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Exposure Assessment: thoughts after an ISM Audit

Tim Roberts, Industrial HygieneJim Floyd, ALS

LBNL

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The Rule(10 CFR 851.21)

(a) Contractors must establish procedures to identify existing and potential workplace hazards and assess the risk of associated workers injury and illness. Procedures must include methods to:

(1) Assess worker exposure to chemical, physical, biological, or safety workplace hazards through appropriate workplace monitoring;

(2) Document assessment for chemical, physical, biological, and safety workplace hazards using recognized exposure assessment and testing methodologies and using of accredited and certified laboratories;

(3) Record observations, testing and monitoring results;

(5) Evaluate operations, procedures, and facilities to identify workplace hazards;

(6) Perform routine job activity-level hazard analyses;(7) Review site safety and health experience information

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LBL Strategy

• Risk-based— Use of Similar Exposure Groups (SEGs)— Factoring in engineering controls

• OSHA— Lead, Asbestos, noise, etc.

• DOE Notice 456.1— Nano

• AIHA “Occupational Exposure Assessment” model— Used as a guide to good practices

• Based on a very new comprehensive job hazards analysis (JHA) tool

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HSS View

• “The LBNL non-radiological exposure assessment program does not include adequate exposure assessment procedures and protocols and does not perform sufficient qualitative and quantitative exposure assessments to fully meet the requirements…”

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What are the requirements?

• OSHA requirements are pretty clear• 10 CFR 851 has some specific wording, but not fully

defined• DOE N 456.1 • Guidance from the IH Standard, STD-6005-2001• A new Technical Standard is being developed and is

scheduled to be rolled out, this year.

• Interpretations are mixed

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Questions

• Tiered Approach—Risk-based screening

• Qualitative vs. quantitative assessments—when is IH Professional Judgment applicable?

• Role of line management vs. EHS organization

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Employees that will not need an Exposure Assessment

Proposed Approach

Hazard ID

ExposureAssessment

(quant.)Hazard Assessment

(qualitative)

3-tiered system

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Hazard Identification

• Line management:—Through the work planning process (JHA), workers self

identify hazardous materials and agents associated with work

—line management verification step

• EHS:—Checks of the chemical inventory program—Walkthroughs—Response to employee (or supervisor) evaluation requests—On-going review of new regulations/requirements

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Criteria for Assessment

Priority for evaluation is based on overall risk:• Presumed exposure• Inherent hazard(s) of material

—e.g., Carcinogen, Sensitizer, Reproductive Toxin• Frequency of use• Quantity of material• Controls

—(e.g., Respirators and Fumehoods or Enclosures)• Employee or management requests

Decision tool for quantitative assessments

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Next Steps

• Complete a regulatory requirements analysis 9/09

• Benchmarking 12/09

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What are your thoughts?

• We would like to hear from you!

• Tim Roberts:TRoberts@lbl.gov

(510) 495-2709

• Jim FloydJGFloyd@lbl.gov

(510) 486-6369