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7 Steps to Industrial Hygiene Success

1 S T E D I T I O N E - B O O K

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Contents

The Changing Face of Industrial Hygiene ................................................................................................................................3

The IH Program Management Cycle ...........................................................................................................................................3

STEP 1: Similar Exposure Groups (SEGs): The Foundation for a Great IH Program ...................................................4

STEP 2: Qualitative Exposure Assessment (QEAs): Essential Risk Assessment Methodologies for IH Program Management ..............................................................................................................................................5

STEP 3: Sampling Plans: Moving Beyond Compliance .......................................................................................................8

STEP 4: Lab Analysis – Uncovering Hidden Gems of Efficiency .......................................................................................10

STEP 5: IH Data Analysis: Defining Your Goals and Selecting the Best Metrics ..........................................................12

STEP 6: Medical Surveillance: Strengthening Your Last Line of Defense for Worker Health .................................14

STEP 7: Evaluating and Communicating Performance: The Keys to Engagement with Your IH Program .......15

The Value of VelocityEHS IH Solutions .......................................................................................................................................18

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The Changing Face of Industrial HygieneThere’s a growing trend I’ve noticed in recent years of companies downsizing or even eliminating their in-house IH professionals and placing greater reliance on EHS generalists and third-party consultants to manage their IH programs. Maybe the previous IH manager retired or moved on, and now management is looking to you to run your company’s IH program. If this sounds familiar, you’re not alone.

For non-IH professionals just stepping into the role, it can be intimidating. No bones about it, IH is a scientific, highly technical discipline that relies on complex calculations and exposure data to drive critical decisions about workplace health and compliance. Even if the previous IH program manager maintained organized data and records, where do you even begin?

For seasoned IH professionals still in the program management role, you might be struggling with how to maintain and improve IH program performance in the face of dwindling staff and resources. You might also be wondering what IH program strategies and best practices are out there today to help you lighten your load, reduce costs and boost program performance.

This e-Book is a compilation of some of the most valuable insights and best practices I've gathered over more than 30 years as both a Certified Industrial Hygienist (CIH) and developer of IH software technologies. It’s intended for both the seasoned IH professional and those new to IH program management, and offers a unique, outside-the-box approach to IH program management that will not only help you focus and refine your program, but help you minimize program costs, simplify compliance and improve the health of your workers.

I hope you’ll enjoy.

The IH Program Management CycleThere are many moving parts to an effective IH program. Similar exposure groups (SEGs), qualitative exposure assessments (QEAs), sampling plans, lab analysis, data analytics and reporting systems, medical surveillance and program evaluation processes all deserve equal focus, and should be carefully coordinated to ensure optimum IH program performance.

In reality, though, many IH’ers unfortunately manage their IH program elements in silos, without much thought for how each element functions in relation to the others. We need to shift our thinking about IH toward a more holistic, process-based approach where IH program elements are interdependent, and improvements in one area support improvements across the entire program.

That's why we've created the IH Program Cycle to provide a simple, process-based model that IH professionals at any level of expertise can apply to IH Program Management. Not only does it offer a sequential, common-sense approach to IH, it embeds the principle of continuous improvement into the IH program itself. Each time we run through the process, the information and insights gained from our previous runs can be systematically incorporated into the program.

In the following sections, we’ll take an in-depth look at each of the seven IH program elements and give you, the reader, practical guidance on how to build, maintain, refine and integrate those elements to form a highly effective IH program.

Dave Risi, CIH, CSP Principal Solution Strategist

for IH | VelocityEHS

1. Similar Exposure

Groups (SEGS)

2. Qualita�ve Exposure

Assessment

3. Sampling Plans

4. Lab Analysis

5. Data Analysis

6. Medical Surveillance

7. Evalua�ng & Communica�ng

Performance

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Similar Exposure Groups (SEGs): The Foundation for a Great IH ProgramNumerous OSHA Standards and other workplace exposure standards require companies to evaluate the health risks of their workers, and ensure they are controlled to a safe level. These evaluations are most commonly performed through qualitative risk assessment (QEA), or through quantitative measures such as air monitoring/sampling of individual worker exposures.

