Cal

1. Cal/OSHA and DHS �Flavor Industry Safety and Health Evaluation Program� (FISHEP) Kelly Howard, CIH Senior Industrial Hygienist Cal/OSHA Consultation Service Division of Occupational Safety and Health

2. FISHEP 1st case of BO in 2004; 2nd in 2006 Inspections, citations, and special orders FISHEP initiated in early 2005 Additional 28 companies identified as formulators No popcorn makers Consultation or Enforcement DHS HESIS fact sheet

3. Food Flavoring Couple thousand food �production� companies 28 food �flavoring� companies Flavors are used in everything Diacetyl (2,3-butanedione) is a natural ingredient in beer, milk, bay oil, and other foods

4. What is a flavor? Break apart a strawberry and you get 400-500 ingredients Reverse engineer it with 20-30 to make up the core �strawberry� flavor, such as:

5. Where does diacetyl come in? Butter Diacetyl is what imparts butter flavor, along with other things, like acetoin �creaminess� Cream strawberry flavor �Cheese cake� Butterscotch Chocolate

6. FISHEP Focus Onsite evaluations at all 28 IIPP HazCom Respirator Protection Annual ingredient use Employee ingredient exposure assessment Ventilation Medical screening Follow-up

7. Formulation Process Hundreds of ingredients Never the same thing two days in a row High variability in tasks in any given day Production vs. Batch process

8. Formulation Process 4 - 40 ingredients 20 - 180 minutes <1 lb to 2000 lbs of diacetyl per year A couple of ounces to 50 lbs of diacetyl in a batch 1-2 flavors per employee in a week, to 4-5 flavors per employee per day Powder vs. Liquid product Batch ticket developed Collect ingredients Weight/mix Transfer Ethanol PGA Water Package

9. Exposure Assessment Issues Adequate minimum quantification levels Personal acute, chronic and area samples equally important Limited direct-read capabilities Big-time interferences

10. Issues High degree of unknown �FEMA Priority� ingredients >2000 ingredients 34 high priority 14 with PELs Additional 2 with RELs Additional 4 with WEELs 42% without any known safe exposure levels Additive/synergistic effects?

11. Issues Use of markers to estimate overall exposures Acetoin Acetic acid Benzaldehyde Acetaldehyde Acetoin and Diacetyl very similar in molecular structure. Acetoin has one less double bond, and one more hydrogen. Acetoin and Diacetyl very similar in molecular structure. Acetoin has one less double bond, and one more hydrogen.

12. Issues Respirators Employees not clean shaven Subjective fit-testing Insufficient filter change schedules Hazard communication �been doing this for years� Employee medical removal What is �removal�? Definitive vs. ambiguous measures

13. Typical Diacetyl Exposure Levels Direct reading peaks: 107-590 PPM OBZ STEL Liquids: <0.13-38.6 PPM Powders: 0.91-3.8 PPM OBZ Process Averages Liquids: <0.017-8 PPM Powders: 1.1-5 PPM

14. FISHEP Exposure Control Respirators Full-face, quantitative fit-test Filter change-out schedule Work-practices Heating Hot water Compressed air Enclosure