter should also
post-weigh the filter, using the same balance if feasible.
- c. In addition to filter cassettes for sampling, approximately
10 percent of all filter cassettes shall be control blanks.
- (1) Do not use these for sampling, but remove the caps at
the worksite and immediately put them back in place.
- (2) Post-weigh the filters after returning to the
office.
- (4) Average the weight changes of the blanks for the same
area and shift.
- (5) If the average weight change is positive--i.e., the
average weights of the blanks increased--subtract this average weight change
from the weights of the cotton dust samples; if the average weight change is
negative, add this average weight change to the weights of the cotton dust
samples.
G. Calibration Check.
- 1. Check the flow-rate calibration setting for 7.4 liters per
minute using a 2- or 3-liter burette.
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- 2. Perform the calibration check in the Area Office before the
instruments are taken to the field, and when they are brought back after use.
However, the vertical elutriator should not be used more than 2 weeks
without a calibration check.
- 3. The following is the calibration check procedure:
- a. Set up the vertical elutriator as if to sample with filter
and cassette.
- b. Secure the rubber stopper made for calibration checks into
the elutriator body inlet.
- c. Wet the inside of the burette.
- d. Set up the burette in the ring stand.
- e. Connect the tubing between the elutriator and the
burette.
- f. Allow the elutriator to run 1 minute before taking
readings.
- g. Take readings by timing the bubble with a stopwatch.
- h. Take three readings and average them.
i. Record the data. H. Electrical Power. Refer to Chapter I, D. 3. through D. 8., of this manual.
I. Setting up the Elutriators in the Field.
- 1. Because of space requirements, vertical elutriators are
transported disassembled. At the plant, reassemble the vertical elutriator
where it is convenient. Assembly time is approximately 10 minutes per
elutriator. If space can be provided by the employer, the vertical
elutriators should be assembled at a central location and then carried to the
sampling location. It is possible to carry the vertical elutriator
throughout the plant while it is assembled.
OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of Compliance Programming
- 2. For practical purposes, one person can carry only one vertical
elutriator at a time. At the plant, the management may provide a hand cart
to convey the instruments to the worksite.
- 3. Each industrial hygienist should know the sampling locations,
and should place the vertical elutriator as designated on the plant layout
sketch. All OSHA industrial hygienists at the plant must assist in setting
up the elutriators.
- 4. If the vertical elutriator is carried while assembled, all
parts must be rigidly secured. The filter must not be in the elutriator
while it is being carried. The filter should be inserted after the vertical
elutriator has been located at the sampling site.
- 5. If the employer can provide the space, the assembled vertical
elutriators can be stored overnight in the plant (rather than disassembling
the instruments each evening and putting them in the station wagon). Before
transporting the elutriator at the end of the day, remove the filter and
replace the cover caps.
J. Sampling.
- 1. After locating the elutriator and providing electrical power,
run a clean, lint-free cloth through the elutriator body to remove any dust
from the elutriator that may have accumulated since the last
cleaning.
- 2. Obtain one of the three-piece cassettes. The cassettes must,
of course, already have filters in them. Remove the top section and the
small plug from the bottom section. Insert the cassette into the opening at
the top of the vertical elutriator as is done for collecting a sample.
Instead of collecting a sample, however, merely run the sampler 2 or 3
minutes, to assure that any extraneous dust that may have been left in the
elutriator after the cleaning is flushed out.
- 3. Stop the sampler. Remove this cassette and insert another
cassette for collecting the sample. Since the cassettes can be loosened by
vibration, the cassette must be inserted securely and taped to the
- OSHA Instruction CPL 2-2.31 JAN 16 1981 Office of
Compliance Programming
- vertical elutriator body using electrical tape to prevent
leakage during sampling.
- 4. Secure the tubing to the pipe with tape, especially at the top
where the weight of the tubing may cause a pinch at the cassette
connection.
- 5. The following is a rough guide for changing filters during the
sampling shift, depending upon the dust concentration.
- Number of . Dust Concentration Changes
Filters/Shift
- 6. When changing the filter, the vertical elutriator pump must be
turned off because the filter may be ruptured while working under negative
pressure.
- 7. The filter can be changed simply by tilting the vertical
elutriator body. For convenience, one end of the tape for sealing the
cassette can be stuck to the body of the vertical elutriator so that it will
be handy to reach while holding the vertical elutriator in the tilted
position.
- 8. Make checks on the operation of the vertical elutriator every
hour. When checking the operation, lock to see if the cassette is taped down
tightly, if all tubing is connected, and if the rotameter designates the
proper flow.
K. Cleaning the Vertical Elutriator.
- 1. Clean the inside of the vertical elutriator body with a damp
cloth each day after sampling.
- 2. Use a cloth or a brush to clean the dust from the pump motor
and body each day after sampling.