Page 34 - OHS, September 2020

INDUSTRIAL HYGIENE
identification and assessment of traditional “safety” considerations, it also emphasizes the importance of occupational health and, essentially, industrial hygiene.
Historically, many organizations have developed and applied processes to identify, evaluate and control risks of, in particular, a physical safety nature. Over time there has been an emphasis on hazards stemming from things like falls, the hazardous motion of tools and machinery, process hazards (e.g. pressure, temperature) and acute risks from particular types of work. Risk assessments that include chemical/material considerations will often only identify chemical-related process risks that can result in explosions, fires and chemical releases to the environment, but have not always considered the occupational health component of risk, especially chronic exposures to toxic substances.
ANSI/ASSP Z10.0 emphasizes that the occupational “health” side of things should also be included in assessments and systems. What many may consider “industrial hygiene” (IH) issues are included in this part of assessment. The Standard says that organizations shall identify hazards for risk assessment, and that the assessment of OHS risks includes: “health exposures (e.g. chemical, physical and biological agents), human factors (includes ergonomics) [and] workplace violence and safety hazards” (ANSI/ ASSP Z10.0, section 8.3).
The corresponding guidance manual for ANSI/ASSP Z10.0 (ASSP Z10.100-2019 Guidance and Implementation Manual for ANSI/ASSP Z10.0-2019 Occupational Health and Safety Management Systems) contains a helpful chapter discussing this new emphasis. It includes examples of several types of IH stressors that may need evaluation.
Those who have used earlier editions of the Z10.0 standard may have wondered to what extent industrial hygiene factors should be included in their risk assessments. Practically speaking, ANSI/ ASSP Z10.0 now provides examples of hazards of an IH nature that should be included.
Competence in Industrial Hygiene
While the standard places an increased emphasis on IH, not everyone has the background to anticipate, identify, assess and control that sort of risk. Persons who may be great at identifying “safety” issues and using various qualitative or semi-quantitative (matrix style) risk assessment tools may be left wondering how to apply the concepts to sub-acute IH aspects. Depending upon the industry one is in, IH can include many different topics and areas of expertise, with a wide variety of considerations for planning, sampling technology and data interpretation.
Traditional IH Assessments and the
Link to OHS Risk Assessment Requirements
This article will discuss classic personal air sampling (exposure assessments) and noise testing (sound level measurement and noise dosimetry) factors—what many think of as IH monitoring.
There can be a variety of drivers for why an organization may want to conduct IH monitoring. This can include the assessment of compliance with OSHA and company requirements, the determination of adequacy of engineering controls (for example, local exhaust ventilation), the evaluation of employee complaints and other reasons.
ANSI/ASSP Z10.0 expects that organizations will assess risk to protect worker health and to know and address “legal (e.g. OSHA or contractual) and other requirements” (which could include internal requirements) as well as the needs and expectations of interested parties, including workers.
How should one link these IH related risk assessments while balancing an organization’s risk assessment framework? The organization’s risk policy and assessment methodology should be developed by the organization in a way that best accounts for its needs. Certain methodologies may not mesh well with IH information. There is no one right way to combine the information, and no one technique that fits all scenarios. If there is a hierarchy of assessment documentation, the “higher level” documents should in some way link to IH exposure assessments that contain an evaluation of monitoring results, compliance and relative risk. Since work processes and monitoring results can fluctuate, the summary level documents are probably not where you should try to keep detailed and evolving monitoring results. Third party software is available to document, statistically evaluate and trend results.
When is IH sampling needed? A full discussion of this topic is not possible here; the answer must be determined based upon precise company processes and applicable regulations. However, the next few paragraphs describe some considerations.
Fundamentally, employers are obligated to provide a safe workplace. It is up to the employer to ensure that occupational exposures to toxic materials, and noise exposures, are within allowable limits. That does not mean that all exposures need to have air sampling or noise testing accomplished, although there sometimes there are regulatory requirements to do so (depending upon the substance or situation).
For never-before-sampled processes, to determine what actions may be needed, an individual needs to evaluate factors like material inputs and toxicity, applicable regulations, work tasks, mechanical processes and environmental variables. There should be a reason for sampling. In some cases it is necessary and appropriate, and yet in other cases, a qualified individual can review situational factors and historical or related data, and determine that sampling is not required.
The need for follow-up testing should be reassessed on a periodic basis. Some considerations include:
■ OSHA regulations sometimes require periodic sampling after initial sampling, depending upon how close the results were to regulatory limits and other factors.
■ Changes to raw material composition and form can change exposure levels. If chemical/material “inputs” have changed, sampling may be indicated.
■ Exposures can vary, and the potential for variation should be taken into account. Differences can exist between areas, shifts, individual workers, time of year, etc.
■ IH monitoring technology continues to improve. Would it make sense to conduct monitoring using newer technologies that sometimes provide better data?
■ Evaluate whether or not COVID-19 factors have affected materials of use, production volumes and work methods. If work tasks or control methods have evolved, OSHA sometimes requires new sampling to be done. Even where OSHA does not specifically require it, new sampling may be needed.
30 Occupational Health & Safety | SEPTEMBER 2020
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