Document 0Jj5mQKxwGJZG4moJEVjrrL3J

ACTIVITIES AND OBJECTIVES: 1 TEXAS AREA REGIONAL SENIOR INDUSTRIAL HYGIENIST Accountability Objectives: 1. To develop and implement appropriate industrial hygiene programs directed to the prevention of occupational illnesses and disease among Point Comfort Operations employees. (Importance: 75Z) 2. To provide industrial hygiene support to Rockdale Works. (Importance 10Z) 3. To provide industrial hygiene support to Marshall Works. (Importance: 10Z) 4. To provide for personal development, managerial and technical. (Importance: 5Z) APC 004642 2 Accountability Objective: to develop and implement appropriate industrial hygiene programs directed to the prevention of occupational illnesses and disease among Point Comfort Operations employees. 1. Upgrade Hearing Conservation Program a. Review designation of plant areas and operations greater than 90 dBA by 1982 December 20. b. Publicize rules requiring hearing protection in January, 1983. c. Issue recommendations on hearing protection for mobile equipment operators by 1983 May 01. d. Delineate plant areas and operations greater than 85 dBA by 1983 October 01. e. Investigate significant threshold shifts as required. 2. Upgrade the Respiratory Protection Program. Delegate to Senior Industrial Hygiene Technician; complete by 1983 December 31. a. Written list of operations requiring respiratory protection. b. Revised written respiratory protection program. c. Appropriate training and fit testing. d. Upgrading of storage and maintenance of respirators. 3. Draft Point Comfort Operations Industrial Hygiene Manual by 1983 February 01. The Manual will describe objectives of Industrial Hygiene Program, functions of the Industrial Hygiene Department, management/staff responsibilities and specific industrial hygiene programs (i.e. Hearing Conservation). a. Present to management in March, 1983. b. Develop plans to conduct management training in industrial hygiene in 1983. 4. Conduct detailed industrial hygiene reviews of departments and maintenance work groups in order to: a. Uncover and correct unidentified health hzards, if necessary. b. Prepare "Industrial Hygiene Job Descriptions" to include list of job activities and tasks, chemical and physical exposures, use of personal protective equipment, etc. APC 004643 3 c. Revise master "Materials Inventory" to include: 1. Associated processes, departments and/or locations. 2. Quantity used or generated. 3. Job classes exposed. ' d. Assign specific air sampling and noise monitoring surveys to Senior Industrial Hygiene Technician; report test results to management; develop and revise master "Sampling Schedule". Schedule and Target Dates: 1. Raw Materials and Marine Department by 1983 February 01. 2. Paste Plant by 1983 March 01. 3. Electrolyte Department by 1983 April 01. A. Painters by 1983 May 01. 3. Insulators by 1983 June 01. 6. Brick Masons by 1983 July 01. 7. Carpenters by 1983 August 01. 8. Machine Shop by 1983 September 01. 9. Digestion by 1983 October 01. 10. Clarification by 1983 November 01. 11. Precipitation by 1983 December 01. 12. Calcination by 1984 January 01. 13. Gas Plant by 1984 February 01. 14. Oilers by 1984 March 01. 15. Maintenance Mechanics by 1984 April 01. 16. Electrolyte Department and conduct urinary fluoride survey by 1984 May 01. 17. Pipefitters by 1984 June 01. 18. Welders by 1984 July 01. 19. Electricians by 1984 August 01. 20. Mobile Equipment Mechanics 1984 September 01. 21. Instrument Mechanics by 1984 October 01. 5. Conduct Industrial Hygiene Orientation and Refresher Training per schedule. 6. Participate in Project Safety Reviews and other occupational health related issues as required. 7. Participate in MSHA-OSHA governmental inspections as required. APC 004644 4 Accountability Objective: to provide industrial hygiene support to Marshall Works (Importance 10Z) 1. Promote a systematic review of Marshall Works' industrial hygiene program, its organization, objectives and priorities; specifically with regard to: a. Management recognition and understanding of the industrial hygiene program. b. Hearing conservation program. c. Chemical inventory and control. d. Occupational health training, management and employees. e. Respiratory protection program. f. Record keeping. 2. Provide general assistance as needed. AFC 004646 5 Accountability Objective: to provide industrial hygiene support to Rockdale Works (Importance 10Z) 1. Promote a systematic review of Rockdale Works' industrial hygiene program, its organization, objectives and priorities; specifically with regard to: a. Management recognition and understanding of the industrial hygiene program. b. Sampling schedule (air and biologic) c. Chemical inventory and control. d. Hearing conservation program. e. Respiratory protection program. f. Occupational health training, management and employees. g. Radiation control. h. Record keeping. 2. Provide general assistance as needed. APC 004646 6 Accountability Objective: to provide for personal development, managerial and technical' (Importance 5Z) 1. Attend a management development course in first quarter, 1983. 2. Attend the American Industrial Hygiene Conference in Philadelphia, 1983 May 21-27. 3. Attend selected local section meetings of the American Industrial Hygiene Association. APC 004647 . <r Joe Damiano To: J~c^/ a //er This mimo sni n sutoto ISO matnc atantitrd 86 12$ mm i 176 mm 2 7. /* U*' k O ^.Jc. ye** M T EJalcoa POINT COMFORT OPERATIONS jpC 004648 IT/V do? r '??, j / - rc :: k cP <a ) ' c- ^ *^7 04 .4 ?. yU is "^a. a A r A ^r",u ^. /vr. A . S i ' #//<?< . 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(2,/s''` c * 2~VV' ^^/l. r<- A-sc ,< & * S *S ,, J 'yf$-r ^ <^t /. c.^., A* A,* J le> o A- ,"// ^srugra^ pO ^ w" ? iw o ^ 1^4 Q f * * JT bJ / ('t A 4 * i rtf /'^** A,e*zt. 2. 0 !* r r ' ' ARC 004660 -J- % / Q-/*- C-~rr1 t t 1 c *^*, '-Ti-V" / y -- ^. / >^. **t ft ^ < !. .>.-/ /M.t,.'-/< i^/* /-- wi`-'* t- /u?*. V-v* S **vi /^ *7 JTH UO * /t ft , 3 * A- r'> ,. ^e^-t+s <-^A i-y* /dc * , S C---ft L- f i,n ->/ f /* r <* -?. &**'-$* f't*j.r'- 3. . hr* C.&* APC 004661 tv Ind. Hyg. Assoc J 43(6)562-568 (1982) lanagement is challenged constantly to enhance occupational health programs for employees. Industrial /giene auditors must assume their share of this responsibility by operating on a highly professional level sing accepted auditing principles. This document describes the planning, organizing, directing and controlling f an industrial hygiene audit for the purpose of measuring the effectiveness of established occupational aalth objectives. > ndustrial hygiene audits RENOA H HAAS 3M Corporation itroduction Manufacturing and development/ research activity may genrate environmental factors which may cause stress, sickess. or impaired health of employees in the workplace, iach manufacturing plant must have an industrial hygiene 'rogram to minimize or eliminate potential workplace :azards. The program objectives and the general interrelalonships of Industrial Hygiene with other'plant functions i.e.. Manufacturing, Medical. Engineering. DevelopmentPersonnel) should be clearly defined and documented. The purpose of an audit is to examine plant occupational lealth programs to verify their effectiveness for preventing occupational disease and assure consistency with corporate ind government standards and regulations. In addition, an mdit must verify that program documentation will with* 'land third-party scrutiny. orief description of program The auditor(s) should examine the prior three months' occupational health documents including but not limited to :he areas of airborne chemical sampling, industrial hygiene, analytical support laboratory, chemical control, respira tory protection, radiation, exhaust ventilation, industrial hygiene/ plant interface, training/ communication, self-related or unique plant programs (*.?., TSCA). A predetermined number of cases from these documents need to be selected to verify consistency to industrial hygiene practices. OSHA or other governmental standards as well as corporate standards, practices and/or guidelines. In addition, a physical plant inspection should be con ducted to verify the plant implementation of occupational health practices and programs. responsibilities/ frequency management - Senior location management has the primary responsibil ity for developing and implementing an effective industrial hygiene program. plant industrial hygiene - Department audits shall be conducted by the site indus trial hygienists. The frequency of the audits required Caiiri^w 1IW. Awww JI2 to have an effective program shall be determined by the location. - The site industrial hygienist(s) should audit related indus trial hygiene programs/projects, i.e.. ventilation design. Preventive Maintenance process, chemical control. It is recommended that the plant formally audit Industrial Hygiene-related programs on an annual basis. . auditorfs)/audit ream composition The plant designated auditors) must have the skills required to assure an effective audit, i.e.. industrial hygienists, safety professionals and physicians. It is also recommended that the senior plant manager participate in selected audits to assure awareness of plant management support to employee health programs. recordkeeping/reporting Each plant has the responsibility for developing and imple menting a recordkeeping and reporting system which will ensure that audits are made on time and that all of the programs are documented adequately. Audit records should show deficiencies found and the corrective action taken or planned. Following a department or program IH audit, a written report should be sent to the manager of the area and to his/her management. planning process -- team approach Conducting an audit with a team of selected professionals gives added benefit in the following areas: 1. Professional development of auditors. ARC 004562 2. Enhanced audit team expertise. 3. Increased scope/ objective of the audit, thereby reducing total number of audits. An audit team leader must be assigned to plan, organize and direct the plant audit program. The responsibilities of the audit team leader are to: ' ............... Sat. M Hff. Anoc J (43) u(int. 19(2 1. Communicatewith the auditee. 2. Advise auditee when the team will arrive and of the length, scope and objectives of the audit. 3. Provide training for auditors. 4. Manage the on-site audit. 5. Perforin audit work (as necessary). 6. Review work of auditors. 7. Inform upper management of the audit/action plans. 8. Follow action plans designed to address audit findings. 9. Improve audit techniques. The members of the audit team have the responsibility of: 1. Gathering and studying information on the department or function to be audited, i.e.: - Previous audit reports. - Action plans in process. - Department accident rates. - Department/function mission. 2. Preparing accurate audit work papers (see recommended audit protocols) to document findings in department or function audited. 3. Obtaining all key information and developing all find ings. (An example of developing an audit finding: One unlabeled respirator in a department does not indicate an unsatisfactory respirator program. The auditor must design the audit to determine the reason for the effect he/she saw. Has the employee been trained? Supervisor trained? By developing the finding in this case, the audi tor found the supervisor had not received enough infor mation to realize that the respirator should have been labeled with the employee's name. In this manner the auditor assisted the plant in addressing the concern by identifying the cause of the finding, not the effect. 4. Preparing interim recommendations and discussing them with the department/functional supervisor. 5. Preparing final recommendations for conference with management. 6. Binding and filing all audit workpapers. audit protocol An audit program should include all areas of employee health significance. The following are sample audit protoc ols. The location Industrial Hygiene audit program should not necessarily be limited to these areas. irborna contaminant monitoring overview Evaluation of workplace conditions to ensure that possible air contaminants are controlled to prevent potentially harmful chemical concentrations, and that actual exposure levels are documented, are essential parts of an industrial hygiene program. objective Assure adequate sampling for control of airborne chemicals is supported by adequate documentation. HiMhcsn IndtuWll Hypnt teocubon JOUftfMl scope Review documented sampling program and rate using the system below. Select 10-20 cases from the prior three months and verify as follows: program review 1. Is there a documented sampling program? YES/NO 2. Evaluation of the program: a. Is there adequate trained staff to imple ment the objectives of the program? (As defined by corporate job descriptions) YES/NO Scope: Review training Industrial Hygiene staff has received. b. Is there documentation of operations; processes which require periodic sampling? YES/NO c. Does the sampling plan emphasize per sonal sampling? YES/NO Note: Examine actual sampling data sheets to verify. d. Is there a documented sampling schedule? YES/NO 3. Increased scope/ objective of the audit, thereby reducing total number of audits. An audit team leader must be assigned to plan, organize and direct the plant audit program. The responsibilities of the audit team leader are to: 1. Communicate with the auditee. 2. Advise auditee when the team will arrive and of the length, scope and objectives of the audit. 3. Provide training for auditors. 4. Manage the on-site audit. APC 004553 3. Perform audit work (as necessary). 6. Review work of auditors. 7. Inform upper management of the audit/action plans. 8. Follow action plans designed to address audit findings. 9. Improve audit techniques. e. Is the sampling equipment inventory ade quate to support program objectives? YES/NO f. Is a primary air flow calibration standard used to ensure air flow accuracy? YES/NO g. Is the air flow calibration accuracy trace able to NBS? YES/NO h. Can you verify that collected samples are either refrigerated or otherwise properly stored and protected prior to analysis? YES/ NO i. Are records of all sampling data main tained and documented in a chronological file? Select cases to verify. YES/ NO j. Sampling results documented to depart ment supervisors? Select cases to verify. YES/ NO k. Medical department copied on all results over the TLV for compound the established company action level. Select cases to verify. YES/ NO ] ; Sampling Data Sheet Review -- Select 10-20 cases from prior 3 months to verify. a. Sample log number. YES/ NO b Chemical sampled identified. YES/ NO c. Department number. YES NO d. Documentation of calibration before and after sampling period. YES/ NO e. Employee number (or other unique employee identification system used at the plant.) YES/NO f. Collection method identified. YES/ NO g. Sampling time (8 hours or IS minutes). YES/NO h. Approved NIOSH collection method used? YES/NO i. Pump. name, model. YES/NO j. Collecting device identified by type, manu facturer. lot number, size and composition (i.e.. Gelman. glass fiber filter,-or size 0.5U. lot number 60714 37 mm). YES/NO k. Analytical method stated. YES/NO l. Approved NIOSH method of analysis used? YES/NO m. Blanks included for each sample? YES/NO n. Results posted on data sheet? YES/NO o. Future actions required identified, (i.e., resampling, employee protection required)? YES/NO industrial hygiene analytical support laboratory Thorough, accurate and reliable analytical support for the industrial hygiene program is essential. This support can-bc. obtained i her internally or externally, provided the required quality and credibility can be demonstrated. The laboratory must be well staffed and instrumented. It must have a good analytical quality assurance program, use approved methods and have a reliable tracking systems for samples and analyti cal results. abjective To determine if the Industrial Hygiene Program has accurate, reliable, credible, analytical support and ade quate documentation. ' scope - Review documented program. Select 10 cases from prior 3 months to verify adequate documentation. prognin review I. If the industrial hygiene analytical support is provided by an in-house laboratory address questions la - d. a. Is the laboratory AIHA accredited?