Ethylene oxide emergency plans and employee alerts

January 13, 1987
Mr. George L. Notarianni
Gas Monitoring & Analysis, Inc.
[Recipient address omitted]
Dear Mr. Notarianni:
This is in response to your letter of November 26 requesting clarification of 29 CFR 1910.1047 - Occupational Exposure to Ethylene Oxide.
The Occupational Safety and Health Administration (OSHA) defines an emergency situation as "an occurrence such as but not limited to equipment failure, rupture of containers, or failure of control equipment that may result in an unexpected significant release of EtO". Quantities of EtO sufficient to produce acute toxic effects is exposed employees constitute such an emergency.
Section 29 CFR 1910.1047(h)(1) requires written plans for emergency situations to be developed for each workplace where there is a possibility of an emergency. These plans shall be written in accordance with 29 CFR 1910.38 (Employee Emergency Action Plans and [29 CFR 1910.39] Fire Prevention Plans).
Paragraph (h)(2) of the standard requires some method of alerting employees of an emergency promptly. OSHA gives the employer the flexibility to choose any effective method of alerting employees, including communication systems, voice communication system, or a bell or other alarm. If the employer choose to install an emergency alarm system, the system must meet the requirements of 29 CFR 1910.165 (Employee Alarm System). However, it should on mentioned that 29 CFR 1910.165(b)(5) states the following:
"For those employees with 10 or fewer employees in a particular workplace, direct voice communication is an acceptable procedure for sounding the alarm provided all employees can hear the alarm."
Therefore, a sophisticated alarm system might be unnecessary for some facilities such as small hospitals with only one EtO sterilizer.
In response to your specific questions:
Question 1: Does an institution need to install an alarm sensitive down to one ppm PEL?
Answer: At this time, the ethylene oxide standard does not require an institution to install an alarm system sensitive down to one ppm. However, the standard does require monitoring and some method of alerting employees of an emergency.
Question 2: With the proposed court mandated institution of an STEL for EtO, would it be appropriate for an EtO alarm to measure EtO exposure down to the STEL of 10 ppm as originally proposed by OSHA?
~~Answer: The current standard does not include a STEL therefore, at this time it would not be appropriate for an alarm system to measure down to 10 ppm. OSHA is still gathering data to support STEL. This part of the standard is expected to be finished by March 1987.~~
[This document was edited on 02/05/2004 to strike information that no longer reflects current OSHA policy. On April 6, 1988 an excursion limit of 5ppm was published in the Federal Register 53:11414-38 and codified at 1910.1047(c)(2).]
Question 3: If an employer has not complied yet with the provision, are they in violation of the ethylene standard?
Answer: Yes, if an employer has not instituted an effective method of alerting employees they are in violation of the standard.
Please feel free to contact us if further assistance is needed.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

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[Requester letter reproduced on OSHA page; omitted here.]