Standard Guide for Air Monitoring at Waste Management Facilities for Worker Protection

SIGNIFICANCE AND USE
5.1 The techniques of air monitoring are many and varied. This guide is intended to describe standard approaches that are used in designing an air monitoring program to protect waste management site workers.  
5.2 When entering a remedial action site to initiate an investigation or a cleanup operation, operating personnel may be faced with fire, explosion, and acute or chronic health hazards. A robust safety and health program, including site-specific injury and illness prevention program (IIPP) and a safety and health plan, must be in place to direct worker activity. Details for such plans can be found in the OSHA Interim Final Rule for Hazardous Waste Operations and Emergency Response and Refs (1, 2).8 Air monitoring is an integral part of such a program. This guide describes equipment and sampling procedures which can be used to evaluate the airborne hazard potential so as to gain and maintain a safe work environment at the site.  
5.3 Upon obtaining air quality measurements at the site, a decision must be made as to whether conditions are under control and safe or not. That decision will depend on the nature and concentrations of the contaminants (toxicity, reactivity, volatility, etc.), the spatial extent (area affected, number of workers, etc.) of the contaminants, and the level of worker protection available and needed. Since all such parameters are typically site specific, this guide does not include air quality measurement based guidance on decision making.  
5.4 This guide does not include monitoring sites containing radioactive materials, nor does it cover general safety aspects, such as access to emergency equipment or medical support for emergency needs. These items should be covered in a work place safety and health plan.  
5.5 Ideally, this guide is used in combination with Guide D4687.
SCOPE
1.1 This guide is intended to provide a standardized approach for establishing and carrying out an air monitoring program to protect workers at waste management facilities. This guide may apply to routine operations at an active treatment, storage, or disposal site or the extraordinary conditions that can be encountered in opening and cleaning up a remedial action site.  
1.2 The user shall understand that it is impossible to predict all the issues that could arise at a waste management facility due to hazardous airborne emissions. Although air contaminant measurements obtained in accordance with this guide may indicate acceptable or tolerable levels of toxic agents are present, care and judgment must still be exercised before concluding that all atmospheric contaminants at the site are under control and that a reasonable safe work environment exists.

General Information

Status
Published
Publication Date
31-Jan-2016
Technical Committee
D22 - Air Quality

Relations

Effective Date
01-Feb-2016
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01-Nov-2023
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01-Sep-2023
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Overview

ASTM D4844-16: Standard Guide for Air Monitoring at Waste Management Facilities for Worker Protection provides a framework for establishing and conducting air monitoring programs to safeguard workers in waste management environments. Developed by ASTM International, this guide is tailored for both routine operations at treatment, storage, and disposal facilities and for more complex, unpredictable conditions found at remedial action or cleanup sites. Its main focus is on the detection and control of hazardous airborne contaminants that pose acute or chronic health risks to personnel.

Employing standardized methodologies, ASTM D4844-16 aims to ensure that airborne hazards are accurately assessed and effectively managed, thereby supporting a safe work environment and compliance with occupational health regulations.

Key Topics

  • Air Monitoring Program Design
    The guide covers standard approaches to designing air monitoring protocols, taking into account the specific needs and realities of various types of waste management sites.

  • Worker Protection Focus
    Air monitoring is emphasized as a core part of a broader safety and health program, which should include an injury and illness prevention program (IIPP) and a comprehensive safety and health plan as outlined in OSHA regulations.

  • Site Characterization
    For remedial action sites, the guide highlights the importance of thorough site characterization and qualitative assessment before beginning operations, due to the uncertainty and variety of hazards present.

  • Monitoring Techniques
    The document discusses both personal and area monitoring, use of direct-reading instruments and laboratory analysis, and considerations for both long-term (time-weighted average) and peak exposure sampling methods.

  • Selecting Monitoring Parameters
    Guidance is provided on choosing which toxic agents to monitor, based on regulatory requirements, potential health risks, and the characteristics of the waste site.

  • Quality Assurance
    Emphasizes the necessity of quality control at every step, including calibration, data management, and analytical precision, recommending that quality programs meet standards such as ISO 17025.

Applications

ASTM D4844-16 is broadly applicable in a range of waste management and remediation contexts, including:

  • Active Treatment, Storage, and Disposal Facilities
    Supports routine worker air quality monitoring during ongoing operations, ensuring that controls such as engineering measures and personal protective equipment remain effective.

  • Remedial and Cleanup Operations
    Guides managers in assessing and responding to unpredictable and potentially severe airborne hazards at sites undergoing investigation or remediation.

  • Regulatory Compliance and Worker Safety
    Assists facilities in meeting OSHA and other relevant regulatory requirements for worker protection and process safety during waste handling.

  • Incident Response
    Provides procedures for rapidly identifying and quantifying airborne hazards in the event of spills, leaks, or unexpected chemical reactions.

  • Data Analysis and Risk Management
    Recommends robust data collection, storage, and analysis to identify trends, manage risks from routine or anomalous exposures, and optimize protective measures.

Related Standards

ASTM D4844-16 references and complements several key standards and resources for air monitoring and worker protection, including:

  • ASTM D4687: Guide for General Planning of Waste Sampling
  • ASTM D1356 & D5681: Terminology standards for atmospheric sampling and waste management
  • ASTM E1370: Guide for Air Sampling Strategies for Worker and Workplace Protection
  • NIOSH Manual of Analytical Methods and OSHA Analytical Methods Manual: Authoritative references for validated analytical procedures
  • ISO 17025: General requirements for laboratory competence and quality assurance in testing and calibration
  • OSHA 29 CFR 1910 (Hazardous Waste Operations): Regulatory framework for site safety planning
  • Other ASTM Methods (e.g., D3162, D3686, D4532): Methods for sampling/testing specific airborne contaminants such as carbon monoxide, organic vapors, respirable dust, and metals

Adopting ASTM D4844-16, in conjunction with related standards, helps waste management facilities enhance worker protection, maintain compliance, and foster a culture of continuous health and safety improvement.

