SAVANNAH RIVER SITE Manual: 4Q 1.1 Procedure: 101A ... · Industrial Hygiene support to spills,...

SAVANNAH RIVER SITE Manual: 4Q 1.1 Procedure: 101A Industrial Hygiene Survey Procedures Revision: 3 Page: 1 of 27 Type: Administrative Effective Date: 10/29/09 EXPOSURE ASSESSMENT

1.0 PURPOSE [S/RID 1, 2, 3, 4] The goal of hazard characterizations and Similar Exposure Group (SEG) assessments is to document and confirm that exposures in facilities and within groups of workers are controlled to the degree, that even with day-to-day variability, the maximum exposures will typically be under established Occupational Exposure Limits (OELs). This procedure defines the basic strategy for developing hazard characterizations for workplaces (facilities, projects, and processes) and conducting exposure assessments to assess potential occupational exposures to workers performing routine and planned work. It establishes the methods for performing hazard characterizations and determining if an exposure is acceptable, uncertain, or unacceptable and documents the basis for this conclusion. It is recognized that even in a well controlled situation, occasional exceedences of the OELs may occur and do not indicate that an operation is not under control. In the event that exceedances do occur, thorough evaluation of the event will occur and corrective actions will be established and tracked in accordance with site procedures defined in those programs. Exposure Assessments are not intended to serve as an individual’s work history; databases such as Medgate support this function. The Exposure Assessment (EA) program of documentation only applies to facilities and organizations during their lifecycle, starting at concept design and ending with decontamination and demolition. Unique facility programs (chemical inventory at the facility level as an example) do not require collaboration or documentation with this procedure’s requirements.

2.0 SCOPE This procedure is only for the use of Industrial Hygiene (IH) staff for performing hazard characterizations and determining potential worker exposure. The frequency for use of this procedure is defined below:

Frequency of Reassesssment

OSR Form Annual Three Year 4-922 X Not Applicable 4-923 X* All 4-920 X* All

* For carcinogens only.

Industrial Hygiene Surveys Procedures Manual: 4Q1.1 Procedure: 101A Exposure Assessment Revision: 3 Page: 2 of 27

2.0 SCOPE, continued Exposure Assessment within the conduct of research and development is outside the scope of this procedure. Research and Development (R&D) captures exposure assessment within the electronic Hazards Analyses Process (eHAP). For chemicals whose primary exposure mode is via skin exposure, REFER to the Dermal Exposure Assessment Tool. CONSULT the IH Exposure Assessment Program Subject Matter Expert (SME). Emergency response planning is to be documented as all other planned work within this procedure. However, real emergency responses do not necessitate completion of this procedure. Industrial Hygiene support to spills, incidents and emergencies is defined in “IH Event Response”. This is an Administrative Procedure. The user is not required to have this procedure present while performing the activity. The following OSR forms may be utilized in the performance of this procedure: OSR 4-920, Risk Assessment Determination Documentation OSR 4-922, Hazard Characterization and Workplace Description OSR 4-923, SEG Hazard Characterization. These forms are only available via the Lotus Notes IH Forms Database. Should any of this documentation address CLASSIFIED information, line management is obligated to produce identical documentation forms for maintenance within a CLASSIFIED information system.

Upon issuance of this procedure, the titles of OSR forms 4-920, 4-922, and 4-923 were changed from the previous Procedure Manual 4Q1.1, Procedure 101A revision.

Old OSR Form Name OSR Form New OSR Form Name Facility Hazard Characterization and Workplace Description

4-922 Hazard Characterization and Workplace Description

Work Force Hazard Characterization

4-923 SEG Hazard Characterization

Qualitative Risk Assessment 4-920 Risk Assessment Determination Documentation


2.0 SCOPE, continued Existing Facility Hazard Characterization and Workplace Description (OSR 4-922), Work Force Hazard Characterization (OSR 4-923) and Qualitative Risk Assessment (OSR 4-920) forms generated through Procedure Manual 4Q1.1, Procedure 101A, Revision 0, will be maintained as the exposure assessment of record until updated in accordance with this procedure. All information generated on these OSR forms will continue to be retained by the Lotus Notes data system as archived records.

3.0 TERMS/DEFINITIONS

Agent A chemical, physical (includes ergonomic), or

biological agent that has an OEL or has the potential to affect the health of a worker based on an IH's knowledge, a material safety data sheet, or worker concerns.

An agent can include a degradation/decomposition

chemical that is generated as part of the process (i.e., process waste tank vapors, heated polymers, welding flux).