(Ifyes, do not answer lb through Id.) YES/NO b. Is the laboratory staffed by trained chem ists and technicians? Review training. YES/ NO c. Does the laboratory have the necessary instruments and equipment required to perform analysis by the NIOSH or other approved methods? YES/ NO d. Is there a documented analytical quality assurance program? Review documents. YES/ NO SM 2. If the industrial hygiene analy tical support is established from an external vendor laboratory, address questions 2a - c. a. Is the laboratory AIHA accredited? YES NO b. Are the analytical categories accredita tion documented? YES NO c. Is the lab used for only those aspects for which it is accredited? YES. NO documentation verification (select sample cases) 1. Job number assigned? YES NO 2. Person performing analysis identified? YES/NO 3. NIOSH method of analysis identified? YES/NO 4. Equipment parameters stated? YES NO 5. Controls and blanks used? YES/NO 6. Dated equipment calibration curves available? YES NO 7. Acceptable turn-around time? (As defined by the Industrial Hygiene Department) YES. NO chemical control overview A site which uses chemicals must have elements in its control programs designed to ensure awareness of chemicals used and that adequate safety and health information is available to chemical users. objective Assure awareness of chemical composition of plant chemi cals for the purpose of providing adequate protection for the chemical worker. program review I. Document Examination -- review prior three months chemical purchasing documents for manufacturing and development. Select 10 to 20 cases for verification of criteria below. This includes petty cash vouchers. a. Is there a plant chemical procurement approval procedure? YES/NO I. Is this procedure current? YES/NO b. Evaluation of procedure: 1. Does the staff designated to approve chemical purchases have appropriate chemical training(as defined by Corpo rate Job Descriptions)? Review training. YES/NO 2. Does the chemical purchase proce dure require approval from Industrial Hygiene. Safety and Manufacturing? YES/NO 3. Does the approval procedure include chemicals purchased for manufac APC 004654 turing, development and petty cash vouchers? YES/ NO c. Are Material Safety Data Sheets obtained for each chemical purchased? YES/ NO d. Is the chemical storage and staging area approved by Industrial Hygiene? YES/NO e. Does Industrial Hygiene review testing of new processes? YES/NO im.lnt.Hrt lose. J <*3) at 1982 f. Does Industrial Hygiene have approval of increased usages? YES/NO g. Does Industrial Hygiene review all site chemicals used annually? YES / NO noise<u overview Excessive noise can cause permanent hearing loss and con tribute to general fatigue and work inefficiency. A program of evaluation and control of workplace noise is mandatory. program review Review prior three months location sound pressure level documents. Review most recent plant sound pressure level screening survey. Review hearing conservation department direction to supervisors, procedures and action plans. I. Is there a documented program for imple menting the noise evaluation and control requirements of the Occupational Safety and Health Act? YES/NO 2. Evaluation of the program and its effectiveness. a. Does the staff have training in sound mea surement procedures? YES/NO b. Is industrial hygiene equipped with a Type I precision sound level meter? YES/NO c. Is there documentation of calibration of all sound measurement equipment? Cali bration before and after sound measure ments? Is it traceable to a primary stan dard. i.e.. Bureau of Standards? YES/NO d. Are employee exposures documented in accordance with ANSI requirements? YES/NO 1. Microphone positions documented? YES/NO 2. Is the person that measured sound pres sure level identified on documentation? YES/NO 3. Date of survey recorded? YES/NO 4. Sound pressure level recorded? YES/NO e. Is Medical aware of employees whose exposure exceed the allowable daily noise dose of 0.50 or greater? (Examine 10 actual cases). YES/NO f. Signs posted in areas where noise exceeds 90 dB (A)? YES/NO g. Have corrective actions been taken in areas where employees noise exposure exceed the allowable daily dosage? (Exam ine actual cases). YES/NO h. Has the Supervisor been given documented direction for implementation of hearing conversation programs in areas that equal or exceed 90 dB (A)? YES/NO i. Is there a listing of all areas that equal or exceed: 1. 90 dB (A)? 2. 85 dB (A)? Antncan Industrial Hyptnt AsstdatiM XXJRNAl (43)t/K respiratory protection 2 ' overview Manufacturing process or laboratory procedures must be provided with engineering controls which will prevent potentially harmful contamination of workplace air. How ever, there may be emergency or short-term operations or procedures where respiratory protection can be provided by the use of face mask respirators. program review 1. Is there a documented program for respirator use which will ensure that the requirements of OSHA 1910.134 are met? YES/NO 2. Evaluation of the program and its effectiveness. a. Is a list available of the current operations which require the use of respirators? YES/NO b. Is there a respirator issuing approval proce dure that requires Industrial Hygiene and medical sign off? YES/NO c. Is the program responsibility for respira tors clearly identified? YES/NO d. Examine the approval records for follow ing items: 1. Name, employee identification, dept., of the person issued a respirator. YES/NO 2. Date issued. YES/NO 3. Type of respirator issued. YES/NO 4. NIOSH approval number. YES/NO 5. Reason respirator issued. YES/NO e. Initial employee/supervisor respirator use and care instruction (training) documented? YES/NO f. Is there a periodic plant audit of respira tors currently in use? YES/NO g. Is there documented retraining on a regu lar basis, i.e.. annually? YES/NO 1. Does the training and retraining inform the employee of reasons for which he/ she is required to wear the respirator? YES/NO 2. How to clean the respirator? YES/NO 3. When to change the cartridge or dis pose of the respirator? YES/NO 4. Proper storage of the respirator? YES/NO i. Is a documented fit test conducted on each employee issued a respirator? YES/NO radiation<SI overview Ionizing and non-ionizing radiation sources must be con trolled and employee exposure monitored to ensure that employees are protected properly. objective Ionizing and non-ionizing radiation sources are controlled. Assure adequate employee monitoring and documentation. Assure compliance with Federal and State and Local Radia tion Regulations. APC 004666 StS program review Examine past years survey results of ionizing and non ionizing sources of radiation, including contractor surveys. Examine past six months employee monitoring documents. Examine radiation worker training program. - Ionizing Radiation6* 1. Is there a current inventory of all ionizing radiation sources in the plant? 