Assignment Content
Explain how the passage of the OSH Act in 1970 changed the way industrial hygienists (IHs) evaluated health hazards at facilities covered by the Act.
List two OSHA regulations that you believe are the most important for an IH when reducing the risk of health hazards in a workplace. Explain your reasoning for choosing the regulations.
List at least three forms of toxicology data that an IH can use to perform a risk assessment for an occupational chemical exposure. Explain how the three types of data can be used by an IH.
Discuss how you would manage initial and on-going industrial hygiene sampling at a facility if you did not have a full-time IH on staff. How would you incorporate the IH program into an existing safety and health management system?
UNIT VIII STUDY GUIDE
Implementing Industrial Hygiene
Management Strategies
Course Learning Outcomes for Unit VIII
Upon completion of this unit, students should be able to:
2. Discuss industrial hygiene related standards.
2.1 Summarize how industrial hygiene standards and other regulatory standards interrelate.
3. Examine the foundational scientific principles for industrial hygiene practices.
4. Assess methods for performing industrial hygiene workplace analysis.
5. Analyze industrial hygiene related data.
6. Evaluate exposure to workplace hazards utilizing published occupational exposure levels.
7. Recommend controls for industrial health hazards.
8. Formulate industrial hygiene management strategies.
8.1 Explain how industrial hygiene policies and procedures fit into an overall Occupational Safety
and Health (OSH) management system.
Reading Assignment
Chapter 3: Management Systems
In order to access the following resource, click the link below.
Corcoran, D. (2018). The OSH professional and environmental management responsibilities (Unpublished
paper). Columbia Southern University, Orange Beach, AL.
Click here to access this paper.
Unit Lesson
Throughout this course, we have looked at how to anticipate, recognize, evaluate, and control health hazards
in the workplace. However, industrial hygiene (IH) activities do not exist in a vacuum. Health hazards are only
one set of hazards that must be addressed to provide the healthy, safe workplace required under the
Occupational Safety and Health (OSH) Act of 1970. Physical hazards associated with the workplace must
also be evaluated and controls implemented to reduce the risk associated with the hazards. Additionally,
environmental risks must also be addressed. All of these activities must somehow be synergized with the
goals of the company, which typically include making a profit for the owner(s) or shareholders.
Management System Overview
To achieve these goals, it is important for companies to implement and maintain effective management
systems (Fuller, 2015). The management systems must not only consider the companys goals and
objectives, but must ensure that the company complies with all regulatory requirements from agencies like the
Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), the
Department of Transportation (DOT), the Food and Drug Administration (FDA), and applicable state agencies
(Fuller, 2015). If the company competes on the global market, even more requirements for countries where
the company competes for business must be included in the management system. The blending of all these
requirements can make the implementation of a safety system extremely complicated.
OSH 6302, Advanced Industrial Hygiene
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UNIT x STUDY GUIDE
Typically, IH programs and policies are included in a broader environmental health
Title and safety (EHS) policy.
The titles of the policy (and department) can vary from company to company. Besides EHS, other common
titles are occupational safety and health (OSH), safety health and environmental (SHE), and health safety and
environmental (HSE). Whichever title is used, the overarching goal of these programs and policies is to blend
the programs and policies into one coherent approach to protecting workers and the environment. This
approach reduces the amount of duplication for the three fields (Fuller, 2015).
Proactive versus Reactive Management Systems
There are two approaches companies can take to OSH management programs, proactive or reactive. A
proactive program will attempt to control exposures to hazards in order to prevent harm to worker health or
the environment, even if that means going beyond regulatory requirements. A reactive approach typically just
meets the minimal, regulatory requirements and then addresses any harm that may occur as it occurs. Safety
professionals are typically faced with both management system approaches during their careers and must
learn to operate within or attempt to change the system.
The choice of implementing and maintaining a proactive or reactive management system will also help
determine the approach a company takes with the IH portion of the OSH policies. A reactive system will
typically only require the use of legally enforceable occupational exposure limits (OELs), like the OSHA
permissible exposure limits (PELs). A proactive system will typically use the most conservative of all
published OELs. Of course, the primary concern of management with the choice of which OELs to use is the
cost. The more conservative the OEL, the more that must be spent for controls to reduce exposures to that
level. In many cases, one of the most difficult things an OSH professional must do is persuade management
of the cost benefits associated with utilizing more conservative OELs.
