Comments and Suggestions for Revision of W505 Control

Comments and Suggestions for Revision of W505 Control

Administrative Controls Section

1.Section 9.5 first sentence has: “from slowing increasing rates of leaks…” – perhaps it should be slowly increasing rates, or just increasing rates….

2.Section 9.9 on Use of Creams and Lotions – I believe the term barrier cream is no longer used by most lotion manufacturers. They now are called pre-work creams. I also do not think they should even be considered as alternatives to proper elastomeric gloves. In my view their only purpose is to help remove materials from the skin during hand washing after or during work, and as a skin moisturizer. The whole section needs a re-write IMHO. Only the last sentence in that section has it correct: “It is generally considered that barrier creams and lotions are not an effective replacement for correctly selected and properly worn gloves.” That sentence should be the first sentence of this section.

3.Section 9.14 – last paragraph should state that workers and supervisors actively participate in the development, implementation and training of not only administrative controls but also engineering controls and use of personal protective equipment.

4.Section 9.15 – 1st paragraph – while engineering controls may not be feasible during emergencies, certainly emergency procedures (administrative controls) along with PPE are needed – so “sole reliance is placed on PPE” is not correct. 2nd paragraph, 1st sentence – need to insert “be” in after may.

5.Section 10 – Practical Applications of Control Strategies, page 240. Does phthalic anhydride produce fume? I thought it sublimates to form a gas. Fumes as you know are typically formed as metal oxides as a result of combustion. This fume term is used throughout the example.

6.Section 10, page 252 – the statement that “an emissions based maintenance program has been shown …to result in improved fleet availability, increased power and….lower exhaust emissions” seems to conflict with one of the answers to the Mock Practice Exam questions regarding CO and forklifts (Question #10) which asks which the most appropriate control of CO. While replacement of the fleet of LPG forklifts would be IDEAL – the appropriate control would be regular maintenance, which is consistent with the verbage on pg 252.

7.Mock Exam Questions:

#3: I think “most common” is better than commonest.

#13: In the design of a plant….

#20: The term Lip extraction may not translate easily – we don’t use that term in the US. I think you are describing a slot vent.

#31: Answer a) is 0.3-0.5 m/s – I think there is general consensus that capture velocity should be a minimum of 0.5 m/s for control of gases and vapors. I would choose answer b: (0.5 – 1.0 m/s ) to address cross-drafts and other turbulence issues.

#55: Respiratory protective devices are designed…

8.Finally, I heard from our students that there was not a single administrative control question on the final exam! So much for the entire morning lesson!