2. Are all radiation workers on a program to monitor their potential exposure? (This includes plant radiation officer). 3. Are radiation workers on a medical monitor ing program? YES/ NO YES/NO YES/NO 4. Is industrial hygiene included in the approval cycle for all new radiation source procure ments? Note: Examine purchase records to verify. YES/NO 5. Are all sources of radiation surveyed quar terly or as regulation directs? YES/NO 6. Are there documented six-month leak tests on radiation control structures (sealed sources)? YES, NO 7. Is there a documented radiation worker training program? YES/NO 8. Are survey instruments calibrated annually? (Examine past five years documentation). YES/ NO 9. Have radiation users' department supervi sors been given specific direction for manag ing radiation practices, i.e.. film badge imple mentation. recording practices. leak test prac tices. safety practices, labeling? YES/NO 10. Are specific plant disposal and maintenance procedures documented? YES/ NO 11. Are all radiation sources labeled? YES/NO - Non-Ionizing Radiation{T> Ultraviolet. Microwave. Visible Light, and Infrared. 1. Is there a current site inventory listing ail significant sources of non-ionizing radiation? (As defined by OSHA or the NIOSH/OSH Current Intelligence Bulletin). YES/NO 2. Is there a documented annual survey pro gram for non-ionizing sources of radiation? YES/ NO 3. Are non-ionizing radiation workers on a medical monitoring program. Note: If not. the justification for exclusion from medical monitoring must be documented. YES/ NO 4. Have sources been labeled with type of radi ation involved, body organs at greatest risk and control measures required? YES/ NO 3. Is all of the non-ionizing radiation survey equipment on an annual calibration pro gram? Is this documented and retained for previous years? YES/NO at 6. Are all employees who work with significant sources of non-ionizing radiation on a doc umented annual training program? YES NO 7. Have non-ionizing radiation usedepartment managers been given specific precautions, medical monitoring requirements and label ing requirements? YES NO exhaust ventilation 6' overview Local exhaust ventilation installed to remove airborne con taminants from the workplace represents a major source of employee health protection. In order for these engineering controls to be effective, they must be designed, installed and maintained properly. The Industrial Hygiene program must include a mechanism to ensure involvement with responsible groups in each phase of the local exhaust ventilation program. objective Assure airborne contaminants are removed from the work environment. Assure adequate design and mainte nance procedures. program rtviaw Examine current inventory of local exhaust. Select 10 random cases to examine design and preventive mainte nance documents. 1. Is there a current inventory of all site local exhaust? YES, NO 2. Are local exhaust hoods surveyed and labora tory hoods surveyed semi-annually for speci fied air flow? YES/NO 3. Are these measurements current? YES/ NO 4. Open surface tanks surveyed on quarterly basis? Y ES/ NO a. Does the Preventive Maintenance program include CFM or LFM (cubic feet per min ute/ linear feet per minute) readings at: 1. The hood? 2. The branches and mains? YES, NO YES / NO 3. Are designs for new or revised local exhaust ventilation systems reviewed by Indus trial Hygiene? YES/NO 6. Does industrial hygiene examine and sign off on all new/ revised local exhaust systems prior to use? YES/ NO Does initial checkout include static pres sure reading at: APC 004666 1. Hood? YES/NO YES/NO 2. Up and down stream from air cleaner? YES/NO 3. Up and down stream from fan? YES/NO Does initial checkout include: I. Supply velocity (diffusion outlet)? YES/ NO 7. Are local exhaust and laboratory hoods labeled with desired velocity, actual velocity, date of last measurement, sign-off of inspector and telephone number to call for repair? YES/ NO Sat M. Hft AtMC. J (*9 lupin 1912 8. Are all air flow instruments calibrated on an annual basts?. Is the documentation retained for previous years calibration? YES/ NO 9. Has the person performing Preventive Maintenance programs on local exhaust sys tems received measurement training? Is this documented? YES/NO training/communication'9' overview Advising employees of the properties of the materials with which they work is necessary to protect their health and safety. Proper handling procedures, good work practices and emergency actions must also be part of the employee training. While the primary responsibilities for their training belong to the individual department supervisors, the indus trial hygiene staff must act as an information resource to aid the supervisors in carrying out their responsibility. objective To assure that employees are apprised of potential hazards of agents (/>., chemicals, lasers, microwave) they use in the course of their employment and how they can prevent expo sure via prescribed work practices. program rtviaw Examine prior three months chemical/industrial hygiene employee and supervisor training programs. (May need to examine one full year). Speak to ten supervisors, chosen at random to verify training. Speak with education department to review contents of training received by employees and supervisors. Select random sample of 10 employees from manufactur ing and development labs. Follow documentation of their training (paper search). 1. Does industrial hygiene staff assist the educa tion department in conducting training. YES/NO a. Is this documented? YES/NO 2. How many supervisors were trained in the previous months? What percentage is this of the total number of manufacturing and devel opment laboratory supervisors? Is this docu mented? (Select ten random cases). YES/NO 3. How many manufacturing and development laboratory employees have received Indus trial Hygieneawareness training in the past 12 months? What percentage is this of the whole? YES/NO 4. Is specialized awareness training given to high risk groups? Can this be documented? YES/NO a. Emergency squad members? b. Potential high hazard, use departments? YES/NO 3. Is the department supervisor given training that will assist him with feedback of sampling data results of the employee? YES/NO 6. Examine awareness training packages for the employee. YES/NO Amncwi Industrial Hypmt Association JOURNAL (43) VU a. Are they specific about potential hazards. YES. NO (Respirator worker and radiation worker training programs are addressed in their respec tive audit sections). industrial hygiene/emergency procedures overview Protection of the health of persons during an emergency situation often requires the involvement of industrial hygiene. Areas of involvement include proper procedures, sign, label ing. availability for consultation, review of established action plans and specialized training. objective Assure all potentially high hazard areas are properly labeled to enable a fast, appropriate response tasite emergency. program review Survey plant. Examine ail chemical banking tanks, large supply pipes and personnel exclusion areas for proper label ing and emergency phone numbers. Review emergency squad members training program. Select ten random members to follow training documentation. I. Have the potential high hazard areas been identified and documented? YES/ NO 2. Has the emergency response staff been given specific training on an annual basis? YES; NO 3. Is there a documented procedure that instructs the emergency staff to contact Industrial Hygiene for chemical and other potential health hazard emergencies? . ES NO 4. Are chemical banking tanks clearly labeled as to contents? Are large chemical pipes clearly labeled? YES NO 3. Are chemical staging/ storage areas approved