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Overview
Section 1: Planning
- When to Plan
- Who Does the Planning
- What Plans Need to be Made
Section 2: Implementing
- Suggestion Box: When to Schedule Monitoring
Section 3: Managing & Responding to Results - Managing the Results
- Responding to Elevated Results
Section 4: Infosheets,
Sample Forms, & Further Information
- Infosheet 1: Hiring an Industrial Hygiene Consultant
- Infosheet 2: Project Information for the IH
- Checklist 1: Reporting Results to Workers
- Table 1: Air Monitoring Action Trigger Levels
- Sample Recordkeeping Form
- Sample Air Monitoring Results Reporting Form (Individual)
- Sample Air Monitoring Results Reporting Form (Group)
Overview
Exposure assessment, or monitoring, measures workers’ exposure to
airborne contaminants during the performance of their jobs.
Why perform monitoring?
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It is required by OSHA
- Required by some owner specifications
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The exposure level determines what has to be done to protect
workers, including:
- the need for engineering controls
- the effectiveness of engineering controls
- the type of respirators required on the job
- the need for blood lead monitoring.
Overview of the Tasks
1. Planning
- a) Designate a Lead Program Manager (LPM)
- b) Identify lead generating tasks
- c) Hire IH consultant
2. Implementing
- a) Select tasks to be monitored
- b) Schedule monitoring
- c) Prepare personel for monitoring
- d) Organize day of monitoring
3. Managing and Responding to Results
- a) Review IH report and results of monitoring
- b) Respond to elevated results
- c) Provide results to workers
- d) Maintain records of results
— This Guide will elaborate on these tasks —
When to plan
- At the same time the project is being planned
- No later than during job mobilization
- If job has started, or lead disturbing tasks have begun, plan fast to do what has to be done!
Who does the planning
- Corporate safety office or management at the site begins the planning
and appoints the Lead Program Manager (LPM) who assists in project
planning.
- The LPM needs to be trained in lead hazards and their control Resources (G-1).
What plans need to be made
- Identify tasks/trades with potential for generating lead dust and fume.
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LPM needs to be familiar with scope of work throughout the course of
the project since tasks or intensity of work often vary during the life of
the project.
- Hire an Industrial Hygiene (IH) Consultant – See Infosheet 1
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Supply IH consultant with information to help him/her gain an
understanding of the project – See Infosheet 2
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To do their job well, they will have to have a sense of such items as
the scope of work, the tasks being performed, and the number of
workers engaged in these tasks.
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In the meantime: OSHA requires that employees must be protected
with respirators as soon as lead disturbing work begins. Refer to 1.3.b “OSHA Presumed Exposure Level for Selected Tasks” (Guide for
Managing a Respiratory Protection Program)
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Section 1 Notes
- Selecting an IH you can work with is important. The IH provides information that determines the level of worker protection. OSHA or the owner may
review this information at any time. Also, the IH can help interpret the OSHA standard.
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The IH performs the monitoring; the LPM organizes things so that the IH can do
the job with the least disruption to the project.)
Select tasks to be monitored
- Review all lead generating tasks
- Conduct walkthrough of site with IH
- Make sure IH sees all lead tasks
- Orient IH to safety issues at site
Schedule monitoring – See Suggestion Box on the next page
- Determine work schedule with project manager
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Select day when activities are going to be representative of an
average workday
- Call IH consultant and schedule
Prepare personnel for monitoring
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Arrange with site supervisor/foreman the day before - the fewer
surprises the better
- Inform workers and unions that monitoring is taking place
- A toolbox talk on what to expect and an explanation of monitoring
the week before is suggested
Organize the day of monitoring
- Review sampling plan with IH
- Ensure all tasks and highest exposures are selected
- Ensure IH has access to site and workers
- Review with IH tasks/locations/workers to be monitored
- Accompany IH to sampling locations
- Introduce IH to workers and supervisors
Summarize day with I H
- Meet with IH at end of work shift for a quick review of the day’s activities.
