Industrial Hygiene Monitoring How Much is Enough? When Can It Stop?? Presented by: Jonathan Haas,...

Industrial Hygiene MonitoringHow Much is Enough?When Can It Stop??

Presented by:Jonathan Haas, CSP, CIH

Orange Park, Florida 32073(904) 298-1817

STAR Consultants, Inc.580 Bellerive Dr. Unit 5B

Annapolis, MD 21409(410) 349-9713 (410) 757-0524 FAX

www.starconsultants.net

SamplingPresented at:

AIHA Florida

Annual Region IV Conference

Tampa, FLFriday March 24, 2006

You may download this presentation by going to www.starconsultants.net

http://www.starconsultants.net/

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What I Typically See

Industrial hygiene at a company location is handled by a safety manager

The safety manager typically has been on the job for less than two years

Industrial hygiene monitoring is conducted by a consultant

Reports from prior years have not been read by the current safety manager

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Monitoring is conducted to a list of contaminants that was prepared some time ago – sometimes many years ago

Monitoring is repeated this year because it was on the list last year and has always been monitored. The reason why is not known.

Employees who are monitored are notified of the results

Employees similarly exposed are not

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Medical services, whether on site or contract occupational, have not been provided with summaries of data

Exposure monitoring results, if provided to Medical services occasionally are filed in the employees “jacket” but usually are filed somewhere else

Data summaries for similar exposure groups are not available anywhere on site

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IH Consultants rarely are contracted to review all prior data and provide summaries and recommendationsIH Consultants rarely are contracted to fully document all materials by similar exposure group, the toxicity, usage and controls – resulting in a fully documented QEASafety staff rarely have a process to review new materials to make a determination if monitoring is needed before full production

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Good HSMS Programs Help

Employee complaints (coughing, irritation, etc.) are signs that one or more Health and Safety Management Systems are not working properly. IH Consultant observations for defective ventilation, unacceptable use of PPE, or improper handling of materials is another sign that HSMS programs are defectiveWhat one HSMS program misses, another is supposed to catch – see next page

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WORKSITEHAZARD

ANALYSIS

WORKSITEHAZARD

ANALYSIS

HAZARDPREVENTION& CONTROL

HAZARDPREVENTION& CONTROL

SAFETY& HEALTHTRAINING

SAFETY& HEALTHTRAINING

• PolicyGoals, ObjectivesPlanning• Visible Top Management Leadership• Responsibility and

Authority• Line AccountabilityResourcesContract Worker

CoverageWritten S&H

Management System• Annual Self-Evaluations

Baseline InventoriesRoutine Hazard

Analysis (JHA – Ergo)

Change (Pre-use) Hazard Analysis

IH Program Routine Self-

Inspections(required, general,

specific)Reporting System• InvestigationsTrend Analysis

Certified Professional Resources

Hazard Elimination and Control MethodsEngineeringAdminPPE

Work Rules/Practices/ Discipline

Occupational Health Care

Preventive Maintenance

• Tracking of Corrections

Emergency Preparedness

• ManagersSupervisorsWorkers

Contractors•CommitteesEmergenciesPPE

30 Elements OSHA’s VPP ElementsIH affects those noted

Management Commitment

Management Commitment

EmployeeInvolvement

EmployeeInvolvement

• Encouragement• Participation• (Committees)

1/26/89 & 3/25/03

MANAGEMENTLEADERSHIP

MANAGEMENTLEADERSHIP

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Clients Need

A process for determining monitoring needed based on a standardized qualitative exposure assessment process that results in a numberA process for taking initial measurements or contracting for same that determines if additional monitoring is neededA process, when initial measurements indicate a continuing need for monitoring, for determining the number of samples needed to make the next decision

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Hypothetical Case 1Client has determined that a new material should be monitored Discussions with employees reveal that certain situations results in worse exposure, based on their knowledge of the jobMonitoring of those worst case exposures using a validated method of collection with analysis in a AIHA accredited lab shows all samples “Below Detection Limit” Do you recommend additional tests?

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Hypothetical Case 2Client has determined that a new material should be monitored Discussions with employees reveal that certain situations results in worse exposure, based on their knowledge of the jobMonitoring of those worst case exposures using a validated method of collection with analysis in a AIHA accredited lab shows all samples above the Exposure LimitDo you recommend additional tests?

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Hypothetical Case 3Client has determined that a new material should be monitored Discussions with employees reveal that certain situations results in worse exposure, based on their knowledge of the jobMonitoring of those worst case exposures using a validated method of collection with analysis in a AIHA accredited lab shows 50% of the samples above the Exposure LimitDo you recommend additional tests?

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Hypothetical Case 4Client has determined that a new material should be monitored Discussions with employees reveal that certain situations results in worse exposure, based on their knowledge of the jobMonitoring of those worst case exposures using a validated method of collection with analysis in a AIHA accredited lab shows none of the samples above the Exposure LimitDo you recommend additional tests?

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Professional JudgmentIf you are called to testify in a court case involving your monitoring, your exposure assessment determination process will be attacked

If you used a validated sampling method and accredited lab, that is an expected question

What will you say when a statistical analysis of the samples you took, which were all below the exposure limit, shows that 5% overexposures are predicted?? Did you advise the client?

