brookhaven science associates u.s. department of energy prioritizing air sampling needs at bnl...

Brookhaven Science AssociatesU.S. Department of Energy

Prioritizing Air Sampling Needs at BNLPrioritizing Air Sampling Needs at BNL

BNL’s Approach to Completing an Industrial Hygiene Exposure Baseline Monitoring Program

Presented by Robert Selvey

BNL Industrial Hygiene ManagerNovember 30 2007


Hey Boss, I need to complete an IH baseline

O. K.

[long awkward pause]


I mean, WE need to complete an IH baseline

O.K.

Get to it!


That’s it ?

Get to it ?

I guess.

What’s an IH baseline anyway ?


Conducting exposure surveys of Industrial Hygiene Hazards on ALL our operations

Eeek !


Well, can I have the money and the people ?

For What ?


For the IH baseline !!!

You mean it takes resources?


Duh !!

I mean “Yes sir”How much ?


Well, its required by DOE & OSHA How much ?


You know:10 CFR 851, ISM and stuff like that

How much ?


If we don’t do it, we won’t be in compliance

How much ?


We can get PAAA fines

How much ?


We can get audit findings

How much ?


Time goes by… Weeks later


I have beenthinking a lot about the IH Baseline

I vaguely remember


You wanted to know about the resources

Oh Yeah, How much ?


Is “lots” close enough ?

What do you think ?


[Ummm]How big is this project anyway ?


Is “really big” close enough ?

What do you think ?


[Sigh] [Sigh]


He doesn’t get it

He doesn’t get it

Disclaimer: The preceding presentation was fictionalized. Any resemblance to

actual persons or organization is strictly coincidental.


Prioritizing Air Sampling NeedsPrioritizing Air Sampling Needs

An Approach to completing an Industrial Hygiene

Exposure Baseline Monitoring Program

Getting Management’s commitment for the resources

Conducting a really big, technical project in a way that is achievable


What was the process BNL used to quantify the What was the process BNL used to quantify the “how much $$$” and “what to sample” ?“how much $$$” and “what to sample” ?

The Product

Completed BaselineSurvey

The mysteriousblack box

of priority, funding,

and resources

The Need

Exposure Monitoring

Tools to determine the “SIZE” of the

need

Tools to determine the “SIZE” of the

need

Need to get MANAGEMENT

to do things it FINANCIALLY hurts

to do

Need to get MANAGEMENT

to do things it FINANCIALLY hurts

to do

Tools to PLAN what to

monitor

Tools to PLAN what to

monitor

Tools to DIRECT

PROGRESSon the project

Tools to DIRECT

PROGRESSon the project


Getting management do things it financially hurts to doGetting management do things it financially hurts to do

Approaches It’s required by regulations. It’s the right thing to do- it’s impacts people’s lives. It reduces liability. It will save money in the long run (ROI). We got an audit finding, it must be corrected.

Approaches• The project was added to a Deficiency Reporting System (NTS) that has

accountability by senior management.• The project was added to high level Strategic Planning & Improvement

Commitments (Site Business Plan).• It was linked to a program already understood by senior management (ISM).• It became a “fix” in a larger corrective action plan (10CFR851 Gap Analysis).

We inserted our need We inserted our need into the thingsinto the things senior managers understand and are tracking senior managers understand and are tracking

These are reasons to do it, These are reasons to do it, but not viable approaches but not viable approaches that that Management can act on.Management can act on.


Feedback and Improvement

Industrial Hygiene Baseline Monitoring- What is the right program ?

10CFR851 Section 6: “Contractor must implement…

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.”


Initial or baseline surveys [and periodic resurveys and/or exposure

monitoring as appropriate] of all work areas or operations to identify and



[Initial or baseline surveys and periodic resurveys and/or exposure

monitoring] as appropriate of all work areas or operations to identify and


Everything gets monitored

Only the big stuff gets monitored



Industrial Hygiene Baseline Monitoring


Initial or baseline surveys [and periodic resurveys and/or exposure

monitoring as appropriate] of all work areas or operations to identify and


AIHA: A Strategy for Assessing and Managing Occupational Exposures:

“Ideal strategy for defining the exposure profile ...monitor each worker’s exposure each day… generally not possible, a subset of workers and days … is chosen

Representative Sampling Approach

Everything gets monitored

BNL: Everything [every type of operation] gets monitored using a Representative Sampling Approach


Making the program technically sound to regulators

Fundamental Guidance Documents

AIHA: A Strategy for Assessing and Managing Occupational Exposures

NIOSH: Occupational Exposure Sampling Strategy Manual

We balanced the cost to implement (i.e. reality)

with

“performance based” regulator expectations

by giving BNL a Risk based prioritization of

representative sampling.

The highest risk gets monitored first.


The process in use at BNL

Action 1

BNL IH SMEs envisioned what the final “acceptable” product should be = statistically valid,

representative sampling of all exposure scenarios- facility operations, services, and science.

BNL IH SMEs created a program and developed options for the line organizations to use.

