Chapter 4
INDUSTRIAL HYGIENE

Contents

Approved by Paul Blodgett
Revised 05/13

4.1 Policy
4.2 Scope
4.3 Drinking Water (Moved to Chapter 42)
4.4 Non-ionizing Radiation (Moved to Chapter 43)
4.5 Noise (Moved to Chapter 39)
4.6 Ventilation, Hoods, and HEPA Filters

4.6.1 Hoods and Local Exhaust Points
4.6.2 HEPA Filters
4.6.3 System Design, Installation, and Testing
4.6.4 Surveillance
4.6.5 Additional Information

4.7 Chemicals

4.7.1 Chemical Hygiene and Safety Plan
4.7.2 Chemical Inventory
4.7.3 Additional Information
4.7.4 Technical Area Requirements

4.7.4.1 Food and Beverage
4.7.4.2 Cosmetics

4.8 Asbestos (Moved to Chapter 36)

4.9 Confined Spaces (Moved to Chapter 34)

4.10 Roof Access

4.10.1 General
4.10.2 Additional Information

4.11 Lead (Moved to Chapter 37)
4.12 Beryllium Safety Program (Moved to Chapter 38)
4.13 Respiratory Protection (Moved to Chapter 44)
4.14 Heat Stress (Moved to Chapter 40)

4.15 Procurement

4.15.1 General
4.15.2 Additional Information

4.16 Standards
4.17 References
4.18 Exposure Assessment
4.18.1 General
4.18.2 Initiating Exposure Assessments
4.18.3 Low-Risk Exposures
4.18.4 Qualitative Exposure Assessment
4.18.5 Quantitative Exposure Assessment
4.18.6 Review of Previous Exposure Assessments
4.18.7 Terms and Definitions
4.18.8 Additional Information


NOTE:

. . . . .

Denotes a new section.

. . . . . . . .

Denotes the beginning of changed text within a section.

. . . . . . . .

Denotes the end of changed text within a section.

____________________

4.1 Policy

Berkeley Lab industrial-hygiene policy requires that all operations at the Laboratory be performed in a safe, responsible, and compliant manner. This includes maintaining personnel exposure to chemical, physical, and biological agents within acceptable exposure limits. This policy further requires that exposures be minimized by the use of hazard elimination, engineering controls, personal protective equipment, and administrative controls.

4.2 Scope

This chapter provides requirements and guidance related to select industrial-hygiene concerns, hazards, and controls.
Industrial-hygiene issues covered in this chapter include drinking water, non-ionizing radiation, noise, ventilation, hoods, HEPA filters, biohazards, chemicals, asbestos, confined spaces, lead, respirators, and procurement.

4.3 Drinking Water (Moved to Chapter 42)

4.4 Non-ionizing Radiation (Moved to Chapter 43)

4.5 Noise (Moved to Chapter 39)

4.6 Ventilation, Hoods, and HEPA Filters

4.6.1 Hoods and Local Exhaust Points

Local exhaust ventilation hoods and points are required for many operations to ensure reduction of airborne concentrations of contaminants that could pose risk to employees. Hoods include, for example, laboratory fume hoods, soldering bench hoods, extractor arms, gloveboxes, and other exhausted equipment enclosures that perform a safety or health function.

EH&S establishes minimum standards of performance for each hood or system based upon code requirements, nationally recognized standards, and good professional judgment. The performance standard for each hood is listed in the computerized record for that hood. If a hood fails to meet the minimum performance standard then it is considered deficient. If a deficient hood cannot be safely used by making an administrative modification to its use during the time it takes to be repaired then it must be taken out of service. The responsible line manager must ensure that a deficient hood is fixed, and to use the hood within its safety limits until it is fixed.

4.6.2 HEPA Filters

High efficiency particulate air (HEPA) filters may be used to filter hazardous chemical, biological, or radioactive particles from air streams with an efficiency of 99.97 percent. HEPA filters used for safety at Berkeley Lab can be found in vacuum cleaners used to clean up dust and debris that contain asbestos, lead, or other particulates; biological safety cabinets in which biohazardous materials are handled; and in-place ventilation exhaust systems connected to lab hoods and glove boxes where radionuclides are used.