Exposure A worker's contact with a chemical, physical, or

biological agent. Occupational exposures can occur via several pathways, including inhalation, ingestion, skin contact, and rarely injection. Exposure is defined as the concentration of a chemical or biological agent measured in the breathing zone outside of respiratory protection. Exposure to physical agents (i.e., noise, non-ionizing radiation, heat stress, etc.) is defined as the concentration representative of the maximum dose a worker receives. NOTE that if a data set is not lognormally distributed as determined by Medgate; CONSULT management and SEEK further statistical expertise for data review.


3.0 TERMS/DEFINITIONS, continued Exposure decision – Acceptable Occupational exposure to a chemical, physical, or

biological agent judged to present a minimal risk for illness or disease based on current or historical sampling, modeling or referenced literature citation matching the combination of physical factors and conditions of use. Where monitoring (appropriate physical, biological or chemical agent sampling in air or on surfaces) is performed, the lognormal statistical analysis value (using Medgate Lognorm) for the 95th percentile shall be less than 50% of the established OEL. Where modeling is performed, the modeling result will target a similar decision criteria (less than 50% of a selected OEL), unless a technical defense is recorded for selecting an alternate criterion.

NOTE: “Acceptable exposures” criteria for carbon

monoxide, lead, manganese, styrene, toluene, and xylene are 20% of the chemical OEL for the purpose of Hearing Conservation enrollment.

Exposure decision – Occupational exposure to a chemical, physical, or Unacceptable biological agent that, the lognormal statistical

analysis value (using Medgate Lognorm) for the 95th percentile is greater than the established OEL. Also, if no OEL or sampling method is available and there is evidence of adverse health effects, the exposure is unacceptable. Typically, comfort issues (i.e., air conditioning broken, odors, illumination) are not evidence of an unacceptable exposure. If protective equipment mitigates an exposure that would otherwise be unacceptable [e.g., noise doses greater than 85dBA Time Weighted Average (TWA)], this scenario should still be identified as unacceptable.


3.0 TERMS/DEFINITIONS, continued Exposure decision –Uncertain Occupational exposure to a chemical, physical, or

biological agent which cannot be categorized as acceptable or unacceptable because of a lack of quantitative or qualitative information.

IH Forms Database The Lotus Notes database that stores information

regarding exposure assessments and supporting information.

Mixture rule The approach for determining the combined effects of

two or more chemicals which have the same target organ (i.e., lung). Where appropriate, use the American Conference of Governmental Industrial Hygienists (ACGIH®)/Occupational Safety and Health Administration (OSHA) Mixture Rule philosophy when determining if an exposure to a chemical agent is acceptable, uncertain, or unacceptable.

Occupational Exposure Limit A generic term used to represent a pair of numbers: (OEL) (1) the agent concentration or intensity that is

allowable (based on health-effects data) and (2) the time period over which one averages workplace concentrations to evaluate whether the measured concentrations are less than the allowable limit. Some substances may have several occupational limits. The IH performing an exposure assessment will use the most restrictive value from OSHA or ACGIH®.

Professional judgment The application or appropriate use of knowledge

gained from formal educational experience, experimentation, inference, and analogy. The capacity of an experienced professional to draw correct inferences from incomplete quantitative data, frequently on the basis of observations, analogy, and intuition. Within this procedure, professional judgement MUST be founded upon a calculation or model, historical data and its statistical treatment, or referenced literature citation.


3.0 TERMS/DEFINITIONS, continued Qualitative data An estimate of the exposure to a chemical, physical,

or biological agent based on professional judgment. Quantitative data A measured value of a chemical, physical, or

biological agent using a direct reading device or an integrated sample. The data can be from within a similar exposure group or from another source with exposures that are representative relative to the task, process, and methods. The data can come from industry groups, published data, or any referenced source.

Similar Exposure Group (SEG) A group of workers having a similar exposure

profile for the chemical, physical, or biological agent(s) being studied because of the similarity and frequency of tasks, material, processes, and methods when performing the tasks.

Significant Exposure Any exposure to a chemical, physical or biological

agent where the exposure assessment process does not yield a minimal decision. Minimal assessments are de facto insignificant exposures.

4.0 RESPONSIBILITIES

Facility Manager Reviewing and approving the OSR 4-922

describing the inventory of hazards for that facility. Facility Health and Safety (H&S) Assisting Field IH staff with prioritization of IH Manager work towards the conduct of Exposure

Assessments. Obtaining necessary resources to ensure effective

implementation of this procedure.

Assigning renewal commitments within Site Tracking, Analysis, and Reporting (STAR) for the annual review and update of OSR 4-922.


4.0 RESPONSIBILITIES, continued Field H&S Manager Performing review and approval of exposure

assessment(s). Assisting Facility H&S Manager with exposure

assessment prioritization and resource needs. Industrial Hygiene Professional Performing and following this procedure.