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Document The ProcessYour client needs to understand how you make recommendations for added sampling, fewer samples, or the termination of samplingPulling the cloak over your head and saying “Trust me – I know what I’m doing” makes you either Obi Wan or the Evil Sith depending on who is askedShowing your client a strategy based on statistics and probability, with graphs of examples, gains you credibilityYou will not be stammering when attacked as a witness

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Industrial Hygiene Data

Before we can debate how much is needed and when can we stop, we need to debate how much predicted overexposure is acceptable

The debate is NOT about how much actual overexposure is acceptable, but is about how much predicted overexposure is acceptable

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How Much Exceedance is OK?

Does the acceptable percentage predicted to exceed the limit depend on what the material’s toxicity – the reason for the limit?

Does the acceptable percentage predicted to exceed the limit depend on who is asked?

Employees

Management

The industrial hygienist

Yes

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What Predicted Exceedance % is OK?

Reproductive toxin

Adequate controls

Good PM for controls

Knowledgeable people

Good concern handling

Great supervision

Good mgmt of change

Your daughter works it

Reproductive Toxin

Iffy controls

Poor PM for controls

MSDS available

Poor concern handling

Weak supervision

No mgmt of change


Situation A Situation B

Do controls change the answer?

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The Wall Street Journal TestHow would management react to having a Wall Street Journal article describe how they were knowingly permitting employees to be potentially overexposed to a reproductive toxin, based on available data?And describing how one out of five children have observable birth defects and that data predicts that your plant averages one day a year over the exposure limit? (0.4% of 250 days)

With anger, right?

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Carcinogen

Adequate controls




Great supervision

Good mgmt of change


Carcinogen

Iffy controls


MSDS available


Weak supervision

No mgmt of change



Do controls change the answer?

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Lung damage

Adequate controls




Great supervision

Good mgmt of change


Lung damage

Iffy controls


MSDS available


Weak supervision

No mgmt of change



Do controls matter, really?

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Irritant only

Adequate controls




Great supervision

Good mgmt of change


Irritant only

Iffy controls


MSDS available


Weak supervision

No mgmt of change



Do controls matter, really?

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Available SoftwareReally easy to use: Ihstat.xls

Determines whether samples are normally distributed or log normally distributed

Determines % predicted to exceed limit

Really terrific to use: MinitabSame as above, plus terrific graphs

Used by many for Six Sigma projects

Obsolete: Logan

Unusable: NIOSH Decision Logic graphs

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Here is a Minitab graph of the same data

Monitoring Decisions

Starting from no data at all

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IH Monitoring Decisions Based on Statistical Data Results

Take three “Worst Case”* samples

Any sample > full or short term limit

All three < 10% of limit

All < limit; both means <50% of limit

All < limit; either mean >50% of limit

Reduce exposure

No more samples needed

Start PM

*Worst case sampling can be personal samples or area samples and can last for only as long as the agent is handled that day. If sampling is just for 15 to 30 minutes, the result is compared to a Short Term Limit ( or calculated STEL ). The result is also to be converted to an 8-hour time weighted average and compared against that full shift exposure limit.

InvestigateReduceRepeat

Calculated STEL Full shift limit 0 to 1 PPM; STEL = 3 times full shift limit;

is based on full shift Full shift limit 2 to 10 PPM; STEL = 2 times “ “ “

exposure limit when Full shift limit 11 to 100 PPM; STEL = 1.5 times “ “

none is published Full shift limit >100 PPM; STEL = 1.25 times “ “ “

No

Yes

Yes

No

No

Yes

Yes

(See next page)

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Worst CaseBoth means > 50% Limit Investigate, Reduce, Repeat

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Reduce exposure


Start PM







No

Yes

Yes

No

No

Yes

Yes

(See next page)

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Worst Case Both means < 50% LimitStart Periodic Monitoring

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Reduce exposure


Start PM







No

Yes

Yes

No

No

Yes

Yes

(See next page)

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Worst Case Both means < 10% LimitNo Predicted ExceedanceStop Monitoring

Monitoring Decisions

Based on Results of Periodic Monitoring

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Periodic Monitoring Decisions based on Statistics

Take 8 full-shift samples, random

Any sample > Limit Conduct exposure assessment “Worst Case”

Yes

No

% Predicted >Limit < 0.1%

Yes

Take 4 random samples / year

No

%Predicted >Limit = 0.1 - 5%

Yes

Take 8 random samples /year

No

%Predicted >Limit = 0 Yes

Conduct exposure assessment“Worst Case”

% Predicted >Limit > 5% Yes

Stop monitoring for this.

No

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Exceedance Predicted 1.4%Continue at 8 samples / year

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Yes

No


Yes


No


Yes


No





No

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Exceedance Predicted 0.3%Continue at 8 samples / year

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Definitely looks lognormal when plotted

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Yes

No


Yes


No


Yes


No





No

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Exceedance Predicted <0.1%Reduce to 4 samples / year

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Yes

No


Yes


No


Yes


No





No

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Exceedance Predicted = 0.000%Communicate & Stop Sampling

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Precautions

Some regulations mandate monitoring

Changes in the workplace will change QEAProduction rate

Changed ventilation

Different chemical composition

Changed methods for handling

Even though nothing has changed, management may expect additional sampling just because it is time to confirm all’s well

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Summary

Statistics and probability can be used to modify sampling frequency

Use of graphs to communicate data to similar exposure groups will enhance HAZCOM

Use of graphs will enhance Medical program understanding of workplace stressors

Use of graphs for tracking and trending is an expectation of VPP under OSHA

Industrial Hygiene Monitoring How Much is Enough? When Can It Stop?? Presented by: Jonathan Haas,...

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