Why personal protective equipment can only be a temporary solution

A removed high temperature insulation (blanket/pillow/jacket/shell) that has been in use for a longer period of time "suffers" during use. High temperatures, humidity, vibrations, etc. take their toll.

The coming together of harmless substances (stainless steel alloys of engine and turbine hot parts such as chromium (III) compounds on the one hand and likewise harmless alkali or alkaline earth metals (e.g. calcium as an important component of insulation materials used today (fabric, mats, tile, etc.) on the other hand at high operating temperatures produces unfortunate and hitherto little noticed thermochemical chain reactions (high oxidation) harmful substances - good and good becomes evil!

In the case described, chromates are formed, i.e. carcinogenic, partly mutagenic and even fertility-disrupting chromium (VI) compounds (calcium chromate, sodium chromate, etc.). The expert speaks of "hazardous substances" or also "substances of very high concern" (SVHC) and so it is not surprising that the "chromium (VI) rapid test" detects the presence of chromium (VI) compounds on an ordinary insulating jacket that was mounted on an engine hot part, as shown by the discoloration of the test tip:

The legislator has clear rules of conduct for the release of hazardous substances; these are defined both in the country-specific occupational health and safety laws and in the hazardous substances ordinances (OSHA) and differ only minimally internationally.

Every worker in the construction or power plant industry "knows" how to behave in the presence of asbestos and does everything possible to avoid coming into contact with this hazardous substance.

The prescribed behavior and packages of measures in the event of possible contact with asbestos substances are not much different from those for chromium (VI) compounds.

Nevertheless, many are still of the opinion that wearing personal protective equipment would be completely sufficient, but this is not true.

Likewise, very few people are aware that wearing personal protective equipment in normal operation must not be a permanently acceptable solution on the part of the employer.

It is not for nothing that, for example, the wearing of an FFP2 mask at the workplace is limited in time by the legislator and the wearer is granted additional breaks or must be assigned other work in between, for which he then does not have to wear the FFP2 mask!??

Let us now turn to the legal texts of the Hazardous Substances Ordinance and the Occupational Health and Safety Ordinance

The?chromium (VI) compound calcium chromate, which is frequently released?after the use of calcium-containing insulations, is classified as "carcinogenic cat. 1B" (H350) and as "very toxic to aquatic organisms with long-term effects" (H410) and is thus?considered a hazardous substance.

Thus, and there are no two opinions about this, the following basic obligations apply:?

1. The employer may?only allow an activity involving hazardous substances?to commence?after a risk assessment has been carried out in accordance with Section 6 and the necessary protective measures have been taken in accordance with Section 4.
2. In order to ensure the health and safety of employees during all activities involving hazardous substances, the employer shall take the necessary measures in accordance with the Occupational Safety and Health Act and, in addition, the measures required by this Ordinance. In doing so, he shall take into account the rules and findings published in accordance with Section 20 (4).
3. The employer shall give?priority to substitution?on the basis of the result of the substitution test in accordance with Section 6, §1, Sentence 2, Number 4.
4. The employer shall exclude hazards to the health and safety of employees during activities involving hazardous substances. If this is not possible, he shall reduce them to a minimum. The employer shall take these requirements into account by determining and applying suitable protective measures.

He (the employer) shall?substitute?hazardous substances or processes with substances, mixtures or products or processes which are?not hazardous?or are?less hazardous?to the health and safety of employees under the respective conditions of use.

The practice of carrying out stripping work in personal protective equipment alone indicates that a hazard exists!        

However, the wearing of?personal protective equipment must not be regarded as a permanent measure, which, moreover,?can only be expected of the employee for a limited period of time.

If the protective suit is worn, it is actually already too late, even if it is of course indispensable at that moment.

The?contractor?(insulator/service company) is therefore?obliged, in accordance with the above-mentioned legal requirements,?to minimize or eliminate the present danger for the next time.

However, further use of contaminated insulation must be ruled out in any case!

This would mean that?hazardous substances are put into circulation again against better knowledge and cannot be excused with a terse "we only had the old insulation set available".

The hazard assessment must be carried out before work is started and would have prescribed the provision of a new set of replacement insulation, at best the substitute product.

The magic word is therefore substitution.

If substitution is technically possible, it must be applied.

In our example, the?harmful substance is calcium chromate?(CaCrO4).

The formation of these chromates is due to an unfortunate thermochemical reaction during the use of the (calcium-containing) high-temperature insulating materials in conjunction with, for example, chromium-containing hot parts (engine/turbine/pipeline) at application temperatures of more than 300°C.

The actually harmless substance calcium oxide (CaO) as a component of almost all common insulating materials is, so to speak, the driving force in the oxidation process:

chromium (in the form of chromium (III) (Cr2O3)) +

calcium (in the form of calcium oxide (CaO)) =
 
calcium chromate (CaCrO4)+        

Consequently, calcium-free insulating material is the substitution solution:

NO CALCIUM - NO CALCIUM CHROMATE

Since?calcium-free insulating materials are available, most of which have even better insulating properties than the materials used so far,?and these calcium-free materials prevent the formation of the hazardous substance calcium chromate,?substitution must be carried out to meet the regulations already mentioned above:

(2) In order?to ensure the health and safety of employees during all activities involving hazardous substances, the employer shall take the necessary measures in accordance with the Occupational Safety and Health Act and, in addition, the measures required by this Ordinance. In doing so, he shall take into account the rules and findings announced in accordance with Section 20 (4).

(3)?The employer shall give priority to substitution on the basis of the result of the substitution test in accordance with Section 6, § 1, Sentence 2, Number 4.?

"He (the employer) shall?substitute hazardous substances or processes with substances, mixtures or products or processes that are not hazardous or are less hazardous to the health and safety of employees under the respective conditions of use."

"The employer shall?exclude hazards to the health and safety of employees during activities involving hazardous substances."

The exhaust pipe can still look like this after the (calcium-containing) insulation has been removed:

After substitution (calcium-free insulation after previously decontaminated hot parts), the exhaust line after the use of the substituted insulation blanket looks like it should:

Compliance?with the?Ordinance on Hazardous Substances?and the?Occupational Health and Safety Act?ensure?safe working and environmental conditions?and?symbolize the sense of responsibility of employers and service companies!?

And no matter how you want to bend the paragraphs and regulations, there can be no two opinions about the need for substitution, mainly because there are neither technical nor economic reasons not to do it.

Take care of yourself and stay healthy!

Olesnica, 2022-07-19