VPP: Don't Overlook Industrial Hygiene

While VPP programs are touted for their safety achievements, they need to make sure that health problems don't spoil the party. That's why industrial hygiene needs to be fully integrated into these programs.

World-class organizations are using management systems to "manage" environmental, health and safety (EHS) concerns in both domestic and global businesses. The most recognized U.S. management system is OSHA's Voluntary Protection Program (VPP). Other consensus standards include:

  • American Chemistry Council's Responsible Care program
  • ANSI Z10 "Occupational Health and Safety Management Systems" draft standard
  • British Standards Institute's "Occupational Health and Safety Management Systems" (OHSAS 18001)
  • International Labour Organization "Guidelines for Occupational Safety and Health Management Systems."

According to a recent survey conducted by the American Industrial Hygiene Association (AIHA), over 53 percent of world-class operations use management systems such as VPP or OHSAS 18001 to improve their EHS performance.1

This article focuses on one of the overlooked aspects of VPP industrial hygiene concerns.

OSHA established VPP in 1982 to recognize single worksites with exemplary safety and health programs. As of July 2005, there were 1,341 VPP worksites (968 federal and 373 state-plan sites). According to OSHA, VPP sites on average have a lost workday rate 52 percent below the industry average. This helps reduce accident costs significantly, reduces the chance of OSHA citations and fines and creates a better work environment.

Occupational Illnesses Tip of the Iceberg

There are many reasons industrial hygiene (IH) takes a backseat to safety-related issues in general. IH exposures often are transparent and chronic, which makes them more difficult to recognize and report. In addition, occupational illnesses also are difficult to trace back to a specific source.

OSHA defines an occupational illness as "any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to factors associated with employment."

Occupational illness costs are difficult to estimate. According to the Archives of Internal Medicine (AIM), $26 billion is spent in the United States annually on occupational illnesses.2 AIM also estimates more than 60,300 fatalities result from occupational illnesses annually. By contrast, the Bureau of Labor Statistics (BLS) reported 121 deaths. Reported occupational illness fatalities resulted from various exposures, including:

Temperature extremes
Oxygen deficiency
Caustic, noxious or allergenic substances
Cancer
Cardiovascular and cerebrovascular disease
Chronic respiratory disease
Pneumonconioses
Nervous system and renal disorders.

Nonfatal occupational illness cases in the United States that were reported to BLS totaled 439,002 annually vs. 862,200 annual incidents estimated by AIM. These cases resulted from:

Carpal tunnel syndrome
Dermatitis
Welder's flash
Infectious and parasitic diseases
Cancer
Coronary heart disease
Cerebrovascular disease
Chronic obstructive pulmonary disease.

VPP Core Elements and IH Aspects

There are four core elements within VPP:

  • Management Leadership and Employee Involvement
  • Worksite Analysis
  • Hazard Prevention and Control
  • Safety and Health Training

The first core element, Management Leadership and Employee Involvement, is the foundation of VPP. Industrial hygiene aspects should be integrated into the organization's safety and health policy statements, procedures and responsibilities. The written safety and health program should outline specific workplace "health" exposures and control methods.

The second core element, Worksite Analysis, has more obvious areas where industrial hygiene is involved. Some of these include baseline safety and IH hazard analysis, initial screening (full-shift sampling), written sampling strategies, analysis of new processes, materials and equipment, job safety analysis, incident investigation of occupational illnesses, hazard reporting and written industrial hygiene programs.

IH aspects in the third core element, Hazard Prevention and Control, include systems for eliminating or controlling health hazards and exposures in the workplace. Examples might include health hazard reporting systems, hazard correction tracking, preventive maintenance of ventilation systems and other IH-related control measures and occupational health care programs.

The final core element, Safety and Health Training, pulls the other three core elements together, providing education and direction to employees. Companies must recognize their specific IH concerns and effectively communicate needed information to their employees. Examples of IH training include training in the site health management system, training to enable employees to recognize health hazards and proper methods of control. All training should be documented and evaluated for effectiveness.

