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OSHA 1910.1044AppB

DBCP technical guidelines

Subpart Z

27 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1044 App B, how can I identify DBCP in the workplace?

DBCP is a dense yellow or amber liquid with a pungent odor at high concentrations, and any detectable odor indicates overexposure. The Substance Technical Guidelines for DBCP in 1910.1044 App B list synonyms (for example, Nemagon, Nemafume, Fumazone), the chemical formula (C3H5Br2Cl), and key physical traits you can use for identification.

Under 1910.1044 App B, what are the key physical properties of DBCP relevant to exposure control?

DBCP boils at about 195°C (383°F), melts at about 6°C (43°F), has a specific gravity of 2.093, low vapor pressure at 20°C (0.8 mm Hg), and is soluble in water up to about 1000 ppm. These properties affect how DBCP behaves in spills, ventilation, and sampling—see the physical data in 1910.1044 App B.

Under 1910.1044 App B and 1910.106, how is liquid DBCP classified for fire safety?

Liquid DBCP is classified as a Category 4 flammable liquid for purposes of complying with 1910.106. That means it is a lower-risk flammable liquid but still requires appropriate storage, handling, and control of ignition sources as described in 1910.106 and the DBCP guideline in 1910.1044 App B.

Under 1910.1044 App B and 1910.157, what fire extinguisher class is appropriate for DBCP hazards?

DBCP is classified as a Class B fire hazard for purposes of complying with 1910.157, so you should provide fire extinguishers and extinguishing procedures suitable for flammable liquids (Class B). See the DBCP fire hazard classification in 1910.1044 App B for additional guidance.

Under 1910.1044 App B and 1910.309, how should electrical equipment be classified where DBCP is present?

Areas where DBCP is present should be treated as Class I, Group D hazardous locations for electrical equipment under 1910.309. The DBCP guideline explicitly states this classification to guide selection and installation of electrically powered equipment in DBCP areas; follow 1910.309 requirements for hazardous locations.

Under 1910.1044 App B, are ignition sources allowed where DBCP is present?

No—sources of ignition are prohibited where DBCP presents a fire or explosion hazard. The DBCP guideline in 1910.1044 App B explicitly states that ignition sources must be controlled or eliminated in such areas.

Under 1910.1044 App B, what metals should not be used with DBCP because of incompatibility?

DBCP reacts with chemically active metals such as aluminum, magnesium, and tin alloys, so you should avoid storing or using containers, piping, or equipment made from those alloys with DBCP. The incompatibilities are specified in 1910.1044 App B.

Under 1910.1044 App B, what hazardous gases can be produced if DBCP burns?

If DBCP is involved in a fire, it can produce toxic gases and vapors such as hydrogen bromide (HBr), hydrogen chloride (HCl), and carbon monoxide, so firefighters and responders must use appropriate respiratory protection and avoid inhalation. See the decomposition products discussion in 1910.1044 App B.

Under 1910.1044 App B, what immediate steps must be taken if DBCP is spilled?

Immediately evacuate the area and re-enter only after thorough ventilation; then ventilate, collect liquid DBCP for reclamation or absorb it with paper, vermiculite, dry sand, earth, or similar material. The spill response steps are listed in 1910.1044 App B.

Under 1910.1044 App B, can people without protective equipment enter a spill area before cleanup is complete?

No—persons not wearing protective equipment must be restricted from areas of spills or leaks until cleanup has been completed, as specified in 1910.1044 App B.

Under 1910.1044 App B, what disposal methods are recommended for small amounts of liquid DBCP?

For small quantities of liquid DBCP, absorb it on paper towels, move the contaminated towels to a safe place such as a fume hood, and burn them; alternatively, collect small liquid quantities for reclamation. These waste disposal recommendations are in 1910.1044 App B.

Under 1910.1044 App B, how should large quantities of liquid DBCP be disposed of safely?

Large quantities of liquid DBCP should be reclaimed or atomized in a suitable combustion chamber equipped with an appropriate effluent gas cleaning device; if absorbed and placed in sealed containers, some State-approved sanitary landfills may accept them—follow the specific guidance in 1910.1044 App B and applicable state regulations.

Under 1910.1044 App B, how should air monitoring for DBCP exposure be conducted to determine 8-hour exposures?