by Industrial Hygiene to minimize chemical emergencies? YES NO 6. Are high hazard areas and special installa tions (such as PCB transformers) clearly labeled to permit quick action in emergencies? YES. NO other programs Each plant may have unique industrial hygiene concerns, (/.e., facility exposure limits, heat stress, ergonomic, vibra tion. illumination, laser) which would require periodic industrial hygiene evaluation and control. If these special conditions exist, auditors must attempt to identify and eval uate documented programs to address these concerns, or the need for creating one. APC 004667 department supervisor seif-audits The department supervisor has the responsibility for ensur ing the health and safety of the employees in his / her depart ment. Self-audits must be performed on a regular basis to ensure department compliance to plant health and safety practices and to promptly address potential concerns. J*7 Department self-audit checklists need to be tailored to the individual department. Industrial Hygiene should periodi cally assess the checklist for content to assure specific department concerns are adequately covered. In addition. Industrial Hygiene should review the check list on a periodic basis for potential concerns and to assure corrective actions have been implemented. acknowledgements 1 would like to acknowledge Mr. Harvey Abend. Mr. Charles Garner. Mr. Chris Norden, Mr. Victor Nusbaum. Mr. Tom Owens and Mr. Frank Reid of IBM Corporation for their reviews and professional comments on this audit procedure. references 1 OSH Act 1910.98 and 1910 95. ANSI Standards SI 25-1978 SI.2-1962 (R1976), SI.4-197 (R1976), SI.22-1978. 2. OSH Act 1910.124 3. OSHA 1910.134 4. ANSI Z88.2 1969. 5. OSH Act 1910.96. 6. American National Standard Practice for Occupational Radi ation Exposure Records System. N2. 2-1966 ANSI NY, 10018(1966). 7. OSH Act 1910.97: NIOSH/OSHA Current Intelligence Bul letin 33 (Dec. 4, 1979). 8. American Conference of Qovemmental Industrial Hygien ists: Industrial Ventilation Manual -- A Manual of Recom'' mended Practice (Current Edition). Committee on Industrial Ventilation, P 0. Box 16153. Lansing, Michigan 48901. 9. OSH Public Act Section 6 (B) 7. 22 June. 1981: Revised I March. 1982 APC 004658 Ml tm. M Hyf. feaoc. J (431 uiint. 1982 E. E. RUMBERGER PITTSBURGH OFFICE / !' POINT CDM^RT OPERATIONS 1982 November 12 RE: INDUSTRIAL HYGIENE PLANT AUDITS With the encouragement of Messrs. Fetterolf and Hornbeck, we are initiating auditing of plant Industrial Hygiene Programs. Obviously, we will get to some plants quite soon, with most plants being audited somewhat later. In the meantime, the enclosed audit booklet will provide you with pertinent informa tion on the purpose, objectives, and scope of the I.H. Audit. More importantly, it may provide you with some additional insight into the key elements which constitute an effective, pro-active, and preventive health protection effort. Section I (2 pages) defines plant and location management accountability. Section II (4 pages) discusses the objectives and the manner in which the audit will be conducted. Section III covers the scope and content of the audit. Included in this section is a table of contents listing the 10 key elements or areas which will be explored during the audit. The remainder of Section III constitutes a preliminary worksheet to be completed by the plant industrial hygienist prior to the location visit. It will provide an important assist to the Audit Team in planning the plant visit. The worksheets will be requested at the time an audit is being scheduled. Finally, the Plant I.H. Audit is not intended to be an "inspection" but, rather, an "ASSESSMENT" of strengths and weaknesses. Its purpose is to be beneficial to the Location Manager and the Supervisor of Industrial Hygiene. E. E. RUMBERGER EER/eds Enclosure cc: Dr. L. P. Schaller - Pt. Comfort Operations J. Damiano - Pt. Comfort Operations fr^ ai rriA APC 004659 EMPLOYEE HEALTH PROTECTION AND THE INDUSTRIAL HYGIENE AUDIT 1982 SEPTEMBER APC 004660 I PLANT I.H. ACCOUNTABILITY S lC APC 004661 CONCLUSION OF ALCOA POLICY GUIDELINES IN THE COURSE OF DOING BUSINESS, THE COMPANY WILL OPERATE IN A MANNER THAT DOES NOT IMPACT UNFAVORABLY UPON THE HEALTH OF ITS EMPLOYEES OR ITS CUSTOMERS. RESPONSIBILITY IT IS A FUNDAMENTAL RESPONSIBILITY OF LOCATION MANAGEMENT i AND SUPERVISORY PERSONNEL TO IMPLEMENT PREVENTIVE AND PROTECTIVE MEASURES TO PROTECT THE HEALTH OF ALL EMPLOYEES... AND EMPLOYEES AT ALL LEVELS MUST CONTRIBUTE TO THESE EFFORTS. ACCOUNTABILITY LOCATION MANAGERS HAVE THE ULTIMATE ACCOUNTABILITY FOR EMPLOYEE HEALTH PROTECTION. APC 004662 i LOCATION MANAGER'S ACCOUNTABILITY FOR _________INDUSTRIAL HYGIENE EACH LOCATION MANAGER IS ACCOUNTABLE FOR ACHIEVING THESE OBJECTIVES; 1. PREVENTION OF OCCUPATIONAL DISEASE OR IMPAIRMENT TO HEALTH. 2. PROTECTION OF CORPORATE INTERESTS FROM FUTURE LIABILITIES. 3. COMPLIANCE WITH APPLICABLE HEALTH PROTECTION STANDARDS AND REGULATIONS. Since there can be both short- and long-range effects on an employee's health as a result of his occupational exposures, it is incumbent upon the Location Manager, at all times, to conduct a pro-active program of preventive measures to insure against immediate or eventual employee health impairment. Some occupational disease becomes apparent many years after the employees have been exposed. In this sense, the Location Manager's accountability continues long after his tenure at a given plant is concluded. An Industrial Hygiene Program requires the active participation of almost every department within a plant, including Operating, Engineering, Technical and Quality Assurance, Purchasing, Industrial Relations, Medical, Safety, and Environmental Control. Effective dialogue between the Industrial Hygienist and these departments is essential. The commitment of the Location Manager will determine the degree of effectiveness of a program that is devoted to the control of health hazards in his plant. Therefore, if an Industrial Hygiene Program is to be successful, it must have his leadership and support. APC 004563 ii THE audit V. APC 004664 INDUSTRIAL HYGIENE PLANT AUDITS STYLE AND PURPOSE The Plant I.H. Audit will not be an "inspection"... a word sometimes identified with a regulatory or "nit-picking" approach. Rather, it will be an ASSESSMENT of the plant's I.H. Program's STRENGTHS and WEAKNESSES to be provided for the benefit of location management and the supervisor or manager of the I.H. function. The Audit will focus on ten areas or key elements associated with effective plant I.H. efforts. (Items are listed on Evaluation Worksheets.) The purpose will be to identify those things being done well... in addition to those areas where improvements are needed. OBJECTIVES The plant I.H. Audit has the following objectives: 1. To assess the adequacy of location programs for preventing occupational disease or impairment to health. 2. To insure that those programs are working as intended, and are not merely on paper. 3. To recognize the strengths, as well as the weaknesses, in location health protection efforts. 4. To make constructive recommendations as to how to improve plant programs and efforts. 5. To share ideas among locations. 6. To eventually share a summary assessment with appropriate Corporate management. APC 004565 iii CONTENT AND EVALUATION WORKSHEET The Audit will be planned with the plant several weeks prior to the actual visit by the Audit Team. The conduct of the plant I.H. Audit will focus on personal discussions with plant personnel; observations; a thorough walk-through tour of the plant; and an inspection of I.H. records. Prior to the plant visit, the leader of the Audit Team will request some preliminary information from the plant Industrial Hygienist or the person responsible for Industrial Hygiene. The main item will be the completion of the enclosed Evaluation Worksheet which should be sent to the Audit Team leader several weeks in advance of the visit. This form has two objectives; 1. To assist the Audit Team in planning the site visit. 