But there's a problem: how can a company expect to accurately evaluate and manage workers’ health risks when they have 100, 1,000, or 10,000 employees? Performing risk assessments and sampling on each individual worker would be far too time consuming and costly, exceeding even the largest of IH program budgets. So, how do we evaluate workplace exposures and ensure the health of all workers, while making the most efficient use of our time and resources?

SEGs are the answer.

What Are SEGs?Similar exposure groups (SEGs) rely on the principle of grouping workers into job profiles and assessing the health risks to those workers based on the assumption of similar exposure conditions. SEGs are commonly defined using any combination of exposure conditions, including:

• Location• Job

• Task• Equipment used

Let’s work through an example to help illustrate the steps in grouping workers into SEGs.

Say that our Houston Refinery has 250 employees who work as Operators, Administrative Staff, Maintenance and other key job roles to operate the plant. Following a facility tour and detailed discussions with experienced EHS professionals at the plant, we find that only 5 groups of workers have any significant exposures. These 5 groups are identified and formed into SEGs.

STEP 1By grouping workers based on similar exposure, you’ve already dramatically reduced your risk assessment and sampling efforts by focusing on these 5 groups, rather than on all 250 employees individually.

Why Are SEGs ImportantQuite simply, SEGs are the foundation for your IH program. Once established, they offer a more convenient, easier- to-understand visualization of workplace job tasks and operations, and their associated exposure risks. Additional benefits include efficiency, reduced complexity, and better communication.

EfficiencyPerhaps the greatest advantage of SEGs is that they allow you to optimize your sampling activities by using data from a relatively small number of samples from the exposed population to accurately predict exposures across a wider population of workers. The information can also be used to compare exposure risks with related SEGs at other locations.

Once a SEG’s baseline exposure is established, the information allows you to more effectively allocate and prioritize exposure monitoring and control efforts, ultimately saving you significant amounts of time and resources.

Reduced ComplexitySEGs can also be used to better manage risk profiles for workers who perform a variety of job tasks throughout the day and may be exposed to multiple workplace stressors. For example, the average exposures for a shift (8-hour TWA) can vary widely depending on the time spent performing specific tasks. Identifying SEGs for specific tasks provides high-resolution visibility of which tasks present exposure risks, which then provides a more accurate determination of what controls, if any, need to be implemented.

Better CommunicationCreating SEGs also helps to facilitate greater transparency and continuity of your IH program. In the past, IH programs relied heavily on the professional judgement or experience of a seasoned IH professional. Over the years, these IH pros became increasingly familiar with the jobs and tasks that had the highest exposure risks, and they simply knew where to prioritize their sampling and assessment activities.

Unfortunately, this cumulative knowledge was not well documented, and existed as a loose collection of sample data and other records stored in spreadsheets or simple database software. As IH professionals retired or transitioned away from the role, incoming IH managers would have to painstakingly analyze the data to figure out the status of the IH program, including what sampling was being done, why it was being done and where exposure risks existed.

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Creating SEGs enables continuity and transparency of the knowledge gained through those years of experience— knowledge that can be easily transferred and referenced by the new IH manager or EHS professional now responsible for IH program management.

When communicating the exposure risks to workers or management, remember that they will prefer to have the data summarized by the job profile or the tasks being performed. This also enables controls to be specified at the job or task level. For example, all Operators conducting liquid sampling inUnit 1 should wear ½ mask respirators. Controls applied at the SEG level protect all workers performing the job/task, rather than just the individual worker that was sampled.

Lastly, one of the greatest benefits of developing SEGs is to have a consistent characterization of the workplace and identify any groups of workers that have a potential for overexposure. So, when the IH manager with 30+ years of experience and knowledge at that plant retires, they can hand over the keys with all of that knowledge documented in a manner that can be easily used and managed.

How Do I Create SEGs?Many EHS professionals hesitate to define their SEGs without a lot of supportive quantitative sampling data. I believe this is the wrong approach, and actually subtracts from the benefits of creating SEGs.

