berkeley lab exposure assessment: thoughts after an ism audit tim roberts, industrial hygiene jim...
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Berkeley Lab
Exposure Assessment: thoughts after an ISM Audit
Tim Roberts, Industrial HygieneJim Floyd, ALS
LBNL
Berkeley Lab
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
Berkeley Lab
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
Berkeley Lab
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…”
Berkeley Lab
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
Berkeley Lab
Questions
• Tiered Approach—Risk-based screening
• Qualitative vs. quantitative assessments—when is IH Professional Judgment applicable?
• Role of line management vs. EHS organization
Berkeley Lab
Employees that will not need an Exposure Assessment
Proposed Approach
Hazard ID
ExposureAssessment
(quant.)Hazard Assessment
(qualitative)
3-tiered system
Berkeley Lab
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
Berkeley Lab
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
Berkeley Lab
Next Steps
• Complete a regulatory requirements analysis 9/09
• Benchmarking 12/09
Berkeley Lab
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
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