Lab Safety Plan - Chemical Exposure Assessment

11.   Chemical Exposure Assessment

 

11.1. Regulatory Requirements

11.1.1. It is University policy to comply with all applicable health, safety and environmental protection laws, regulations and requirements. PERRP(Public Employee Risk Reduction Program) requires that all employers “measure an employee’s exposure to any substance regulated by a standard which requires monitoring if there is reason to believe that exposure levels for that substance exceed the action level (or in the absence of an action level, the exposure limit).” Repeated monitoring may be required if initial monitoring identifies employee exposure over the action level or exposure limit. 

11.1.2. OSHA regulates Permissible Exposure Limits (PELs) for airborne contaminants to which “nearly all workers may be exposed daily during a 40-hour workweek for a working lifetime (of 40 years) without adverse effect”, are based upon an 8-hour Time-Weighted Average (TWA) exposure. Thus, the PELs are the maximum permitted 8-hour TWA concentration of an airborne contaminant without respiratory protection. OSHA has also defined Short Term Exposure Limits (STELs) as the maximum TWA exposure during any 15-minute period, provided the daily PEL is not exceeded and Ceiling (C) exposures that shall not be exceeded at any time.

11.1.3. OSHA has listed established PELs, STELs and Ceiling exposures for chemical contaminants in the NIOSH Pocket Guide to Chemical Hazards.  In the absence of a published Ceiling limit, OSHA requires employee exposure to concentrations above the PEL be controlled to prevent harmful effects. Further, OSHA has promulgated specific standards covering several regulated carcinogens, which may include an Action Level (AL), triggering medical surveillance requirements or the imposition of a specific Excursion Limit (such as for asbestos) with a unique measurement of the duration of an exposure.

 

11.2. Exposure Assessment Overview

11.2.1. All Kent State employees require protection from exposure to hazardous chemicals above PELs, STELs and Ceiling concentrations. The profession with expertise in exposure assessment monitoring is Industrial Hygiene. At Kent State, the person supervising, directing, or evaluating the exposure assessment monitoring must be competent in the practice of industrial hygiene. EHS employs personnel with this expertise or will use a consultant. General questions regarding exposure assessment can be directed to EHS.

11.2.2. Minimizing exposure may be accomplished using a combination of engineering controls, administrative controls and personal protective equipment, listed in order of priority. Assessing exposure to hazardous chemicals may be accomplished through several methods performed by EHS, including employee interviews, visual observation of chemical use, evaluation of engineering controls, use of direct reading instrumentation, or the collection of analytical samples from the employee’s breathing zone.

11.2.3. Personal exposure assessment will be performed under either of the following situations:

11.2.3.1 Based on chemical inventories, review of Standard Operating Procedures (SOPs), types of engineering controls present, laboratory inspection results and/or review of the Laboratory Hazard Assessment Tool or other reasoning, EHS determines whether an exposure assessment is warranted; or user of a hazardous chemical has concern or reason to believe exposure is not minimized or eliminated through use of engineering controls or administrative practices and the potential for exposure exists. The user should then inform his or her PI/Laboratory Supervisor, who will in turn contact EHS.  EHS will then determine the best course of action in assessing employee exposure, including visual assessment, air monitoring, medical evaluation, examination, or medical surveillance.

11.2.3.2. In the event of any serious injury or exposure, including chemical splash involving dermal or eye contact, immediately call 911 and obtain medical treatment immediately. Do not wait for an exposure assessment to be performed before seeking medical care.  For minor injuries, such as a localized, small burn from hydrochloric acid, first aid in the lab may be sufficient. If you believe a call to 911 is necessary, do not hesitate.  Seek immediate care if there are any concerns.

11.3. Exposure Assessment Protocol

11.3.1. EHS, or their delegate, can conduct exposure assessments for members of the campus community.

11.3.2. Employees have a right to observe testing, sampling, monitoring or measuring of employee exposure. They are also allowed access to the records and reports related to the exposure assessment.

11.3.3.  Exposure assessments may be performed for hazardous chemicals, as well as for physical hazards including noise and heat stress to determine if exposures are within PELs or other appropriate exposure limits that are considered safe for routine occupational exposure.

