RPM | REQUIREMENTS AND POLICIES MANUAL

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    Title:

    Exposure Assessment

    Publication date:

    5/5/2020

    Effective date:

    12/15/2019

    BRIEF

    Policy Summary

    Lawrence Berkeley National Laboratory's (Berkeley Lab's) Exposure Assessment policy requires that Laboratory personnel exposure to chemical and physical workplace hazards be maintained within acceptable exposure limits. The Exposure Assessment policy further requires that exposures be minimized by the use of hazard elimination, engineering controls, personal protective equipment, and administrative controls.
    Occupational exposures addressed by this policy include, but are not limited to, chemicals and physical agents (e.g., noise, hot and cold extremes, and non-ionizing radiation). Assessments for confined spaces, lasers, ergonomics, biological agents, and radiological exposures are handled by their respective programs.

    Who Should Read This Policy

    Berkeley Lab managers, supervisors, employees, and affiliates who might be exposed to chemical or physical hazards or who are responsible for managing exposures for workers, during work performed at Berkeley Lab or during Laboratory-sponsored work

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    To Read the EHS Program Details, Go To:

    http://www.lbl.gov/ehs/ih/programs/exposure.shtml

    Contact Information

    For assistance with exposure assessments, contact the Health and Safety Representative assigned to your division (see the Whom to Call page on the EHS Web site).
    For questions about the overall Exposure Assessment Program, contact: Subject Matter Expert for Exposure Assessment, EHS Division

    Title:

    Exposure Assessment

    Publication date:

    5/5/2020

    Effective date:

    12/15/2019

    POLICY

    To Read the EHS Program Details, Go To:

    http://www.lbl.gov/ehs/ih/programs/exposure.shtml

    Purpose

    This policy describes Lawrence Berkeley National Laboratory's (Berkeley Lab's) approach to evaluating chemical and physical workplace health hazards at the Laboratory and/or during Laboratory-sponsored work at other locations.
    Occupational exposures addressed by this program include, but are not limited to, chemicals and physical agents (e.g., noise, hot and cold extremes, and non-ionizing radiation). Assessments for confined spaces, lasers, ergonomics, biological agents, and radiological exposures are handled within their respective programs.

    B. Persons Affected

    Berkeley Lab managers, supervisors, employees, and affiliates who might be exposed to chemical or physical hazards, or who are responsible for managing exposures for workers, during work performed at Berkeley Lab or during Laboratory-sponsored work

    C. Exceptions

    None

    D. Policy Statement

    1. Overexposure to chemical or physical agents may lead to various types of occupational diseases, both acute and chronic. A partial list of common occupational health conditions is provided below:
      1. Respiratory irritation due to exposure to ozone.
      2. Asbestosis or lung cancer from asbestos.
      3. Headaches or systemic injury associated with organic solvents.
      4. Hearing loss as a result of noise exposure.
    2. Additional hazards may accompany the presence of exposure agents.. For example, chemicals may pose fire hazards in addition to the health hazards related to direct exposure.
    3. Prior to handling chemicals, persons must complete training that covers (a) hazards of chemicals and (b) methods for controlling the hazards. Training may include courses such as EHS0345, Chemical Hygiene for Facilities; EHS0348, Chemical Hygiene and Safety; EHS0356, Nano-Safety for Crafts and Technical Work; EHS0310, Respirator Training; and EHS0330, Lead Worker Training.
    4. Users of hazardous chemicals and agents must follow training guidance and written procedures covering:
      1. Exposure controls.
      2. Use of controls for chemical handling, including PPE.
    5. Assessments may be initiated by multiple methods:
      1. Requested through the Laboratory's Work Planning and Control (WPC) processes.
      2. Requested on the Laboratory's Chemical Management System.
      3. Requested by Activity Leads or other work planners, where work involves any new agents or materials that pose any concern about possible exposures.
      4. As requested by a supervisor or employee.
      5. Flagged by the EHS Division or other Laboratory divisions/departments during a walk-through.
      6. Prompted by another EHS Division review or approval process
    6. Exposure assessments may be qualitative or quantitative:
      1. Baseline Exposure Assessments are often performed to determine whether a more in-depth quantitative assessment is necessary.
      2. Quantitative assessments include air monitoring, noise dosimetry, and magnetic surveys. They are performed in part to establish whether the assigned controls for a task are sufficient to maintain exposure levels within acceptable limits.
      3. Worker exposures shall be maintained below applicable Occupational Exposure Limits (OELs) such as Permissible Exposure Limits (PELs) and Threshold Limit Values (TLVs).
    7. Line management (Supervisors and Activity Leads, for instance) ensure that Environment, Safety & Health (ES&H) requirements are followed to control exposures.
    8. The Exposure Assessment Program will be evaluated periodically for accuracy and effectiveness.