Managing IH Forms and correspondence in accordance with this procedure. Obtaining review of the exposure assessment baseline analysis by the Industrial Hygiene Exposure Assessment Program SME. Obtaining review of the exposure assessment baseline analysis by the Field H&S Manager . Scheduling reassessment based on the required frequency.

IH Exposure Assessment Providing and defending technical basis for the Program SME exposure assessment program. Creating additional factors for agents not listed in

the IH Programs Rank Computation Values by CAS Number Table.

Reviewing and approving baseline exposure

assessments. SEG First Line Manager (FLM) Concurring with accuracy of the workplace hazard

inventory.


5.0 PROCEDURE This procedure is divided into 2 subsections:

5.1. Develop/Revise the Hazard Characterization and Workplace Description (OSR 4-

922) 5.2. Develop/Revise the SEG Hazard Characterization (OSR 4-923) and Completing

the Risk Assessment Determination Documentation (OSR 4-920). A Temporary Inventory form (see attachment 1 for a typical sample) may be used to document planned work and will be attached to the Lotus Notes OSR 4-923 form. Document on the Temporary Inventory form one of two decisions: either the applicable Minimal Assessment Code for the agent of exposure, or the document number of the RADD created within the SEG form. Some Similar Exposure Groups (SEGs) may be defined through existing qualification processes that exist site wide which will require initiation of sampling plans based upon the methods/materials/controls/qualification matrix applied to that discipline (SEG). . Hazard characterizations are developed for workplaces (facilities, projects, or processes) to provide a summary of the chemical, physical (includes ergonomic), and biological agents to which workers may be exposed while in a particular workplace. Rather than detailing every potential hazard that may be present in a workplace, a hazard characterization for a workplace concentrates on classical groupings and special or unique agent. The assessment of the risk each hazard poses to workers is then addressed in the exposure assessment(s) developed for SEGs as described in Section 5.2. The IH meets with SEG First Line Manager (FLM) and conducts a walkdown of the facility to develop/revise the Hazard Characterization and Workplace Description form. Multiple FLMs may be interviewed to ensure the OSR 4-922 accurately reflects the hazards for the workplace. Hazard Characterization and Workplace Description (OSR 4-922) must be updated annually. Forms, diagrams and associated information shall not contain Unclassified Controlled Nuclear Information (UCNI) or higher information. UCNI or higher information is handled separately by the Field IH using the same philosophy. For planned work, the expectation is that the IH will walk down the job or be familiar with the work from recent/previous exposure. The expectation is that the participating or approving IH is familiar with the physical space and configurations that will be in place for the work evolution being evaluated.


5.0 PROCEDURE, continued

NOTE: A workplace can be a combination of facilities, buildings, projects or

processes. Likewise, a workplace can be divided into separate facilities, buildings, projects, or processes.

Include at a minimum the following: • facility/building/project • status • date • additional location description.

5.1 Develop/Revise the Hazard Characterization and Workplace Description (OSR 4-

922) • Facility current use • Workplace Description (i.e., describe size, special controls, special hazards,

engineering controls, etc.) • Ventilation systems (i.e., general-recirculating/once-thru, local-welding hood) • Brief description of chemical process(es) including major chemicals in the

process(es). Any time that “planned work” identifies a new hazard from a product, activity, process change, etc. that results in that hazard to be permanently tied to the facility (e.g., addition of a compressor generating noise levels greater than 85 dBA where none had been before), that hazard will be annotated onto the Hazard Characterization and Workplace Description document (OSR 4-922). Chemical Hazards from Inventory Tool:

• OSHA carcinogens (excluding 0 – 0.09% range or cited as trace)

• ACGIH® Al/A2 carcinogens (excluding 0 – 0.09% range or cited as trace)

• Special or unique hazards (i.e., beryllium, organic mercury, reproductive hazards, open area abrasive blasting, walk-in paint booth, shock sensitive, pyrophoric, class IV oxidizer, peroxide former, organic peroxide, highly reactive, highly acute toxicity, etc.)


5.1 Develop/Revise the Hazard Characterization and Workplace Description (OSR 4-922), continued Facility Specific Hazards from Activities or Areas:

• Noise sources - Areas posted as >85 dBA (reference location of or attach

Sound Level Survey Index)

• Unique noise sources (i.e., large steam relief valves, ultrasonic cleaners)

• Heat stress hazards

- seasonal heat - seasonal heat plus PPE (describe typical and worst case) - radiant heat sources (i.e., boilers, extrusion press)

• Cold stress hazards

- seasonal cold - cryogenic liquids

• NIR devices do not include non-occupational (general lighting) or

insignificant (PID lamps)

• Lasers (include inventory of Class 3B, 4 and Class 1 with embedded 3b/4 Lasers that are accessed during activities such as maintenance, calibration, or alignment)

• Asphyxiation Hazards (i.e., nitrogen inerting systems, fire suppression

systems)

• Ergonomics (i.e., gloveboxes, material handling)

• Biohazards

- cooling towers

- use of recirculating cutting fluids

- infectious agents of a unique level (i.e., 247-F during demolition, animal waste in typically unoccupied areas such as attics)

- bloodborne hazards beyond first aid nature (i.e., Medical facilities)

- indoor environmental quality issues (i.e., chronic water intrusion

or CO2 levels >1000 ppm) of a repeat nature.


