Oberon Class Submarine Occupational Hygiene Project Final Report

Comment. The authors of this report identify the American Conferenceof Governmental Industrial Hygienists (ACGIH) as a regulator. This isnot entirely correct. In the ACGIH booklet (ACGIH, 2001) listing theTLVs and BEIs, their Policy Statement printed inside the front coverexplicitly states that they are to be used as guides for practicingoccupational hygienist and not as legal standards. Many governmentsworld wide have adopted these TLVs with some differences and havemade them regulatory values, e.g., OSHA PELs in USA, Worksafe (asExposure Standards) referenced by Commonwealth and State OH&Slegislation.iii.iv.Enclosure 3. ‘Hazard Risk Assessment – Aerosol Contamination ofSubmarine Atmospheres’ by A. Spurling from the Submarine ForceElement Group. Dated 17/2/2003.The Collins Class Air Purification Manual (ABR 6105) sets a limit of0.5 mg/m 3 for aerosols. If this value is exceeded then breathingapparatus is required. The philosophy is expressed as ‘can’t discernbetween harmful and non-harmful aerosols in real time, then treat all asharmful’. All submarines (Collins class) have aerosol monitors fitted inthe Main Generator Room. High readings have been obtained onoccasions. Explanations for higher emissions were put forward as wellas steps to reduce high exposures. There is a directive that monitorsmust be on at all times when diesel engines are operating. The HazardRating Index (personnel) is 10 (acceptable with continuous review).Enclosure 4. “MPC Definitions”. No author or date.The definitions agreed upon are consistent with the UK application ofthe terms.a. MPC 90 – if exceeded, reduce below this level within 24 hours.b. MPC 24 – if exceeded, reduce below this level within one hour, andbelow MPC90 within 24 hours.c. MPC 1 hour – a health based emergency level – immediate use ofprotective equipment (EABS, OCCABA) until contaminant level dropsbelow this level then the MPC 24 and MPC 90 guidelines apply.26