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Frequently Asked Questions

ASTM D4844-16 is a guide published by ASTM International. Its full title is "Standard Guide for Air Monitoring at Waste Management Facilities for Worker Protection". This standard covers: SIGNIFICANCE AND USE 5.1 The techniques of air monitoring are many and varied. This guide is intended to describe standard approaches that are used in designing an air monitoring program to protect waste management site workers. 5.2 When entering a remedial action site to initiate an investigation or a cleanup operation, operating personnel may be faced with fire, explosion, and acute or chronic health hazards. A robust safety and health program, including site-specific injury and illness prevention program (IIPP) and a safety and health plan, must be in place to direct worker activity. Details for such plans can be found in the OSHA Interim Final Rule for Hazardous Waste Operations and Emergency Response and Refs (1, 2).8 Air monitoring is an integral part of such a program. This guide describes equipment and sampling procedures which can be used to evaluate the airborne hazard potential so as to gain and maintain a safe work environment at the site. 5.3 Upon obtaining air quality measurements at the site, a decision must be made as to whether conditions are under control and safe or not. That decision will depend on the nature and concentrations of the contaminants (toxicity, reactivity, volatility, etc.), the spatial extent (area affected, number of workers, etc.) of the contaminants, and the level of worker protection available and needed. Since all such parameters are typically site specific, this guide does not include air quality measurement based guidance on decision making. 5.4 This guide does not include monitoring sites containing radioactive materials, nor does it cover general safety aspects, such as access to emergency equipment or medical support for emergency needs. These items should be covered in a work place safety and health plan. 5.5 Ideally, this guide is used in combination with Guide D4687. SCOPE 1.1 This guide is intended to provide a standardized approach for establishing and carrying out an air monitoring program to protect workers at waste management facilities. This guide may apply to routine operations at an active treatment, storage, or disposal site or the extraordinary conditions that can be encountered in opening and cleaning up a remedial action site. 1.2 The user shall understand that it is impossible to predict all the issues that could arise at a waste management facility due to hazardous airborne emissions. Although air contaminant measurements obtained in accordance with this guide may indicate acceptable or tolerable levels of toxic agents are present, care and judgment must still be exercised before concluding that all atmospheric contaminants at the site are under control and that a reasonable safe work environment exists.

SIGNIFICANCE AND USE 5.1 The techniques of air monitoring are many and varied. This guide is intended to describe standard approaches that are used in designing an air monitoring program to protect waste management site workers. 5.2 When entering a remedial action site to initiate an investigation or a cleanup operation, operating personnel may be faced with fire, explosion, and acute or chronic health hazards. A robust safety and health program, including site-specific injury and illness prevention program (IIPP) and a safety and health plan, must be in place to direct worker activity. Details for such plans can be found in the OSHA Interim Final Rule for Hazardous Waste Operations and Emergency Response and Refs (1, 2).8 Air monitoring is an integral part of such a program. This guide describes equipment and sampling procedures which can be used to evaluate the airborne hazard potential so as to gain and maintain a safe work environment at the site. 5.3 Upon obtaining air quality measurements at the site, a decision must be made as to whether conditions are under control and safe or not. That decision will depend on the nature and concentrations of the contaminants (toxicity, reactivity, volatility, etc.), the spatial extent (area affected, number of workers, etc.) of the contaminants, and the level of worker protection available and needed. Since all such parameters are typically site specific, this guide does not include air quality measurement based guidance on decision making. 5.4 This guide does not include monitoring sites containing radioactive materials, nor does it cover general safety aspects, such as access to emergency equipment or medical support for emergency needs. These items should be covered in a work place safety and health plan. 5.5 Ideally, this guide is used in combination with Guide D4687. SCOPE 1.1 This guide is intended to provide a standardized approach for establishing and carrying out an air monitoring program to protect workers at waste management facilities. This guide may apply to routine operations at an active treatment, storage, or disposal site or the extraordinary conditions that can be encountered in opening and cleaning up a remedial action site. 1.2 The user shall understand that it is impossible to predict all the issues that could arise at a waste management facility due to hazardous airborne emissions. Although air contaminant measurements obtained in accordance with this guide may indicate acceptable or tolerable levels of toxic agents are present, care and judgment must still be exercised before concluding that all atmospheric contaminants at the site are under control and that a reasonable safe work environment exists.

ASTM D4844-16 is classified under the following ICS (International Classification for Standards) categories: 13.030.40 - Installations and equipment for waste disposal and treatment; 13.040.40 - Stationary source emissions. The ICS classification helps identify the subject area and facilitates finding related standards.

ASTM D4844-16 has the following relationships with other standards: It is inter standard links to ASTM D4844-03(2009), ASTM D5681-23, ASTM D4185-23, ASTM D1356-20a, ASTM D7539-10(2020), ASTM D1356-20, ASTM D6561-20, ASTM D6562-20, ASTM D3686-20, ASTM D7948-20, ASTM D7773-19, ASTM D3249-95(2019), ASTM D6832-13(2018), ASTM D5681-18, ASTM D5681-17. Understanding these relationships helps ensure you are using the most current and applicable version of the standard.

ASTM D4844-16 is available in PDF format for immediate download after purchase. The document can be added to your cart and obtained through the secure checkout process. Digital delivery ensures instant access to the complete standard document.

Standards Content (Sample)