5.1 Develop/Revise the Hazard Characterization and Workplace Description (OSR 4-922), continued

• Supplemental Information – Any information not recorded in the fields

cited above on the OSR 4-922 that is pertinent to a full statement of the hazard characterization is to be placed here.

WHEN completed, THEN

SEEK a review of the baseline document from IH EA Program SME, AND OBTAIN management review and concurrence on the information, AND ASSIGN renewal commitments with Site Tracking, Analysis, and Reporting (STAR) for the annual review and update of this OSR 4-922.

5.2 Develop/Revise the SEG Hazard Characterization (OSR 4-923) and Completing the

Risk Assessment Determination Documentation (OSR 4-920)

NOTE: IH staff may complete the documentation discussed within this

procedure after rendering any decision made either in support of “operational urgency” (as defined in work planning requirements) or by the On Call IH for the site.

Exposure assessments (EAs) are performed on groups of workers, SEGs, who have a

similar exposure profile for the chemical, physical and biological agent(s) being evaluated. Workers are grouped based on the similarity and frequency of the tasks they perform, the materials and processes with which they work, and the similarity of the way they perform the task. A worker can belong to more than one SEG. Exposure assessments must be updated annually for: • Occupational Safety and Health Administration (OSHA) carcinogens • A1 and A2 carcinogens • Chemical, physical, and biological agents that have OSHA or Department of

Energy (DOE) agent or substance-specific requirement • EAs that are rated as unacceptable (but workers are protected through the use of

protective equipment).


5.2 Develop/Revise the SEG Hazard Characterization (OSR 4-923) and Completing the Risk Assessment Determination Documentation (OSR 4-920), continued EAs not addressed above must be updated on a frequency not to exceed three (3) years. Any EA for which the OEL is changed or for which the frequency, controls, or process changes in a manner that could increase worker exposure must be reviewed and revised, if necessary, prior to work resuming. Chemical agents present in concentrations of less than 0.1% for carcinogens or l.0% for noncarcinogens do not require an EA unless the IH determines that a worker may be exposed in excess of applicable OELs.

5.2.1 Establishing and Prioritizing SEGs

Non-exempt and construction craft SEG’s are identified using the site Human Resources (HR) non-exempt seniority roster (e.g., descriptors and job titles) and construction craft codes respectively. The following table will be considered as a priority scheme when scheduling the completion of Workforce Hazard Characterizations.

Order Job Class SEG’s

1 Maintenance or Construction Crafts

Multi Skilled Technician (MST), E&I, Equipment Repair, Maintenance, Machinist Laborer, Millwright, Carpenter, Insulator, Welder

2 Operations Production Operator

3 Laboratory Laboratory Technician

4 Support Industrial Hygiene, Mobile Equipment Mechanics, Power Operators, Radiological Controls Technicians, Railroad, Rigging

5 Emergency Response Firefighters, Paramedics

6 Scientists Chemists, Biologist, Physicists

7 Engineering Engineers, Engineering Technicians

8 Medical Nurses, Phlebotomists, X-Ray Technicians

9 Administrative Drafter, Locksmith, QA, Reprographics, Materials Processor, Clerical, MC&A, Management


5.2.1 Establishing and Prioritizing SEGs, continued

The above SEG order is based on Industrial Hygiene review considering likely exposure potential based on degree of control, variability of work scope, and formalized training/procedures. The SEG order may be revised to allow a SEG with a higher estimated risk to be evaluated sooner. Schedule approval should occur jointly with facility and H&S management as defined within the facility schedule.

Provide as an attachment to OSR 4-922 any ALTERNATE priority of SEGs if the order shown above in this section is not being used.

5.2.2 Initiating the Hazard Assessment

NOTE: Each SEG’s chemical agents are identified using the IH Assessment

Inventory Tools available in the Chemical Safety and Lifecycle Management website. In addition, process/institutional knowledge of the SEG FLM and the IH is used to add chemical agents not typically identified in the IH Assessment Inventory Tool. Examples include beryllium in radiological feedstock, silica generated from work with concrete, lead from handling shielding, asbestos installed within a facility, or nitric acid as an ambient fugitive emission. Physical and biological agents are also identified using process/institutional knowledge. Keep all working copy information in attachments in editable format until all work is done. Only when complete information is obtained, to the satisfaction of the accountable field IH, is the record to be saved as a PDF file.