Ask if there were any problems that could affect results or any situations
in need of immediate response.
Suggestion Box: When to Schedule Monitoring
At a minimum, follow OSHA’s monitoring schedule:
- Beginning of job (to make an initial determination)
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At least every six months if exposure is between the action level (AL)
of 30 micrograms (30 mcg/m3 ) and the permissible exposure level (PEL)
of 50 micrograms (50 mcg/m3 )
- At least every three months if exposure is above the PEL
Any major variation in the work process can reduce or increase exposure
levels. Remonitor whenever changes occur.
- New tasks and/or tools are introduced
- Crew size increases
- Work configuration changes significantly (enclosure, confined area)
- Increase in number of hours worked
Even with the best intentions, things go wrong. Here are some scheduling
pitfalls that managers have to deal with:
- Monitoring cannot be conducted as planned due to such factors as:
- Weather
- Change in work plans for the day
- Equipment breakdown
- Monitoring begins but cannot be finished because of above
- A worker who is being monitored is assigned to another task
- Work is unusually light and it is difficult to get a representative sample
If such things happen, reschedule as soon as possible
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Section 2 Notes
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The LPM has a detailed knowledge of the site (exposures/tasks). His job is to communicate relevant information to the IH so he/she can do the best possible job.
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The LPM has responsibilities for reviewing the IH’s report, informing workers
and keeping records. These tasks are described below.
Managing the Results
Review IH report and results of monitoring.
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Compare results to OSHA Action Level (AL) and Permissible Exposure
Level (PEL) – See Table 1 Air Monitoring Action Trigger Levels
- Review IH recommendations
- Initiate response if necessary – See Responding to Elevated Results, on
next page.
Provide results in writing to each monitored workers within 5 days of receipt
of results.
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See Sample Air Monitoring Results Reporting Form (Individual)
- Distribute during weekly toolbox talk or with paychecks
Provide results to all workers potentially exposed to lead.
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See Air Monitoring Results Reporting Form (Group)
- Post prominently in change room or distribute to workers
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See Checklist 1: Reporting Results to Workers
- Attach to front of group results file folder
- Prepare and schedule a toolbox talk to review the results
Maintain records of results
- Use Sample Recordkeeping Form
Responding to Elevated Results
Monitoring results above the PEL might indicate a problem with engineering and work practice controls. Consult the Guide for Managing Engineering & Work Practice Controls for further guidance on troubleshooting. The following points summarize the main steps to be taken:
- Make sure there are controls in place
- Check out the equipment to make sure it is functioning.
- Talk to the workers, to find out if:
- engineering controls are working properly
- they are familiar with the equipment
- they have any suggestions for improving existing controls
- they use the controls and, if not, why not
- what they do when the equipment isn’t working properly
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Hold a safety meeting with managers and a toolbox talk with
workers about the controls.
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Investigate with them if the controls are suited to the site and
the particular application. An investigation of other controls may
be in order.
- If problems are found and corrected, reschedule monitoring.
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Given the measured exposure, ensure that the types of
respirators worn by the workers are sufficiently protective and
are being used properly.
Section 3 Notes
- OSHA requires that the way to protect workers from exposure to lead is first by engineering and work practice controls. If the controls emplyoed are state-of-the-art, and the monitoring results show workers are exposed above the PEL, then the controls must be supplemented with respiratory protection.
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Infosheet 1: Hiring an Industrial Hygiene Consultant
Infosheet 2: Project Information for the IH
Checklist 1: Reporting Results to Workers
Tabl1 1: Air Monitoring Action Trigger Levels
Sample Recordkeeping Form
Sample Air Monitoring Results Reporting Form (Individual)
Sample Air Monitoring Results Reporting Form (Group)
Infosheet 1: Hiring an Industrial Hygiene Consultant
- IH consultant has construction experience (preferable)
- IH consultant has a supervisory Certified Industrial Hygienist (CIH)(preferable)
- Sample analyzed by accidental laboratory (necessary)
- Request sample report
- Is it well written (do you understand it)?
