Eating, drinking not allowed in areas with hazards

By ANAD Industrial HygieneApril 23, 2015

Eating, drinking not allowed in areas with hazards
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ANNISTON ARMY DEPOT, Ala. -- Anniston Army Depot has recently updated its Safety Regulation, ANADR 385-1, and concerns about eating and drinking on the industrial shop floor have been addressed in the new regulations.

Historically, the practice of eating and drinking has taken place in close proximity to shop operations in several production buildings.

Employees at ANAD are often required to work with materials which are potentially harmful if ingested.

Certainly, no one would deliberately consume a toxic substance. However, workers can inadvertently ingest hazardous materials by eating, drinking, chewing gum, applying cosmetics, using tobacco or even taking medication in an industrial environment.

Three components of this issue have shaped the depot's new policy.

The first is compliance with federal regulations, as mandated by the Department of Labor and the Army.

Second is concern about the practical health hazards involved with ANAD processes and activities. In other words, what actions, beyond literal compliance, help provide a more healthy work environment?

Finally, all potential benefits and the direct and indirect costs were considered before limiting eating and drinking on ANAD industrial shop floors.

The Occupational Safety and Health Administration recognizes many materials here on the depot as ingestion hazards capable of causing death or serious physical harm. The primary OSHA regulation, 29 CFR 1910.141(g) (2), states, "No employee shall be allowed to consume food or beverages in a toilet room nor in any area exposed to a toxic material."

Army commands must evaluate the effects of likely environmental hazards, such as contamination of food and water, on the ability to complete the mission. Since preventable non-battle losses can play a significant role in the outcome of military operations, the Army Safety Program, AR 385-10, requires leadership to use risk management to minimize environmental exposures.

To learn if these regulations apply to your area, you should check the list of affected shops on the depot's Intranet site. On the Intranet, look under Organizations/Safety Bulletins and click on "Eating Restricted Areas" in the left column.

Supervisors in the industrial areas of the installation are encouraged to retrieve the list from the Intranet and share it with employees.

Not all industrial areas have the same contamination potential.

Obviously, buildings and areas with operations that include machine shops, welding bays, blasting booths, paint lines and dip tanks have reasonable probability for a significant quantity of a toxic material to be on surfaces (tables, drinking cups, etc.) and, therefore, be ingested by an employee.

This is supported by historical industrial hygiene monitoring, required personal protective equipment and engineering controls in these areas limiting personnel exposure to toxic materials.

Conversely, a number of buildings and offices used only for administrative work, are not affected by the new policy.

Contact the Safety Office or Industrial Hygiene if your area is not listed and there is a reasonable probability a significant quantity of a toxic material may be ingested.

Industrial Hygiene is currently assessing practical health hazards of work sites in question and will be updating the online list regularly.

Also, if a change in the work area occurs which may affect the level of potentially hazardous contaminants on the shop floor, the supervisor should immediately notify IH.

To limit ingestion hazards, building renovations may be needed to facilitate break areas.

Requiring people to eat and drink in designated areas can affect work schedule and productivity. Also, worker morale is always an important factor.

Considering OSHA and Army regulations and the practicality, all potential benefits and costs related to limiting eating and drinking have been objectively compared, labor union concurrence was obtained and the final ANAD policy was determined.

This policy and details are included in ANADR 385-1, Section 2.5, Prevention of Accidental Ingestion of Contaminants. Employees working in designated work centers where restrictions apply will observe the following:

• Food is not allowed on the shop floor.

• Break rooms are not located on the shop floor.

• Refrigerators, microwaves, ovens, etc. for the storage or preparation of food are not allowed on the shop floor. These appliances are only allowed in designated break rooms.

• Water fountains and coolers are permissible in work areas where restrictions apply, but their location must be approved by IH. Water fountains and coolers will be for use by numerous employees, not at individual work stations. They must be separated from potential sources of toxic materials by physical barriers, distance or ventilation controls and inspected weekly for cleanliness.

• Closable-top drinking containers are also permitted in work areas where restrictions apply. Closable-top drinking containers are personal-size liquid containers which, when used, the mouth only contacts surfaces segregated from the ambient environment (e.g. twist-top, plastic bottle). Aluminum cans and sports bottles (pop-up drinking bottles) are not considered closable-top drinking containers.

Creating policy and putting controls in place can help limit the amount of toxic material contaminating food and drinking sources.

Supervisors should incorporate these recent changes into periodic safety training as well as new hire orientation.

However, all personnel are responsible for maintaining the health and fitness of the ANAD community. Industrial Hygiene and the Safety Office ask everyone to do their part to stop eating and drinking in areas with hazardous materials and to inform others when necessary.