To control significant room surface contamination, five applications of fixative were applied using a fogging method. A decision was made to restrict ventilation in order to create an even coating of fixative on room surfaces. Following application of the fixative, a industrial hygienist concluded that respiratory protection and sampling/monitoring were unnecessary for re-entry, as the "hazard had been engineered out of the activity" due to the associated Material Safety Data Sheet (MSDS) low hazard rankings. However, there was a lack of understanding that the fixative, when applied in a restricted ventilation area, could produce potential harmful chemical vapors due to a lack of adequate curing. The control measures of the MSDS identified that while respiratory protection is not required, the product should be used in a well ventilated area. Upon re-entry several workers were overcome by strong vapors and had to exit the room.
Lessons Learned: Do not assume that MSDS zero health hazard ratings mean little or no risk to personnel. Thoroughly evaluate all factors specific to the work environment and task demands during hazard analysis and work planning.
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