This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: D4844 − 16
Standard Guide for
Air Monitoring at Waste Management Facilities for Worker
Protection
This standard is issued under the fixed designation D4844; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope D3249 Practice for General Ambient Air Analyzer Proce-
dures
1.1 This guide is intended to provide a standardized ap-
D3269 Test Methods for Analysis for Fluoride Content of
proach for establishing and carrying out an air monitoring
the Atmosphere and Plant Tissues (Manual Procedures)
program to protect workers at waste management facilities.
(Withdrawn 2010)
This guide may apply to routine operations at an active
D3413 Test Method for Lead (Inorganic) in Workplace
treatment, storage, or disposal site or the extraordinary condi-
Atmospheres by Atomic Absorption Spectrometry (With-
tions that can be encountered in opening and cleaning up a
remedial action site.
drawn 1989)
D3449 Test Method for Sulfur Dioxide in WorkplaceAtmo-
1.2 The user shall understand that it is impossible to predict
spheres (Barium Perchlorate Method) (Withdrawn 1989)
all the issues that could arise at a waste management facility
D3476 Test Method for bis (Chloromethyl) Ether (bis CME)
due to hazardous airborne emissions.Although air contaminant
in Workplace Atmospheres (Gas Chromatography-Mass
measurements obtained in accordance with this guide may
Spectrometry (Withdrawn 1989)
indicate acceptable or tolerable levels of toxic agents are
present, care and judgment must still be exercised before D3614 Guide for Laboratories Engaged in Sampling and
concluding that all atmospheric contaminants at the site are Analysis of Atmospheres and Emissions
under control and that a reasonable safe work environment
D3686 Practice for Sampling Atmospheres to Collect Or-
exists.
ganic Compound Vapors (Activated Charcoal Tube Ad-
sorption Method)
2. Referenced Documents
D3687 Practice for Analysis of Organic Compound Vapors
2.1 ASTM Standards: Collected by the Activated Charcoal Tube Adsorption
D1356 Terminology Relating to Sampling and Analysis of Method
Atmospheres
D3824 Test Methods for Continuous Measurement of Ox-
D1605 Practices for Sampling Atmospheres for Analysis of
idesofNitrogenintheAmbientorWorkplaceAtmosphere
Gases and Vapors (Withdrawn 1992)
by the Chemiluminescent Method
D2820 Test Method for C Through C Hydrocarbons in the
D4185 Practice for Measurement of Metals in Workplace
Atmosphere by Gas Chromatography (Withdrawn 1993)
Atmospheres by Flame Atomic Absorption Spectropho-
D2913 Test Method for Mercaptan Content of the Atmo-
tometry
sphere
D4240 Test Method for Airborne Asbestos Concentration in
D3162 Test Method for Carbon Monoxide in the Atmo- 3
Workplace Atmosphere (Withdrawn 1995)
sphere (Continuous Measurement by Nondispersive Infra-
D4323 Test Method for Hydrogen Sulfide in theAtmosphere
red Spectrometry)
by Rate of Change of Reflectance
D4490 Practice for Measuring the Concentration of Toxic
Gases or Vapors Using Detector Tubes
This guide is under the jurisdiction of ASTM Committee D22 on Air Quality
D4532 Test Method for Respirable Dust in Workplace At-
and is the direct responsibility of Subcommittee D22.04 on WorkplaceAir Quality.
Current edition approved Feb. 1, 2016. Published February 2016. Originally mospheres Using Cyclone Samplers
approved in 1988. Last previous edition approved in 2009 as D4844 – 03(2009).
D4599 Practice for Measuring the Concentration of Toxic
DOI: 10.1520/D4844-16.
Gases or Vapors Using Length-of-Stain Dosimeters
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM D4600 Test Method for Determination of Benzene-Soluble
Standards volume information, refer to the standard’s Document Summary page on
Particulate Matter in Workplace Atmospheres
the ASTM website.
3 D4687 Guide for General Planning of Waste Sampling
The last approved version of this historical standard is referenced on
www.astm.org. D5681 Terminology for Waste and Waste Management
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D4844 − 16
D6561 Test Method for Determination of Aerosol Mono- 3.2.2 remedial action site—a remedial action site is a
mericandOligomericHexamethyleneDiisocyanate(HDl) location or facility that may pose a threat to human health and
inAir with (Methoxy-2–phenyl-1) Piperazine (MOPIP) in the environment.
the Workplace
4. Summary of Guide
D6562 Test Method for Determination of Gaseous Hexam-
ethylene Diisocyanate (HDI) in Air with 9-(N-
4.1 The procedures described in this guide address safety
methylaminomethyl)Anthracene Method (MAMA) in the
considerations, acute health hazards, and chronic health haz-
Workplace
ards due to airborne hazardous materials.
D6785 Test Method for Determination of Lead inWorkplace
4.2 Monitoring concepts are described for cleanup opera-
Air Using Flame or Graphite Furnace Atomic Absorption
tions at remedial action sites as well as routine activities at
Spectrometry
operational waste management sites.
D6832 Test Method for the Determination of Hexavalent
Chromium in Workplace Air by Ion Chromatography and
5. Significance and Use
Spectrophotometric Measurement Using 1,5-
5.1 The techniques of air monitoring are many and varied.
diphenylcarbazide
This guide is intended to describe standard approaches that are
D7035 Test Method for Determination of Metals and Met-
used in designing an air monitoring program to protect waste
alloids in Airborne Particulate Matter by Inductively
management site workers.
Coupled Plasma Atomic Emission Spectrometry (ICP-
AES)
5.2 When entering a remedial action site to initiate an
D7036 Practice for Competence of Air Emission Testing
investigation or a cleanup operation, operating personnel may
Bodies
be faced with fire, explosion, and acute or chronic health
D7539 Practice for Using a Test Chamber for Humidity
hazards. A robust safety and health program, including site-
Conditioning of Test Panels of Pavement Marking Paints specific injury and illness prevention program (IIPP) and a
D7773 Test Method for Determination of Volatile Inorganic
safety and health plan, must be in place to direct worker
Acids (HCl, HBr, and HNO ) Using Filter Sampling and activity. Details for such plans can be found in the OSHA
Suppressed Ion Chromatography
Interim Final Rule for Hazardous Waste Operations and
D7948 Test Method for Measurement of Respirable Crystal- Emergency Response and Refs (1, 2). Air monitoring is an
line Silica in Workplace Air by Infrared Spectrometry
integral part of such a program. This guide describes equip-
E1370 Guide for Air Sampling Strategies for Worker and ment and sampling procedures which can be used to evaluate