2. To provide the plant Industrial Hygienist, the Location Manager, and other plant personnel with some idea of the scope of the Audit. 3. To enlist the plant Industrial Hygienist (supervisor or manager) as a participating member of the Audit Team. APC 004566 iv THE PLANT VISIT The plant visit will require from 1-3 days, depending upon size and complexity of operations. The focus will be on: 0 Personal Interviews and Discussions 0 Walk-through Tour and Observations 0 I.H. Facilities, Procedures and Records Review 0 Evaluation Report and Recommendations The typical sequence of events will be: 1. Final Planning Meeting with Manager for I.H. 2. Short Meeting with Location Manager and Staff 3. Interview with Location Manager (only) 4. Plant and I.H. Program Assessment a. Discussion with Manager for I.H. -- Facilities, Personnel, Processes, and Health Hazards b. Conducted Plant Tour (Incl. interviews with Production Department Managers) c. Staff Department Manager Interviews -- Safety, Engineering and Maintenance, Procurement, Medical, and Hourly Employee Representatives to the Joint Health & Safety Committee d. I.H. Records Review 5. Report and Discuss Findings with Manager for I.H. 6. Short Summary Meeting with Location Manager 7. Summary Meeting with Location Manager and Staff 8. Final Wrap-Up with Manager for I.H. ^pC 004567 v RECOMMENDATIONS AND REPORTS The Audit Team will conclude the plant visit with a verbal assessment report with recommendations to the Manager for I.H. (detailed) and the Location Manager and his staff (summaries). Within two weeks following the visit, the leader of the Audit Team will issue a written DRAFT report to the Location Manager and the Manager for I.H. The report will contain both Summary and Detailed Sections. The plant will have an opportunity to respond and provide input to the final report. The Audit Team will issue the final report to the plant. A copy of the Summary will be provided to the appropriate Corporate Division Manager . Any follow-up actions will be monitored jointly between the plant and Corporate Industrial Hygiene groups. vi APC 004668 Ill EVALUATION WORKSHEETS cc APC 004669 INDUSTRIAL HYGIENE PLANT AUDIT EVALUATION WORKSHEETS (LOCATION) THESE WORKSHEETS SHOULD BE COMPLETED BY THE PLANT INDUSTRIAL HYGIENIST (OR PERSON RESPONSIBLE FOR I.H.) WELL IN ADVANCE OF THE PLANT VISIT -- AND RETURNED TO THE LEADER OF THE AUDIT TEAM. THE WORKSHEETS HAVE TWO OBJECTIVES: 1. TO ASSIST THE AUDIT TEAM IN PLANNING THE SITE VISIT. 2. TO PROVIDE THE PLANT WITH SOME IDEA OF THE SCOPE AND CONTENT OF THE AUDIT AND FORM A BASIS FOR DISCUSSIONS DURING THE AUDIT. THE PLANT INDUSTRIAL HYGIENIST (OR PERSON RESPONSIBLE FOR I.H.) IS EXPECTED TO SERVE AS A MEMBER OF THE AUDIT TEAM. THE AUDIT TEAM WILL EXPLORE HIS/HER FUNCTIONS, AS WELL AS ASSESS THE SUPPORT THEY RECEIVE IN CONDUCTING AN EFFECTIVE I.H. PROGRAM. THE QUESTIONS IN THESE WORKSHEETS ARE NOT MEANT TO BE ALL-INCLUSIVE; RATHER, THEY SERVE AS A STARTING PLACE FOR DISCUSSIONS DURING THE PLANT VISIT. (DATE) KEY ELEMENTS IN PLANT I.H. PROGRAMS SECTION PAGE 1 " POLICIES & PROCEDURES......................................................................... 1 2 - ORGANIZATION & STAFFING................................................................... 3 3 - FACILITIES & EQUIPMENT........................................... 6 4 - WRITTEN I.H. PROGRAMS......................................................................... g 5 - ENVIRONMENTAL MONITORING & SURVEILLANCE. ..... 12 6 - RECORDKEEPING............................................................................................. 16 7 - HEALTH HAZARD CONTROLS ................................................................... 18 8 - HEALTH HAZARD TRAINING ................................................................... 20 9 - COMMUNICATIONS & COORDINATION.................................................... 22 10 - CHEMICAL CONTROL.................................................................................. 25 APC 004571 1. POLICIES AND PROCEDURES The foundation for effective health protection management starts at the top... with the Location Manager and his or her staff. Section 1 will explore the plant management's commitment to meeting the objectives of Industrial Hygiene. 0 What is the Location Manager's role? 0 where and how are he and his staff involved? 0 What policies and procedures have been established? 0 What are the mechanisms for continuity of managing employee health protection? The effectiveness of any I.H. Program will be highly dependent upon the role of plant management. The following types of questions are a starting place to evaluate plant management's position. -1- APC 004572 1. POLICIES AND PROCEDURES 1.1 - Has an I.H. written policy been: Adopted? Published? Supplied in Orientation Literature? 1.2 - Does the Location Manager participate (at least annually) in an I.H. tour of the facility? 1.3 - Are potential health hazard problems discussed in Location Manager's staff meetings? Often _____ Rarely _____ Sometimes Never Don't Know _____ 1.4 - Is there a Joint Health & Safety Committee (Labor and Management)? 1.5 - Is I.H. represented as a member of the Joint Health & Safety Caimittee? 1.6 - Are potential health hazards discussed? Often _____ Rarely _____ Sometimes _____ Never _____ Don't Know _____ 1.7 - Are results of personal exposure surveys provided to employees? Always _____ Sometimes _____ Never YES NO -2- APC004673 2. ORGANIZATION AND STAFFING Discussion in this area is intended to determine if the I.H. organization and staffing are appropriate for the specific needs of the plant. Where I.H. responsibilities are divided, more detail as to the manner of this division will be sought. It is essential that those carrying out I.H. responsibilities be adequately trained. The Audit Team will not be looking for depth of training, per se, received by the hygienist and technician; rather, it will be matching the training received by the principals with the complexity and number of health problems at the specific plant location. There will be a considerable amount of discussion centered around the day-to-day activities of the I.H. Supervisor, who he deals with, and how he attains his objectives, through his own efforts and through cooperative ventures with other managers. The Audit Team will explore this area through discussion with the I.H. Supervisor and other appropriate managers throughout the plant. APC 004674 3 2. ORGANIZATION AND STAFFING 2.1 Does one individual have the clearly defined responsibility and accountability for I.H. activities? YES 2.2 - What are the I.H. Supervisor's qualifications? Professional Industrial Hygienist _ Scientist or engineer, with some I.H. training (Describe the type and source of training.7 NO Primarily administrative Other 2.3 - Are there plans for providing the I.H. Supervisor with basic or supplementary training? (If so, describe.) 2.4 - Is I.H. Supervisor certified by ABIH? 2.5 - Is I.H. Supervisor a member of AIHA? 2.6 - Does I.H. Supervisor periodically attend professional meetings? National ____ Local ____ Corparate-spcnsared conferences ____ 2.7 - Does the I.H. Supervisor have technician support? 2.7.1 - Has the technician received training in I.H. monitoring and measuring? (If so, describe the type and source of training.) 2.7.2 - Are there plans for basic or supplementary training? (If so, describe.) 