4.6.3 System Design, Installation, and Testing

New systems for contaminant control including local exhaust ventilation systems, hoods and in-place filters must meet the requirements of applicable codes including California Building Code, California Mechanical Code, and California Fire Code. In addition, applicable industry standards must be consulted for guidance. These standards include those promulgated by American Conference of Governmental Industrial Hygienists, American Society of Heating, Refrigerating and Air-Conditioning Engineers, American Industrial Hygiene Association, and American National Standards Institute. EH&S must be consulted to determine the applicable design, construction and performance standards applicable to a project.

Responsibility for assuring code compliance and conformance with applicable standards rests as follows:

New or relocated fume hoods and gas cabinets must be provided with electronic flow meters to indicate the velocity of air flowing into the hood, and to alarm when the velocity falls outside of permissible range. Other new or relocated exhaust systems used for contaminant control must have a visible means of indicating that the system is operating properly such as a pressure gauge or manometer. These indicators are to enable the user to determine if the system is operating properly and are in addition to any monitoring devices installed as part of building operations.

New fume hood systems, including those involving fume hoods relocated from another location, must be tested in accordance with applicable tests contained in ASHRAE 110-1995 as a condition of acceptance. The tracer gas containment test must conform to the 4.0 AI 0.1 criteria contained therein. This testing is performed by a third party, is paid for by the project, and must be validated (generally by witnessing) by EH&S.

New systems may not be used for contaminant control until their installation and performance has been evaluated and verified to meet applicable standards established by EH&S, and they have been “tagged” as such.

4.6.4 Surveillance

EH&S conducts periodic surveys of the performance of contaminant-control systems on the following schedule:

Surveys are scheduled so that all hoods in a given building are due on the first day of a particular month, and are past due three months after that date.

The results of all calibration, certification and other checks are recorded in a database on LBNL’s network, which is considered the point of record. Additionally, most systems have stickers on them that indicate when the last check was performed.

Some HEPA filter equipped systems are used for product protection only (e.g., “clean benches” for maintaining sterility of non-infectious organisms or for clean assembly of optical or vacuum systems, supply HEPA filters in semiconductor or nanomaterials fabrication rooms). EH&S is happy to assist in setting up testing of these systems, but the responsibility and expense for testing these systems belong to the research program.

4.6.5 Additional Information

To have the performance of local exhaust systems evaluated, call the EH&S Ventilation Program Coordinator at ext. 2324.

For information regarding the testing of HEPA filtering systems contact the EH&S HEPA Filter Program Coordinator at ext. 2324.

4.7 Chemicals

4.7.1 Chemical Hygiene and Safety Plan

All work with chemicals, including engineered nanomaterials, will be conducted in a responsible manner that protects workers. Berkeley Lab’s chemical hygiene and safety guidelines and requirements are contained in LBNL/PUB-5341 Chemical Hygiene and Safety Plan (CHSP). A primary focus of the CHSP is worker protection from hazards related to chemicals in conformance with the Federal Occupational Safety and Health (OSHA) Hazard Communication and ”Laboratory” Standards. Control procedures for Engineered Nanomaterials are included to address the worker health provisions of  DOE Secretarial Policy 456.1 Secretarial Policy Statement on Nanoscale Safety.

4.7.2 Chemical Inventory

LBNL maintains a online system for tracking hazardous materials known as the Chemical Management System (CMS). The purpose of CMS is to provide chemical custodians, EH&S staff, emergency response teams, and regulatory agencies with accurate and up-to-date chemical-hazard information. Current chemical inventory reports must be provided for compliance with DOE and City of Berkeley regulations. An accurate and up to date chemical inventory is also required by the Emergency Planning & Community Right to Know Act.  Emergency Responders need to know the maximum quantity of hazardous materials on-hand at any time in order to respond to incidents with appropriate training, equipment and organizational support. Chemical users should be familiar with and understand the nature of the chemical hazards with which they work. 