Don't worry about being 100% accurate when identifying your SEGs on your first go-round. Like the IH Program Cycle itself, identifying your SEGs is an iterative process that takes time to fine-tune. The most important thing is to just get started. Start developing your SEGs by first observing the workers at your site and asking questions like:

• What common jobs/roles are workers placed into? (e.g., Operator, Maintenance, Electrician, Pipefitter)

• What tasks do they perform that create potential health risks/exposures? (e.g., welding, liquid sampling, opening vessels)

• Are there different methods or equipment used for similar tasks that affect the exposure risks? (e.g., open versus closed systems, new versus old equipment that hasn’t been properly maintained)

• What stressors are the workers potentially exposed to at their jobs or during the tasks? (e.g., noise, benzene, asbestos, lead)

If you’re familiar with your site and know the operations well, you can build an initial list of SEGs even before you go out into the work environment. If you don’t have that degree of familiarity, you will need to spend more time directly observing the workers at your site. Remember, the goal is to get started, not to be 100% accurate on your first attempt.

For instance, SEGs in most manufacturing environments can be characterized by a combination of location, job and task, while other industries may not require all of these attributes.

Industries with highly distributed work sites, like oil and gas pipeline transmission, typically don’t need to assign a location to their SEGs. Table 1 on page 6 below includes an example of a Pipeline Operator performing a blowdown of a pipeline containing crude oil. The potential for exposure to noise and benzene during this task is consistent regardless of the location, so it does not need to be specified. This will save you from having to perform air monitoring at every location where the operators perform blowdown procedures on the pipeline, and it can help minimize the number of SEGs you ultimately need to create.

If you are feeling overwhelmed by the number of potential SEGs at your facility, you can break the process up into different phases. A common approach is to start with full shift exposures (i.e., no tasks, all full shift TWAs), then identify the task, then maintenance activities. I have seen companies take this approach until they are confident they have appropriately assessed the full shift exposures. In reality, it may take a year or two to expand the scope of your SEGs to include tasks and maintenance activities.

Again, the most important step is to just begin this process, and continuously improve your SEGs over time. Rome wasn’t built in a day, and neither is a highly effective IH program.

Qualitative Exposure Assessment (QEAs): Essential Risk Assessment Methodologies for IH Program ManagementOnce you have established your SEGs, the next step is to assess the exposure risks to them. The industrial hygiene profession uses the term qualitative exposure assessment, or QEA, for performing a risk assessment for industrial hygiene concerns.

What Are QEAs?QEAs are simply an estimation of the potential health risks for each SEG. Some of your SEGs may have sampling data to help you with quantifying exposure risk, while others will have no hard data and require you to determine risk levels through other methods, including using your best professional judgement!

QEAs have been done informally since the 1950’s and were formally recognized when AIHA published their first version of “A Strategy for Occupational Exposure Assessment” in 1991.

STEP 2

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Since then, AIHA has published several updates to the text and QEAs are now widely considered a best practice for industrial hygiene around the world.

The ultimate result of performing QEAs is a risk rating that can be used to prioritize resources for IH sampling, implementation of controls and inclusion of workers in medical surveillance programs. QEAs can also help you identify high-risk potential exposures that require immediate corrective actions, rather than taking the time and effort to perform IH sampling and waiting for analytical results to be returned from the lab before you implement controls to protect worker health.

In this section, we’ll cover several of the most common methods used to perform QEAs and help you set up a simple risk matrix report that can be used to easily prioritize exposure risks and communicate those risks to workers and management.

QEAs as Part of Your IH ProgramIf SEGs are the foundation of a good IH program, QEAs are the actionable insights which drive your IH program forward. Once performed, they provide a comprehensive and visual breakdown of the potential risks in your workplace so you can get to the important work of protecting your people.

Here are some of the greatest benefits of performing QEAs:

SimplicityQEAs do not need to be complex, rely on complex models or require a strong knowledge of statistics. With training, QEAs can be performed by EHS staff with even limited IH expertise.

Quicker and CheaperSampling to quantify each potential exposure to each worker could take years and be prohibitively expensive. QEAs enable even the smallest of IH budgets to pack a punch, accurately and comprehensively assessing risks in a fraction of the time and cost.