Workplace Protection
the airborne hazard potential so as to gain and maintain a safe
work environment at the site.
2.2 ISO Standard:
ISO 17025 General Requirements for the Competence of
5.3 Upon obtaining air quality measurements at the site, a
Testing and Calibration Laboratories
decision must be made as to whether conditions are under
2.3 Federal Standards: control and safe or not.That decision will depend on the nature
and concentrations of the contaminants (toxicity, reactivity,
OSHA Analytical Methods Manual
NIOSH Manual for Analytical Methods volatility, etc.), the spatial extent (area affected, number of
workers, etc.) of the contaminants, and the level of worker
OSHA, 29 CFR Part 1910 Hazardous Waste Operations and
Emergency Response; Interim Final Rule, December protection available and needed. Since all such parameters are
typically site specific, this guide does not include air quality
measurement based guidance on decision making.
3. Terminology
5.4 This guide does not include monitoring sites containing
3.1 Definitions: radioactive materials, nor does it cover general safety aspects,
3.1.1 General—Terminology commonly used in air moni- such as access to emergency equipment or medical support for
toring can be found in Terminology D1356. Terminology emergency needs. These items should be covered in a work
commonly used in waste and waste management can be found place safety and health plan.
in Terminology D5681.
5.5 Ideally, this guide is used in combination with Guide
3.2 Definitions of Terms Specific to This Standard: D4687.
3.2.1 operating site—an operating site is a location or
6. General Considerations
facility where waste is treated, stored, or disposed as part of an
on-going operation.
6.1 The scientific field addressing the assessment of air-
borne hazards to workers is industrial hygiene. Professional
industrial hygienists, besides performing such tasks as measur-
Adopted by ASTM as an American National Standard.
ing the concentration of contaminants in air, recommend the
1985 manual available from Occupational Safety and Health Administration,
means for controlling such airborne hazards, protecting
OSHAAnalytical Laboratory, Salt Lake City, UT.
Fifth edition manual, January 2015, available from the National Institute of
Occupational Safety and Health, (NIOSH), Cincinnati, OH.
7 8
Available from the Superintendent of Documents, Government Printing Office, The boldface numbers in parentheses refer to the list of references at the end of
Washington, DC, 20401. this guide.
D4844 − 16
workers, and demonstrating compliance with applicable laws 7. Procedures
and regulations.Acertified industrial hygienist generally offers
7.1 Operating Site:
the optimum combination of background and credentials for
7.1.1 The procedures described in this section apply to air
recognizing, evaluating, and controlling workplace health haz-
monitoringactivitiesatanoperationalwastetreatment,storage,
ards. If industrial hygiene staff support is not available on site,
or disposal site. At an operating site, controls (work practices,
coverage can be obtained through the use of consultants and
engineering controls, and personal protective equipment) are
possibly through loss prevention insurance carriers. The re-
used to minimize the exposure of workers to hazardous
mainder of this guide reflects the general thought process that
conditions. These are defined in the site health and safety plan.
an industrial hygiene professional would likely go through in
7.1.2 Knowledge of Materials—Knowledge of the materials
establishing an air monitoring program to protect workers at a
arrivingatorpresentatanoperatingsiteiscriticaltothedesign
waste management site.
of a sampling plan. If hazardous wastes are received by a site,
it is critical that they be listed on a manifest. The results of
6.2 Establishing a Test Protocol:
incoming shipment waste sample analyses is also helpful for
6.2.1 Various combinations of equipment and sampling
identifying substances of greatest threat to healthy and safety.
techniques are used in work place air monitoring. The best
Information on wastes and their hazards may also be available
monitoring program is one that combines accuracy with timely
from knowledge that specific disposal site users will tend to
response in a cost effective manner.
deliver the same types of wastes to the site due to a consistent
6.2.2 The particular test protocol that is selected for an
generating process and shipment history. For example, paint
industrial hygiene study depends on the nature of the contami-
manufacturers will tend to send mixtures of solvents, resins,
nants and the end purpose of the monitoring effort (that is,
and pigments, whereas plating firms will generally send
routine monitoring, searching for worst case exposure, looking
alkaline heavy metal waste sludge, and so on. Deviation from
for contaminant leaks in a process, etc.) (See Guide E1370.)
established patterns, however, is possible and should not be
discounted in sampling plan design.
6.3 Selecting Specific Methods:
7.1.3 Worker Sampling:
6.3.1 Thechoiceofsamplingmethodisgenerallydependent
7.1.3.1 Personal sampling of the worker’s breathing zone is
on analytical methodology to be employed. There may be no
typically the most critical of workplace sampling that is
difference in the analytical work whether it is for a 15-min
needed.While some workers may be stationed in an operations
ceiling sample or a 7-h integrated sample. If an analytical
trailer at a control panel and sedentary, others may be moving
method has poor sensitivity, however, it may be necessary to
about the work site and very physically active. Addressing
increase the pump flow rate for the short duration sampling to
these different situations requires an assessment capable of
make certain that sufficient sample is collected for a meaning-
following and appropriate to the activity of the worker.
ful analysis. Adjustments such as this are determined by
7.1.3.2 The first type of personal monitoring to consider is
sampling personnel and laboratory personnel based upon the
long duration time-weighted-average (TWA) sampling. For an
measurement needs of the study and workplace limitations.
8-h work shift, ensure that TWA samples are at a minimum of
Guidance on air sampling strategies for worker and workplace
7-hdurationeitherasasinglesampleoraseriesoftwoormore
protection can be found in Test Method E1370. Extensive
samples. For any other work hour situation, the procedure is to
guidanceonthelatestdevelopmentsinairsamplingtechnology
sample for the duration of the shift less 1 h. For workers
is available in Refs (3, 4).