1. MEET with the SEG’s FLM(s) to update the OSR 4-923, SEG Hazard Characterization. Multiple FLMs may be interviewed to ensure the OSR 4-923 reflects the information for the SEG. Personnel not permanently assigned to the facility are typically not included in the OSR 4-923. RECORD results of the interview(s) onto the Exposure Assessment Facility Specific Hazard Survey Form.

2. Along with the SEG FLM, INDICATE any facility specific chemical, physical

and biological agents and ADD that hazard to the Facility Specific Hazard Inventory Form.

3. COMPLETE the OSR 4-923 and INCLUDE at a minimum the following:

• facility/building/project • the name of the SEG


5.2.2 Initiating the Hazard Assessment, Step 3, continued • job description of worker • describe typical activities performed • supplemental information. NOTE: For planned work, the minimal information to be placed on the SEG

form are the SEG title and a description of the activity being evaluated, along with the Lotus Notes document number from the archived forms.

4. GENERATE the initial report using the Exposure Assessment Inventory Tool.

NOTE 1: Do not delete any apostrophe’s found in the download version of the

inventory tool! They exist as elements of programming logic and must remain in the tables.

NOTE 2: For planned work, one may make use of the temporary inventory tool

form for recording decisions. Either record the minimal assessment criteria that is met, reference another RADD already created or complete a RADD in Lotus Notes for the SEG in question, and return to the Temporary Inventory form and record it.

5. BRIEF the FLM on the process, his/her obligations to complete the hazards

inventory review, and sequence of actions that follow in this section.

6. Along with the SEG FLM, ENTER "Y" for Yes (used by SEG) or "N" for No (not used by SEG) in the "Used by SEG" column of the "Exposure Assessment by Building-FLM" Report. For any product marked Yes, COMPLETE the additional information regarding PPE, amount used, and controls.

7. GENERATE "Exposure Assessment by Building-IH" Report. SAVE through

the "Export" function of FMTS as an XLS File. Then OPEN the saved file and LOAD "Used by SEG" data as reported by the FLM. Then PRINT "EA by Building-IH" for review with the FLM for verification of information.


5.2.2 Initiating the Hazard Assessment, continued 8. As may be necessary to complete report information, PERFORM a walk down of

the facility location(s) where exposure to the chemical, physical, or biological agents occurs as practicable. This activity should be conducted with someone knowledgeable about the SEG activities.

5.2.3 Minimal Assessment Screening

1. The IH reviews the "Exposure Assessment by Building-IH" and "EA Facility Specific Summary" to understand the opportunity that use of the product may yield a minimal assessment. Meeting any of the following criteria (and having no evidence of adverse health effects) satisfy the requirement for a minimal assessment.

a. Does not meet OSHA's definition as "hazardous" based on the Material

Safety Data Sheet (MSDS) (even if the ingredients are proprietary). b. Is used in a manner that meets OSHA's Consumer Product Exemption

intent as defined by the OSHA Hazard Communication Standard 1910.1200.

c. Is composed of non-carcinogenic chemicals present at a concentration

below 1.0% and cannot reasonably exceed 10% of an OEL (i.e., a metal or salt with a minimal vapor pressure which is not heated or aerosolized) and has no evidence of adverse health effects, or is a non volatile agent (such as pigments in paint) contained in a liquid or gel.

d. Has a carcinogenic chemical present at a concentration below 0.1% and

cannot reasonably exceed 10% of an OEL (i.e., a metal or salt with a minimal vapor pressure which is not heated or aerosolized) and has no evidence of adverse health effects, OR is a nonvolatile agent (such as silica) contained in a liquid or gel.

e. Is not capable of exceeding OELs when modeled (saturation concentration

model), or dilution ventilation incorporated to the model shows concentrations less than 50% of the applicable OEL. In the case that a model is created, and the model affirms that the Occupational Exposure Limit cannot be exceeded, then the modeling output report must be captured as a pdf file and attached to the SEG Hazard Characterization form


5.2.3 Minimal Assessment Screening, continued f. Is detectable (odor or irritation) at a concentration below the OEL, no

systematic toxicological impact (sensitizer, carcinogenic, mutagen) and is not noticed in the workplace.

g. Is used in a negative pressure glovebox (does not apply during intrusive

maintenance activities). h. Is a grease or oil used at ambient temperature or less and is not

aerosolized. i. Is a "bound" nanotechnology particle (BNP) per DOE directive N 456.1.

NOTE: For any “planned work” where chemical, physical or biological agents are

involved, the appropriate letter code for the minimal assessment criterion will be recorded into the Temporary Inventory form.