Industrial Hygiene

The practice of industrial hygiene covers many aspects of occupational safety and health. Many of these can be overlooked in traditional safety programs, because they do not seem to fit in with programs such as lockout/tagout or confined spaces. Additionally, many IH hazards can cause long-term damage, such as occupational diseases, as opposed to immediate injuries. Examples of IH hazards include:

Biological
Bloodborne pathogens
Infectious agents
Molds/fungi
Ergonomic
Biomechanical stress
Physical
Noise
Ionizing radiation
Non-Ionizing radiation
Thermal stress
Chemical
Gases/vapors
Particulates/fumes
Metals
Solvents
Lead
Asbestos
Other compounds.

Industrial Hygiene Hazard Analysis

As part of any comprehensive safety and health program or management system, health hazards related to IH exposures need to be identified. This can be accomplished using hazard and task analyses to evaluate processes and determine the hazards associated with each. If a task or hazard analysis is already being used for safety issues, IH issues (health hazards) should be incorporated into the analysis.

Hazard analyses may include:

  • Use of direct reading instruments
  • Review of processes and MSDS information
  • Site visits at facilities during normal operations
  • Review of maintenance items, including periodic operations
  • Review of available baseline air sampling data
  • Determining if additional air sampling is necessary
  • Comprehensive reviews of the entire worksite, including multiple shifts
  • Documentation of completion for these types of items.

It is important that the entire site is covered and that each job, task or procedure is viewed from both a safety and an industrial hygiene perspective. The following examples illustrate this point:

Example 1: A welder may have the proper shield, gloves, fire watch and even a hot work permit, but has the hazard of welding fumes been evaluated? Are stainless steel, plated parts or galvanized metal being welded at the plant? If so, they could generate exposures to metal fumes (i.e., chromium, nickel, cadmium, zinc, etc.) and other airborne contaminants.

Example 2: You have evaluated dust exposures at your plant by sampling for "total" particulate. Should you also sample for "respirable" particulate? Have you analyzed the dust for metals or other specific compounds?

Example 3: Some chemicals can have synergistic effects or may act on the same target organs in the body. Therefore, evaluating each individually may not accurately reflect total exposures.

Once we have evaluated each job, task or procedure, then we should establish a system to proactively evaluate significant changes that may cause additional exposures. For example:

  • If new equipment, processes or products are added to a facility, then the hazards from both a safety and an IH perspective should be re-evaluated.
  • Changing the solvent used in a process could have a positive or negative effect on safety and health.
  • Changing a process (i.e., from spray application to using a roller or vice versa) also can increase or decrease exposure potential.
  • Not all industrial chemicals have either OSHA permissible exposure limits (PELs) or ACGIH threshold limit values (TLVs). Just because a compound does not have an established exposure limit does not indicate that it presents no potential health hazards.

VPP and other management systems require that the results, as well as the process, of hazard analysis be documented. This analysis should consider safety and IH hazards as well as the specific task, job or process being analyzed. It should identify the hazard controls in place and recommend additional controls, if needed. The analysis should be used in future training and planning and should be easily understood by employees. Additionally, the analyses should be updated as the environment, procedures or equipment change (or if errors are identified that require updating).

Industrial Hygiene Analysis of Non-Routine Tasks

Evaluating non-routine tasks should focus on both safety and IH hazards. Most audits or assessments take place on the first shift and cover the day-to-day operations of a facility. Many maintenance activities, cleaning and calibration procedures take place during offshift hours and at night. When performing a hazard analysis, ask:

  • "How often and when is the equipment serviced or calibrated?"
  • "Is there a weekly, monthly or periodic maintenance schedule?"
  • "Are there tasks performed on other shifts that are different from first shift?"
  • "Are we missing anything?"

