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Recent Industrial Hygiene & Safety Projects
OSHA Side-By-Side Industrial Hygiene Sampling
Hygieneering, Inc. recently performed OSHA Side-By-Side industrial hygiene sampling for one of our manufacturing clients. Hygieneering advised our client to insist that OSHA provide sufficient advance notice regarding the specific industrial hygiene sampling OSHA planned to perform so a competent industrial hygienist could perform Side-By-Side industrial hygiene sampling. Full shift personal air samples were collected for various welding fumes and hexavalent chromium. Surface wipes samples were also collected for hexavalent chromium within the eating and drinking areas. If an employer doesn’t collect its own samples, the employer will be hard-pressed later to challenge OSHA’s potentially flawed technical analyses. Where exposure to toxic substances is involved, sampling results are often the basis for significant citations. Such citations may require costly corrective measures to reduce impermissible exposures. The employer should insist that OSHA provide sufficient advance notice of industrial hygiene sampling so competent personnel can perform Side-By-Side industrial hygiene sampling, which allows the employer to challenge defective samples taken by OSHA.
Lockout Tagout Program Implementation - Commercial Client
Hygieneering assisted our commercial client with compliance of the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.147 “The Control of Hazardous Energy Lockout/Tagout)” Standard. This food industry client expanded operations that included numerous pieces of processing and building operation equipment that required equipment specific lockout tagout procedures. Our scope of services included the following:
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Performed a comprehensive assessment of each machine/piece of equipment that required an energy control procedure to identify hazardous energy sources, energy isolation points, hazards, specific lockout/tagout sequences, etc.
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Provided example template procedures that we have used to develop procedures for other clients, for reference purposes. We worked with the client to customize the energy control procedure to meet their specific needs.
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Took digital photos of each energy isolation point for each machine/piece of equipment and incorporate these photos into written energy control procedures, as applicable.
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Reviewed the energy control procedures with the client to ensure each procedure is verified for accuracy by a designated client representative.
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Provided a manual that contains the final equipment-specific energy control procedures and the sign off sheet that verifies each energy control procedure has been reviewed for accuracy.
In summary, hundreds of ESLPs were prepared successfully and put into action.
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Healthcare Setting Hazardous Drug Wipe Sampling in Support of USP 800
The Hygieneering Industrial Hygiene Department has been conducting wipe sampling for hazardous drugs (HDs) in various healthcare settings in support of the upcoming official start date of USP 800 in December 2019. Environmental wipe sampling is conducted for some common marker HDs that can be assayed include cyclophosphamide, ifosfamide, methotrexate, fluorouracil, and others in order to evaluate HD containment and associated work practices. Common areas of concern are oncology departments and pharmacies but can be anywhere HDs are stored and used. Contact Hygieneering if you need assistance in setting up a proactive sampling strategy to assist in evaluating potential HD contamination in your work setting.
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OSHA Process Safety Management (PSM)/Environmental Protection Agency (EPA) Risk Management Plan (RMP) 3-Year Compliance Audit Report
Hygieneering recently completed a PSM audit for one of our industrial refrigeration clients with approximately 30,000 pounds of anhydrous ammonia at their facility. The focus of the project was to assist in identifying and managing the liabilities associated with highly hazardous chemicals, as defined by the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals regulation as well as the Environmental Protection Agency (EPA) 40 CFR 68 “Risk Management Plan” regulation.
Hygieneering’s role was to:
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Review existing PSM/RMP program to determine the overall effectiveness and to verify that procedures and practices covered under the standard are compliant.
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Satisfy OSHA's 29 CFR 1910.119 and EPAs 40 CFR 68 requirements to periodically evaluate the effectiveness of the PSM/RMP programs at a minimum of three (3) years.
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Conduct interviews with employees and management to determine knowledge of the current PSM/RMP programs.
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Conduct a walkthrough of the facility to determine compliance with current PSM/RMP program elements.
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Assist in identifying and managing the liabilities associated with PSM/RMP in the facility.
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Provide recommendations based on audit findings and observations.
In the end, the findings indicated an overall positive and proactive attitude towards safety and health by management as well as by employees regarding PSM/RMP. However, minor deficiencies were noted in various elements of the PSM/RMP program and were provided with corrective recommendations to the client.
New Product Safety Review
One of our larger hospital facility clients was in the process of rolling out a new disinfectant cleaner used as a surface wipe in the pharmacy. There were some odor complaints and general health concerns voiced by the staff using the new disinfecting agent product. Hygieneering’s role involved meeting with the stakeholders, reviewing the product safety data sheet for chemical components, designing and implementing an air sampling strategy/risk assessment and providing recommendations.
Following the SDS and operational review, this project was conducted to quantify the potential employee exposure to acetic acid, hydrogen peroxide and peroxyacetic acid during operations requiring use of the new cleaner pharmacy areas. This sampling was conducted to evaluate the efficacy of current work practices and engineering controls in keeping exposures of acetic acid, hydrogen peroxide and peroxyacetic acid below recognized occupational exposure limits (OELs).