- Are results presented as 8-hour time weighted averages? (they should be)
- Compare costs to thoe of several other consultants
- Is the turn-around time for reporting results acceptable?
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The information gathered from different consultants can be used to choose the best one
Infosheet 2: Project Information for the IH
- Scope of work lead generating tasks
- Approximate project timetable
- Approximate number of workers engaged in lead generating tasks
- Trades and tasks of workers, focusing on lead generating tasks
- Location of project and accessibility
- Description of controls used (engineering, administrative, respirators)
- Copy of Respiratory Protection Program
- Details on site safety hazards
- Site contact person and phone number
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It is recommended that the LPM have this information ready at hand when speaking with the consultant
Checklist 1: Reporting Results to Workers
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| Results reviewed then copied to recordkeeping table or spreadsheet |
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| Results copied into form for reporting to workers and dated (Group and Individual
reporting form) |
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| Individual results given to monitored workers |
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- Group form posted in area where all workers can view them
or
- Group form handed out to all workers
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Table 1: OSHA Air Monitoring Action Trigger Levels*
If initial air monitoring results are:
Less than the AL, then:
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Not required to repeat monitoring unless there is a change in equipment, process, controls, task or personnel
Greater than the AL but less then the PEL initial determination, then as per the OSHA standard, employers are required to conduct:
- Blood lead monitoring
- Worker training in lead
- Representative monitoring
Greater than PEL, then:
- Implement entire standard
Greater than PEL (subsequent monitoring), then:
- Use section ‘Responding to Elevated Results’
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* Note: there are parts of the OSHA standard that do not depend upon air sampling results,
for instance, housekeeping. Refer to the standard for more information.
Samle Recordkeeping Form
| First Name |
Last Name |
Monitoring Date |
Tasks |
Results 8-hr TWA (mg/m3) |
Exceed the PEL (Y/N) |
Workers given results (Y/N) |
Action Taken |
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AIR MONITORING RESULTS REPORTING FORM (Individual)
This report presents your results for the for crystalline silica exposure conducted on ___/___/___
Contractor's Name__________________________
Employee name __________________________
Work Site/Location__________________________
Description of engineering /administrative controls at the site______________________________
______________________________________________________________________________
______________________________________________________________________________
Job Description __________________________
Monitoring Result __________________________
PEL Exceeded (Circle One) Yes / No
These results represent exposure levels during the time and date the task was performed and the conditions present at the time the monitoring occurred. The Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) for lead represents the highest level of lead dust or fume to which a worker should be exposed to over an 8-hour work-shift. If exposure exceeds the PEL employers must supplement engineering controls with proper respiratory protection.
The OSHA PEL 8-hour TWA for lead is 50 micrograms/m3 (50 mcg/m3 )
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AIR MONITORING RESULTS REPORTING FORM (Group)
This report presents results for personal air monitoring for crystalline silica dust conducted on ___/___/___
Contractor's Name__________________________
Employee name __________________________
Work Site/Location__________________________
Description of engineering /administrative controls at the site______________________________
______________________________________________________________________________
______________________________________________________________________________
Monitor Worker |
Job Description/ Location |
Monitoring Results 8-hour TWA mg/m3 |
PEL Exceeded? Y/N |
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These results represent exposure levels during the time and date the task was performed and the conditions present at the time the monitoring occurred. The Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) for lead represents the highest level of lead dust or fume to which a worker should be exposed to over an 8-hour work-shift. If exposure exceeds the PEL employers must supplement engineering controls with proper respiratory protection.
The OSHA PEL 8-hour TWA for lead is 50 micrograms/m3 (50 mcg/m3 )
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© 2004 by The Mount Sinai – Irving J. Selikoff Center for Occupational and Environmental Medicine
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