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This section provides an overview of air sampling and site monitoring that is legally defensible.
It answers questions about monitoring protocols that must be initiated for emergency and contingency situations.
1. DOCUMENTATION
Essentially in any sampling endeavor, without documentation, you have what is called "personal opinion.'' The intent of documentation is to provide the basis for professional opinion. The documentation then becomes a dialogue of historical perspective and the empirical sampling event.
When assembling historical documentation, make sure that you define how the information is used. Often in order to understand sampling results, the environment, including work practices, must be analyzed. Work practices include human factors; therefore, you must be very careful to present a dialogue of these work practices that is not individually invasive.
When you decide on documentation techniques, before you write the first chronicle, enter field notes, or take that first picture, make sure that everyone understands what the purpose of the information is and who will have access to this information.
Be very careful when the original scope of work calls for only general information.
Often as the investigation continues, you may be asked to provide very specific reasons for general information development. Consequently, even for general information screening or limited audits, you may need to keep very specific information available to substantiate your opinions.
Whenever a review of human factors is required, especially interviews, all parties must understand the limitations on personal anecdotal information. If you don’t intend to personally name the interviewee, make sure all parties understand.
The overriding message here is define your scope of work and write this definition for all to see. If you need to work under the auspice of attorney/client privilege or through any other set boundaries, make sure the scope of work reflects these facts.
2. SAMPLE DOCUMENTATION
To assist in determining appropriate engineering controls, take photographs (as appropriate) and detailed notes concerning the following:
• Visible airborne contaminants
• Work practices
• Potential interferences
• Movements
• Other conditions
Prepare blanks during the sample period for each type of sample collected. One blank will suffice for up to 20 samples for any given analysis. These blanks may include opened, but unused, charcoal tubes.
3. COMPETENCY FOR SAMPLING TECHNICIANS
When deciding who is defined as a competent sampling technician, the first criterion is as follows: Is the scope of work completely defined according to sampling requirements? If you have any doubts about the situation with which samplers are involved, whether those doubts stem from a lack of background knowledge of the site or unknown hazards, the sampling scope is not completely defined.
For undefined sampling scopes, a senior sampling professional will need to initiate the site work. If the sampling choices once in the field are multi-factorial, in that circumstances on-site are very dynamic, a team of senior sampling professionals is required.
Remember that a phenomenon known as perceptual shift will occur during sampling.
As we become more or less secure with our environment, we start to see things differently.
A strong team is able to keep its members on target, thus providing a more complete picture of the sampling environment.
Once a scope of work is defined, sampling can often be delegated to less senior personnel. The purpose of this text is to provide information to assist in the standardization of both the initial and the delegated work effort. Despite the many ways of communicating before the sampling event, dialogue must be continued throughout the sampling event.
Unfortunately this dialogue may not be free-flowing conversation without limitations. The original team that defined the scope of work must be available to the on-site personnel. The actual conversations on-site, while delimited by many events, must give way to free flowing discussions within this team so that the collected data are useful and relevant.
4. SAMPLING ACTIVITY HAZARD ANALYSIS
To analyze the activities involved in sampling, an Activity Hazard Analysis (AHA) may be required. An example AHA is given in TBL. 1.
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TBL. 1 Air Sampling and Monitoring Activity
Air sampling and monitoring
Hazards
Electrical Sampling pumps Ambient a environment p and readings
Recommended Controls
• Grounded plugs should be used.
• Generators or air pumps should be used in dry areas, away from possible ignition sources.
• Don’t stand in water or other liquids when handling equipment.
• Electrical equipment will conform to OSHA 1910.303(a) and 1910.305(a),(f),(f)(3).
• Ground fault interrupters are used in the absence of properly grounded circuitry or when portable tools must be used in wet areas.
• Extension cords should be protected from damage and maintained in good condition.
• Air pumps should be placed within easy reach using
an OSHA-approved ladder or elevated platform or by
placing the pump on a stake.
• Personnel should be thoroughly familiar with the use, limitations, and operating characteristics of the monitoring instruments.
• Perform continuous monitoring in variable atmospheres.
• Use intrinsically safe instruments until the absence of combustible gases or vapor is anticipated.
