Transcript Industrial Hygiene Monitoring How Much is Enough? When Can It Stop?? Sampling

Industrial Hygiene Monitoring
How Much is Enough?
When Can It Stop??
Sampling
Presented by:
Jonathan Haas, CSP, CIH
Orange Park, Florida 32073
(904) 298-1817
STAR Consultants, Inc.
580 Bellerive Dr. Unit 5B
Annapolis, MD 21409
(410) 349-9713 (410) 757-0524 FAX
www.starconsultants.net
You may download this presentation by going to
www.starconsultants.net
Presented at:
AIHA Florida
Annual Region IV Conference
Tampa, FL
Friday March 24, 2006
What I Typically See
Industrial hygiene at a company location is
handled by a safety manager
The safety manager typically has been on the
job for less than two years
Industrial hygiene monitoring is conducted by
a consultant
Reports from prior years have not been read
by the current safety manager
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What I Typically See
Monitoring is conducted to a list of
contaminants that was prepared some time
ago – sometimes many years ago
Monitoring is repeated this year because it
was on the list last year and has always been
monitored. The reason why is not known.
Employees who are monitored are notified of
the results
Employees similarly exposed are not
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What I Typically See
Medical services, whether on site or contract
occupational, have not been provided with
summaries of data
Exposure monitoring results, if provided to
Medical services occasionally are filed in the
employees “jacket” but usually are filed
somewhere else
Data summaries for similar exposure groups
are not available anywhere on site
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What I Typically See
IH Consultants rarely are contracted to review
all prior data and provide summaries and
recommendations
IH Consultants rarely are contracted to fully
document all materials by similar exposure
group, the toxicity, usage and controls –
resulting in a fully documented QEA
Safety staff rarely have a process to review
new materials to make a determination if
monitoring is needed before full production
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Good HSMS Programs Help
Employee complaints (coughing, irritation,
etc.) are signs that one or more Health and
Safety Management Systems are not working
properly.
IH Consultant observations for defective
ventilation, unacceptable use of PPE, or
improper handling of materials is another sign
that HSMS programs are defective
What one HSMS program misses, another is
supposed to catch – see next page
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OSHA’s VPP Elements
IH affects those noted
30 Elements
MANAGEMENT
LEADERSHIP
Management
Commitment
Employee
Involvement
WORKSITE
HAZARD
ANALYSIS
HAZARD
PREVENTION
& CONTROL
SAFETY
& HEALTH
TRAINING
Baseline InventoriesCertified Professional • Managers
Routine Hazard
Resources
Supervisors
Analysis (JHA –
Hazard Elimination Workers
• Policy
• Encouragement
Contractors
Ergo)
and Control Methods
Goals, Objectives • Participation
•Committees
Change (Pre-use)
Engineering
Planning
• (Committees)
Emergencies
Hazard Analysis
Admin
• Visible Top
PPE
IH Program
PPE
Management Leadership
Routine SelfWork Rules/Practices/
• Responsibility and
Inspections
Discipline
Authority
(required, general, Occupational Health
• Line Accountability
specific)
Care
Resources
Reporting System Preventive
Contract Worker
• Investigations
Maintenance
Coverage
Trend Analysis
• Tracking of
Written S&H
Corrections
Management System
Emergency
1/26/89 & 3/25/03
• Annual Self-Evaluations
Preparedness
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Clients Need
A process for determining monitoring needed
based on a standardized qualitative exposure
assessment process that results in a number
A process for taking initial measurements or
contracting for same that determines if
additional monitoring is needed
A process, when initial measurements
indicate a continuing need for monitoring, for
determining the number of samples needed
to make the next decision
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Hypothetical Case 1
Client has determined that a new material
should be monitored
Discussions with employees reveal that
certain situations results in worse exposure,
based on their knowledge of the job
Monitoring of those worst case exposures
using a validated method of collection with
analysis in a AIHA accredited lab shows all
samples “Below Detection Limit”
Do you recommend additional tests?
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Hypothetical Case 2
Client has determined that a new material
should be monitored
Discussions with employees reveal that
certain situations results in worse exposure,
based on their knowledge of the job
Monitoring of those worst case exposures
using a validated method of collection with
analysis in a AIHA accredited lab shows all
samples above the Exposure Limit
Do you recommend additional tests?
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Hypothetical Case 3
Client has determined that a new material
should be monitored
Discussions with employees reveal that
certain situations results in worse exposure,
based on their knowledge of the job
Monitoring of those worst case exposures
using a validated method of collection with
analysis in a AIHA accredited lab shows 50%
of the samples above the Exposure Limit
Do you recommend additional tests?
