industrial hygiene monitoring how much is enough? when can it stop?? presented by: jonathan haas,...
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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
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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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What I Typically See
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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What I Typically See
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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What I Typically See
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
Your daughter works it
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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What Predicted Exceedance % is OK?
Carcinogen
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Carcinogen
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Situation A Situation B
Do controls change the answer?
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What Predicted Exceedance % is OK?
Lung damage
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Lung damage
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Situation A Situation B
Do controls matter, really?
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What Predicted Exceedance % is OK?
Irritant only
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Irritant only
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Situation A Situation B
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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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 Case Both means < 50% LimitStart Periodic Monitoring
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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 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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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 0.3%Continue at 8 samples / year
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Definitely looks lognormal when plotted
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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 <0.1%Reduce to 4 samples / year
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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 = 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