handling organic wastes (for example, vapor degreaser solvent
6.3.2 Information describing general methodology is avail-
waste) the sampling program could include charcoal tube
able from a number of sources. Practice D1605 lists some of
sampling followed by analysis for one or two of the solvents
the classic methods that have been used when sampling for
most likely to be present in the waste. Such TWA monitoring
gases or vapors. The American Conference of Governmental
would be repeated periodically to asses worker exposure and
IndustrialHygienistsoffersapublication,Ref (5),thatprovides
ensure that exposure is not increasing.
a review of some equipment and methodologies. The combi-
7.1.3.3 Another type of personal monitoring that can be
nation of equipment and procedures selected is based on the
carried out is for peak exposures. For example, a 15-min
precision, accuracy, and sensitivity needed to support the test
ceilingsamplemightbetakenwhileasetofcontainersisbeing
protocol.
openedforinspectionorremovalofitscontents.Thesametype
6.3.3 Once the goals and protocol for the sampling program
of sampling might be done while contents of a truck are
have been defined, specific sampling/analytical methods are
pumped into a holding tank. In cases such as these, personal
selected. Within the Annual Book of ASTM Standards, Volume protective equipment (for example, respiratory protection) is
11.03 is dedicated to atmospheric analysis and to occupational often used to minimize worker exposure to vapors. Ceiling
health and safety issues. Some applicable methods from that samples help ensure that workers are using respirators having
reference are listed in Annex A1. Other sources of health and a sufficient filtration and capture efficiency for worker safety.
safety support include the NIOSH Manual of Analytical 7.1.3.4 In some cases, ceiling samples might be the only
Methods and the OSHAAnalytical Methods Manual. Specific
type of monitoring necessary for certain toxic agents. For
equipment and sampling media for a particular set of airborne example, steel mill waste acid pickling solution received for
contaminants and sampling conditions are selected from these
neutralizationmayonlyrequiresamplingforanddetermination
types of sources. of hydrogen chloride. In that instance, only 15-min samples
D4844 − 16
would be of interest, since exposure to HCl is controlled on a closed site. Fugitive emission (see Ref 7) monitoring shall
15 min exposure basis by health/regulatory agencies. include these and perhaps other compounds; and
(4) where a range of similar compounds are present, such
7.1.3.5 Personal dosimeters, worn by the employees, have
as in some organic wastes and landfill gas. In this case, the
come into general use. These devices give an overall average
cumulative effect shall be estimated rather than the potential
exposure assessment and also record the instantaneous expo-
effect of individual contaminants.
sures of the worker during the day. These units, which are read
out on a smartphone, laptop, or notebook computer, are 7.1.6 Data Storage and Analysis:
7.1.6.1 The various forms of air monitoring described in
generally good for only one specific contaminant, although the
same electronic system can be used for other specific contami- 7.1.3, 7.1.4, and 7.1.5 will result in the accumulation of a large
amount of data by the site operator. The data need to be
nants. These might be very useful in monitoring a heavy
equipment operator for exposure to carbon monoxide or a recorded and catalogued in a manner that provides for ready
retrieval and comparison.
waste treatment plant attendant for exposure to sulfur dioxide.
7.1.6.2 Store and retrieve data so that the level of airborne
7.1.3.6 Another consideration in monitoring, safety, and
contamination can be reviewed over time. In this way annual,
health plans is the additive effect of certain substances.
seasonal, or diurnal trends as well as source specific contami-
Paragraph 7.1.3.2 presented the concept of screening for only
nation may be identified.
one or two solvents. When this is done, the eventual compari-
son with permissible exposure limits must be done using a 7.1.6.3 The site operator may want to determine if certain
safety factor. This safety factor is intended to account for the shipments or customers are sending waste material that is
particularly hazardous and difficult to handle.
possible effects of other similar compounds that may be
present, but are not measured routinely. 7.1.7 Quantitative Considerations—Even the best run waste
site may have to analyze for unknowns in the work atmo-
7.1.4 Area Monitoring:
sphere. Following are situations that can arise and will require
7.1.4.1 A good complement to personal monitoring is fixed
appropriate monitoring and mitigative action to ensure worker
location area monitoring. This can be done with either sample
safety.
collecting-type equipment, direct measurement instruments, or
7.1.7.1 The premise of most of the discussion of Section 7
specialized fixed-parameter monitors such as those described
isthatthesiteoperatorhasatleastsomeworkingknowledgeof
in 7.1.3.5. Area monitoring offers the advantage of potentially
the materials being handled. This may not always be the case.
providing an early warning for area worker exposure.
7.1.7.2 An unexpected odor or phase separation may indi-
7.1.4.2 Acombustible vapor meter in a solvent storage area
cate an unknown or unexpected substance is present in the
can give a warning before an employee enters the area.
waste material.
7.1.4.3 A carbon monoxide monitoring system around a
7.1.7.3 An abnormal reaction in a neutralization process
pyrolyzer or incinerator can warn both the operator in the
may be a sign that an unexpected volatile is being emitted.
control room and workers in the loading area of a hazard due
to a system upset or other unexpected event.
7.2 Remedial Action Site:
7.1.4.4 An oxygen meter permanently mounted in a below 7.2.1 The level of hazard that is found by air monitoring at
ground pit can warn an employee of an oxygen-deficient a remedial action waste site can vary from relatively innocuous
atmosphere before they enter the confined space.
to very dangerous. The uncertainty associated with the types
7.1.4.5 Direct reading colorimetric tubes Ref (6), offer a and composition of wastes present at these sites complicates
convenient means for obtaining a quick reading. Besides their
virtually every aspect of site cleanup and monitoring. For these
suitability for qualitative checks (see Annex A2), they also reasons a thorough site characterization must be made before
provide
...