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Hypothetical Case 4
Client has determined that a new material
should be monitored
Discussions with employees reveal that
certain situations results in worse exposure,
based on their knowledge of the job
Monitoring of those worst case exposures
using a validated method of collection with
analysis in a AIHA accredited lab shows none
of the samples above the Exposure Limit
Do you recommend additional tests?
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Professional Judgment
If you are called to testify in a court case
involving your monitoring, your exposure
assessment determination process will be
attacked
If you used a validated sampling method and
accredited lab, that is an expected question
What will you say when a statistical analysis of
the samples you took, which were all below the
exposure limit, shows that 5% overexposures
are predicted?? Did you advise the client?
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Document The Process
Your client needs to understand how you make
recommendations for added sampling, fewer
samples, or the termination of sampling
Pulling the cloak over your head and saying “Trust
me – I know what I’m doing” makes you either Obi
Wan or the Evil Sith depending on who is asked
Showing your client a strategy based on statistics
and probability, with graphs of examples, gains you
credibility
You will not be stammering when attacked as a
witness
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Industrial Hygiene Data
Before we can debate how much is needed and
when can we stop, we need to debate how
much predicted overexposure is acceptable
The debate is NOT about how much actual
overexposure is acceptable, but is about how
much predicted overexposure is acceptable
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How Much Exceedance is OK?
Does the acceptable percentage predicted to
exceed the limit depend on what the
material’s toxicity – the reason for the limit?
Does the acceptable percentage predicted to
exceed the limit depend on who is asked?
Employees
Management
The industrial hygienist
Yes
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What Predicted Exceedance % is OK?
Situation A
Reproductive toxin
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Situation B
Reproductive Toxin
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Do controls change the answer?
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The Wall Street Journal Test
How would management react to having a
Wall Street Journal article describe how they
were knowingly permitting employees to be
potentially overexposed to a reproductive
toxin, based on available data?
And describing how one out of five children
have observable birth defects and that data
predicts that your plant averages one day a
year over the exposure limit? (0.4% of 250
days)
With anger, right?
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What Predicted Exceedance % is OK?
Situation A
Carcinogen
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Situation B
Carcinogen
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Do controls change the answer?
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What Predicted Exceedance % is OK?
Situation A
Lung damage
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Situation B
Lung damage
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Do controls matter, really?
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What Predicted Exceedance % is OK?
Situation A
Irritant only
Adequate controls
Good PM for controls
Knowledgeable people
Good concern handling
Great supervision
Good mgmt of change
Your daughter works it
Situation B
Irritant only
Iffy controls
Poor PM for controls
MSDS available
Poor concern handling
Weak supervision
No mgmt of change
Your daughter works it
Do controls matter, really?
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Available Software
Really easy to use: Ihstat.xls
Determines whether samples are normally
distributed or log normally distributed
Determines % predicted to exceed limit
Really terrific to use: Minitab
Same as above, plus terrific graphs
Used by many for Six Sigma projects
Obsolete: Logan
Unusable: NIOSH Decision Logic graphs
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Here is a Minitab graph of the same data
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Monitoring Decisions
Starting from no data at all
IH Monitoring Decisions Based on Statistical Data Results
Take three “Worst Case”* samples
Reduce
exposure
Yes
Any sample > full or short term limit
No
Yes
All < limit; either mean >50% of limit
No
Yes
All < limit; both means <50% of limit
Investigate
Reduce
Repeat
Start PM
(See next page)
No
All three < 10% of limit
Yes
No more samples needed
Calculated STEL
Full shift limit 0 to 1 PPM; STEL = 3 times full shift limit;
is based on full shift
Full shift limit 2 to 10 PPM; STEL = 2 times “
“
“
exposure limit when
Full shift limit 11 to 100 PPM; STEL = 1.5 times “
“
none is published
Full shift limit >100 PPM; STEL = 1.25 times “
“
“
*Worst case sampling can be personal samples or area samples and can last for only as long as the agent is handled that day.
If sampling is just for 15 to 30 minutes, the result is compared to a Short Term Limit ( or calculated STEL ). The result is also to be
converted to an 8-hour time weighted average and compared against that full shift exposure limit.
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Worst Case
Both means > 50% Limit
Investigate, Reduce, Repeat
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IH Monitoring Decisions Based on Statistical Data Results
Take three “Worst Case”* samples
Reduce
exposure
Yes
Any sample > full or short term limit
No
Yes
All < limit; either mean >50% of limit
No
Yes
All < limit; both means <50% of limit
Investigate
Reduce
Repeat
Start PM
(See next page)
No
All three < 10% of limit
Yes
No more samples needed
Calculated STEL
Full shift limit 0 to 1 PPM; STEL = 3 times full shift limit;
is based on full shift
Full shift limit 2 to 10 PPM; STEL = 2 times “
“
“
exposure limit when
Full shift limit 11 to 100 PPM; STEL = 1.5 times “
“
none is published
Full shift limit >100 PPM; STEL = 1.25 times “
“
“
*Worst case sampling can be personal samples or area samples and can last for only as long as the agent is handled that day.