Action 2

The IH SMEs met with the line organization to explain the program and give them options to

meet a commitment: They would complete an IH baseline.

The size of the effort in each organization was determined by the line organization.

The resources needed to met the “size of the effort” for each organization was calculated.

Action 3

The search for the funds to implement the program was done.

Multiple pathways are being used- existing IH staff (reassigned), newly trained technicians, line

organization staff, contractors.



Industrial Hygiene Sampling Needs- Technical Part of the Project

Step 1 Define Scope: Identify Hazard Categories- Done by the site IH SMEs

Welding/Cutting/Brazing Noise Silica Asbestos Beryllium Biohazards Cadmium Chemicals Heat Stress Lead Radiofrequency (RF/MW) Reproductive Hazards Soldering Static Magnetic Fields Confined Space Lasers Ergonomics

Excluded:• Bloodborne Pathogens• Indoor Air Quality



Industrial Hygiene Sampling Needs- Scope

Step 1b Create a Monitoring Priority for the site- Done by the site IH SMEs

Welding/Cutting/Brazing Noise Silica

Asbestos Beryllium Biohazards Cadmium Chemicals Heat Stress Lead Radiofrequency (RF/MW) Reproductive Hazards Soldering Static Magnetic Fields

Confined Space (handled on an entry event basis by line organizations) Lasers (handled with centralized SME evaluation program) Ergonomics (handled with centralized SME evaluation program)

Sampling targeted for every event(based on feedback from previous monitoring)

Monitoring Planned (Representative Sampling, based on exposure potential rating & Feedback from previous monitoring)



Industrial Hygiene Baseline Monitoring- Overview

IH Baseline Monitoring Program

IH Hazard Matrix

IH Needs Calculator

IH Scheduler

Internal ResourcesS&H Rep & line organizations

External ResourcesContractor

Identify Hazards Categories in each line organization

Identify Monitoring Resources needs in each line organization

Identify Specific Monitoring Events, Risk, & Date



Industrial Hygiene Sampling Needs- Resource Determination

Step 2

IH Matrix Identification of Hazards & the applicability in each department

Used in the initial conceptualization of the program

[Has be replaced with other databases and is not

maintained]

Hazards

Organizations

What this Tool did:

• Let line organization’s senior managers grasp the size of the needs in their area / operations.

• Educated them on what Industrial Hygiene is.



Industrial Hygiene Sampling Needs- Resource Determination

Step 3 The IH SMEs developed the IH Needs Calculator, an Excel® spreadsheet to further define the RESOURCES required for regulatory compliance.

For each line organization and each hazard category, an entry was made for:

number of monitoring events x estimate of time for each event =

RESOURCES NEED FOR EACH DEPARTMENT

With existing personnel, the IH Needs Calculator estimated: 11 years to conduct full characterization. -Rejected by Management -

The IH Needs Calculator was used to estimate the number of new term FTE to complete the program in 5 years, 2 years, and 1 year.

Senior management selected and committed resources for 2 year completion.

What this Tool did:

Allowed the line organization and site senior managers to know the

amount of resources needed to characterize their operations and

the site. They could choose to: • Do it themselves with their staff.• Rely on the overhead service providers.• Buy their own expert.• Accept the risk.


Step 3:

Estimate of the resource needs (per line organization)

# of monitoring events (not total samples) needed to characterize exposure

Determined the resource (personnel hours) to conduct monitoring & reporting.

[Has be replaced with other databases and is not maintained]


Industrial Hygiene Baseline Monitoring- IH Needs Calculator

Estimate was made for number of events for:• Source inventory• Area Characterizations- air and surface sampling• Inventory of exposed workers• Personnel Exposure monitoring events

The service provider could be split among various organizations

Hazard



Industrial Hygiene Sampling Needs- IH Scheduler

Step 4. The IH Scheduler is a tool BNL developed (Access® database) to define Exposure Characterization, Hazard Ranking and Sampling Frequency.

The IH Scheduler: • lists planned and completed monitoring events. • assigns a health risk to each events to be monitored.• establishes the frequency for routine monitoring events based on the risk.• determines the date of next monitoring event.• documents the resource to conduct monitoring (by name and estimate hours per event).

It is maintained by line organization units and contains:• Location of the hazard• Operation• Hazard (e.g. noise, chemicals)• Risk Rating• Date of Sampling• Monitoring Resource

What this Tool does:

• Targets the higher hazards operations

• Gives attention to PROACTIVE monitoring




BNL Risk Ranking - Exposure Monitoring Data

Risk Category

Exposure Level Relative Risk Frequency of Monitoring

A

Worker exposure exceeds OEL on TWA8

Significant risk All workers in SEG during each job until PPE requirements characterized, then all workers quarterly

B

Area exposure level exceeds OEL but worker exposure is <TWA8 based on

duration in area

May be at significant risk. Needs further evaluation: compliance with OEL uncertain

25% of workers in SEG, quarterly

CArea/worker exposure is >10%

of OEL to OEL levelModerate risk 10% of workers once per year

DArea/worker exposure <10% of

OEL. Low risk 1 representative sample per year

for three years, then one sample per 3 year cycle

UUnknown area/personal

exposureRisk assigned on best available

guidanceSample on next operation(s) until

characterized as A-D

Exposure Potential is based on:

• Historic Monitoring Data- feedback

• Recently Completed Monitoring- feedback (re-assign rating as needed)

• Professional Judgment Estimate of an IH Professional (based on quantity in use, vapor pressure, potential for aerosolizing, engineering controls, etc.)




