by Paul Puncochar, CIH
Hazard identification is an ongoing process that is a critical component of any health and safety program. A common approach of this process is to use the principles of industrial hygiene to recognize, evaluate and control employee exposures to workplace hazards. The hazard identification process is applicable to a range of workplace and hazard types, resulting in a benefit to both employee health and safety and environmental protection concerns.
Regardless of the workplace hazard, the goals for utilizing hazard identification include:
- Identification of workplace hazards presenting unacceptable risk to employee health, safety and productivity.
- Selection of practical and feasible control strategies that minimize employee exposures and optimize employee comfort.
Potential challenges facing the health and safety professional include defining what is "unacceptable" and "practical." Recognition by administrators and management staff that hazard identification is a process requiring continued review is also crucial to meeting these goals and achieving overall program success.
The types of hazards found today can vary significantly between workplaces, covering an array of exposure concerns from B. anthracis spores (anthrax) to zinc oxide fume.
Safety hazards are a concern in virtually all workplaces and should be clearly identified and controlled. From an industrial hygiene perspective, chemical/hazardous materials and noise are usually the most prevalent. Other exposure hazards are evolving, particularly the biological threats. This is illustrated by current concerns about mold in both occupational and residential settings, and recent concerns of B. anthracis exposure to mailroom employees. Exposure concerns such as these have health and safety professionals continually searching for effective control strategies.
Chemical and biological hazards can also impact environmental protection. Clear identification and characterization of waste streams can minimize both employee exposure and environmental concerns. Fugitive process emissions (e.g., lead dust and fume) within a plant can present immediate employee health risks through inhalation exposures and future environmental risks through the accumulation of toxic materials on equipment and other building surfaces.
Health Protection vs. Comfort
In most cases, OSHA compliance is the benchmark and foundation for health and safety programs. Regardless of the specific OSHA standard, the health and safety professional certainly wants to control the hazard to within what is considered legally acceptable.
Controlling exposures from an employee comfort and productivity approach may be less common, and is usually at a different level than OSHA compliance. The typical scenario includes workplace exposures outside of normal ranges or what is expected. Indoor air quality issues based on employee complaints fall in this category. In this situation, employees may comment that the temperature is hotter or colder than usual, or the lighting is different, or there are unrecognizable odors, or other comfort-related issues. The resulting investigations usually find that while there are no OSHA compliance violations, they certainly may lead to a loss in productivity. Many similar situations are common in today's workplace.
OSHA recognized the importance of employee comfort issues in recent standards development, such as the voluntary use provisions of the respirator standard (29 CFR 1910.134). As most employees equate discomfort with adverse health effects, controlling workplace hazards from a comfort and productivity perspective may be as important as meeting OSHA compliance.
Hazard Identification Process
The practice of industrial hygiene utilizes the recognition, evaluation and control-phased approach to hazard identification. The American Industrial Hygiene Association (AIHA) describes industrial hygiene as both science and art. As a science, it is very much data-driven where conclusions are drawn based on observations, facts and experimentation. As an art, it involves "judgement, creativity and human interaction". The hazard identification process is dependent upon both science and art aspects.
The hazard recognition phase involves basic characterization and information gathering. Hazard recognition is sometimes like performing detective work. The health and safety professional will find some exposure hazards obvious, such as high noise levels, while others are not so obvious, such as determining the cause of employee health complaints. In either case, hazard recognition attempts to gather existing information about the exposure.
Many methods, tools and resources are available for completing the hazard recognition phase, including:
- Plant/facility walk-around surveys
- Employee/staff interviews
- Records review
- Government/non-government standards review
- Literature review
The walk-around surveys use observational skills and other senses, such as hearing and smelling, to gather information about a particular process or task. Real-time monitoring equipment, such as a sound level meter, may be used to qualify the hazard for further evaluation. Most of the monitoring/sampling data collection, however, is reserved for the hazard evaluation phase.
Employee/staff interviews attempt to capture the hands-on personal aspects that the hazard presents. Records review may look at the process flow diagrams, exposure monitoring data, environmental reports, SOPs and job hazard analysis documents. Standards review will consider applicable exposure limits (e.g., OSHA PELs) and performance standards (OSHA, ANSI, etc.). Finally, literature reviews, such as material safety data sheets and toxicology profiles/studies, provide a significant amount of information concerning a hazard.
The evaluation phase attempts to determine the degree of severity of the hazard. This is accomplished using a three-step process that includes:
1) An assessment or measurement of the exposure
2) Comparison of the measured exposure to the benchmark used, such as the permissible exposure limit
3) Determination of whether the risk is acceptable
The first step may or may not include actual exposure data collection. For example, if the records review on a process identified previous employee exposures below a PEL for a contaminant, additional monitoring may not be necessary. In this case, the health and safety professional must use his acquired skills and judgment to determine whether the data is reliable and representative.
Comparison of the measured exposure to the benchmark can also present challenges if no exposure limits have been established, or performance guidelines published that define a safe level. Biological hazards, such as mold, often present the greatest challenges in this area. Other criteria, such as history of complaints or comparison of problem area data to non-problem (i.e., clean) area data, are often necessary in these instances. Determination of whether risk is acceptable most often depends on how generally accepted the benchmark used is. Non-technical management staff, for example, may be more likely to accept, and understand, the use of an OSHA PEL as a benchmark, rather than an ACGIH TLV or other industry guideline that is more stringent.
Implementation of control strategies is the last phase considered in the hazard identification process. Control strategies must always consider minimum OSHA compliance requirements. However, recognizing employee comfort as a vital element is also important. Best practices for controlling exposure hazards includes a hierarchy of preferred methods, including (from most to least preferred):
1) Engineering controls, such as process enclosures or local exhaust ventilation
2) Administrative controls including employee training and good housekeeping
3) Personal protective equipment (PPE) such as respiratory protection, hearing protection, eye and head protection
Regardless of the method selected, practical and simple considerations such as the following can help minimize future problems:
- Consider all the information obtained in the hazard identification process. Monitoring and sampling data alone may not always indicate the need for exposure controls.
- Gather employee input when selecting exposure controls. Those employees most affected by the hazard often bring a wealth of information and knowledge concerning the hazard-generating operation, process or task.
- Select PPE that is comfortable to the employee. Allow the employee to choose from a few different manufacturers and models to maximize wear-time; comfort translates to wear-time and PPE must be worn to be effective.
The final element of hazard identification is recognition that the process is on-going. The following situations describe when an exposure hazard should be re-evaluated:
1) When there is a change in the process or task where the hazard originally occurred.
2) When monitoring or sampling results are inconclusive or there is uncertainty about the exposure.
3) After control strategies have been implemented to determine or validate their effectiveness.
In conclusion, hazard identification can be a complex and time/resource-consuming process. Careful consideration of the legal requirements, accumulated process information and data, and program goals will help assure both the employee and company needs are met.
Sidebar: Typical exposure hazards present in today's workplace include:
- Chemicals and other hazardous materials that result in employee exposure and
- environmental risks
- Excessive noise and vibrations
- Temperature extremes that result in heat and cold stress
- Biohazards including both normal (e.g. mold) and man-made (e.g., bioterrorism)
- Ionizing and non-ionizing radiation
- Ergonomic hazards resulting in musculoskeletal disorders (e.g., back injuries)
- Safety-related hazards (e.g., slips, trips and falls) causing personal injury
Paul Puncochar is a certified industrial hygienist with 3M Occupational Health and Environmental Safety, St. Paul, Minn. For more information, visit www.3m.com/occsafety.