This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: D4844 − 03 (Reapproved 2009) D4844 − 16
Standard Guide for
Air Monitoring at Waste Management Facilities for Worker
Protection
This standard is issued under the fixed designation D4844; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope
1.1 This guide is intended to provide a standardized approach for establishing and carrying out an air monitoring program to
protect workers at waste management facilities. This guide may apply to routine operations at an active treatment, storage, or
disposal site or the extraordinary conditions that can be encountered in opening and cleaning up a remedial action site.
1.2 Any user of this guide must The user shall understand that it is impossible to predict all the difficultiesissues that could
developarise at a waste management facility due to hazardous airborne emissions. Although air contaminant measurements
obtained in accordance with this guide may indicate acceptable or tolerable levels of toxic agents are present, care and judgment
must still be exercised before concluding that all atmospheric contaminants at the site are under control.control and that a
reasonable safe work environment exists.
2. Referenced Documents
2.1 ASTM Standards:
D1356 Terminology Relating to Sampling and Analysis of Atmospheres
D1605 Recommended Practices for Sampling Atmospheres for Analysis of Gases and Vapors (Withdrawn 1992)
D2820 Test Method for C Through C Hydrocarbons in the Atmosphere by Gas Chromatography (Withdrawn 1993)
D2913 Test Method for Mercaptan Content of the Atmosphere
D3162 Test Method for Carbon Monoxide in the Atmosphere (Continuous Measurement by Nondispersive Infrared Spectrom-
etry)
D3249 Practice for General Ambient Air Analyzer Procedures
D3269 Test Methods for Analysis for Fluoride Content of the Atmosphere and Plant Tissues (Manual Procedures) (Withdrawn
2010)
D3413 Test Method for Lead (Inorganic) in Workplace Atmospheres by Atomic Absorption Spectrometry (Withdrawn 1989)
D3449 Test Method for Sulfur Dioxide in Workplace Atmospheres (Barium Perchlorate Method) (Withdrawn 1989)
D3476 Test Method for bis (Chloromethyl) Ether (bis CME) in Workplace Atmospheres (Gas Chromatography-Mass
Spectrometry (Withdrawn 1989)
D3614 Guide for Laboratories Engaged in Sampling and Analysis of Atmospheres and Emissions
D3686 Practice for Sampling Atmospheres to Collect Organic Compound Vapors (Activated Charcoal Tube Adsorption Method)
D3687 Practice for Analysis of Organic Compound Vapors Collected by the Activated Charcoal Tube Adsorption Method
D3824 Test Methods for Continuous Measurement of Oxides of Nitrogen in the Ambient or Workplace Atmosphere by the
Chemiluminescent Method
D4185 Practice for Measurement of Metals in Workplace Atmospheres by Flame Atomic Absorption Spectrophotometry
D4240 Test Method for Airborne Asbestos Concentration in Workplace Atmosphere (Withdrawn 1995)
D4323 Test Method for Hydrogen Sulfide in the Atmosphere by Rate of Change of Reflectance
D4490 Practice for Measuring the Concentration of Toxic Gases or Vapors Using Detector Tubes
D4532 Test Method for Respirable Dust in Workplace Atmospheres Using Cyclone Samplers
D4599 Practice for Measuring the Concentration of Toxic Gases or Vapors Using Length-of-Stain Dosimeters
This guide is under the jurisdiction of ASTM Committee D34 on Waste Management and is the direct responsibility of Subcommittee D34.01.01 on Planning for
Sampling.
Current edition approved Feb. 1, 2009Feb. 1, 2016. Published March 2009February 2016. Originally approved in 1988. Last previous edition approved in 20032009 as
D4844D4844 – 03–03.(2009). DOI: 10.1520/D4844-03R09.10.1520/D4844-16.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM Standards
volume information, refer to the standard’s Document Summary page on the ASTM website.
Withdrawn. The last approved version of this historical standard is referenced on www.astm.org.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D4844 − 16
D4600 Test Method for Determination of Benzene-Soluble Particulate Matter in Workplace Atmospheres
D4687 Guide for General Planning of Waste Sampling
D5681 Terminology for Waste and Waste Management
D6561 Test Method for Determination of Aerosol Monomeric and Oligomeric Hexamethylene Diisocyanate (HDl) in Air with
(Methoxy-2–phenyl-1) Piperazine (MOPIP) in the Workplace
D6562 Test Method for Determination of Gaseous Hexamethylene Diisocyanate (HDI) in Air with 9-(N-methylaminomethyl)
Anthracene Method (MAMA) in the Workplace
D6785 Test Method for Determination of Lead in Workplace Air Using Flame or Graphite Furnace Atomic Absorption
Spectrometry
D6832 Test Method for the Determination of Hexavalent Chromium in Workplace Air by Ion Chromatography and
Spectrophotometric Measurement Using 1,5-diphenylcarbazide
D7035 Test Method for Determination of Metals and Metalloids in Airborne Particulate Matter by Inductively Coupled Plasma
Atomic Emission Spectrometry (ICP-AES)
D7036 Practice for Competence of Air Emission Testing Bodies
D7539 Practice for Using a Test Chamber for Humidity Conditioning of Test Panels of Pavement Marking Paints
D7773 Test Method for Determination of Volatile Inorganic Acids (HCl, HBr, and HNO ) Using Filter Sampling and Suppressed
Ion Chromatography
D7948 Test Method for Measurement of Respirable Crystalline Silica in Workplace Air by Infrared Spectrometry
E1370 Guide for Air Sampling Strategies for Worker and Workplace Protection
2.2 ISO Standard:
ISO 17025 General Requirements for the Competence of Testing and Calibration Laboratories
2.3 Federal Standards:
OSHA Analytical Methods Manual
NIOSH Manual for Analytical Methods
OSHA, 29 CFR Part 1910 Hazardous Waste Operations and Emergency Response; Interim Final Rule, December 1986
3. Terminology
3.1 Definitions:
3.1.1 General—Terminology commonly used in air monitoring can be found in Terminology D1356. Terminology commonly
used in waste and waste management can be found in Terminology D5681.
3.2 Definitions of Terms Specific to This Standard:
3.2.1 operating site—an operating site is a location or facility where waste is treated, stored, or disposed as part of an on-going
operation.
3.2.2 remedial action site—a remedial action site is a location or facility that may pose a threat to human health and the
environment.
4. Summary of Guide
4.1 The procedures described in this guide address safety considerations, acute health hazards, and chronic health hazards due
to airborne hazardous materials.
4.2 Monitoring concepts are described for cleanup operations at remedial action sites as well as routine activities at operational
waste management sites.
5. Significance and Use
5.1 The techniques of air monitoring are many and varied. This guide is intended to describe the standard approaches that are
used in designing an air monitoring program to protect waste management site workers.
5.2 When entering a remedial action site to initiate an investigation or a cleanup operation, operating personnel may be faced
with the extreme hazards of fire, explosion, and acute or chronic health hazards. A thoroughrobust safety and health program,
including a site-specific site-specific injury and illness prevention program (IIPP) and a safety and health plan, must be in place
to direct worker activity. Details for such plans can be found in the OSHA Interim Final Rule for Hazardous Waste Operations and
Emergency Response and Refs (1, 2). Air monitoring is an integral part of such a program. This guide describes equipment and
sampling procedures which can be used to evaluate the airborne hazard potential so as to gain and maintain control over the
situationa safe work environment at the site.
Adopted by ASTM as an American National Standard.
1985 manual available from Occupational Safety and Health Administration, OSHA Analytical Laboratory, Salt Lake City, UT.