2. ADD the character (A thru I identified above) in the appropriate column

("Minimal Assessment Criteria") of either report (Building-IH Report or Facility Hazard Specific Report) or Temporary Inventory form for chemical, physical, or biological agents that meet the above criteria for a minimal assessment. At this point the EA for that agent is complete.

3. OBTAIN concurrence of the accuracy of the information in the IH Exposure

Assessment by Building-IH Report and Facility Hazard Specific Report from the SEG FLM.

5.2.4 Ranking Remaining Agents

1. RANK each remaining agent(s) that has not met the criteria for a minimal assessment using the following process.

NOTE: EAs are not required, or even recommended, for equivalent MSDSs ( same

CAS number and concentration ranges). For example, an RADD for a SEG using 50% nitric acid from Olin Chemical can address use of 1% nitric acid from JT Baker as well as for recycled (i.e. H-OF) nitirc acid whose origin is variable provided the risk ranking uses the most significant toxic version.

a. SELECT the first agent that will be assessed and ENTER the following information on OSR 4-920:

• Facility/Building/Project • Similar Exposure Group (job description and job title)


5.2.4 Ranking Remaining Agents, Step 1a, continued • Additional location description (explain where within the

project/facility the agent is used) • Job Description [what is the task being done, i.e., repair pump,

transfer (agent name), drill holes in concrete, perform procedure abc123 to make up process solution] using Medgate task descriptions (if none exist, create one and ask Medgate system administrator to add it to the validated task list).

• MSDS Number • Procedure/Work Package/Assisted Hazards Analysis (AHA)

Number (#) (if applicable at the time of the review) • Agent and CAS number (if applicable) • Constituent (if surrogate selection is used) and CAS number • Pressure and temperature at which agent is used • Leak and spill experience with the product (do not put information

from the MSDS regarding expected response to leaks and spills) • Parameters [Indoors, outdoors, Confined Space (OSHA defined)

number, Other (describe)] • Any employee concerns.

NOTE: Classes of products may be documented on a single OSR 4-920 when

all products present the same significant agents. As an example, a group of spray paints where all products list the same constituent formulation and differ only the the pigment.

b. LOCATE agent selected on the IH Programs Rank Computation Values

by CAS Number Table ("the table"). IF a radiological agent, THEN ASSIGN all zeroes as Rank Computational Values.


5.2.4 Ranking Remaining Agents, Step 1b, continued IF a biological agent, THEN FOLLOW directions as found under each ranking criteria below. IF a physical agent, THEN FOLLOW directions as found under each ranking criteria below. IF the agent is a nanotechnology material, THEN RECORD all zero values as defaults. Since DOE Directive 456.1

requires nanotechnology work to be under an exposure assessment logic, it will be recorded in Lotus Notes IH forms. However, in light of no toxicological data by which to establish and occupational exposure limit (OEL), it is impossible to manage exposures any other way than be prudent avoidance. All nanotechnology agents exposure assessments will yield "uncertain" exposures due to the lack of an OEL. To that end, any monitoring data collected cannot be used for exposure assessments but may only be used as process monitoring to demonstrate effective controls. For convenience and to support best efforts when rendering decisions relative to "acceptable" exposures, IH staff may reference such data in forms.

RECORD on the OSR 4-920 the value from "the table" and MARK as

VALUE. IF no value is in "the table" cell, THEN USE the default value cited in the procedure, AND MARK as DEFAULT. IF the agent is not listed in the table, THEN NOTIFY IH Programs to create the ranking values.


5.2.4 Ranking Remaining Agents, Step 1b, continued IF a mixture, THEN SELECT a targeted component as agent according to the following guidance:

• Percentage in the mixture • Greatest toxicity agent • Volatilization potential relative to acetone at a Vapor Pressure of

300 mm Hg • Special notations as sensitizers, reproductive hazards, or specific

regulation such as beryllium • Simplicity of collection and analysis of the constituent from the

analytical chemists perspective.

COMPLETE the Rank Computation Section as done for a pure agent. After completing the step above, then FOLLOW the process below.

1.) ENTER the value for Route(s) of Entry on OSR 4-920.

An agent affects workers primarily through the following route(s).

Possible choices include.

8 – Lungs and skin (Skin Notation for ACGIH TLV®) 4 – Lungs only 2 – Skin only (exit this exposure assessment logic and refer to the

Dermal Exposure Assessment Tool). 1 – Eye or Mouth

A default value of 4 is used for physical agents and if no value is available for chemical and biological agents.


5.2.4 Ranking Remaining Agents, Step 1b, continued 2.) ENTER the value for Acute Toxicity on OSR 4-920. IF more than one value exists, the order for selection is inhalation

followed by the greater value from ingestion/dermal, THEN

Ingestion Inhalation Dermal Value Oral LD 50

Mg/kg LC 50 PPM 4 Hr.