    E. Roles and Responsibilities

    See ESH Manual (PUB-3000), Chapter 4, Section 4.5 for roles and responsibilities related to the execution of this policy's implementation. Key roles are listed here.

    Role

    Responsibility

    Activity Leads and Project Leads
    • Ensure that work is performed consistent with procedures and controls defined in applicable work planning documents (e.g., WPC Activities).
    • Request an Exposure Assessment if there is concern about potential exposure.
    • Ensure that persons within their areas of responsibility comply with this policy and its implementing documents and have completed the required training prior to beginning work.

    Exposure Assessment Subject Matter Expert
    • Develops and administers the Exposure Assessment Program and this policy and its implementing documents.

    EHS Technical Program Subject Matter Experts
    • Determine exposure assessment needs in relation to technical program requirements.
    • Perform appropriate exposure assessments, including completing all appropriate documentation.

    Health and Safety Representatives
    • Perform appropriate exposure assessments, including completing all appropriate documentation.
    • Respond to exposure assessment requests.
    • Assist line management in anticipating and recognizing exposure concerns.
    • Assist EHS subject matter experts in planning and conducting exposure assessments in relation to individual technical program needs.

    Line Managers
    • Ensure that persons within their areas of responsibility comply with this policy and its implementing documents and notify the appropriate EHS Division Subject Matter Experts or Health and Safety Representatives of process changes that may affect employee exposures.

    Potentially Exposed Workers
    • Request an Exposure Assessment when a concern is present regarding potential exposure, perform work in accordance with the controls and procedures defined in work planning documents (e.g., WPC Activities), and follow guidance and work practices provided in workplace training (such as On-the-Job Training [OJT]) to evaluate and control exposures.

    Supervisors
    • Request an exposure assessment when a concern is present regarding potential exposure, and ensure that persons within their areas of responsibility comply with this policy and its implementing documents and have completed the required training prior to beginning work.

    F. Definitions/Acronyms

    See ESH Manual (PUB-3000), Chapter 4, Section 4.6, and the Implementing Documents of this policy for technical terms related to the details of this policy and its implementation.

    Term

    Definition

    Activity

    Baseline Exposure Assessment

    A Baseline Exposure Assessment is a process to screen activities to help determine associated risks and hazards. These assessments are generally qualitative, although some quantitative data (collection or review) may be involved.

    Chemical Agents

    Includes all chemicals used at the Laboratory (or in Laboratory-sponsored work). This includes pure chemicals, mixtures (such as paint or cleaning agents), and materials such as asbestos, silica, and engineered nanomaterials.

    Engineered Nanomaterials

    Discrete materials having structures with at least one dimension between 1 and 100 nanometers, and intentionally created, as opposed to those that are naturally or incidentally formed. Engineered nanomaterials do not include larger materials that may have nanoscale features (e.g., etched silicon wafers), biomolecules (e.g., proteins, nucleic acids, and carbohydrates), or materials with Occupational Exposure Limits (OELs) that address nano-size particles for that substance.

    Exposure

    Inhalation, ingestion, absorption, injection, or contact with a chemical, biological, or physical agent.