The resulting data showed that even though the laboratory results indicated low levels of contaminants, well below occupational exposure limits. However, it also clearly showed that levels of acetic acid were present at levels well above the odor threshold and the type of odor was consistent with acetic acid. The situation was considered a nuisance odor situation and not a health hazard.
Based on the observations and results of this assessment, many recommendations were provided to the client in the following categories:
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Proper respiratory selection and use to assist in the odor situation
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Use of local exhaust ventilation to control at the point of cleaning tasks
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Location selection of bin cleaning to a more remote/airflow-controlled location
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OSHA compliance related recommendations for the sampling conducted
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Occupational Exposure Monitoring in the Healthcare Environment
Hygieneering recently completed annual occupational exposure monitoring for 2 of our healthcare clients. In these environments there are many potential contaminants that healthcare workers may be exposed to in their normal duties. Our staff of industrial hygienists provided on-site worker exposure monitoring for the following contaminants:
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Formaldehyde
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VOCs – acetone, ethyl alcohol and xylene
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High-Level Disinfectants (HLD)
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o-Phthalaldehyde (OPA),
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Glutaraldehyde
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Peracetic Acid
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Hydrogen Peroxide
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Ethylene Oxide (EtO)
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Mercury
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Waste Anesthetic Gases (WAGS) -sevoflurane and desflurane, and nitrous oxide
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This work provided our clients with documentation that workers were not exposed above recognized occupational exposure limits and provided documentation for OSHA compliance as well as Joint Commission obligations.
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Bi-Lingual Safety Assistance
One of our manufacturing clients with 5 facilities across the US has a Hispanic workforce. Our client was dealing with overall safety program implementation quality and consistency issues across the various facilities. A big part of that was the language barrier with many of the workers. Hygieneering’s service to our client was to provide a bi-lingual safety professional/trainer to assist in the management of the safety program. At each facility on a monthly basis, our bi-lingual safety professional conducted a field safety audit, managed a safety meeting, and provided training on a ‘topic of the month’. In addition, the training materials and associated written programs were provided in Spanish. This is an ongoing program.
OSHA Citation Assistance
Hygieneering recently completed working with one of our food manufacturing clients that had some OSHA Citation issues to be addressed. Our team stepped in with a focused effort to bring many of their health and safety programs into regulatory compliance. Hygieneering developed written OSHA required written management programs and conducted on-site worker training for:
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Lockout / Tagout
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Confined Space
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Hazard Communication
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Hearing Conservation
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Emergency Action Plan / Emergency Response Plan
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Respiratory Protection
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Bloodborne Pathogens
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Hot Work Permit
This project was addressed by placing one of our staff safety professionals on-site for several weeks and also using other staff professionals to focus on other more detailed issues regarding Process Safety Management compliance. We assisted our client with progress updates to OSHA which reduced potential fines.
OSHA Silica Sampling
With the now in effect OSHA general industry 1910.1053 and construction industry 29 CFR 1926.1153 new silica standards, Hygieneering industrial hygienists have been collecting worker personal breathing zone air samples to support compliance efforts for our clients. Full shift respirable air sampling with a cyclone and laboratory analysis for crystalline silica was conducted in all types of environments. Our sampling provided OSHA compliant data to document respiratory protection needs. In addition, we provided work practice and engineering control recommendations to reduce employee exposure to silica.
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Healthcare Facility Noise Management During Construction
Hygieneering was engaged to prepare a written Noise Management Program for a hospital undergoing renovations with the work zone directly below the neonatal intensive care unit (NICU). The intent of the program was to spell out steps to provide additional caution, controls and monitoring that were necessary to protect this fragile hospital population. The plan focused on noise management and noise monitoring protocols as it relates to keeping noise levels at acceptable levels within the NICU areas during the renovation activities. The American Academy of Pediatrics recommends that sound levels be lower than 45 dBA in NICU areas. This is a challenging level on a day to day basis and even more so during renovation projects.
The written program included sections on:
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Providing Hospital Management noise monitoring options to manage risk at the desired sound level.
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Implemented the practices of ‘quiet demolition’ techniques whenever feasible.
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Implementation and incorporation of administrative controls where possible.
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Implementing an active noise monitoring and communication program to assist in managing the noise issue during the project. Defining noise monitoring (task-based, spot check and continuous). Using telemetry techniques with auto notifications built in for real-time response to Action Levels.
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Instituting swift communication mechanism with affected parties for job shut down if noise levels become unacceptable (i.e.: with pre-established Action Levels and responses).
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Ensuring daily communication of work activities planned between the contractor, Project Manager, NICU staff and Hospital safety that monitored the project.
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Establish record keeping practices.
Temporary Environmental, Health & Safety Staffing
With the demand for qualified and experienced environmental, health and safety professionals on the rise, Hygieneering clients are reaching out to us to provide Temporary Environmental, Health & Safety professionals. Our Temporary Environmental, Health & Safety Professionals are being contracted to address high priority action items identified by site, corporate or OSHA/EPA inspections. Our Temporary Environmental, Health & Safety Professionals also provide our clients with the time they need to prospect new candidates, knowing their EHS management system is being implemented and maintained by a qualified and experienced professional.