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5. SECURITY
Whenever confidential or security issue data are collected, this information must be secured. One of the most difficult issues when on-site is just what to write down or record on media. Too much information is as bad as too little information.
For the junior sampling technician, raw data should not be interpreted in the field without consultation with the scope development team. Usually this consultation will pro duce advice to the sampling technician; don’t record that advice other than through a verbal discussion with senior staff.
Samples should be handled only by workers specifically designated as samplers. The worker who signs the chain-of-custody record will guarantee sample integrity until its final arrival at the laboratory.
5.1 Sample Containers-Laboratory
The analytical laboratory will often provide sample containers. The containers for soil or water sampling will be either high-density polyethylene or glass with Teflon®-lined lids and will be pretreated with preservatives as applicable. The type of sample containers and preservatives required for each analysis will be specified by the laboratory in coordination with the scope of work.
Sample filter cassettes, sorbent tubes, and other collection devices for air samples may also be obtained for the laboratory. Coordination with the laboratory is essential to ensure that sample containers meet the laboratory's internal quality control requirements as well as regulatory requirements.
5.2 Sample Handling and Decontamination
After sample collection in the field, the exterior of sample containers will be decontaminated if gross contamination is present. The sample containers will be handled with gloves until they are decontaminated with a detergent wash and water rinse. Care will be taken to avoid damaging the temporary labeling during decontamination. After decontamination, permanent labels will be placed on clean sample container exteriors.
The sample containers will be well cushioned with packing materials and packaged as described below for transportation to the laboratory. Care will be taken to seal bottle caps tightly. The samples will be shipped to the laboratory under chain-of-custody protocols.
Asbestos samples should never be sent with packing peanuts because the static charge generated during shipping will alter the pattern of fiber deposition on the cassette filters.
Volatile samples must be sent in cooling chests to maintain a 4°C atmosphere during shipment. Semi-volatiles should also be sent in cooling chests.
5.3 Procedures for Packing and Shipping Low Concentration Samples
Samples will be packaged as follows:
• Use waterproof metal (or equivalent strength plastic) ice chests or coolers only.
• After determining the specific samples to be submitted and filling out the pertinent information on the sample label and tag, put the label on the bottle or vial prior to packing.
• Secure the lid with strapping tape (tape on volatile organic compound [VOC] vials may cause contamination).
• Mark volume level on bottle with grease pencil.
• Place about 3 in. of inert cushioning material, such as vermiculite, in the bottom of the cooler.
• Enclose the bottles in clear plastic bags through which sample tags and labels are visible and seal the bags. Pack bottles upright in the cooler and isolate them in such a way that they don’t touch and won’t touch during shipment.
• Place bubble wrap and/or packing material around and among the sample bottles to partially cover them (no more than halfway).
• Add sufficient ice (double bagged) between and on top of the samples to cool them and keep them at approximately 4°C until received by the analytical laboratory.
• Fill cooler with cushioning material.
• Put paperwork (chain-of-custody record) in a waterproof plastic bag and tape it with duct tape to the inside.
• Tape the drain of the cooler shut with duct tape.
• Secure the lid by wrapping the cooler completely with strapping, duct, or clear shipping tape at a minimum of two locations. Don’t cover any labels.
• Attach completed shipping label to the top of the cooler.
• Label "This Side Up'' on the top of the cooler, "Up'' with arrow denoting direction on all four sides, and "Fragile'' on at least two sides.
• Affix numbered and signed custody seals on front right and back left of cooler.
Cover seals with wide, clear tape.
5.4 Procedures for Packing and Shipping Medium Concentration Samples
An effort will be made to identify samples suspected of having elevated contaminant concentrations based on field observations and screening tests. These samples will be segregated and packed in a separate container to the extent allowed by prevailing field conditions. Lids for these samples will be sealed to the containers with tape. Medium concentration samples will be packed in the same manner as described for low concentration samples.