Skin LD 50 Mg/kg

8 < 5 < 10 < 10 4 5-50 10 -100 10 -200 2 > 50 -100 > 100 -1000 > 200 -5000 1 > 100 > 1000 > 5000 SELECT a default value of 4 for physical and biological agents and if no value is available for chemical agents.

3.) ENTER a value for Chronic Toxicity on the OSR 4-920.

8 – OSHA or ACGIH® A1/A2 carcinogen or reproductive, embryotoxic, or teratogenic effects

4 – Lung damage, COPD, asthma, pneumoconiosis; bone or

kidney damage; methemoglobinemia, carboxyhemoglobinemia; chemical asphyxiant; Peripheral Nervous System impairment

2 – URT, LRT, respiratory irritant; CNS depression or

impairment; metal fume fever; allergic reaction; hematologic effects

1 – Skin, eye or GI irritant; drowsiness or dizziness; simple

asphyxiant SELECT a default value of 4 for physical agents and if no value is available for chemical and biological agents.


5.2.4 Ranking Remaining Agents, Step 1b, continued 4.) ENTER a value for Warning Properties on the OSR 4-920.

8 - >3X OEL 4 - <3X OEL but > OEL 2 - <OEL but >0.1 OEL 1 - < 0.1 OEL SELECT a default value of 8 for chemical agents and a value of 4 for biological agents and physical agents if no value is available.

5.) ENTER a value for Physical Factor on the OSR 4-920.

8 – Vapor pressure >300 mm Hg @25 degrees C 4 – Vapor pressure 100 – 300 mm Hg @25 degrees C 2 – Vapor pressure <100 mm Hg or a very fine powder (i.e., flour). 1 – Nondusting solids except very fine powders (i.e., flour) SELECT a default value of 8 for physical agents and if no value is available for chemical and biological agents.

6.) ENTER a value for Number of Employees on the OSR 4-920.

There is no default value. SELECT the appropriate value based on the number of employees in the SEG. ASSUME all workers in the SEG are equally exposed.

8 – (>50) 4 – (21 – 50) 2 – (5 – 20) 1– (1 – 4)


5.2.4 Ranking Remaining Agents, Step 1b, continued 7.) ENTER a value for Amount Used (Pounds) Per Year on the OSR

4-920. There is no default value. USE “8” for all physical or biological agents.

SELECT the appropriate value based on the amount used by a

"typical" worker per year in the SEG and record it on OSR 4-920. Corrections for the percentage of an ingredient within a product are not required but may be performed to avoid creating an unrealistic ranking score. For liquids (i.e., paints, solvents, acids) or gases, estimating the weight of the agent is satisfactory; it is not necessary to convert using specific gravity and density of the major ingredients.

8 – >1,000 pounds/year 4 – >100 – 1,000 pounds/year 2 – 10 – 100 pounds/year 1 – <10 pounds/year

8.) ENTER a value for Degree of Exposure on the OSR 4-920. There

is no default value. For physical agents, USE “16” for exposures above the applicable OEL; USE “8” when less than OEL but above 10% of OEL; and USE “1” when less than 10% of the OEL. For biological agents, USE “8”.

Selections are made based on the agent’s presence within workers’

breathing zones. Concentrations in tanks, piping, drums, lab hoods (that are not entered) are not generally used. With the exception of chronic emissions (which are typically well below an OEL) that release an agent into the workplace, leaks are not generally considered. An example of chronic emissions that would be considered would be uniformly stained or oxidized metal in an area using acids.


5.2.4 Ranking Remaining Agents, Step 1b8, continued

16 - Agent is released in concentrations that exceed 50% of the OEL in the breathing zone. Examples include large scale spray painting, opening equipment that is poorly drained or flushed, large scale abrasive blasting, and indoor welding with natural ventilation.

1 – Agent is rarely present in concentrations that exceed 10% of

the OEL in the breathing zone. Releases if any are of a fugitive (i.e., valve packing) nature. Examples include agents normally used in a closed system (i.e., piping), indoor welding with local exhaust (lab hood or welding exhauster).

8 – Not a 16 or a 1. Examples would include painting large

surfaces indoors or outdoors with a brush or roller, indoor welding using mechanical dilution ventilation outdoor welding without exhaust, outdoor demolition done with copious amounts of water to reduce emissions.

9.) CALCULATE a total score for each agent and include any

information of worker complaints/concerns identified by the SEG FLM or based on institutional history.