OSHA Required Programs
OSHA has issued some regulations requiring companies to implement safety management programs. The
regulation that most commonly applies to health hazards is the Process Safety Management of Highly
Hazardous Chemicals, 29 CFR 1910.119 (OSHA, 1970b). This regulation only applies to facilities that use
specific chemicals above a threshold level set in the standard. However, for those companies that meet the
requirement, the regulation requires the company to implement a safety management system to reduce the
risks associated with the chemical(s) (OSHA, 1970b).
OSHA Voluntary Programs
Not every work location falls under the process safety management regulation. Fortunately, several other
options exist that companies can use to help implement and maintain effective OSH management systems.
Some of these programs have actually been created by OSHA and offered to companies who want to
participate on a voluntary basis (Fuller, 2015). The most popular and widely used programs are OSHAs
(2011) Voluntary Protection Programs (VPPs). These programs allow companies to work with OSHA on a
voluntary basis to evaluate the effectiveness of their OSH management systems. The company must
implement its management system prior to applying for VPP status, but the program contains some criteria
that the company can use as a guideline for establishing the management system (OSHA, 2011).
The VPP then contains a process whereby OSHA will perform a review of the management system, including
an on-site audit to evaluate the effectiveness of the system (OSHA, 2011). After the evaluation, the site can
earn placement in one of three categories: star (the highest level), merit, or demonstration. Obtaining VPP
star status indicates a facility has developed and implemented a highly effective OSH management system.
Other Voluntary Programs
There are also several nonprofit organizations that publish guidelines that can assist a company in developing
and implementing effective OSH management systems. One of the most widely recognized is the American
National Standards Institute (ANSI; Fuller, 2015). While some ANSI standards do not relate directly to OSH,
many do, and some are even incorporated by reference by OSHA in 29 CFR 1910.6 (OSHA, 1970a). When a
guideline is incorporated by reference, the mandatory sections are adopted as standards under the OSH Act
(OSHA, 1970a). Some of the ANSI standards related to management systems are listed on pages 53 and 54
OSH 6302, Advanced Industrial Hygiene
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of the textbook. Of importance is a fairly new ANSI Z10 Standard titled Occupational
Safety
UNIT x Health
STUDYand
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Management Systems (Fuller, 2015).
Title
Another nonprofit organization that publishes guidelines that are used by many organizations is the
International Organization for Standardization (ISO). The textbook discusses ISO and some of its guidelines
starting on page 58. Of particular importance for this units lesson are the ISO 9001 and ISO 14001
standards. These two standards relate to management systems. Companies that compete globally will often
be required to obtain certification under one or both of the standards (Fuller, 2015). Certification requires
development of an effective management plan, including OSH components and on-site inspections. In many
cases, ISO certifications include an IH component.
One additional nonprofit organization important to OSH professionals working in the health industry would be
The Joint Commission. The Joint Commission issues standards for hospitals to obtain certification (The Joint
Commission, n.d.). The process involves many requirements, including a component that is commonly
performed by his: infection control. Infection control typically requires the anticipation, recognition, evaluation,
and control of biological hazards.
IH Management System Component
A one-time measurement of exposures at a facility provides very limited data for risk assessments of ongoing
exposures. There are many variables that can affect the overall risk associated with a chemical hazard.
Exposures can change dramatically depending on changes in work practices, ventilation, seasons of the year,
and workloads.
Therefore, it is important to establish some policies associated with sampling for exposures at a facility. In
other words, how often will you sample for specific compounds at a facility? In some cases, OSHA has
established a sampling schedule based on the results from initial sampling. For example, OSHA requires
ongoing sampling every three months for exposures to hexavalent chromium that exceed the PEL and every
six months for exposures that exceed the action level, but are less than the PEL (OSHA, 1970d). The
additional sampling has to be continued indefinitely until two samples, collected at least seven days apart,
show the exposures are less than the action level and the PEL.
