1. Think like an Enforcement
Officer
Susen Trail, CIH
Occupational Health Enforcement
State of Wisconsin

2. • 6:30AM: Ozone generator on, sign on door
• 6:50AM: Ozone generator timer off.
• 6:55AM: Custodian removes generator
• 7:30AM: Custodian removes sign from door
• Employees in hallway complain of bleach odor
• 7:50AM: employee enters room
• 8:00-8:05AM: employee leaves room, passes
out briefly, taken outside and then by ambulance
to ER
Complaint Report: Ozone Exposure

3. Comparison
EPA and OSHA ozone exposure:
Under 0.05ppm
• sharp irritating odor,
• irritation of eyes,
• dryness of nose and throat,
• and cough.
Above 0.05ppm:
• headache,
• upset stomach, or vomiting,
• pain or tightness in chest,
• shortness of breath,
• tiredness, which may last for
several days to weeks.
Employee symptoms
• Burning in nose and throat and
lungs
• Nausea
• Shortness of breath, sleepiness
• Passed out, after left room
• Persistent SOB
• Reduction in FEV1/FVC measured
7 weeks later

4. Problems:
• Why didn’t the custodian report adverse
health effects?
• They lost the manual for the generator
and the manufacturer closed shop
• The employer’s Safety Contact tested for
CO2, CO, RH and Temperature that day
• The Exposure occurred 9 months previous
to report

5. Attempt to Assess Exposure
• No information on output from ozone
generator
• Air sampling conducted by consultant
– Conditions were not similar to exposure
– Results show
• 0.5ppb/cubic foot
• 0.000367ppb/cubic foot
• 0.001251ppb/cubic foot
• No information on Ozone concentration in
outside air

6. Employer’s Actual Measurements
assumptions
• Outside air was 100%
• 15 ACH
• Reentry rule: after 2
hours minimum
• The adverse health
effects were from
Glade Plug-Ins
• Measured at 6.8%
• 0.2 ACH
• Re-entry occurred in
5 minutes
• Effects reported after
the Ozone reacted
with the VOCs

7. What can you Cite?
• Hint: 10 violations, 6 standards

8. Violations Found:
• Wisconsin SPS 332.35:Ozone PEL is
0.1ppm, STEL is 0.3ppm.
• 1910.134(a)(1) and (d)(1)(iii)
• and 1910.132(d)(1)
Failure to assess employee exposure to air
contaminants.

9. Violations Found:
• 1910.1200(a)(1)
• 1910.1200(e)(1)(ii)
• 1910.1200(h)(1) and (h)(3)
• Training employees in the hazards of
equipment used by them and around
them, both routine, custodian, and non
routine, employee

10. Violations Found:
• 1910.1200(a)(1) “Other forms of warning”
• 1910.145(a)(2)(i) “Caution signs shall be
used to warn against potential hazards”
Required Action: Leave the sign on the door
until the hazard is known to be abated.

11. Violations Found:
• January 1956 Commercial mechanical
Code, Ind. 58.41(3)
• Outside air supply shall not be less than
7.5cfm/occupant and a minimum of 6 ACH

12. Difference between Public Sector
‘OSHA’ and OSHA
• The Reports are written for prevention of
recurrence, not punishment

13. With thanks and appreciation to:
Wane Baker, P.E., CIH
for sharing his articles, presentations and discussions
As well as to:
Dan Feldt, MPH, CIH
Leroy Dobson and Chris McSweeny at WOHL
for practical information on ozone sampling and data