11.3.4. The costs of exposure monitoring are the responsibility of the lab, department and organization in which the personnel are employed. 

11.3.5. General protocol in conducting an exposure assessment may include any of the following:

  • Employee interviews;
  • Visual observation of chemical usage and/or laboratory operations;
  • Evaluation of simultaneous exposure to multiple chemicals;
  • Evaluation of potential for absorption through the skin, mucus membranes or eyes;
  • Evaluating existing engineering controls (such as measuring face velocity of a fume hood);
  • Use of direct reading instrumentation; and
  • Collection of analytical samples of concentrations of hazardous chemicals taken from the employees breathing zone, or noise dosimetry collected from an employee’s shirt collar or various forms of radiation dosimetry.

11.3.6. If exposure monitoring determines an employee's exposure to be over the action level (or the PEL) for a hazard for which OSHA has developed a specific standard (e.g., lead), the medical surveillance provisions of that standard shall be followed.

11.3.7. It is the responsibility of the PI/Laboratory Supervisor to ensure that any necessary medical surveillance requirements are met.  When necessary, EHS will make recommendations regarding adjustments to engineering controls or administrative procedures to maintain exposure below any applicable PEL. Where the use of respirators is necessary to maintain exposure below permissible exposure limits, Kent State will provide, at no cost to the employee, the proper respiratory equipment and training.

11.3.7.1. Respirators will be selected and used in accordance with the requirements of the    University’s Respiratory Protection Program.

11.3.7.2. In assessing exposure to hazardous chemicals for which OSHA has not published a PEL, STEL or Ceiling exposure, EHS defers to the Threshold Limit Values (TLVs) established by the           American Conference of Governmental Industrial Hygienists (ACGIH) or the Recommended      Exposure Limits (RELs) established by the National Institute of Occupational Safety & Health     (NIOSH). Please contact EHS for more information regarding these chemicals.

11.37.7.3.  If a mask is worn for nuisance dust, or any contaminant below the PEL, a voluntary use form must be signed by the user.

11.4. Notification

11.4.1. EHS will promptly notify the employee and his/her PI/Laboratory Supervisor of the results in writing) after the receipt of any monitoring results. EHS will establish and maintain an accurate record of any measurements taken to monitor exposures for each employee. Records, including monitoring provided by qualified vendors, will be managed in accordance with OSHA guidelines.

11.5. Exposure Assessment Use to Determine and Implement Controls

11.5.1 EHS will use any of the following criteria to determine required control measures to reduce employee’s occupational exposure:

  • Verbal information obtained from employees regarding chemical usage;
  • Visual observations of chemical use or laboratory operations;
  • Evaluation of existing engineering control measures or administrative practices;
  • Recommendations expressed in Safety Data Sheets;
  • Regulatory requirements of OSHA;
  • Recommendations from professional industrial hygiene organizations;
  • Direct reading instrumentation results;
  • Employee exposure monitoring results; and/or
  • Medical evaluation, examination and/or surveillance findings.

11.5.2.  Particular attention shall be given to the selection of safety control measures for chemicals that are known to be extremely hazardous. Per OSHA, the control of harmful exposures shall be prevented by implementation of control measures in the following order:

  • Engineering controls, whenever feasible;
  • Administrative controls whenever engineering controls are not feasible or do not achieve full compliance and administrative controls are practical; and
  • Personal protective equipment, including respiratory protection, during:
    • The time necessary to install or implement feasible engineering controls
    • When engineering and administrative controls fail to achieve full compliance
    • In emergencies
    • As an extra precaution/option for employees

11.6. Medical Evaluation

11.6.1. All employees, including laboratory personnel, who work with hazardous chemicals shall have an opportunity to receive a free medical evaluation, including supplemental examinations which the evaluating physician determines necessary, under the following circumstances:

  • Whenever an employee develops signs or symptoms associated with a hazardous chemical to which an employee may have been exposed in a laboratory;
  • Where personal monitoring indicates exposure to a hazardous chemical is above an OSHA Action Level (AL) or Permissible Exposure Limit (PEL) or recommended exposure levels established by the National Institute for Occupational Safety & Health (NIOSH) or the American Conference of Governmental Industrial Hygienists (ACGIH) in the event OSHA has not established an AL or PEL for a particular hazardous chemical;
  • Whenever an uncontrolled event takes place in the work area such as a spill, leak, explosion, fire, etc., resulting in the likelihood of exposure to a hazardous chemical; or
  • Upon reasonable request of the employee to discuss medical issues and health concerns regarding work-related exposure to hazardous chemicals.