    Exposure Assessment

    The process of defining exposure profiles and judging the acceptability of workplace exposures to environmental agents. These assessments may be quantitative, semiquantitative, or qualitative. They are generally conducted by an ES&H professional, which may include industrial hygienists or safety engineers. These assessments may be conducted for representative employees and are not required to be conducted for each individual. In all cases, employees have full access to exposure-monitoring information, including situations where an individual's exposure is not monitored.

    Occupational Exposure Limit (OEL)

    The maximum concentration of an air contaminant to which working people can be exposed for a specified time interval, usually the maximum average exposure allowed throughout an entire eight-hour shift. OELs are typically PELs or TLVs, which are also defined in this section. In the absence of formally recognized or regulatory-defined OELs, a chemical manufacturer may establish an exposure limit that is appropriate to use. Alternatively, the occupational health staff will have to determine or develop an appropriate protective level. This process often involves industrial hygiene, occupational medicine, and toxicology staff members. The National Institute for Occupational Safety and Health also publishes Recommended Exposure Limits, which may be evaluated for use.

    Hazard Assessment

    A preliminary evaluation (or screening) of an activity to determine if a more comprehensive Exposure Assessment is required. Hazard Assessments can be performed by work leads, supervisors, workers, or an EHS professional. Hazard Assessments are one form of Baseline Exposure Assessment.

    Industrial Hygiene

    The art and science of anticipation, recognition, evaluation, and control of occupational health hazards (including exposures to chemicals, noise, and non-ionizing radiation)

    Permissible Exposure Limit (PEL)

    The OSHA permissible exposure limits are exposure levels considered safe for employee exposure in the workplace. PELs for airborne concentrations of hazardous materials are listed in 29 CFR 1910, Subpart Z, and 29 CFR 1926, Subpart Z, and for physical agents (i.e., noise and non-ionizing radiation) in 29 CFR 1910, Subpart G.

    Physical Agents

    Agents such as noise, hot and cold extremes, and non-ionizing radiation (e.g., radio frequency, electromagnetic, microwave, and magnetic fields). Laser exposure is addressed by the Laser Safety Program (refer to PUB-3000, Chapter 16).

    Professional Judgment

    The application and appropriate use of knowledge gained from formal education, experience, observation, experimentation, inference, peer review, and analogy. It allows an experienced industrial hygienist with incomplete or a minimum amount of data to estimate worker exposure in nearly any scenario (adapted from DOE Guide G 440.1 and AIHA A Strategy for Assessing and Managing Occupational Exposures, Fourth Edition [2015]), although such judgments and their basis should be documented.

    Qualitative Exposure Assessment

    The estimation of exposure determinants based on integration of available information and professional judgment (adapted from DOE Guide G 440.1-3, Occupational Exposure Assessment).

    Quantitative Exposure Assessment

    The determination of exposure based on collection and quantitative analysis of data sufficient to adequately characterize exposures (adapted from DOE Guide G 440.1-3 and AIHA A Strategy for Assessing and Managing Occupational Exposures, Fourth Edition [2015]).

    Similar Exposure Group

    A group of workers having the same general exposure profile for an agent based on the similarity of tasks being performed, and the similarity of the way in which they perform the tasks. The workers use the same general work practices and engineering controls when performing the tasks.

    Task

    For purposes of workplace evaluations and setting priorities, a job (or portion of a job) involving a discrete agent or set of agents to which workers may be exposed. The terms "activity" (not to be confused with WPC Activity) and “operation” are sometimes used in a similar manner.

    Threshold Limit Values® (TLVs):

    Airborne concentrations of materials to which typical workers may be repeatedly exposed without adverse health effects. TLVs are not intended to represent fine lines between safe and dangerous exposures. These values are developed and published by the American Conference of Governmental Industrial Hygienists (ACGIH). There are different values established for eight-hour time-weighted averages, ceilings, and Short-Term Exposure Limits. Other TLVs are available for non-chemical exposures, such as noise and non-ionizing radiation.