OSHA requires employers to determine if employee exposures exceed PELs in 29 CFR 1910.1000 (OSHA,
1970c). OSHA does not include a requirement for ongoing air sampling for any of those compounds. This
required the industrial hygienist to make a subjective decision on the frequency of sampling for specific
compounds. This sampling plan should be included as part of the OSH management systems plan (Fuller,
2015). A common approach is to establish a sampling plan based on a risk assessment to determine residual
risk. Thus, compounds with higher toxicity and/or higher exposure potential would have more frequent
sampling than other compounds. Another aspect of the IH sampling policy is that additional sampling should
be indicated if there are any changes in processes that would indicate a higher exposure may be present
(Fuller, 2015). Examples would include the addition of more production lines, changes in the chemicals that
are being used, changes in the concentrations of specific chemicals being used, and changes in engineering
controls like ventilation systems.
References
Fuller, T. P. (2015). Essentials of industrial hygiene. Itasca, IL: National Safety Council.
The Joint Commission (n.d.). Accreditation guide for hospitals. Retrieved from
https://www.jointcommission.org/assets/1/18/171110_Accreditation_Guide_Hospitals_FINAL.pdf
Occupational Safety and Health Act, 29 U.S.C. § 654 (1970).
Occupational Safety and Health Administration. (1970a). Occupational safety and health standards: General
(Standard No. 1910.6). Retrieved from https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910.6
OSH 6302, Advanced Industrial Hygiene
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Occupational Safety and Health Administration. (1970b). Occupational safety UNIT
and health
standards:
x STUDY
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Hazardous materials (Standard No. 1910.119). Retrieved from https://www.osha.gov/lawsTitle
regs/regulations/standardnumber/1910/1910.119
Occupational Safety and Health Administration. (1970c). Occupational safety and health standards: Toxic and
hazardous substances (Standard No. 1910.1000). Retrieved from
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=Standards&p_id=9991
Occupational Safety and Health Administration. (1970d). Occupational safety and health standards: Toxic and
hazardous substances (Standard No. 1910.1026). Retrieved from https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910.1026
Occupational Safety and Health Administration. (2011). All about VPP. Retrieved from
https://www.osha.gov/dcsp/vpp/all_about_vpp.html
Suggested Reading
In order to access the following resources, click the links below.
The CSU Online Library contains many articles that relate to the Unit VIII readings. The following are just a
few of the related articles that can be found in the Academic Search Complete database:
Many organizations use the International Organization for Standardization (ISO) standards for their
occupational safety and health (OSH) management systems. There are several ISO standards that can apply
depending on the company. The following article reviews ISO 45001 as a model for an OSH management
system and its effects on controlling musculoskeletal disorders (MSDs).
Rostykus, W. G., Ip, W., & Dustin, J. A. (2016). Managing ergonomics: Applying ISO 45001 as a model.
Professional Safety, 16(12), 3442. Retrieved from
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=a9h&AN=119843039&site=ehost-live&scope=site
Another common OSH management system is the ANSI/ASSE Z10 standard. The following article
summarizes that management systems standard.
Manuele, F. A. (2014). ANSI/AIHA/ASSE Z10-2012: An overview of the occupational health & safety
management systems standard. Professional Safety, 59(4), 4451. Retrieved from
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=a9h&AN=95254895&site=ehost-live&scope=site
An important component of any OSH management system is evaluation for continual improvement. The
following article discusses one method that can be used to identify management system deficiencies.
Lyon, B. K., Popov, G., & Roberts, A. (2018). Causal factors analysis: Uncovering & correcting management
system deficiencies. Professional Safety, 63(10), 4959. Retrieved from
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=a9h&AN=132120628&site=ehost-live&scope=site
One option available to companies to test their management systems and show their effectiveness is through
OSHAs Voluntary Protection Program (VPP). The following article looks at the VPP program.
Keenan, J. (2018). Safety excellence through VPP. Professional Safety, 63(4), 1719. Retrieved from
https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc
t=true&db=a9h&AN=128783042&site=ehost-live&scope=site
Learning Activities (Nongraded)
OSH 6302, Advanced Industrial Hygiene
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Nongraded Learning Activities are provided to aid students in their course of study.
do notGUIDE
have to submit
UNIT You
x STUDY
them. If you have questions, contact your instructor for further guidance and information.
Title
OSHA has produced two recent videos on effective safety and health management programs. You can see
them listed at https://www.osha.gov/video/. How well do the videos increase your knowledge about safety and
health management programs?
Click here to view the transcript for the Three Core Elements of Effective Safety and Health Programs video.
Click here to view the transcript for the Safe + Sound Week 2018: Are You Ready to Show Your Commitment
to Safety? video.
OSH 6302, Advanced Industrial Hygiene