11.6.2. All work-related medical evaluations and examinations will be performed by Deweese Health Clinic during the normal work hours of 8 am until 5 pm.   Employees may seek a medical evaluation elsewhere.   Evaluations and examinations will be provided without cost to the employee, without loss of pay, and at a reasonable time and place.

11.6.3. Any laboratory employee or student worker who exhibits signs and symptoms of adverse health effects from work-related exposure should file a Report of Injury  to EHS.   At the sign or symptoms of exposure, the student should seek medical treatment from the Deweese Health Clinic or University Hospitals in Ravenna.

11.6.4. Information to Provide to the Clinician

At the time of the medical evaluation, the following information shall be provided:

  • Personal information such as age, weight and University employee ID number;
  • Common and/or IUPAC name of the hazardous chemicals to which the individual may have been exposed;
  • A description of the conditions under which the exposure occurred;
  • Quantitative exposure data, if available;
  • A description of the signs and symptoms of exposure that the employee is experiencing, if any;
  • A copy of the Safety Data Sheet (SDS) of the hazardous chemical in question;
  • History of exposure including previous employment and non-occupational (recreational) hobbies; and
  • Any additional information helpful in assessing or treating an exposure or injury such as a biological component of exposure or existence of an antitoxin.

11.6.5. Physician’s Written Opinion

For evaluation or examinations required by OSHA, the employer shall receive a written opinion from the examining physician which shall include the following:

  • Recommendation for further medical follow-up;
  • Results of the medical examination and any associated tests, if requested by the employee;
  • Any medical condition which may be revealed during the examination which may place the employee at increased risk because of exposure to a hazardous chemical found in the workplace; and
  • A statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination or treatment.
  • Confidentiality & Individual’s Access to Personal Medical Records

11.6.6. All patient medical information is protected by Ohio and federal law and is considered strictly confidential. The medical facility is prohibited from disclosing any patient medical information not directly related to the work-related exposure under evaluation and should not reveal any diagnosis unrelated to exposure. Any patient information disclosed by the medical facility to the employee’s supervisor will be limited to information necessary in assessing an employee’s return to work, including recommended restrictions in work activities, if any. Any patient information disclosed by the medical facility to EHS will be limited to information necessary to develop a course of exposure monitoring, or perform hazard assessments and incident investigations, if appropriate, the medical facility will otherwise disclose patient medical information only as required by Ohio and Federal law, such as for Worker’s Compensation Insurance claims. Each employee has the right to access their own personal medical and exposure records. The medical facility will provide an employee with a copy of their medical records upon written request.

11.7. Medical Surveillance

11.7.1. Medical surveillance is the process of using medical examinations, questionnaires and/or biological monitoring to determine potential changes in health because of exposure to a hazardous chemical or other hazards. Certain OSHA standards require clinical examination as part of medical surveillance when exposure monitoring exceeds an established Action Level or PEL.

11.7.2. Kent State uses the Deweese Health Clinic for medical surveillance. Medical surveillance is required of employees routinely exposed to certain hazards as part of their job description (such as silica) and may be offered to other employees based on quantifiable or measured exposure.  Examples of hazards that are monitored through the medical surveillance program may include: Asbestos, Beryllium, Formaldehyde, Lead, Methylene Chloride, Noise (Hearing Conservation Program), Radioactive Chemicals (Bioassay Program), Respirator Use (Respirator Protection Program), Silica (Respirable Silica Program), and other particularly hazardous substances. Individuals with questions regarding work-related medical surveillance are encouraged to contact EHS for more information.

 

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