IH Strategies in Bad Economic Times

Start with a thorough inventory. Then "rank" exposure groups for potential monitoring.

DEVELOPING and implementing a comprehensive industrial hygiene strategy can be daunting even under the best circumstances. Ensuring proper characterization, prioritizing actions, performing monitoring, and interpreting the results requires process knowledge, technical skills, sufficient personnel, and of course, money. When you are required to develop the same strategy and properly implement it when finances are a significant issue, though, the situation can be overwhelming. Under these circumstances, many organizations end up doing absolutely nothing, opening themselves up to both regulatory and toxic tort liabilities.

So, knowing that you cannot do everything, what can you do? What is the best approach? How can you balance the need to protect your workers with the need to ensure sound fiscal management?

One approach that has been implemented in a variety of industries is described here. It involves developing a framework for both short- and long-term strategies for assessing employee exposures to chemical and physical agents. Although annual re-assessments of the strategy are still required, the typical strategy would span three or more years.

Assessing the Work Environment
The first step involved in developing any industrial hygiene strategy is a thorough characterization of the work environment. This involves the traditional "walk-around" but also includes such things as:

  • Engineering design reviews
  • Reviews of operational procedures
  • Development of complete chemical, physical, and biological agent inventories, with a characterization of the agents for health-effects data, regulatory requirements, exposure limits and guidelines
  • Workforce characterization by job title/description, task analyses, and numbers of workers of the various types
  • Determination of the applicability of homogenous exposure groups, which may be established based on job descriptions, tasks performed, chemicals handled, processes involved in, etc.
  • A review of any quantitative data that has been obtained historically.
  • Once this characterization is complete, you should be armed with a complete inventory of workers, tasks, agents, and potential exposures. You should now be able to assign each worker to at least one homogenous exposure group.
  • With this information in hand, the next step in developing the strategy is the most important. You must now "rank" exposure groups for potential monitoring. Optimally, the ranking will be based on "weighted" criteria such as:
  • Availability of an OSHA Permissible Exposure Limit (PEL), an ACGIH Threshold Limit Value (TLV), or some other Occupational Exposure Limit (OEL)
  • Potential for the agent to be absorbed through the skin
  • Availability of applicable Biological Exposure Indices (BEIs)
  • Concentrations and physical states of the agents handled
  • The actual toxicity of the agents handled and the likelihood that workers may be exposed above toxic or published levels
  • Acute vs. chronic health effects, warning properties, and the reversibility of effects resulting from overexposure
  • Presence or absence of appropriate engineering and/or administrative controls
  • The number of personnel actually exposed to the various agents
  • The frequency of exposure
  • Historic or current medical issues
  • Historic exposure monitoring results

Regardless of which of the criteria you choose (and those may vary greatly by the type of work environment in which you operate), the idea is to categorize the agents so that the quantity, frequency, and immediacy of the monitoring are based on risk. This will then allow you to spread your exposure assessments over a longer timeframe. (See Table I for an example of a general strategy summary.)

Table I

RISK RANKING*

CATEGORY

2003 Air Monitoring

2004 Air Monitoring

2005 Air Monitoring

2003 Biological Monitoring**

>1000

A

All identified compounds

All identified compounds

TBD

All identified compounds

625-999

B

50% of identified compounds

75% of identified compounds

100% of identified compounds

50% of sampled compounds

400-624

C

None

50% of identified compounds

75% of identified compounds

None

<400

D

None

None

TBD

None

* A new criterion will be added in 2003 to address historical monitoring results; this will cause a shift in category structure initially and on specific rankings each year based on monitoring results.

** For those agents with established or accepted BEIs.

Conducting Exposure Monitoring
When the time comes to perform the exposure monitoring, you may find this is not as straightforward as it may first appear. Where are the sources of exposure, what are the exposure pathways, and which is the "critical" pathway?

What are the objectives of your monitoring? Are you establishing a baseline, doing diagnostic monitoring, or monitoring primarily for compliance purposes? Are you going to do area or personnel monitoring? What other options do you have? How about biological monitoring or skin patch monitoring? Have you evaluated historical medical surveillance results and/or evaluated control systems? What preventive maintenance procedures are in place, and are they properly implemented?

The proper approach depends on what you identified during your characterization and on what you are trying to accomplish. Ultimately, you want to obtain sets of exposure and/or concentration data that can be used to evaluate the acceptability of exposures among workers within the various homogenous exposure groups and to devise effective control strategies, to obtain sets of data to demonstrate actual exposures, and to obtain data regarding control system performance.

Interpretation and Reporting
Now that you have the data, you must interpret it, make decisions, and then provide recommendations in the form of a report. Using the data you have, you can apply professional judgment, statistical analysis, and other tools to evaluate for trends, hot spots, or other issues. You may determine that more data is required. You may make recommendations for improved engineering controls, modified administrative controls, or even increased use of personal protective equipment for a short time.

Annual re-assessment of your strategy based on results obtained may lead you to change your strategy somewhat. Some agents may be moved down in rank based upon results obtained, while others may move up in rank.

Changes to processes, receipt of employee health complaints, indications of concerns based on medical surveillance, availability of new health-effect data, and even new regulations may result in major changes to the strategy. What is most important, though, is that you have a legal and a moral responsibility to ensure that workers are adequately protected. Doing nothing, even in a financially restricted environment, is not an option.

Thinking strategically and basing your strategy on sound risk assessments utilizing properly evaluated criteria will allow for successful evaluation of and improvement to workplace exposures.

This article originally appeared in the October 2003 issue of Occupational Health & Safety.

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