Action Level ‐ A concentration typically one half the published, allowable limit (such as OSHA PEL or the ACGIH TLV) that triggers certain provisions defined by the applicable regulation. It must be implemented to further reduce exposures such as applying additional exposure controls, employee training, or medical monitoring.
Area IH Sample ‐ A sample collected in a work area for the purpose of assessing the air quality in the area where employees are working or will need to work.
Carcinogen ‐ A chemical classified by the IARC as Group 1 or 2A. A product will be assumed to present a carcinogenic hazard if it contains a carcinogen in concentrations of 0.1% or greater (by weight or volume, as applicable). Consumer products containing unregulated carcinogens used in a manner similar to that of normal consumer use are exempt.
Dilution Ventilation ‐ Ventilation systems that dilute contaminated air in a whole building or room by blowing in clean air and exhausting some dirty air. Fans, blowers, and other devices designed to move available air provide dilution ventilation.
Hazardous Materials ‐ Any substance or chemical that is a health hazard or physical hazard, including, chemicals that are carcinogens, toxic agents, irritants, corrosives, and sensitizers; agents that act on the hematopoietic system; agents that damage the lungs, skin, eyes, or mucous membranes; chemicals that are combustible, explosive, flammable, oxidizers, pyrophoric, unstable‐reactive, or water‐reactive; and chemicals that in the course of normal handling, use, or storage may produce or release dusts, gases, fumes, vapors, mists, or smoke that may have any of the previously mentioned characteristics. Also includes any item or chemical that can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment.
Industrial Hygiene‐ That science and art devoted to the anticipation, recognition, evaluation, and control of those environmental factors or stresses arising in or from the workplace, which may cause sickness, impaired health and well‐being, or significant discomfort among workers or among the citizens of the community.
IHBHA ‐ An IHBH is a document that systematically identifies and qualitatively assesses the potential for occupational exposure to chemical, physical, and biological hazards.
LEV ‐ Ventilation systems that capture contaminate emissions at or very near the source and exhaust them outside or away from employees.
Personal IH Sample ‐ A sample collected in an employee’s breathing zone, in front of and within 12 inches of an employee’s nose, for the purpose of assessing the air quality that an employee is breathing. Personal IH samples are sometimes referred to as lapel samples.
TLV ‐ TLVs are guidelines (not regulatory requirements) prepared by the ACGIH. A TLV reflects the level of exposure that the typical employee can experience without an unreasonable risk of disease or injury.
- Provide employees with hazard information and training necessary for them to perform their jobs in a healthy manner.
- Ensure employees have the necessary medical clearances for their jobs and enforce medical work restrictions.
- Prohibit the storage or consumption of food, beverages, or tobacco products where toxic materials are used or stored.
- Promptly respond to recommendations / requirements from the HSE Representative for necessary control measures.
Contractor HSE Representative
- Ensure that IH assessment and sampling activities are conducted by trained / qualified personnel.
- Provide Program with professional and technical support in implementing IH Program requirements.
- Review and approve requisitions for purchase of hazardous materials and safety items procured according to Bureau of Indian Standards (BIS), American National Standards Institute (ANSI) standards, or other international standards, as applicable.
- Formally contact CLIENT and Contractors Management to request types and extent of hazardous agents (physical, chemical, and biological) to which Program CLIENT and contractor employees may be exposed.
- Provide assistance to CLIENT in identifying and documenting existing and potential health hazards in controlled operations.
- Evaluate hazards identified to determine their magnitude and the degree of control measures.
- Communicate hazard information to Program CLIENT and to supervision/management of Contractors.
- Make provisions for any required monitoring program, collection and analysis of IH samples.
- Ensure IH instrumentation (Air Sampling Equipment, Noise Meter, Gas Detector etc.) is tested, calibrated, labeled, and maintained in accordance with manufacturer’s recommendations.
- Interpret regulations and prescribed regulatory requirements, and ensure that applicable requirements are integrated into the written IH Program.
- Review JSA, Method statement and designs as applicable to Industrial Hygiene.
- Review, evaluate, and approve employee information and training programs on IH related hazards/issues.