IH Scheduler

• Identifies specific tasks to monitor- organization and location

• Assesses the hazard and risk

• Tracks sample date information

LocationLocation HazardHazard & Risk Resources & TimeResources & Time

What is Tool does:

• Allows tracking of the status of:

monitoring completed – versus- monitoring needed.

• Plan for future monitoring based on risk



Industrial Hygiene Sampling Needs- Status

How is BNL doing on completing the baseline

IH Scheduler is tracking 600+ monitoring events (1 per day for 2 yr project). At 13 months, the project is 45+% complete.

7.5 FTE assigned at least part time to the project (from the central IH office).

1.5 FTE are participating from line organization or other service providing groups.

BNL has hired an IH Monitoring Contractor to supplement these resources.

BNL committed to completing 1 round of sampling by the Close of FY08.

If resources remain as committed- BNL will meet the project completion date.




Details on the IH Monitoring Contractor supplementing existing staff

Best Value Contract: A nationally recognized expert with extensive experience in research lab environment IH monitoring and hazard assessments.

Scope Of Work • Contractor interacts directly with departments to establish monitoring schedules,

conduct monitoring & prepare employee notification of monitoring results and individual project reports.

• Contractor reviews all ESRs to determine need for IH monitoring ~ 200 ESRs.




Contractor’s Progress

FY07 May-September 59 monitoring events completed in 4 months (about 0.75 event per day)

– Small quantities of chemicals in small science labs manipulated in hoods (Primary emphasis)

– Area/Personal Noise monitoring for plant engineering– Area surveys for mercury in old labs– Surface wipe sampling around balances and soldering stations

Feedback: Barriers to performance by a contractor hired for a limited period Difficulty in ‘catching’ work in progress in bench scale science. ADS funding process releases money too late in the year: funds only arrive in the

Summer, the season for: grant proposal writing, vacations, etc.


Feedback from bench scale research exposure monitoring

It is a difficult to capture exposure monitoring data on this type of work:• Little advanced notice is provided by researchers.• Work is highly temporal in nature.• Work is highly variable in what is done on any given day.• Work changes nearly every day.• Interval between similar operations being conducted can be very long.• Duration of most operation is typically minutes, making collecting adequate

sample volume difficult.

Subjective• “Faking work” (i.e. simulations for the sake of collecting data) is blasphemy

for most researcher.• The researcher who “get safety” are usually willing and easy to monitor,

those that view safety as a “necessary evil” are more difficult to successfully connect up with for monitoring.




IH Monitoring Contractor Phase 1 Monitoring in “Small Science” Final Report

“Without exception, [bench scale chemistry work] exposures did not approach ACGIH, BNL and /or OSHA exposure limits for chemical tasks performed within functioning chemical fume hoods.”

“[Future] Sampling priority would likely be low for compounds with vapor pressure up to 200-mm mercury and quantities up to 6-liters when used in a chemical fume hood or a closed system.”

“An exception could include a material with a very low exposure limit, i.e., 1-ppm or less, and reasonably high vapor pressure, i.e., 100-mm of mercury, when handled in quantities greater than 100-mls.”

Conclusion BNL draws for this effort:

• An “independent” ESH expert on laboratory-scale science confirms the logical expectation that bench-scale experimentation exposures are low.

• BNL will now target the bulk of our monitoring resources (when staffing drop in FY09) on “facility operations”, “services” and “construction”, with a continued but lower emphasis on “bench scale science”.

Conclusion BNL draws for this effort:

• An “independent” ESH expert on laboratory-scale science confirms the logical expectation that bench-scale experimentation exposures are low.

• BNL will now target the bulk of our monitoring resources (when staffing drop in FY09) on “facility operations”, “services” and “construction”, with a continued but lower emphasis on “bench scale science”.


Conclusions

IH Baseline Project

SMEs answered management’s question of “How Much $”- [FTE / time frame].

SMEs packaged the project into programs the senior managers were already tracking.

Line organizations understood their needs and commitment.

Creativity was used to fund the program by multiple pathways.

Prioritizing IH Monitoring Needs

A representative sampling, risk based sampling strategy is used- that makes the program

realistic, attainable, and justifiable.

Feedback was constantly used to refine both processes-

Revised resource estimates.

Revised risk rankings.

Revised planned date of future monitoring events.

New operations were constantly added as more field work discovered needs.


Thank you for your attention

Questions??

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