4 APC 004675 2. ORGANIZATION AND STAFFING (Cont.) 2.8 - Does the I.H. Supervisor have adequate time to devote to I.H.? 2.8.1 - What percent of his time is devoted to I.H.? 2.9 - Does the I.H. Supervisor have direct access to all levels of plant management? 2.9.1 - Is this access frequently used? 2.10- What is the I.H. Supervisor's perception of the visibility of I.H. in his plant within the organizational structure? More than adequate Adequate Less than adequate YES NO ^pC 004676 -5- .3. I.H. FACILITIES AND EQUIPMENT An effective I.H. effort requires adequate facilities, sampling and measuring equipment, and laboratory analytical support. There should be sufficient office space and I.H. laboratory space for maintenance of sampling equipment. Methods and frequency of equipment calibration will be discussed. Plant or other laboratory analytical chemistry support will be reviewed. Decisions in I.H. matters are usually based upon or supported by sampling and analytical data. In Section 3, the Audit Team will assess the plant's I.H. and laboratory capabilities for assuring development of accurate, reliable, and credible data for sampling and chemical analysis. -6- APC 004677 3. I.H. FACILITIES AND EQUIPMENT YES 3.1 - Is adequate I.H. work space available: Office? Storage? Laboratory? 3.2 - Is the I.H. equipment inventory adequate to support program objectives? 3.2.1 - Is equipment routinely calibrated and maintained? (Comment on frequency and procedures for calibration.) NO 3.3. - Are I.H. samples analyzed at: Plant Laboratory (In-House) ______ ALCOA'S EHL (ATC) ______ Outside laboratory (Independent) ______ 3.3.1 - Are collected I.H. samples refrigerated or otherwise properly stored and protected prior to analysis? 3.3.2 - If plant laboratory is utilized for analysis of I.H. samples, does the laboratory have the necessary: Physical Facilities for Trace Analysis? _ Instruments and Equipment? _ Trained Chemists and Technicians? _ 3.4 - Is there a documented analytical quality assurance program, and are quality control records properly maintained for all in-house analyses? _ 3.5 - Are approved analytical methods used for analyses? _ ALCOA'S EHL _______ ASTM _______ NIOSH _______ Other 3.6 - If outside Laboratory is utilized for analysis of I.H. samples, is the laboratory AIHA accredited? (Ccmnent cn reason far cutside laboratory analyses.) _ 7- APC 004678 WRITTEN I.H. PROGRAM It is essential that each plant has a written program even if, in the case of the smaller plants, it entails only a page or two of written material. One of the more important reasons for having a written program is to enable the hygienist to manage his job... rather than have his job manage him. Without the guidelines provided by a written program, the hygienist will tend to operate in a "fire fighting" mode. Furthermore, a program in writing will assist the plant in maintaining a program that is both consistent and appropriate, especially in the event of personnel changes. The Audit Team will explore in detail the contents of each facet of the I.H. Program. The primary thrust is to determine the adequacy of the written material for the specific plant needs. APC 004679 4. WRITTEN I.H. PROGRAM 4.1 - Overall Program 4.1.1 -Are the contents of the plant's overall I.H. Program put into writing? 4.1.2 - If so, does this document include a statement of policy and objectives? 4.1.3 - A description of processes? 4.1.4 - An inventory of potential exposures? Including process materials? By-Products? Physical Hazards (Noise, Radiation, Etc.)? 4.1.5 - A list of job classifications? Including list of tasks each perforins? Potential environmental exposures far each? 4.1.6 - A record of hazardous materials training? 4.1.7 - A sampling schedule? 4.2 - Respirator Program 4.2.1 - Is respiratory protection used in any area of the plant? 4.2.2 - If so, does a written program exist? 4.2.3 < Is respiratory protection mandatary where engineering controls are being instituted, or are not feasible, to control air contaminants to acceptable levels? 4.2.4 - Is there a written Respiratory Protection Program which aims to fulfill the requirements of 29 CFR 1910.134? 4.2.5 - Is the responsibility for program administration clearly defined? NO -9- APC 004600 WRITTEN I.H. PROGRAM (Cont.) 4.2 - Respirator Program (Cont.) 4.2.6 - Do written Standard Operating Procedures detailing selection and use of respirators exist? 4.2.7 - Do SOP include a list of all jobs requiring respirator usage? 4.2.8 - is there a fit-testing program? (Describe type.) 4.2.9 - Are respirators adequately cleaned and maintained, and are they inspected during cleaning? 4.2.10- Do respirator users receive medical approval, and is such approval documented -- and reviewed periodically? 4.2.11- Are all respirators NIOSH/MSHA approved and adequate for intended use? 4.2.12- Is program periodically evaluated to insure proper respirator use and continued effectiveness of program? 4.3 - Hearing Conservation Program 4.3.1 - Are any employees exposed to noise levels equivalent to 85 dBA or higher for an 8-hr. exposure? 4.3.2 - If so, does a Hearing Conservation ' Program exist? 4.3.3 - If Hearing Conservation Program exists, is it in writing? 4.3.4 - Are hearing protectors mandatory where excessive exposures exist? 4.3.5 - Is there enforcement of required hearing protection? 4.3.6 - Are signs requiring hearing protection posted in areas requiring mandatory hearing protection? 4. WRITTEN I.H. PROGRAM 4.4 - Other Programs 4.4.1 - Are there needs for other I.H. sub-programs in your plant (e.g., Urinary Fluoride, Ionizing Radiation, etc.)? 4.4.2 - If so, name them: YES NO 4.4.3 - Are they in written form? 4.4.4 - Are they a part of the overall plant I.H. Program? -11- APC 004682 5. ENVIRONMENTAL MONITORING & SURVEILLANCE The foundation for evaluating potential I.H. problems is accurate environmental monitoring data. Through I.H. sampling, air contaminants are identified; the effectiveness of engineering controls are measured; and the magnitude of employee exposures are determined. The principal objective of this section is to determine if monitoring is being conducted correctly, baseline exposures are established, and a monitoring program is developed for continued surveillance. Special I.H. problems will be reviewed concerning the types of hazardous contaminants existing and the job classes exposed to these compounds. ARC 004683 5. ENVIRONMENTAL MONITORING & SURVEILLANCE -- '; 5.1 - Air Sampling for Chemical Contaminants YES 5.1.1 - List contaminants of major health concerns and comment upon exposure levels. NO 5.1.2 - What is the basis for sampling? Scheduled _____ Complaint _____ Regulation _____ 5.1.3 - Is the sampling schedule maintained? 5.1.4 - Have baselines been established for all job classes where exposures to hazardous contaminants exist? 5.1.5 - Are Sampling Data Sheets ccmplete? 5.1.6 - Is parallel sampling performed during OSHA, MSHA inspections? 5.1.7 - Are blanks and bulks, when required, sent with samples for analysis? 5*1.8 - Has an adequate amount o sampling been conducted for evaluating I.H. concerns? 5.1.9 - Are there any areas needing more data? . -13- APC 004684 5. ENVIRONMENTAL MONITORING & SURVEILLANCE (Cont.) . 5-2 - Noise Monitoring & Surveillance Y! 5.2.1 - Has a total plant noise survey been completed? Personal _____ Area _____ Both _____ 5.2.2 - How often is it updated? 5.2.3 - Are noise measurements repeated in areas when process changes have occurred? 5.2.4 - Are calibrations made before and after measurements? 