JERROLD J. SCHARNINGHAUSEN, PhD
Workplace Safety Division
Directorate of Assessments and Prevention
U.S. Army Combat Readiness Center
Fort Rucker, Alabama

Several Army organizations have received notices of violation from the Occupational Safety and Health Administration (OSHA) for not having their break area in their maintenance facility as clean as practicable of contaminated dust. These violations have primarily occurred where maintenance practices involving heavy metals take place. The requirements under 29 CFR 1910 for beryllium, cadmium, chromium and lead state that all surfaces shall be maintained as free as practicable of accumulations of contaminates. These standards require that the employer shall assure those lunchroom facilities or eating areas are not an additional source of contamination. 

The hygiene provision for eating and drinking areas applies to areas and surfaces where employees consume food or beverages. This is not necessarily limited to surfaces of tables or counters where food or drinks may be consumed. Contamination that is initially deposited on another surface, such as a floor, could later contaminate a surface where food or drinks are placed. For example, if a worker places drinks on the floor while stocking a refrigerator, he or she could inadvertently transfer contamination from the floor into the refrigerator. 

The term "practicable" was used in the standard, as each workplace will have to address different challenges to ensure surface contamination is kept to a minimum. It is OSHA's view that a housekeeping program that is as rigorous as practicable is necessary for many jobs to keep airborne contaminant levels below permissible exposure conditions. So what does this mean? The standard intended that this be accomplished primarily by high-efficiency particulate air (HEPA) vacuuming or using wet methods on floors, rafters and other surfaces, or by methods equally effective in preventing the dispersal of contaminants into the workplace. 

So how does OSHA determine if the break area is “as free as practicable” of contamination? OSHA collects dust wipes to confirm contamination is present during the inspection, but this serves only to establish that the standard applies. There is no maximum allowable level. The dust wipe simply determines the presence or absence of contamination. 

The requirement to maintain surfaces "as free as practicable" is performance-oriented. OHSA has established that it is determined by the documented hygiene practices broken down by task and frequency of task execution to clean surfaces of particulates. OSHA also requires that a schedule of cleaning tasks, by date and name of individual performing the task, be presented to demonstrate execution. 

Employers must evaluate the specific hazards in their workplaces to determine the frequency and type of cleaning required. The hazard determination should consider factors such as the types of contaminants in the workplace, the amount of contamination present, the toxicity of the contaminants, the distance between the eating/drinking areas and work areas, the frequency with which employees use the eating and drinking areas, the ventilation system(s) running in the facility, and the effectiveness of the specific cleaning product(s) and methods used. OSHA also recommends employers refer to industry guidelines, where available, or other recognized resources for information about best hygiene practices for toxic dusts in the workplace. 

HQDA EXORD 031-19, 16 SEP 2019, Subject: Ensuring Safe and Healthy Workplaces that Generate or Have Potential for Exposure to Heavy Metals, emphasizes the importance of a rigorous housekeeping program to prevent hazardous dust accumulation. Units should ensure housekeeping programs/plans are reviewed and approved by the responsible industrial hygienist (IH) or IH program manager, safety program managers and installation environmental program offices. 

Army workplaces are neither required nor advised to collect surface dust wipe samples to verify cleaning effectiveness. The OSHA hygiene provision regarding surfaces being maintained as free as practicable of hazardous dust accumulation is performance-oriented. To date, there is no maximum allowable surface contamination criteria for cadmium, chromium, lead or beryllium. Contact the U.S. Army Public Health Center, Susan Holt, at (410) 417-2835 or email susan.g.holt.civ@mail.mil for more information regarding the limited circumstances when surface dust wipe sampling may be helpful.