ThirdFifth edition manual, February 1984,January 2015, available from the National Institute of Occupational Safety and Health, (NIOSH), Cincinnati, OH.
Available from the Superintendent of Documents, Government Printing Office, Washington, DC, 20401.
The boldface numbers in parentheses refer to the list of references at the end of this guide.
D4844 − 16
5.3 Upon obtaining readings air quality measurements at the site, a decision must be made as to whether conditions are under
control and safe or not. That decision will depend on the nature and concentrations of the contaminants (toxicity, reactivity,
volatility, etc.), the spatial extent (area affected, number of workers, etc.) of the problemcontaminants, and the level of worker
protection available. available and needed. Since all such parameters will be site specific, the necessary decision-making is beyond
the range of this guide.are typically site specific, this guide does not include air quality measurement based guidance on decision
making.
5.4 This guide does not include monitoring sites containing radioactive materials, nor does it cover general safety aspects, such
as access to emergency equipment or medical support offor emergency needs. These items should be covered in a work place safety
and health plan.
5.5 It is recommended that Ideally, this guide beis used in conjunctioncombination with Guide D4687.
6. General Considerations
6.1 That aspect of science which routinely deals with The scientific field addressing the assessment of airborne hazards to
workers is known as industrial hygiene. Professional industrial hygienists, besides performing such tasks as measuring the
concentration of contaminants in air, recommend the means for controlling such airborne hazards, protecting workers, and
demonstrating compliance with applicable laws and regulations. A certified industrial hygienist generally offers the optimum
combination of background and credentials for recognizing, evaluating, and controlling workplace health hazards. If industrial
hygiene staff support is not available on site, coverage can be obtained through the use of consultants and possibly through loss
prevention insurance carriers. The remainder of this guide reflects the general thought process that an industrial hygiene
professional would most likely go through in establishing an air monitoring program to protect workers at a waste management
site.
6.2 Establishing a Test Protocol:
6.2.1 Various combinations of equipment and sampling techniques are used in work place air monitoring. The best monitoring
program is one that combines accuracy with timely response in a cost effective manner.
6.2.2 The particular test protocol whichthat is selected for an industrial hygiene study depends on the nature of the contaminants
and the end purpose of the monitoring effort (that is, routine monitoring, searching for worst case exposure, looking for
contaminant leaks in a process).process, etc.) (See Guide E1370.)
6.3 Selecting Specific Methods:
6.3.1 The choice of sampling method is most often tied in with the analytical method.generally dependent on analytical
methodology to be employed. There may be no difference in the analytical work whether it is for a 15-min ceiling sample or a
7-h full day integrated sample. If thean analytical method has poor sensitivity, however, it may be necessary to increase the pump
flow rate for the short duration samplesampling to make certain that sufficient sample is collected. Such fine adjustments must be
worked out between the collected for a meaningful analysis. Adjustments such as this are determined by sampling personnel and
the laboratory personnel. laboratory personnel based upon the measurement needs of the study and workplace limitations.
Guidance on air sampling strategies for worker and workplace protection can be found in Test Method E1370. Extensive guidance
on the latest developments in air sampling technology is available in Refs (3, 4).
6.3.2 A number of sources of information are available to describe general methodology. Information describing general
methodology is available from a number of sources. Practice D1605 lists some of the classic methods that have been used when
sampling for gases or vapors. The American Conference of Governmental Industrial Hygienists offers a publication, Ref (5), that
provides a review of newersome equipment and methodology.methodologies. The final combination of equipment and procedures
selected is predictedbased on the precision, accuracy, and sensitivity needed to support the test protocol.
6.3.3 Once the goals and protocol for the sampling program have been set,defined, specific sampling/analytical methods must
be are selected. Within the Annual Book of ASTM Standards, Volume 11.03 is dedicated to atmospheric analysis and to
occupational health and safety issues. Some applicable methods from that reference are listed in Annex A1. Other sources of health
and safety support include the NIOSH Manual of Analytical Methods and the OSHA Analytical Methods Manual. The specific
Specific equipment and sampling media for a particular set of airborne contaminants and sampling conditions are selected from
sources such as these.these types of sources.
7. Procedures
7.1 Operating Site:
7.1.1 The procedures described in this section apply to air monitoring activities at an operational waste treatment, storage, or
disposal site. At an operating site, controls (work practices, engineering controls, and personal protective equipment) would be in
place are used to minimize the exposure of workers to hazardous conditions. These are defined in the site health and safety plan.
7.1.2 Knowledge of Materials—Knowledge of the materials arriving at or present at an operating site is critical to the design
of a sampling plan. If hazardous wastes are arriving, be sure that they are listed on thereceived by a site, it is critical that they be
listed on a manifest. The results of incoming shipment waste sample analyses will also help to identify contaminants of greatest
concern in an incoming shipment. It is also likely that specific users of the disposal site is also helpful for identifying substances
D4844 − 16
of greatest threat to healthy and safety. Information on wastes and their hazards may also be available from knowledge that specific
disposal site users will tend to be consistent in the deliver the same types of wastes they send to the site based on the due to a
consistent generating process and history of shipment. shipment history. For example, paint manufacturers will most likelytend to
send mixtures of solvents, resins, and pigments, whereas plating firms will generally send alkaline sludge of heavy metal waste;
waste sludge, and so on. Deviation from established patterns, however, is possible and should not be discounted in sampling plan
design.
7.1.3 Worker Sampling:
7.1.3.1 Of all the different techniques for workplace air monitoring, personal Personal sampling of the worker’s breathing zone
is paramount. typically the most critical of workplace sampling that is needed. While some workers may be quite sedentary
stationed in an operations trailer at a control panel, panel and sedentary, others may be out covering all areas of the work site. For
this reason, the assessment must be moving about the work site and very physically active. Addressing these different situations
requires an assessment capable of following and appropriate to the activity of the worker.
7.1.3.2 The first ordertype of personal monitoring to consider is long duration time-weighted-average (TWA) sampling. For an
8-h work shift, be sure ensure that TWA samples are at a minimum of 7-h duration either as a single sample or a series of two
or more samples. For any other work hour situation, the procedure is to sample for the duration of the shift less 1 h. For workers
handling organic wastes (for example, vapor degreaser solvent waste) the program would call for sampling program could include