4.7.3 Additional Information

It is the responsibility of all groups using chemicals at Berkeley Lab to keep a current and accurate inventory of chemicals in the Chemical Management System.

Contact LBNL’s Chemical Hygiene Officer ext. 5286 for information about LBNL’s Chemical Hygiene and Safety Plan.

Contact the EH&S chemical inventory coordinator, ext. 2994, for information on the Chemical Management System.

4.7.4 Technical Area Requirements

Technical Area – In this context, “technical” uses include non-administrative activities that pose potential hazards. Technical Areas generally include laboratories, shops, workrooms, and similar areas. Offices, conference rooms, food preparation, and consumption areas such as the cafeteria, kitchenettes, and break rooms are generally not Technical Areas.

4.7.4.1 Food and Beverage

Food and beverages (including water, gum, and medicines) may not be consumed or stored in Technical Areas.

4.7.4.2 Cosmetics

Cosmetics, ointments, skin cream, and similar items may not be applied or stored in Technical Areas.

4.8 Asbestos (Moved to Chapter 36)

4.9 Confined Spaces (Moved to Chapter 34)

4.10 Roof Access

4.10.1 General

In order to minimize the potential exposure to chemicals, magnetic fields and radiological hazards for personnel who are working on roofs, restricting or limiting building roof access is required. Based on the activities performed inside a building, roof access is categorized in three ways:

  1. Restricted Access: roof access requires the approval of the Building Manager before any work is performed.
  2. Limited Access: roofs can be accessed by notified personnel in order to perform short-term work (<8 hours per day for not more than 3 consecutive days). Long term work (>3 consecutive days) requires Building Manager approval.
  3. Unrestricted Access: roofs are open to work access with no special restrictions.

Trailers are designated as Type C, Unrestricted Access, unless they are located in a restricted area. Lockout/Tagout may be required as part of the roof access process.

4.10.2 Additional Information

Consult the Roof Access Plan for further information on notifications, signage, and procedures. See Appendix A of the Roof Access Plan for a listing of Buildings and their respective categories.

For more information, contact the Industrial Hygiene Group at ext. 6218.

4.11 Lead (Moved to Chapter 37)

4.12 Beryllium Safety Program (Moved to Chapter 38)

4.13 Respiratory Protection (Moved to Chapter 44)

4.14 Heat Stress (Moved to Chapter 40)

4.15 Procurement

4.15.1 General

The items noted below are included on the Berkeley Lab Procurement Department “Restricted Items” list. These items require notification of EH&S at the time of purchase so that EH&S may review their use with the requestor. Items noted with an asterisk (*) require E&S approval prior to purchase.

EH&S notification and/or approval is handled through the eProcurement process. The Requisition Inputter chooses a category which describes what the material is. It is the responsibility of the Inputter to select the proper category.

4.15.2  Additional Information

For additional information, contact EH&S’s Restricted Items Procurement Coordinator at ext. 5286.

4.16 Standards

LBNL relies upon portions or all of the following external regulatory or peer-consensus standards in the execution of its industrial-hygiene program:

4.17 References

The following Berkeley Lab documents provide additional requirements and guidance on specific industrial-hygiene-related areas. Some of these documents can be downloaded as noted in each section of this chapter.

Additional references that provide significant guidance include:

4.18 Exposure Assessment

4.18.1 General

Exposure assessment is a type of risk assessment that is used to determine whether an activity poses a hazard to a worker. Some activities are straightforward, such as those commonly performed by the public, while others are more complex and require a detailed review of the work and associated controls. More complex activities require an exposure assessment prior to the commencement of work as part of the Work Planning and Control (WPC) process, currently known as a Job Hazards Analysis (JHA). Section 4.18.2, Initiating Exposure Assessments (below), discusses when exposure assessments should be conducted and how to initiate the process.

