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By Chuck Dingman, CIH, CSP Industrial Hygiene Services Manager, Total Safety
So your manager has instructed you to develop a new Industrial Hygiene Program or correct deficiencies in the current program for your organization. Just what does that mean, and where do you begin?
Simply stated, the field of industrial hygiene encompasses agents and conditions that can impact employee health and well-being in the work environment. The list of potential factors or stressors that can impact health and well-being include exposure to chemicals, high noise levels, ionizing and non-ionizing radiation, biological organisms, temperature extremes and ergonomic hazards. All these hazards must be assessed and controls implemented where unacceptable exposure conditions exist. Potential controls include hearing conservation, respiratory protection, radiation safety, heat stress, medical surveillance programs, and work practice and engineering controls. These programs and controls must be managed effectively to protect employee health and well-being. But which programs and controls do you really need?
The Workplace Exposure Assessment Process
There are two options available to you for identifying needed programs and controls. The first is to spend your time, money and effort putting out fires, i.e. reacting to workplace complaints, concerns and demands. The other option is to conduct a comprehensive, systematic assessment of needs and implement a proactive program to address and manage those needs. In either case, the assignment can be daunting, but can be made manageable with the right approach. The Workplace Exposure Assessment (WEA) process provides one such approach.
Traditionally, the WEA process was developed to evaluate potential chemical exposures. With modifications, the same WEA process can, however, be applied to evaluate nearly all potential industrial hygiene health risks.
The process of performing a WEA involves a series of distinct steps. The first step in a chemical WEA is to identify job classifications with potential exposure to specific chemicals. Secondly, a list of tasks that involve potential exposure to those chemicals is made. Step three is to evaluate the toxicity of the chemicals using health codes developed for the Hazardous Materials Information System (HMIS), carcinogenicity ratings, and regulatory or recommended exposure limits.
Finally, a review is made of the respiratory exposure conditions based on the potential for the chemical to become airborne, ventilation or other control systems, and the frequency and duration to which workers may be exposed to the chemical. Workers in job classifications with similar exposure potential to specific chemicals are referred to as Similar or Homogenous Exposure Groups in the WEA process. Decision making logic within the WEA process is applied to produce a listing of SEGs prioritized from highest (A) to lowest (C) exposure potential. In the case of potential chemical exposures, industrial hygiene monitoring is performed initially for “A” priority SEGs and secondarily for “B” Priorities. “C” priorities are those determined through the WEA process to be in control.
Ultimately, the WEA process is used to drive the need for respiratory protection, hearing conservation, ventilation, medical surveillance, personal protective equipment, radiation protection or other industrial hygiene programs. Where programs are needed, a written program is developed that establishes procedurally the process by which the program will be implemented and managed. The end result of the process may be the determination that a program is not needed or can be eliminated. In this case, the organization has data and documentation justifying the lack of a particular program or termination of an ongoing program.
The WEA process does not guarantee success. Ultimate success will require ongoing management support and a focus on staying the course. In the real world, issues will arise that will require a shift in priorities from time to time. The goal is to ensure that these shifts are only temporary and that focus is returned to the systematic path you have charted once the issue is resolved.
For more infomation on how to develop an industrial hygiene program for your company, call us at 888.44.TOTAL.
Preparing for and attaining certification in the OSHA Voluntary Protection Programs (VPP) can sometimes seem to be a confusing and overwhelming task, particularly for companies that do not have mature safety and health management systems already in place. To help, OSHA has developed a program for companies that are interested in improving their safety and health management systems and potentially participating in VPP, but may need assistance in understanding and meeting VPP requirements. The Challenge Program provides a comprehensive self-paced, three-stage roadmap that leads to improved safety and health management systems and preparation for VPP application.
Challenge is open to General Industry and Construction employers (determined by SIC/NAICS code) in both public and private sectors under OSHA federal jurisdiction. The Program is facilitated by OSHA-designated Administrators who may be corporations, nonprofit organizations or federal agencies. The Administrators act as the primary contact between OSHA and the Challenge Participant, and guide the Participant through the program stages. At the completion of each stage, the Administrator will review the participant’s progress and authorize advancement to the next stage. OSHA will formally recognize progression from stage to stage and issue a certificate of graduation upon completion of Stage III. Provided it meets basic criteria, such as mishap rates and citation history, an organization should be ready to submit a VPP application following graduation, and may be considered for expedited review for certification.
To become a Challenge Participate, a candidate organization must first affiliate with an Administrator. A list of Administrators is available on the OSHA website or by calling your local OSHA office. The candidate organization completes an application and statement of commitment that is reviewed by OSHA, and upon acceptance, is designated an OSHA Challenge Participant. The Participant then proceeds through three progressive stages of safety and health program improvement with specific action and outcome requirements related to the VPP elements; management leadership and employee involvement, worksite analysis, hazard prevention and control, and safety and health training. As the Participant organization works through the stages, it will change from being reactive to proactive in identifying and controlling hazards. Additionally, it will progress in knowledge of and compliance with OSHA standards, develop an improved workplace safety culture, have improved documentation, increase safety and health activities, and show improvements in injury and illness rates. Documentation of achievements is required and progress is tracked on an electronic spreadsheet that provides color-coded status on each action and outcome item and a percentage completion level for the current stage.
The beauty of Challenge is the step by step guidance and direction it provides for improving a safety and health management system. The required actions and outcomes for each sub-element in each stage eliminate the guesswork of “what do I do next” for Participants. The status tracking sheet provides a visual and easy to understand tool to chart program progress. Even for organizations that consider their safety and health management systems more mature, Challenge tools and guidelines provide utility in confirming that necessary program elements are in place and functioning effectively. Go online and look at the list of Challenge Participants. It should come as no surprise that the list includes OSHA regional and area offices that are striving to become VPP certified themselves. So follow the lead of the experts. If you think your organization is not quite ready for VPP don’t be troubled – take the OSHA Challenge and travel the road to improved safety and health.
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