charcoal tube sampling with followed by analysis for one or two of the chlorinated solvents most likely to be present in the waste.
Such TWA monitoring, as well as the following information, monitoring would be repeated periodically to asses worker exposure
and ensure that worker exposure is not increasing.
7.1.3.3 Another formtype of personal monitoring that wouldcan be carried out is for peak exposures. For example, a 15-min
ceiling samplessample might be taken while a set of containers wasis being opened to inspect or remove the for inspection or
removal of its contents. The same type of sampling might be done while pumping the contents of a truck are pumped into a holding
tank. At these times, In cases such as these, personal protective equipment (for example, respiratory protection) is often used to
minimize worker exposure to vapors. Ceiling samples will help ensure that workers are using respirators having a high enough
protection factor.sufficient filtration and capture efficiency for worker safety.
7.1.3.4 Ceiling In some cases, ceiling samples might be the only formtype of monitoring necessary for certain toxic agents. If
For example, steel mill waste acid pickling solution were to come in from a steel mill for neutralization, it might be appropriate
to sample for received for neutralization may only require sampling for and determination of hydrogen chloride. In that instance,
only 15-min samples would be of interest, because that is how since exposure to HCl is controlled on a 15 min exposure basis by
health/regulatory agencies.
7.1.3.5 New equipment has come into use to cover both TWA and peak sampling. Some personal dosimeters, worn by the
employees, Personal dosimeters, worn by the employees, have come into general use. These devices give an overall average
exposure assessment and also record the instantaneous exposures of the worker during the day. These units, which are read out
on a portable smartphone, laptop, or notebook computer, are generally good for only one particularspecific contaminant, though
all the different types are read using the same computer. although the same electronic system can be used for other specific
contaminants. These might be very useful in monitoring a heavy equipment operator for exposure to carbon monoxide or a waste
treatment plant attendant for exposure to sulfur dioxide.
7.1.3.6 Another concept to be considered in both the monitoring and safety and consideration in monitoring, safety, and health
plans is the additive effect of certain substances. Paragraph 7.1.3.2 presented the concept of screening for only one or two solvents.
When this is done, the eventual comparison with permissible exposure limits must be done using a safety factor. This safety factor
is intended to take account offor the possible effects of other similar compounds which are likely to that may be present, but are
not measured routinely.
7.1.4 Area Monitoring:
7.1.4.1 A good complement to personal monitoring is fixed location area monitoring. This can be done with either sample
collecting-type equipment, direct readingmeasurement instruments, or specialized fixed-parameter monitors such as those
described in 7.1.3.5. Area monitoring offers the advantage of potentially providing an early warning.warning for area worker
exposure.
7.1.4.2 A combustible vapor meter in a solvent storage area can give a warning before an employee must walk in to find a
leak.enters the area.
7.1.4.3 A carbon monoxide monitoring system around a pyrolyzer or incinerator can warn both the operator in the control room
and workers in the loading area of a system upset.hazard due to a system upset or other unexpected event.
7.1.4.4 An oxygen meter permanently mounted in a below ground pit can warn an employee of an oxygen deficient
oxygen-deficient atmosphere before he entersthey enter the confined space.
7.1.4.5 Direct reading colorimetric tubes Ref (6), offer a convenient means for obtaining a quick reading. Besides their
suitability for qualitative checks (see Annex A2), they also provide reasonable quantitative estimates.
7.1.5 Complex Exposure Potential:
7.1.5.1 Although much of the sampling effort may involve monitoring for one or two particular contaminants on specific
operations, contaminants, there will be other times when the exposure potential is more complex. Examples of more complex
D4844 − 16
monitoring might include: 1) where a sludge is handled on site, and there is a chance of spillage and eventual spreading of the
debris around the site by vehicular traffic and wind, dust samples will need to be analyzed periodically for heavy metals; 2) where
waste from a polymer plant (in particular one processing nitrile rubber or acrylonitrile butadiene styrene, (ABS) plastic) is handled
on site, it may be necessary to devise a sampling protocol which looks for trace quantities of acrylonitrile in an atmosphere
dominated by one or two less harmful organic vapors; 3) where polychlorinated biphenyl, (PCB) vapor can be carried into the
atmosphere by methane gas evolving from a closed site, Ref (7), monitoring must cover these and perhaps other compounds; and
4) where a wide range of similar compounds arise, such as in some organic wastes and landfill gas, the cumulative effect must be
estimated rather than the potential effect of individual contaminants.
(1) where a sludge is handled on site, and there is a chance of spillage and eventual spreading of the debris around the site by
vehicular traffic and wind—monitoring will include periodic collection of dust samples requiring analysis for heavy metals;
(2) where waste from a polymer plant (such as one processing nitrile rubber, acrylonitrile butadiene styrene, or (ABS) plastic,
or a combinations thereof) is handled on site. This may require a sampling protocol that looks for trace quantities of acrylonitrile
in an atmosphere dominated by one or two less harmful organic vapors;
(3) where polychlorinated biphenyl, (PCB) vapor can be carried into the atmosphere by methane gas evolving from a closed
site. Fugitive emission (see Ref 7) monitoring shall include these and perhaps other compounds; and
(4) where a range of similar compounds are present, such as in some organic wastes and landfill gas. In this case, the
cumulative effect shall be estimated rather than the potential effect of individual contaminants.
7.1.6 Data Storage and Analysis:
7.1.6.1 The various forms of air monitoring described in 7.1.3, 7.1.4, and 7.1.5 will result in the accumulation of a
substantiallarge amount of data by the site operator. The data need to be recorded and catalogued in a manner that provides for
ready retrieval and comparison.
7.1.6.2 Store and retrieve data so that the level of airborne contamination can be reviewed over time. In this way seasonal
annual, seasonal, or diurnal trends as well as source specific contamination may be identified.
7.1.6.3 The site operator may want to determine if certain shipments or customers are sending waste material that is particularly
hazardous and difficult to handle.
7.1.7 Quantitative Considerations: Considerations—Even the best run waste site may have to analyze for unknowns in the work
atmosphere. Following are situations that can arise and will require appropriate monitoring and mitigative action to ensure worker
safety.
7.1.7.1 The premise of most of the discussion of Section 7 is that the site operator has at least some working knowledge of the
materials being handled. As stated previously, however, surprises can be expected.This may not always be the case.
7.1.7.2 An unexpected odor or phase separation may indicate an unknown or unexpected substance is present in the waste
material.
7.1.7.3 An abnormal reaction in a neutralization process may be a sign that an unexpected volatile is being emitted. Given this
...

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