The exposure-assessment process is a formal evaluation performed and documented by ES&H professionals to determine the risk of personnel exposure to hazardous chemical, biological, or physical agents, and the necessity and type of appropriate controls (note: assessments for confined spaces, lasers, ergonomics, biological agents, and radiological exposures are handled within their respective programs). Results of exposure assessments are used to validate or improve hazard controls, to extend the same controls to employees in similar exposure groups, to provide employees with appropriate medical tests and examinations (i.e., medical surveillance or certification, including respiratory-protection approval), to monitor employee exposure, and to demonstrate compliance with regulations. Controls are implemented in accordance with the following hierarchy, when feasible:

Exposure assessments are documented and maintained by EH&S, though some information may be maintained in the WPC program. To assure uniform application of exposure-assessment data across their divisions, workers and work leads should contact their division safety coordinator, who will contact EH&S to obtain exposure-assessment information.

4.18.2 Initiating Exposure Assessments

Exposure assessments may be initiated through one or more of several methods:

*To (1) determine the hazard classification(s) of a given chemical, go to the CMS, log in, and select “Chemical Management Hazard List” from the left-hand menu (you can either print out entire lists of hazards or enter any chemical by name or CAS number); or (2) to determine the hazard classification(s) of a group of chemicals owned by a CMS user, enter the CMS and select “Reports Hazard Report.” Note that the only chemicals that will be included in the report are chemicals “owned” by that user. For additional information or access-rights changes, contact the CMS Administrator at ext. 2994.

Upon receipt of the request, the EH&S professional contacts the requester to perform an initial screening (a.k.a. Initial or Baseline Exposure Assessment). If the EH&S professional deems the potential risk unacceptable, the requester will be advised to cease work or initiate interim controls until a more thorough assessment can be performed. The actual response time is based on the risk-based, graded approach, with higher-risk activities receiving greater priority.

At the completion of the assessment, the EH&S professional records the conditions, materials, activities, conclusions, and recommendations, using standard reporting and retention methods. The file usually includes records of the assessment such as sampling worksheet, process description, sampling results, and evidence of laboratory accreditation, if applicable.

Exposure assessment may include qualitative or quantitative evaluations of risk.

4.18.3 Low-Risk Exposures

Many common activities at LBNL are well known, and their risks are small when standard and proper controls are used. Such low-risk exposures do not generally require exposure assessments at each location, although the conclusions and prescribed controls from these assessments should be documented on the JHA or other work documentation. Examples include:

For additional information about low-risk exposure scenarios, contact your assigned industrial hygienist.

4.18.4 Qualitative Exposure Assessment

Qualitative exposure assessments involve a professional judgment of risk, supported by review of data, when feasible. These assessments may be conducted when the hazardous agent cannot be practically measured, the amount of potential exposure is negligible, or when current information is inadequate to evaluate the risk. Hazardous agents include physical hazards (noise, non-ionizing radiation) and chemical hazards.

In a qualitative exposure assessment, the EH&S professional and the work lead or, preferably, the worker review the materials and tasks, and discuss potential exposures and accident scenarios. The EH&S professional, using his or her professional judgment, which may be supplemented with estimations, lists controls necessary to minimize hazardous exposures to an acceptable risk level.

The conditions, analysis, and conclusions are documented using a standard exposure-assessment form (or equivalent method), and recording it in the electronic exposure-assessment data-management system.

4.18.5 Quantitative Exposure Assessment

Quantitative exposure assessments involve measurement (i.e., sampling, surveying, or monitoring) or other quantitative determination (such as modeling) of exposure levels. These assessments may be conducted when there is insufficient information on the extent of potential exposure, or when measurement of the exposure level is specifically required by regulation.

Quantitative exposure-assessment results are compared to Occupational Exposure Limits (OELs) such as OSHA Permissible Exposure Limits (PELs) and American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs). LBNL follows OSHA regulations and exposure standards, except when the 2005 ACGIH TLVs are more protective; then the ACGIH TLVs apply. Employee exposures should be minimized whenever feasible; exposures must be maintained below required exposure limits; appropriate controls must be implemented when required action levels are reached.