10.) DETERMINE if the exposure is acceptable, uncertain, or

unacceptable (Refer to the definitions!):

• IF sufficient information (calculation or model, historical data and its statistical treatment, or referenced literature citation) is available to determine that the exposure is acceptable, THEN

COMPLETE the "Acceptable" notation, AND ATTACH as a pdf file the specific information. • IF monitoring information indicates that the exposure is

not acceptable and cannot be reduced to an acceptable level but protective equipment mitigates the hazard, THEN

COMPLETE the "Unacceptable" notation AND REFERENCE the specific report(s).


5.2.4 Ranking Remaining Agents, Step 1b10, continued • IF the "Acceptable" or "Unacceptable" notation cannot be

selected, THEN COMPLETE the "Uncertain" notation. IF the agent has an acute toxicity, THEN DETERMINE appropriate PPE requirements until the

rating can be changed to "Acceptable" based on additional information.

2. INDICATE on the OSR 4-920 and the IH "Exposure Assessment by Building-

IH" report or Temporary Inventory form if the exposure is "Acceptable", "Unacceptable" or "Uncertain" and the total Score.

3. RECORD under the Minimal Assessment Criteria heading the Risk Assessment

Determination Document (RADD) Number and the Total Score for easy reference and use later on in the procedure.

4. REPEAT Step 1 (a and b 1 through 10) for each agent identified.

Steps 5 through 10 below must be followed when completing the scheduled baseline or during scheduled reevaluations only.

NOTE 1: Any exposure that is not acceptable and the workers are not protected

using engineering controls, administrative controls, or protective equipment is to be communicated to management immediately so that the exposure will be suspended until the hazard can be mitigated.

NOTE 2: Within a SEG, there is no need to repeat evaluations for the same agent

and exposure profile even for different tasks because of an MSDS change from one vendor to another, or minor (inconsequential) changes to the specific MSDS, or different concentrations to the agent (provided the greatest concentration has been assessed). A single RADD may bound the exposure profiles for lower exposures (lower concentrations, lower frequency of task, lower durations of exposure).

NOTE 3: Documents that establish planned work (AHAs, procedure reviews,

PASSPORT packages, work instructions) may be approved once this point in the exposure assessment process is reached.

5. REQUEST IH Program SME review of the analysis, and DOCUMENT that

review in the comment section of the SEG Characterization Form (OSR 4-923).


5.2.4 Ranking Remaining Agents, continued 6. ATTACH the reports to the OSR 4-923 as a .pdf. IDENTIFY the file using the

Building Number, SEG Name and Generation Date (YYMMDD) as the filename (e.g., 717Amechanics080520.pdf).

7. CREATE a summary table that reflects those products evaluated, the applicable

RADD number, and an acceptable, uncertain, or unacceptable decision. 8. Separately RANK order the scores of the uncertain and unacceptable agents to

develop a priority list for further control/assessment. ADJUST the position of any agents as necessary based on substance specific requirements or management direction.

9. REVIEW the IH Exposure Assessment Tool report generated in Section 5.2.4,

the rankings from the step above, and recommendations with the Facility H&S Manager and Line Manager to develop a facility sampling prioritization plan.

10. DEFINE priority with management for working off uncertains versus proceeding

to the next SEG in the Exposure Assessment Project Schedule.

NOTE: With respect to the relationship between exposure assessment and

activity level analysis, only the top 10 % of ranked and uncertain agents are to be addressed by management formally. This necessitates sampling plans and activities to be established as "controls" in AHA, or priority by management in alternate means of reducing uncertainty (modeling, subcontracting technical expertise, etc.).

11. ESTABLISH a STAR commitment assigned to the Field H&S Manager

scheduling reassessment for the facility owner as defined in the frequency of assessment table in Section 5.2.

6.0 RECORDS [S/RID 5]

Records created in support of this procedure are retained and managed in accordance with Procedure Manual 1B, Procedures MRP 3.311 and MRP 3.112. OSR 4-920, Risk Assessment Determination Documentation OSR 4-922, Hazard Characterization and Workplace Description OSR 4-923, SEG Hazard Characterization


7.0 REFERENCES 1Procedure Manual 1B, MRP 3.31, Records Management 2Procedure Manual 1B, MRP 3.11, WSRC Document and Correspondence Numbering System [S/RID (Standards/Requirements Identification Document) 1] 10CFR851.21(a)(1) [S/RID 2] 10CFR851.21(a)(2) [S/RID 3] 10CFR851.21(a)(3) [S/RID 4] 10CFR851, App. A. 6(a) [S/RID 5] 10CFR851.26(a)

8.0 ATTACHMENTS

1 Sample of Temporary Inventory Form


Attachment 1: Sample of Temporary Inventory Form

SAVANNAH RIVER SITE Manual: 4Q 1.1 Procedure: 101A ... · Industrial Hygiene support to spills,...

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