If sampling is just for 15 to 30 minutes, the result is compared to a Short Term Limit ( or calculated STEL ). The result is also to be
converted to an 8-hour time weighted average and compared against that full shift exposure limit.
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Worst Case
Both means < 50% Limit
Start Periodic Monitoring
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IH Monitoring Decisions Based on Statistical Data Results
Take three “Worst Case”* samples
Reduce
exposure
Yes
Any sample > full or short term limit
No
Yes
All < limit; either mean >50% of limit
No
Yes
All < limit; both means <50% of limit
Investigate
Reduce
Repeat
Start PM
(See next page)
No
All three < 10% of limit
Yes
No more samples needed
Calculated STEL
Full shift limit 0 to 1 PPM; STEL = 3 times full shift limit;
is based on full shift
Full shift limit 2 to 10 PPM; STEL = 2 times “
“
“
exposure limit when
Full shift limit 11 to 100 PPM; STEL = 1.5 times “
“
none is published
Full shift limit >100 PPM; STEL = 1.25 times “
“
“
*Worst case sampling can be personal samples or area samples and can last for only as long as the agent is handled that day.
If sampling is just for 15 to 30 minutes, the result is compared to a Short Term Limit ( or calculated STEL ). The result is also to be
converted to an 8-hour time weighted average and compared against that full shift exposure limit.
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Worst Case
Both means < 10% Limit
No Predicted Exceedance
Stop Monitoring
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Monitoring Decisions
Based on Results of Periodic
Monitoring
Periodic Monitoring Decisions based on Statistics
Take 8 full-shift samples, random
Any sample > Limit
Yes
Conduct exposure assessment
“Worst Case”
Yes
Conduct exposure assessment
“Worst Case”
No
% Predicted >Limit > 5%
No
%Predicted >Limit = 0.1 - 5% Yes
Take 8 random samples /year
No
% Predicted >Limit < 0.1%
No
%Predicted >Limit = 0
Yes
Yes
Take 4 random samples / year
Stop monitoring for this.
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Exceedance Predicted 1.4%
Continue at 8 samples / year
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Periodic Monitoring Decisions based on Statistics
Take 8 full-shift samples, random
Any sample > Limit
Yes
Conduct exposure assessment
“Worst Case”
Yes
Conduct exposure assessment
“Worst Case”
No
% Predicted >Limit > 5%
No
%Predicted >Limit = 0.1 - 5% Yes
Take 8 random samples /year
No
% Predicted >Limit < 0.1%
No
%Predicted >Limit = 0
Yes
Yes
Take 4 random samples / year
Stop monitoring for this.
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Exceedance Predicted 0.3%
Continue at 8 samples / year
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Definitely looks lognormal when plotted
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Periodic Monitoring Decisions based on Statistics
Take 8 full-shift samples, random
Any sample > Limit
Yes
Conduct exposure assessment
“Worst Case”
Yes
Conduct exposure assessment
“Worst Case”
No
% Predicted >Limit > 5%
No
%Predicted >Limit = 0.1 - 5% Yes
Take 8 random samples /year
No
% Predicted >Limit < 0.1%
No
%Predicted >Limit = 0
Yes
Yes
Take 4 random samples / year
Stop monitoring for this.
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Exceedance Predicted <0.1%
Reduce to 4 samples / year
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Periodic Monitoring Decisions based on Statistics
Take 8 full-shift samples, random
Any sample > Limit
Yes
Conduct exposure assessment
“Worst Case”
Yes
Conduct exposure assessment
“Worst Case”
No
% Predicted >Limit > 5%
No
%Predicted >Limit = 0.1 - 5% Yes
Take 8 random samples /year
No
% Predicted >Limit < 0.1%
No
%Predicted >Limit = 0
Yes
Yes
Take 4 random samples / year
Stop monitoring for this.
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Exceedance Predicted = 0.000%
Communicate & Stop Sampling
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Precautions
Some regulations mandate monitoring
Changes in the workplace will change QEA
Production rate
Changed ventilation
Different chemical composition
Changed methods for handling
Even though nothing has changed,
management may expect additional sampling
just because it is time to confirm all’s well
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Summary
Statistics and probability can be used to
modify sampling frequency
Use of graphs to communicate data to similar
exposure groups will enhance HAZCOM
Use of graphs will enhance Medical program
understanding of workplace stressors
Use of graphs for tracking and trending is an
expectation of VPP under OSHA
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