    Work Planning and Control (WPC)

    A program to implement integrated safety management. The main goals of WPC are the following:

    • All hazards are analyzed and controlled.
    • All workers demonstrate that they are qualified to perform activities.
    • All work is authorized.

    All authorizations (job hazard analysis, activity hazard documents, biological use authorizations, rad work authorization) are combined in a single program.

    WPC Activity

    A work planning and work authorization document used at LBNL to define work scopes, the hazards and associated controls, and to authorize workers to conduct the work.   

    WPC Activity Lead

    Person responsible for directing, training, and overseeing the work and activities of one or more workers. Activity Leads provide instruction on working safely and the precautions necessary to use equipment and facilities safely and effectively. 

    G. Recordkeeping Requirements

    • WPC Activities
    • Baseline and Quantitative Exposure Assessments

    H. Implementing Documents

    Document Number

    EHS Reference

    Title

    Type

    07.07.013.001

     ESH Manual, CH4

    Berkeley Lab Exposure Assessment Program

    Program

    07.07.019.001

     ESH Manual, CH37

    Lead Hazards and Controls

    Program

    07.07.002.001

     ESH Manual, CH36

    Asbestos

    Program

    07.07.003.001

     ESH Manual, CH38

    Beryllium

    Program

    07.07.016.001

     ESH Manual, CH40

    Heat Stress

    Program

    07.07.023.001

     ESH Manual, CH43

    Non-Ionizing Radiation

    Program

    I. Contact Information

    For assistance with exposure assessments, contact the Health and Safety Representative assigned to your division (see the EHS Division Whom to Call page).
    For questions about the overall Exposure Assessment Program, contact the EHS Division Subject Matter Expert for Exposure Assessment.

    J. Revision History

    Date

    Revision

    By Whom

    Revision Description

    Section(s) Affected

    Change Type

    9/24/2013

    0.1

    T. Roberts

    Reviewed, 8/26/13

    SRD, ImpDocs, Next Review Date

    Minor

    1/2/2010

    0

    T. Roberts

    Rewrite for wiki

    All

    Minor

    5/5/2020

    1

    J. Heim

    Minor policy update replacing references to JHA with WPC and other policy text clarifications.

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    Exposure Assessment

    Document number

    07.07.013.000

    Revision number

    1

    Publication date:

    5/5/2020

    Effective date:

    12/15/2019

    Next review date:

    5/5/2025

    Policy Area:

    Industrial Hygiene and Safety

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    None

    Functional Division

    EHS

    Prior reference information (optional)

    PUB-3000, Chapter 4, Section 4.18

    Source Requirements Documents

    • 10 CFR 851.21(a)(5), Worker Health and Safety Program; Hazard Identification and Assessment; Evaluate Operations, Procedures, and Facilities to Identify Workplace Hazards
    • 29 CFR 1910.1020, Access to Employee Exposure and Medical Records
    • 29 CFR 1910 Subpart Z, Toxic and Hazardous Substances
    • 10 CFR 850, Chronic Beryllium Disease Prevention Program

    Other Driving Requirements

    • Federal Public Law 91-596, Occupational Safety and Health Act of 1970
    • PUB-3851, Worker Safety and Health Program

    Implementing Documents

    Document Number

    EHS Reference

    Title

    Type

    07.07.013.001


    Berkeley Lab Exposure Assessment Program

    Program

    07.07.019.001


    Lead Hazards and Controls

    Program

    07.07.002.001


    Asbestos

    Program

    07.07.003.001


    Beryllium

    Program

    07.07.016.001


    Heat Stress

    Program

    07.07.023.001


    Non-Ionizing Radiation

    Program

    Other References

    • DOE Standard 6005, Industrial Hygiene Practices (guidance only)
    • AIHA, A Strategy for Assessing and Managing Occupational Exposures, Third Edition (guidance only)
    • DOE Guide 440.1-8, Implementation Guide for Use with DOE Guide G 440.1: Occupational Exposure Assessment



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