Exposure monitoring is generally conducted using standard methodology (for example, NIOSH or OSHA sampling protocols). Direct-reading instruments may be used, as appropriate, provided that they are properly selected and calibrated. Laboratory analysis is conducted by accredited laboratories. All quantitative exposure assessments must be reviewed by a Certified Industrial Hygienist prior to being finalized, reported, and filed.

When personal-exposure monitoring is conducted, the monitored workers and their work leads receive a copy of the exposure assessment from EH&S. Health Services also receives copies of exposure assessments so it can assign workers to medical surveillance or certification groups and provide consultation to workers with respect to potential work-related medical questions.

4.18.6 Review of Previous Exposure Assessments

Exposure assessments are valid only as long as conditions remain unchanged. The primary method for determining changes in conditions affecting the validity of an exposure assessment is the update of the JHA, though random or for-cause reassessments may occur at any time. Whenever conditions change significantly (additional tasks and/or new hazards are introduced), or at a minimum annually, the JHA is updated, and any changes in tasks, locations, or controls may require re-evaluation of potential exposures.

During the review of the JHA, the work lead and worker determine whether an exposure assessment of the hazard should be reviewed based upon changes in the work. If so, the work lead must contact his/her division safety coordinator to arrange for EH&S to review the exposure assessment for continued validity.

4.18.7 Terms and Definitions

Baseline Exposure Assessment:A baseline or initial exposure assessment is a process to screen activities to help determine risks and hazards associated with an activity. These assessments are generally qualitative, though some quantitative data (collection or review) may be involved.

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. These assessments are generally conducted by an ES&H professional, which may include industrial hygienists, safety engineers, or in some cases, others. 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. NIOSH also publishes Recommended Exposure Limits (RELs), which may be evaluated for use.

Permissible Exposure Limit (PEL): OSHA PELs 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 in 29 CFR 1910, Subpart G for physical agents (i.e., noise and non-ionizing radiation).

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 440.1-3, Occupational Exposure Assessment, and AIHA Strategy for Occupational Exposures, Third Edition), 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, Occupational Exposure Assessment, and AIHA Strategy for Occupational Exposures, Third Edition).

Activity: For purposes of workplace evaluation and priority setting, a job (or portion of a job) involving a discrete agent or set of agents to which workers may be exposed.

Threshold Limit Value (TLV) : Airborne concentrations of materials to which nearly all workers may be repeatedly exposed without adverse effect. These values are developed and published by ACGIH. There are different values established for eight-hour Time-Weighted Averages, Ceilings, and Short Term Exposure Limits (STELs). Other TLVs are available for nonchemical exposures such as noise and non-ionizing radiation.

Unbound Engineered Nanoparticle (UNP): Those engineered nanoparticles that, under reasonably foreseeable conditions encountered in the work, are not contained within a matrix that would be expected to prevent the nanoparticles from being separately mobile and a potential source of exposure. An engineered nanoparticle dispersed and fixed within a polymer matrix, incapable, as a practical matter, of becoming airborne, would be “bound,” while such a particle suspended as an aerosol or in a liquid would be “unbound.”

4.18.8 Additional Information

For additional information on exposure assessment for chemical hazards, refer to the Chemical Hygiene and Safety Plan and the Exposure Assessment Program. For a more detailed description of the Exposure Assessment Program, contact the Industrial Hygiene Group. For additional information on exposure assessment of other hazards, consult your EH&S Division Liaison.

_____________________

Notes:

1. From Appendix A of the OSHA Occupational Exposure to Hazardous Chemicals in Laboratories standard:

D.3. Environmental Monitoring

  • Regular instrumental monitoring of airborne concentrations is not usually justified or practical in laboratories but may be appropriate when testing or redesigning hoods or other ventilation devices or when a highly toxic substance is stored or used regularly (e.g., 3 times/week).

 

_____________________

<< Chapter 3 || Table of Contents || Chapter 5 >>