- Monitor compliance with IH Program requirements, and evaluate overall effectiveness of the program.
- Communicate details about IH Program to Program HSE department.
- Ensure that appropriate language is contained in contracts so that contractors and subcontractors are notified of applicable IH hazards and requirements pertaining to the work scope.
- Ensure that Contractors and sub‐contractors perform activities in accordance with contract specifications, pre‐task safety planning requirements, and other applicable regulatory requirements.
- Use established, approved engineering practice / procedures (through design) to minimize exposures to hazardous materials.
- Make available or develop and present appropriate training (Noise, Heat Stress, and Exposure to Hazardous Chemicals etc.) on IH topics, as determined by the IH Representative and Program training matrix.
/ Contractor HSE Representative and line management share concurrent responsibility to identify and document existing and potential chemical, physical, and biological health hazards through the following:
- Knowledge and assessment of operations/construction work activities
- Periodic surveillance activities
- Review of material requisitions
- Independent IH document review
- An inventory or tracking system for all chemical substances used/stored at the work site.
Hazard evaluations performed will be forwarded to the responsible supervisor/manager for review and, as appropriate, will be made available for review by affected employees.
Directives Review and Assessment
Site‐specific programs will be reviewed to ensure that statutory occupational health requirements are known and implemented.
The contractor HSE Representative will formally recommend, and responsible management / supervision will promptly implement, measures to eliminate or reduce employee exposures through implementing controls in the following hierarchy:
- Work practices or administration
PPE will be used when administrative or other controls are not feasible or in the process of being implemented.
Employee Industrial Hygiene Training
The contractor HSE Representative will assist supervisors and managers in training employees about potential health hazards requiring engineering controls, administrative controls, or PPE.
The HSE Representative will perform periodic surveys, inspections, program reviews, evaluations, and/or surveillances of work activities. Employees have access to the results of these reviews.
The HSE Representative will ensure that only those trained or experienced in collection and interpretation of IH samples will be allowed to do so.
Appropriate consideration will be given to ergonomics in all stages of the Project starting from design development (with an emphasis on user operation/maintenance) to achieve a proper balance between reliability, cost, and other design criteria. Appropriate expertise in the area of ergonomics will be obtained and used during design analysis and review.
HSE Representative will assist with ergonomics input during the construction stage or modification of existing facilities.
Computer terminals and other workstations will be evaluated for appropriate ergonomic considerations.
Illumination surveys will be conducted as required for the scope of work. Levels of illumination in work areas must conform to applicable regulatory requirements.
- Occupational exposure to carcinogens must be maintained below applicable regulatory standards. The primary objective is to prohibit or reduce the use of known or suspected carcinogens in the workplace.
- Products containing carcinogens may only be used when no other practical substitute can be found for this approval.
- When work involving a carcinogen is identified, a plan will be written describing the acquisition, storage, transportation, and use of the carcinogen(s) and the safe work procedures used to control exposure.
- Engineering control must be the primary method used to minimize exposure and to prevent the release of carcinogens into the work environment.
- Employees who work with, or are potentially exposed to, chemical carcinogens will be provided with documented use‐specific training, including instruction on:
- Possible source of exposure, health effects
- Handling procedures
- Specific application of the chemical use
- Potential hazardous conditions
- Decontamination procedures, proper disposal
- Emergency procedures, including spills
- Medical surveillance requirements.
Control of Exposures to Hazardous Materials
Activities involving hazardous materials must be performed in accordance with applicable regulatory requirements.
Hazardous material exposure will be maintained below the action levels.
Activities involving nonionizing radiation must be performed in accordance with applicable regulatory requirements.
Installation or modification of radio frequency, infrared, ultraviolet, magnetic fields, or microwave sources must be approved before installation
Work ‐specific procedures/plans must be developed and in place for the use and maintenance of devices that emit hazardous levels of nonionizing radiation.
Proper warning symbols must be displayed when required, or as specified by HSE Representative.
Appropriate training will be provided to employees working with, or performing maintenance on, devices that emit nonionizing radiation.