Hygieneering is currently providing Temporary Environmental, Health & Safety professionals for petrochemical, aerospace, and food processing companies nationwide.
Construction Site Safety Audits
Hygieneering is under contract to conduct bi-monthly safety audits for a local construction company. Audits include site visits to various worksites each month to assess job site safety conditions, including auditing against OSHA compliance regulations and company-specific safety program requirements. Common topics addressed are fall protection, electrical safety, crane safety, housekeeping, training records, flammable storage, and respiratory protection. For deficiencies identified, Hygieneering works directly with the job site foremen and workers to implement corrective actions and provides a report of findings for the client’s internal tracking and documentation purposes.
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Industrial Hygiene Assessment at a Specialty Wire Manufacturer
OSHA Compliance Air Sampling and Local Exhaust Ventilation System Review
Hygieneering recently conducted an Industrial Hygiene assessment at a client facility that is a distributor of specialty wire and cable. This facility had several high-speed striping machines for painting lines on various gauge wires.
This exposure study was conducted as a proactive approach to quantify potential employee exposures to volatile organic compounds (VOC-total hydrocarbons) and the following specific contaminants selected based on products used: acetone, cyclohexanone, methyl ethyl ketone, and toluene. Hygieneering determined the air sampling parameters after reviewing applicable Safety Data Sheets (SDSs) and processes at the facility. A semi-quantitative review of the local exhaust ventilation system (LEV) associated with the striping machines was also conducted. A standard hot wire anemometer was used to gather airflow data. A photoionization detector (PID) was used to pinpoint VOC leak points in the local exhaust ventilation system.
The result was that the workers were not overexposed as all personal air sampling results were well less than the corresponding OSHA PELs and the LEV system assessment provided several simple changes to the system to provide more effective VOC control.
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OSHA Process Safety Management (PSM) / EPA Risk Management Plan (RMP) Three-year Compliance Audit
Hygieneering recently conducted an OSHA Process Safety Management (PSM) / EPA Risk Management Plan (RMP) three-year compliance audit for a food processing facility. One of the audit findings of non-compliance was that the facility had not developed energy control procedures (lockout / tagout procedures) for the ammonia refrigeration equipment and had not conducted annual reviews of the standard operating procedures (SOPs).
As a result of the compliance audit, Hygieneering was engaged to develop the energy control procedures, conduct a review of the SOPs, and make revisions to the SOPs when necessary.
In order to thoroughly and accurately develop the energy control procedures, the facility provided a person knowledgeable with the equipment to assist Hygieneering. The final energy control procedures contain detailed steps to de-energize the refrigeration equipment, as well as photos for easy reference.
In order to conduct a thorough SOP review, the facility provided up-to-date and accurate process safety information (PSI), to include Piping and Instrument Diagrams (P&IDs). In this scenario, Hygieneering and facility personnel responsible for operation and maintenance of the refrigeration system reviewed the existing SOPs and P&IDs, then made revisions where necessary. In some instances, the P&IDs were “redlined” and provided to the ammonia refrigeration contractor so that necessary changes could be made.
In summary, several elements of the OSHA PSM / EPA RMP regulations were addressed during this project to include the following:
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Employee Participation – Facility personnel were involved with the SOP review and development of energy control procedures. Attendance sheets were signed by each employee involved in the SOP review and development of energy control procedures.
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Annual Standard Operating Procedure (SOP) review and documentation.
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Review of Process Safety Information (PSI) and revisions to PSI when required.
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Development of Energy Control Procedures (Lockout / Tagout)
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Hexavalent Chromium Air Sampling
Hygieneering was engaged by an industrial manufacturer to determine eight (8) hour time weighted average (TWA) exposures for each of their employees exposed to hexavalent chromium by personal breathing zone air samples. The objective of this project was to accurately characterize full shift exposures to hexavalent chromium on each shift, for each job classification, and in each work area.
Personal breathing zone air samples for hexavalent chromium were collected using low flow air sampling pumps. The flow rates of the pumps were calibrated at 2.0 liters per minute (lpm) with a preweighed PVC filter in line before, during, and after the sampling period. Personal breathing zone air samples were attached to the employee’s breathing zones via tygon tubing from the low flow air sampling pumps. Personal breathing zone air samples were conducted in the workers breathing zone just below the chin, therefore, exposure results didn’t take into account respiratory protection utilized. All personal breathing zone air samples were analyzed by Modified OSHA ID-215; IC and a laboratory accredited by the American Industrial Hygiene Association (AIHA).
In summary, the results of this assessment assisted our client in determining eight (8) hour time weighted average (TWA) exposure for each of their employees exposed to hexavalent chromium, whether existing engineering, administrative controls, and employee personal protective equipment were adequate, and those provisions under OSHA 29 CFR 1910.1026 that apply to their operations.
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