Arsenic in bird study skin collection

Genevieve M. LeMoine inquires regarding the handling of skin
collections dusted with arsenic to protect them from pests.
Unfortunately, she is now saddled with a collection that is, at
least in some respects, a toxic waste dump.

Arsenic is a known carcinogen, a very hazardous substance, a
hazardous waste, a high priority toxic pollutant and is an air
pollutant under EPA's Clean Air Act. But, the chances are that most
everyone is aware of its hazards. Perhaps more importantly, it is
reported in the EPA Toxic Substances Control Act Inventory and is
listed on the Community Right to Know List. In addition, the
presence of arsenic in the workplace (i.e., occupational exposure)
likely makes an institution (i.e., the employer) subject to OSHA's
requirements in 29CFR1910.1018(o).

In general, OSHA requires that (1) employers institute a training
program for employees who are either subject to exposure above the
action level (5 micrograms per cubic meter of air, averaged over an
8 hour period) or who may possibly have skin or eye irritation; (2)
that the training be conducted upon initial assignment, with
refresher courses at least quarterly if respirators are used and
annually otherwise; (3) that the employer also inform those
laundering the clothing of individuals working with arsenic; (4)
that a respiratory protection program (with associated training) be
implemented. There's much more to the OSHA standard, but this gives
you a good idea of the training that you are required to provide
when there is the potential (as has been expressed) of occupational
exposure.

A good beginning might be to determine the exposure level of arsenic
at the institution. In fact, these measurements will almost
certainly be essential to establish work practice controls --
methods by which the arsenic exposure can be kept at or below the
PEL (permissible exposure limit--in this case, 10 micrograms per
cubic meter).

A few good do's--post signs in areas where arsenic occurs; label
all storage containers, provide medical exams (that includes
specific screening for arsenic exposure focusing on, I believe, hair
analysis and urinalysis along with a nasal exam and sputum cytology
exam for early detection of lung cancer), provide training in
personal hygiene and sanitation, upon exposure quickly wash with
plenty of water and soap, and provide appropriate protective
equipment and train employees to use it correctly.

One equally good don't--no food, beverage, smoking, or gum in
areas where there is arsenic. Keep your hands out of your mouth,
nose, and eyes (I know, that sounds pretty crude, but important).

In terms of respirators--first your institution MUST have a
respiratory protection plan. Then, in terms of selecting an
appropriate respirator, if the exposure level isn't greater than 100
micrograms per cubic meter (hence, again the need for measurement),
a half-mask, supplied air respirator is probably adequate.

Now, these requirements should indicate that even vacuuming the
collection is no longer a simple option. In fact, it requires a
considerable amount of training. And moreover, the resulting residue
collected by the HEPA filter (which must be used) is a hazardous
waste that must be disposed of through an appropriate disposal firm.

In terms of that issue, Ms. LeMoine should contact her state
hazardous management agency (in this case the Department of
Environmental Protection, Bureau of Oil and Hazardous Materials
Control, I believe). I also strongly recommend reading over the EPA
booklet, Understanding the Small Quantity Generator Hazardous Waste
Rules: A Handbook for Small Business (EPA, Office of Solid Waste and
Emergency Response, EPA/530-SW-86-019).

Moving the collection, since it will involve handling, increased
materials becoming air-borne, and increased exposure, is a real
problem. Clearly bagging the specimens is an option--but once
bagged, unbagging may be an issue and the bagging material itself
will likely be contaminated and if so may be disposed of only as
hazardous waste.

This is a good time to go shopping for an industrial hygienist and a
good contact would be the American Industrial Hygiene Association,
which can be reached at 703-849-8888. They can make referrals for an
individual with the appropriate training in your particular area. I
strongly recommend spending the money to protect your staff and
patrons. Best,

Michael Trinkley, Ph.D.
Director
Chicora Foundation, Inc.
PO Box 8664
Columbia, SC  29202-8664
803-787-6910

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                  Conservation DistList Instance 11:47
                Distributed: Tuesday, November 25, 1997
                       Message Id: cdl-11-47-001
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