Pre-Use Analysis

A job hazard analysis (JHA) is a living document, which should continuously be updated and revised to reflect changes in processes, jobs or tasks. Pre-Use analysis is crucial in making sure that safety and IH are integrated in the procurement and planning processes. A safety and health review of new processes, plans to purchase chemicals or other process changes should be standard procedure. This approach can avoid issues later. For example, a company purchases large quantities of a chemical in order to reduce costs, but it turns out that storing that quantity of a specific chemical triggers compliance with both OSHA Process Safety Management and EPA Risk Management Planning standards. The cost of complying with those standards could easily outweigh the savings of purchasing in bulk.

Written Industrial Hygiene Program

VPP also requires that each facility have a written industrial hygiene program. This program should cover the identified IH hazards of the workplace (physical, biological and chemical) as well as standard procedures for routine self analysis, a hazard reporting system for employees, and what additional sampling will be required. Like all hazard analysis documentation, the IH program is a living document and also should be updated as often as processes, jobs or tasks change.

The IH sampling plan also is part of the program. The following items should be taken into consideration:

  • Objective to identify health hazards and assess exposures
  • Preliminary baseline sampling (grab samples and initial screening)
  • If the baseline suggests exposure potential, consider full-shift or short-term sampling
  • Exposures covered
  • Priorities
  • Schedule duration, route, frequency
  • Analysis by NIOSH or OSHA methods performed by an AIHA-accredited laboratory
  • Compare sampling results to minimum limits
  • Reporting.

During the initial screening, precise records should be kept to document why the areas were selected, as well as all sampling data and what tasks or processes were occurring during the sampling. Initial sampling can often be performed with direct-reading instruments (to "scan" for potential contaminants that may require additional sampling).

Full-shift sampling should assess those tasks, jobs or processes that were identified by the initial sampling as well as any that could not be assessed during that phase. The data collection should be precise and thorough, just like with initial sampling. Care should be taken to ensure that enough samples are collected to properly evaluate the exposure, samples were collected during the operations most likely to cause the exposure and all work shifts are covered. You should continuously ask yourself, "Have we missed anything?"

IH Expertise

Whenever possible, air sampling should be performed by industrial hygienists. However, initial sampling may be performed by safety professionals with special training. If consultants are used, their reports must contain all the sampling information required in VPP guidance documents. The use of consultants does not remove responsibility for the IH program from the VPP applicant or participant.

Conclusion

VPP is a management system that can help improve safety and health at industrial and manufacturing facilities. Care should be taken to consider both the safety and industrial hygiene aspects of all processes, jobs and tasks. IH aspects can be difficult to identify and may require special expertise, since they can be more long-term in nature and do not usually have immediate measurable health effects on employees. Be sure to evaluate the entire job site (as well as all shifts) to ensure that both non-routine and maintenance-related tasks are covered by the hazard analysis and are included in the IH program.

Footnotes:

1 The Synergist, Jan 2005: 35.

2 Archives of Internal Medicine, vol. 157 (July 28, 1997).

Bruce K. Lyon, CSP, P.E., ARM, CHMM, is principal, safety and national safety practice leader, Occupational Health and Safety, for Clayton. He has more than 22 years of experience in occupational safety, ergonomics and workers' compensation risk control for a wide range of industries, including manufacturing, energy, construction, food processing, chemical and health care. He provides consulting in safety and health management systems, behavior-based safety and system safety. Lyon has considerable knowledge of federal and state OSHA regulations and ANSI standards.

Daniel G. Vaughn-Petersen, CIH, CSP, QEP, CHMM, is regional manager, Kansas City, for Clayton's Occupational Health and Safety practice. He has 11 years of experience in environmental and occupational health and safety and regulatory compliance. An expert in various types of sampling and field analytical equipment, Vaughn-Petersen specializes in custom sampling strategies and projects requiring non-standard methodologies. He has investigated more than 50 office, residential and industrial facilities with indoor environmental quality issues such as mold, volatile organic chemicals, nuisance dust and mechanical ventilation system performance problems. His asbestos and lead-based paint experience covers more than 9 years and approximately 30 million square feet of inspected building space.

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