Local exhaust ventilation is required (as an engineering control) where feasible to maintain concentrations of hazardous and irritating air contaminants below their action level. Such systems must be evaluated by the HSE Representative before the start of the work effort to ensure proper application. Such systems must be use, inspected, and tested in accordance with manufacturer recommendations to ensure proper operation.
General dilution ventilation systems may be used to provide protection from low concentrations of low‐hazard airborne contaminants. They must also be used and maintained in accordance with manufacturer’s recommendations.
Activities involving lasers must be performed in accordance with applicable regulatory requirements.
Class 1 and 2 lasers and laser systems will be installed, adjusted, operated, and maintained by trained and qualified employees.
Class 3 and Class 4 lasers will not be purchased or operated without permission of HSE HOD. A trained laser safety officer is required for all Class 3 and Class 4 laser work.
Proof of qualification of the laser equipment operator must be maintained in project records and in the possession of the operator at all times.
Hazardous Waste Operations
Hazardous waste operations will be conducted in accordance with The Hazardous
Wastes (Management, Handling and Transboundary Movement) Rules, 2010.
Baseline Hazard Assessment
A baseline hazard assessment will be performed in shops, offices, storage buildings, laydown yards, and other similar facilities (temporary or permanent) that are under the control of and its contractors.
The baseline hazard assessment will include the following:
- A brief description of the location, purpose, or use of the facility.
- Identification of the routine activities performed in each facility or outbuilding/area. Be sure to include the following:
- All activities performed while wearing a respirator
- All activities with a regulatory requirement to perform IH air monitoring
- All activities with a regulatory requirement to participate in a medical surveillance program or a requirement to be medically qualified
- Identification of the potential hazards associated with the activity ‐ chemical, physical, and biological.
- Identification of the anticipated frequency and level of exposure to the hazard
- Identification of the controls (engineering, administrative, and PPE) in place to reduce or eliminate the potential for exposure to the hazard (include a sketch of fixed ventilation systems(s), or a description of the portable ventilation system in use / to be used)
- Identification of the need for confirming exposure monitoring
- Identification of follow‐up actions to be performed, including confirming exposure monitoring, development of monitoring plan(s), evaluations, and assessments
Industrial Hygiene Exposure Monitoring
IH Sampling Plan
An IH sampling plan will be developed based on the results of the baseline hazard assessment for each potential exposure. The plan will specify sufficient sampling such that, when completed, an accurate exposure determination can be made.
Sample collection and analysis will be performed using recognized methods, such as the NIOSH Analytical Methods, OSHA Sampling Guide and AIHA approved IH laboratories or equivalent.
Sample collection will be performed by trained personnel, under the direction of an industrial hygienist.
IH sample results will be interpreted by comparing the applicable published, allowable exposure limit.
All IH sample results will be retained on the site in an easily retrievable manner.
Communication of Results
Employees will be notified of the results of monitoring for hazardous substances.
Notification is the dual responsibility of the contractor line management and HSE Representative.
The supervisor (line management representative), will notify the employee of the monitoring results.
When notification of an employee cannot be made due to job completion, release of the employee, or other unavailability, the supervisor will document the unavailability of the employee .
If a potential overexposure is confirmed, the employee will be notified.
The notification must identify the date of exposure, the area, and the specific hazard or airborne contaminant(s). The notification must also include controls (engineering, administrative, and personal protection) in use at the time, and the controls that are being implemented to reduce or eliminate similar exposures (corrective actions), and (if one exists) refer in the notice to a document that states the controls/actions to be taken.
Monitoring notification forms will be maintained at the site until such time as they may be permanently stored. These monitoring forms will be treated as confidential medical documents.
Chain of Custody
Site or contractor HSE Representative will maintain “chain of custody” requirements and document IH sample collection in accordance with applicable regulatory requirements.
Occupational Medical Surveillance
An assessment of the need for medical surveillance will be performed predicated on the results of the baseline hazard analysis, monitoring results, and review of applicable regulations. Employees required to be placed in a medical surveillance program will have an “employee job task/potential exposure analysis” developed based on their activities/expected activities, and transmitted to the medical surveillance provider for use in developing appropriate surveillance procedures.
Reactive Highly Hazardous Chemical