5.3 - Radiation Monitoring & Surveillance (As Appropriate) 5.3.1- Are radiation devices (ionizing and non-ionizing) used at this plant? _______ (If not, proceed to Section 5.4.) ______ Microwave _____ Medical X-Ray _____ Density & Level Gauges _______ Others _______ 5.3.2- Is radiation monitoring routinely conducted? _______ ______ 5.3.3- Who conducts radiation monitoring? Hygienist Engineering Other 5.3.4- Are radiation supervisors adequately trained? _______ 5.3.5- Type of monitoring equipment available? Beta/Gamma Survey Meter Electromagnetic leakage Meritor _______ ______ APC 004606 -14 5. ENVIRONMENTAL MONITORING & SURVEILLANCE (Cont.) 5*3 - Radiation Monitoring & Surveillance (As Appropriate) (Cont.) 5.3.6 - Is there a current inventory YES ---------- of all ionizing and non-ionizing radiation sources? N( -- 5.3.7 - Is a radiation badge program in place? 5.3.8 - Is I.H. included in the approval cycle for all radiation source procurement? 5.3.9 - Are all radiation sources labeled? 5.3.10- Who maintains the radiation records file? 5.3.11- Are radiation records ocnplete? 5.4 - Heat Stress (As Appropriate) 5.4.1 - Are heat stress studies conducted? APC 004606 15 6. RECORDKEEPING An effective I.H. Program must have a well-managed system of recordkeeping. This will help provide: a. Protection of workers' health by providing easily retrievable data on I.H. exposures. b. Protection of the Company's interests by documenting levels below the PEL. c. Procedures to meet legal requirements of recordkeeping. This section will determine whether records are stored in a manner in which they earn be easily retrieved, and if the records are complete. Specific files related to I.H. monitoring will be considered and, where appropriate, the techniques involved in handling computerized data will also be discussed. -16- jpe 004687 6. RECORDKEEPING 6.1 - Is a file maintained for personal exposures? By individual _______ By job class _______ 6.2 - Are calibration records maintained for sampling equipment? 6.3 - Are repair/maintenance records maintained for sampling equipment? 6.4 - Are Sampling Data Sheets filed with survey results? 6.5 - Is a computerized recordkeeping system employed? 6.6 - Other files maintained: Issuance of hearing protection & use? Mandatory _____ By choice _____ Assignment & approval far respirator use? Respirator fit-testing? Audiometer Booth Calibration? Inventory of Hazardous Materials? Material Safety Data Sheets: Company Supplier OSHA/MSHA Inspections & Citations? Employee Health Hazard Training? YES NO -17- APC 004688 7. HEALTH HAZARD CONTROLS Once health hazards are identified and the degree of hazard determined, the next question to be answered is... What should be done to alleviate or control the problem? The proper sequence in seeking solutions is: 0 Substitution 0 Administrative Controls 0 Engineering Controls 0 Personal Protection In this section, the Audit Team will assess the plant's approach and degree of success in solving exposure problems. APC 004660 -18 7. HEALTH HAZARD CONTROLS 7.1 - Are health hazard controls instituted when: Exposures are known to exceed standards? Exposures are unknown and judged to approach or exceed standards? Health effects or discomfort are noticed at exposure levels below standards? 7.2 - Are safer substitute materials, engineering controls, and work practice controls being given priority consideration? (List examples.) YES NO 7.3 - Are ventilation and exhaust systems inspected at installation and periodically for their effectiveness? 7.3.1 - By whom? 7.3.2 - Are new or modified ventilation systems reviewed by I.H.? -19- APC 004600 8. HEALTH HAZARD TRAINING Educating hourly employees, supervisors, and plant management is an important element of a successful I.H. Program. This Audit will explore a variety of aspects of health hazard training including, but not limited to: 0 Who does it? 0 How is it accomplished? 0 Frequency and time spent? 0 Program content (previous and planned)? 0 Attendance records? APC 004601 -20 HEALTH HAZARD TRAINING YES Are there health hazard training programs provided for employees in the following areas: NO PROGRAM INITIAL REFRESHER Hearing Protection _____ Heat Stress _____ Radiation _____ Respiratory Protection _____ Toxic Materials _____ 8.2 - Does training include both hourly and salaried personnel? 8.3 - Do line supervisors receive training equivalent to that indicated above? ARC 004692 9. COMMUNICATIONS AND COORDINATION The overall success of a plant I.H. Program is dependent upon close working relationships and communications between many departments within the plant and I.H. personnel. The purpose of this section will be to explore the scope and effectiveness of the communication between I.H. and these various critical departments. Intercommunication will be evaluated as relates to the ability to identify mutual potential I.H. concerns, as well as to achieve implementation of I.H. corrective actions where a joint effort is required. The nature of the communication (formal, informal, etc.) will also be pursued. -22- APC 004683 9. COMMUNICATIONS AND COORDINATION 9.1 - Medical 9.1.1 - Is biological monitoring and medical surveillance for toxic substances being performed, where appropriate? 9.1.2 - Does the I.H. Supervisor interpret the results before informing the enployee? 9.1.3 - Do the I.H. Supervisor and the physician discuss the results of the tests? 9.1.4 - Are survey results reported to department supervisory or management personnel? 9.1.5 - Are survey results reported to Pittsburgh Industrial Hygienist liaison contact? 9.1.6 - Does the physician participate in employee training programs? 9.1.7 - Is there effective liaison between Medical and I.H. as relates to potential chemical exposures? 9.2 - Safety 9.2.1 - Is I.H. involved in Safety departmental meetings and activities within the plant? 9*2.2 - Is there effective ccrarunicaticn, where necessary, between I.H. and Safety as relates to plant exposure problems (noise, respirators, etc.) and their resolution? 9.2.3- Are I.H. concerns considered in plant Project Safety reviews? (Discuss how this is accomplished.) YES NO p&C 00469* 23 9. COMMUNICATIONS AND COORDINATION (Cont.) 9.2 - Safety (Cont.) YES 9.2.4 - Do JSAs include health risks? 9.2.5 - Have I.H. and Safety developed emergency planning for high-hazard, critical events? 9.3 - Line Production 9.3.1 - Is there effective communication between I.H. and Line Production on I.H. matters and concerns? 9.3.2 - Is the I.H. Supervisor recognized as a resource by the Line Production personnel? 9.3.3 - Is there effective implementation of I.H. recommendations by Line Production? 9.4 - Is there effective communication between the I.H. Supervisor and the following groups: Environmental Control? Engineering & Maintenance? Procurement? Hearing Conservation Coordinator (If other than I.H.)? Works Laboratory Personnel (If they perform services for I.H.)? Plant Management? 9.5 - Do the Corporate I.H. and Environmental Health Led) personnel provide the services you desire? NO AFC 004695 -24 10. CHEMICAL CONTROL Plants purchase and maintain a wide inventory of chemical materials. Pro-active, preventive measures to avoid potentially hazardous exposures start with a knowledge of their existence within the plant. Management of chemicals may start with a continuously updated inventory and/or include such aspects as Material Safety Data Sheets or adequately labeled containers. Depending upon the degree of chemical material use, some plants will have a Hazardous Materials Control Committee. The Audit Team will explore all aspects of the plant's efforts to manage and control chemical materials. -25- APC 004686 10. CHEMICAL CONTROL 10.1 - Is there a plantwide materials inventory of chemicals? YES 10.1.1 - Are there procedures for updating the inventory? 10.2 - Is there a Hazardous Materials Control Committee? 10.3 - Does Procurement obtain I.H. clearance prior to introducing new chemical substances into the worksite? 10.4 - Are MSDS available and transmitted to I.H. personnel for all production chemical substances purchased in the workplace? NO #*# -26- AFC 004607