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Energy Facility Contractors Group Safety Working Group Industrial Hygiene / Industrial Safety Technical Team Dina Siegel, Los Alamos National Laboratory John Hill, Savannah River Nuclear Solutions LAUR 15-23807
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Compliance: 10 CFR 851 §851.21 Hazard identification and assessment. (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;
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Compliance: 10 CFR 851 Appendix A 6. Industrial Hygiene Contractors must implement a comprehensive industrial hygiene program that includes at least the following elements: (a) Initial or baseline surveys and periodic resurveys and/or exposure monitoring as appropriate of all work areas or operations to identify and evaluate potential worker health risks
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Guide: ◦ DOE G 440.1-1B Ignacio, JS and Bullock, WH, Strategy for Assessing and Managing Occupational Exposures, Third Edition, AIHA Press, Fairfax, VA, 2006 (fourth edition is imminent) NIOSH and OSHA analytical methods Use of AIHA or equivalent accredited laboratories
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◦ DOE G 440.1-1B Monitoring results should be recorded with documentation that describes the tasks and locations where monitoring occurred and identifies: Workers monitored or represented by the monitoring; Sampling methods and durations; Control measures in place during monitoring (including use of personal protective equipment); Job hazard and location; and Any other factors that may have affected sampling results.
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DOE G 440.1-1B Quality assurance records for exposure assessment activities should be maintained and retrievable for the monitoring equipment and analytic methods used.
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DOE G 440.1-1B Exposure monitoring data should include: The date(s), number, duration, location and results of each of the samples taken, including a description of the sampling procedure used to determine representative employee exposure where applicable; A description of the sampling and analytical methods used and evidence of their accuracy; The type of PPE worn, if any; Name, social security number, employee identification number if different from the social security number, and job classification of the employee monitored and of all other employees whose exposure the measurement is intended to represent; and The environmental variables that could affect the measurement of employee exposure.
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Data/Resources ◦ Job classifications Bureau of Labor Statistics (BLS) Standard Industrial Classification (SOC) definitions Office of Personnel Management (OPM) Position Classification Standards ◦ Data Collection DOE Technical Standard Beryllium-Associated Worker Registry Data Collection and Management Guidance Industrial hygiene data dictionaries, e.g., Industrial Hygiene National Database Working Group
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Data Collection: AIHA 1 Consider how exposure data will be used. Establish and maintain records so that pertinent questions can be answered accurately and within a reasonable period of time Recognize that other disciplines may have an interest in the data, e.g., medical, legal 1 AIHA: A Strategy for Assessing and Managing Occupational Exposures, AIHA Press, American Industrial Hygiene Association, Fairfax, VA 2006
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Data: Need to determine 1 : Agents associated with a work area or Similar Exposure Group (SEG) Which employees are in which SEG Magnitude and variation in exposures Processes or tasks associated with exposures Length and frequency of exposures Medical surveillance enrollment and disenrollment A worker’s occupational history 1 AIHA: A Strategy for Assessing and Managing Occupational Exposures, AIHA Press, American Industrial Hygiene Association, Fairfax, VA 2006
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Available Data Location, process/operation/task Chemical, physical, and biological agents at the site SEGs Worker data (name, worker id, job title, organization, SEG) Sampling data
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EFCOG Safety Working Group: DOE Sponsor: Pat Worthington ◦ Technical Task Group: Industrial Hygiene/Industrial Safety Task: WSH-2015-09 Listing and description of data elements for exposure assessment that should be documented in formal records and communicated to workers and management (September 15, 2015)
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Establish consistency in contractor recording and reporting of exposure data Aid in providing information to DOE in the event of a data call
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Establish a common list of data elements to record. Establish data elements that can be shared within DOE Provide descriptions of the data elements Develop pick list of entries where possible ◦ Hazards, PPE, Controls, etc.
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Specific Agent and Chemical Abstract Service (CAS) number Activity/Task Description SEG Description Controls used – Engineering, PPE, Administrative OEL used (source, type, e.g., 8 –hour Time-Weighted Average (TWA), ceiling) Units for lab result, units for TWA Level of Detection, Level of Quantification Sampling and Analytical Method Sample Type (e.g., personal breathing zone) Lab Result, TWA result Conclusions (e.g., exposures likely to exceed OEL but controlled, limited exposure above OEL, unlikely to exceed OEL)
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Location of sampling Date of sampling Measurement times (begin, end, total minutes) Length and frequency of exposure Employee name/unique id, job classification, including represented employees, work schedule Sampling strategy/reason for sampling Assumptions for unsampled time Observations/comments, factors that may have influenced sample results Calibration information (e.g., pre and post flow, instrument settings)
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Task descriptions SEG descriptions How to develop and maintain a template Minimum elements to include Field definitions
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September 15, 2015: Listing and description of data elements for exposure assessment that should be documented in formal records and communicated to workers and management (September 15, 2015) Discussion and refinement at 2015 Fall EFCOG SWG IH/IS meeting at Los Alamos National Laboratory
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