Page 7 of Attachment D 
Biological monitoring of worker body fluids for specific organisms carry- 
ing recombinant D.'IA molecules is costly and technically demanding. Quan- 
titative and qualitative sampling of air and surfaces in the production 
and lab areas can be an effective measure of sanitation, environmental 
conditions, and efficacy of control measures. Environmental sampling 
programs have been utilized in hospitals, the food industry, and contain- 
ttent laboratories for years and the principles of these programs are 
applicable to the operations at Cetus. The efficacy, sensitivity, and 
accuracy of environmental sampling and analytical techniques should, how- 
ever, be considered and their validity must be established prior to utili- 
zation. The procedures, analyses, sampling points, and sampling schedules, 
thus established, should be formalized in writing. 
The use of formaldehyde as a disinfectant agent in laboratory areas merits 
Certain precautions. Employees should wear rubber gloves when working 
with formaldehyde and when contact with the hands is likely. If the disin- 
fection process involves occasional brief exposures to formaldehyde at con- 
centrations in excess of 1.2 ng/ cubic meter, an appropriate respirator 
Should be used. A respirator training program would then also be required 
(Cetus does have one in effect), with emphasis on cleaning, maintenance, 
tnd proper fit. A step by step procedure should be outlined and only per- 
sonnel trained in the disinfection procedure and the respirator program 
would be allowed to use formaldehyde. Access to the area during the dis- 
infection procedure should be restricted. Detector tubes should be used 
to determine when it is safe to enter the decontaminated area. These tubes 
can also be used to assure that formaldehyde vapors are not escaping to 
other laboratories, offices, or public areas. If it is determined that 
use of formaldehyde can not be adequately controlled,, a substitute agent 
should be utilized. 
The use of the P-3 level laboratory for P-1 or P-2 level work was mentioned 
fcy the Cetus representatives . If the P-3 area is used consistantly for 
work allowing relaxed procedures, as compared to P-3 level requirements, 
the Safety and Operations Manual for the P-3 Facility should be revised. 
Additional practices, procedures, and safety precautions should be outlined 
for such use of the P-3 facility. The revised policy, and inherent con- 
cerns,' should then be discussed with all personnel involved and then closely 
■Supervised to assure the policy is adhered .to. 
7 
[ 562 ] 