5.5 Chain-of-Custody Records
Chain-of-custody protocols will be established to provide documentation that samples were handled by authorized individuals as a means to maintain sample integrity. The chain-of-custody record will contain the following information:
• Sample identification number
• Date, time, and depth of sample collection
• Sample type (e.g., sludge)
• Type and number of container
• Requested analyses
• Field notes and laboratory notes
• Project name and location
• Name of collector
• Laboratory name and contact person
• Signature of person relinquishing or receiving samples
Chain-of-custody records will be maintained for each laboratory sample. At the end of each day on which samples are collected, and prior to the transfer of the samples off-site, chain-of-custody documentation will be completed for each sample. Information on the chain-of-custody record will be verified to ensure that the information is consistent with the information on the container labels and in the field logbook.
Upon receipt of the sample cooler at the laboratory, the laboratory custodian will break the shipping container seal, inspect the condition of the samples, and sign the chain-of custody record to document receipt of the sample containers. Information on the chain-of custody record will be verified to ensure that the information is consistent with the information on the container labels. If the sample containers appear to have been opened or tampered with, this discrepancy should be noted by the person receiving the samples under the section entitled "Remarks.'' The completed chain-of-custody records will be included with the analytical report prepared by the laboratory.
5.6 Mailing-Bulk and Air Samples
Mail bulk samples and air samples separately to avoid cross-contamination:
• Pack the samples securely to avoid any rattle or shock damage. Don’t use expanded polystyrene packaging.
• Use bubble sheeting as packing.
• Put identifying paperwork in every package.
• Don’t send samples in plastic bags or envelopes.
• Don’t use polystyrene packing peanuts.
• Print legibly on all forms.
For exceptional sampling conditions or high flow rates, contact a Certified Industrial Hygienist (CIH) or the chosen analytical laboratory (approved by the American Industrial Hygiene Association [AIHA]).
6. EQUIPMENT PRECAUTIONS
6.1 BATTERIES
6.1.1 Alkaline Batteries
Replace frequently (once a month) and carry fresh replacements.
6.1.2 Rechargeable Nickel-Cadmium (Ni-Cad) and Lithium (Li-Po) Batteries
Check the batteries under load (e.g., turn pump on and check voltage at charging jack) before use. See the manufacturer's instructions for locations to check voltage. Use 1.3 to 1.4 V per Ni-Cad/Li-Po cell for an estimate of the fully charged voltage of a rechargeable battery pack.
It’s undesirable to discharge a multi-cell Ni-Cad battery pack to voltage levels that are 70% or less of its rated voltage; this procedure will drive a reverse current through some of the cells and can permanently damage them. When the voltage of the battery pack drops to 70% of its rated value; it’s considered depleted and should be recharged.
Rechargeable Ni-Cad or Li-Po batteries should be charged only in accordance with the manufacturer's instructions. Chargers are generally designed to charge batteries quickly (approximately 8 to 16 h) at either a high charge rate or slowly (trickle charge). A battery can be overcharged and ruined when a high charge rate is applied for too many hours.
However, Ni-Cad or Li-Po batteries may be left on trickle charge indefinitely to maintain them at peak capacity. In this case discharging for a period equal to the longest effective field service time may be necessary, because of short-term memory imprinting ( FIG. 1).
FIG. 1 This battery maintenance system accommodates one to five rechargeable
air sampling pump battery packs. (from: SKC)
7. ADVERSE TEMPERATURE EFFECTS
High ambient temperature, above 100°F and/or radiant heat (e.g., from nearby molten metal) can cause flow faults in air sampling pumps. If these conditions are likely, use the pump with a higher operating temperature range (e.g., Dupont Alpha-1) as opposed to a pump with a lower operating temperature range (e.g., SKC).
8. EXPLOSIVE ATMOSPHERES
Instruments must not be used in atmospheres where the potential for explosion exists (29 CFR 1910.307). Instruments must be intrinsically safe and certified by the
• Mine Safety and Health Administration (MSHA)
• Underwriter's Laboratory (UL)
• Factory Mutual (FM)
• Other testing laboratories recognized by the Occupational Safety and Health Administration (OSHA) When batteries are being replaced, use only the type of battery specified on the safety approval label.
Don’t assume that an instrument is intrinsically safe. If you are uncertain, verify its safety by contacting the instrument's manufacturer.
9 ATMOSPHERES CONTAINING CARCINOGENS
A plastic bag should be used to cover equipment when carcinogens are present.
Decontamination procedures for special environments should be followed after using equipment in carcinogenic environments.