Air samples for determining 8-hour average exposure should be taken in the employee's breathing zone and are best collected as a single 8-hour sample or two 4-hour samples; these details are in 1910.1044 App B.

Under 1910.1044 App B, what sampling method and volumes are recommended when using charcoal tubes to measure DBCP?

If petroleum-based charcoal tubes are used, collect a total volume of 10 liters at a flow rate of 50 cc per minute for each tube, and analyze the samples as you would halogenated solvent samples, per 1910.1044 App B.

Under 1910.1044 App B, what accuracy should the chosen DBCP air monitoring method achieve?

The method of measurement should determine the concentration of airborne DBCP at the permissible exposure limit with an accuracy of plus or minus 25 percent, as stated in 1910.1044 App B.

Under 1910.1044 App B, who should perform the evaluation of employee exposures to DBCP?

Employers should assure that the evaluation of employee exposures is performed by a competent industrial hygienist or other technically qualified person, because many duties depend on monitoring results; see 1910.1044 App B.

Under 1910.1044 App B, what personal protective clothing is required to prevent skin contact with DBCP?

Employees must wear impermeable coveralls or similar full-body work clothing, gloves, headcoverings, and workshoes or shoe coverings to prevent any skin contact with DBCP, because it is absorbed through the skin, as explained in 1910.1044 App B.

Under 1910.1044 App B, are standard rubber or neoprene gloves adequate protection against DBCP?

No—standard rubber and neoprene gloves do not offer adequate protection and should not be relied on to keep DBCP off the skin; the guideline warns these materials are insufficient in 1910.1044 App B.

Under 1910.1044 App B, when must splash-proof safety goggles be used?

Employees must wear splash-proof safety goggles wherever there is any possibility of DBCP contacting the eyes, per the protective clothing recommendations in 1910.1044 App B.

Under 1910.1044 App B, what housekeeping methods are unsafe for cleaning up DBCP dust or liquid?

Dry sweeping and the use of compressed air are unsafe for cleaning surfaces with DBCP dust or liquids; instead, use vacuuming with portable or permanent systems that have appropriate exhaust or HEPA/filters, as recommended in 1910.1044 App B.

Under 1910.1044 App B, what requirements apply to vacuum units used to collect DBCP?

Portable vacuum units used to collect DBCP must have their exhaust attached to the general workplace exhaust ventilation or have collection within the vacuum unit equipped with high-efficiency filters or other appropriate means, and such units must be labeled, as described in 1910.1044 App B.

Under 1910.1044 App B, what hygiene facilities and provisions must employers provide where DBCP is used?

Employers must provide adequate washing facilities with hot and cold water, suitable cleansing agents to remove DBCP from skin, and change/dressing rooms with individual clothes storage to prevent contamination of street clothes; contaminated protective clothing must be stored in closed containers for cleaning or disposal, per 1910.1044 App B.

Under 1910.1044 App B, how should DBCP be stored?

Store DBCP in tightly closed containers in a cool, well-ventilated area to minimize hazards and degradation, as recommended in 1910.1044 App B.

Under 1910.1044 App B, when might supplied-air suits or other impervious clothing be necessary for DBCP work?

Supplied-air suits or other impervious clothing may be necessary to prevent skin contact with DBCP in high-exposure operations, and such suits must be selected, used, and maintained under supervision by persons knowledgeable about their limitations, per 1910.1044 App B.

Under 1910.1044 App B, what kinds of operations are most likely to produce DBCP exposure?

Common operations with likely DBCP exposure include its production and formulation into pesticides and fumigants; the guideline lists these typical exposure situations in 1910.1044 App B.

Under 1910.1044 App B, how should contaminated clothing be handled after DBCP exposure?

Contaminated clothing and shoes should be promptly removed, not worn again until completely free of DBCP, and stored in closed containers for cleaning or disposal; defective protective clothing must be repaired or replaced, as directed in 1910.1044 App B.

Under 1910.1044 App B, what special precautions apply because DBCP attacks some rubber materials and coatings?

Because DBCP attacks some rubber materials and coatings, avoid using non-resistant gloves, seals, hoses, or coatings that can degrade; select impermeable materials and inspect PPE and equipment for damage routinely, as noted in 1910.1044 App B.