Most employers understand that they must manage OSHA safety requirements, but many are unaware of workplace health hazards, how dangerous they can be to their employees, or how to manage them.
The following is a basic summary of OSHA industrial hygiene testing requirements designed to help protect employees from exposures to workplace health hazards.
In summary, employers must not expose their employees to excessive levels of OSHA listed chemicals and contaminants, nor excessive noise levels.
OSHA publishes PELs (permissible exposure limits) for noise and a wide array of chemicals and contaminants, which employers must test to determine if there are over-exposures.
Some of the most common health exposure hazards include silica, respirable dust, corrosive chemicals as well as many other heavy metals.
Employers must evaluate their workplace to determine if any of these health hazards exist, and if so, and must then conduct industrial hygiene exposure tests to see if they exceed PELs.
Also keep in mind that OSHA laws only address a fraction of all potential workplace health hazards, and that other agencies, such as NIOSH and CDC, offer additional guidance and recommendations.
Industrial Hygiene Testing Basics:
- If your company has suspect noise levels in a particular area, or multiple areas, then you must conduct noise testing to determine whether or not the noise exceeds their PEL.
- If noise levels exceed OSHA’s 85 decibal PEL over a weighted 8 hour period, or exceed acute noise levels, then your company must either institute engineering changes, administrative changes (rotating shifts for example), or as a last resort, implement a Hearing Conservation Program which includes selection and use of adequate hearing protection, and baseline and annual hearing testing for impacted employees.
- If your company has suspect chemicals or contaminants in a particular area, or multiple areas, then you must conduct exposure testing to determine whether or not the levels exceeds their PEL.
- If levels exceed PEL(s), then your company must either institute engineering changes, administrative changes (rotating shifts for example), or as a last resort, implement a Respiratory Protection Program which has many management elements including proper selection of respirators, respirator fit testing, cartridge change schedules, annual medical evaluation, etc.
- At the start of any process that includes a suspect chemical, contaminant or excessive noise.
- Employers must conduct exposure testing whenever a new suspect process, or suspect piece of equipment, is installed.
- No new testing is required unless something changes in your process which might impact/change the original testing results.
OSHA’s Hierarchy of Controls:
If testing results show an over exposure, it’s important to understand that OSHA requires that the employer first try to eliminate the over exposure completely. If that can’t be done, then the company should evaluate all potential “engineering controls” to help mitigate exposures. If neither of these options are available, then the company must resort to implementing a Respiratory Protection Plan or Hearing Conservation Program.
Keep in mind that these plans have extensive setup and ongoing compliance requirements which can be difficult to manage, including selection of proper PPE, annual medical evaluations, fit testing, assigning qualified staff to manage, signage and more.
Risks & Liabilities:
Companies who fail to manage OSHA health exposure laws not only put their employees at serious risk, but also increase the chances of failing an OSHA inspection and suffering major fines and penalties.
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