ComprehensiveQEAs provide a tool to quickly document all potential exposures, including those with minimal exposure risks. This is commonly known as “negative exposure documentation.”

It provides you with a more extensive risk profile compared to sampling only the higher-risk SEGs.

PrioritizationOnce completed, QEAs make it easier to identify SEGs that require additional investigation and monitoring. SEGs with sufficient data and a high degree of confidence showing they do not require a significant investment in additional monitoring can be more effectively prioritized.

Improved CommunicationQEAs ultimately help you create a well-developed risk matrix that standardizes risk visualization across disciplines. They also provide a valuable tool to show workers and management your IH program activities and the value they bring to the company.

Litigation SupportWell-documented QEAs, along with other IH program information, provide faster access to supporting data without needing to recall files from storage or spend weeks going through old reports if requested by regulators or stakeholders.

Knowledge TransferQEAs provide a great way to capture the knowledge gained through your EHS professionals’ years of experience and integrate that knowledge into your IH program for future IH leaders.

How Do I Perform QEAs?Refer back to our example population of 250 workers at the Houston Refinery, where we've already assigned workers to similar SEGs. Then take the following steps:

Step 1: List any significant stressors for each SEG.How do you identify what potential stressors should be listed? Sources for this information include:

• Walk-through surveys

• Interviews with workers and other knowledgeable personnel

• Chemical inventories & SDSs

• Previous sampling data collected

• Injury/illness recordkeeping logs

Industry Location Job Task Equipment Stressors

Oil & Gas N/A Operator Pipeline Blowdown – Crude Noise, Benzene

Chemical Atlanta Plant - Unit 1 Operator Sampling – Liquid Benzene

Pharmaceutical NJ Plant – Manufacturing Area 01 Formulation Technician Blending Apex Mixer Isopropyl Acetate, API-2

Manufacturing Dayton Plant Painter Spray Painting Paint Booth 22A Toluene

Mining/Metals Plant-Primary Crusher Plant Technician Routine Duties Respirable Dust, Silica, Noise

Table 1: Examples of SEGs for various industries

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Table 2: Similar Exposure Groups (SEGs)

Once you have gathered this information, list all of the potential stressors for each SEG. An example of this is shown in Table 2 above (this should be familiar from our previous section on SEGs).

Step 2: Define Your QEA Strategy/FormulaAfter 30 years in the field of IH, I have seen some companies spend years perfecting their QEA model. Some spend a lot of time modeling their QEAs around variables such as frequency, duration, control technology factors, vapor pressures and even particle size distributions. These can be useful variables, but most companies do not have the resources or expertise to be that thorough, especially when just beginning their QEA program.

Just like when setting up your SEGs, you need to avoid “analysis paralysis” and just start the process. After you’ve established your baseline assessments and ultimately accumulate years of data to help validate your model, you may find it necessary to change your QEA model by adding additional variables that provide an even more precise assessment. Until then, start simple.

AIHA has developed a simple model that we recommend to our customers when they initiate their QEA programs. The formula is:

Risk Rating = Exposure Rating x Health Effect Rating

Here are common ratings used for these variables:

Exposure Rating Health Effect Rating

1: < 10% of the OEL 1: Reversible health effects of concern

2: Between 10% and 50% of the OEL 2: Severe, reversible health effects of concern

3: Between 50% and 100% of the OEL

3: Irreversible health effects of concern

4: > 100% of the OEL 4: Life-threatening or disabling injury or illness

Source: AIHA: A Strategy for Assessing and Managing Occupational Exposures, 3rd Edition

Step 3: Conduct Your QEAsBreak up Table 2 so each SEG and stressor are listed in a unique row. Then, add columns for your Exposure Rating and Health Effect Rating variables, and one column for the calculated Risk Rating. Table 3 on page 8 below shows how to apply the AIHA strategy for the SEGs identified in the Houston Refinery example.

Based on information in Table 3, we see the highest risk is benzene exposure during liquid sampling by Operators at the Reformer Unit, while the lowest risks are benzene exposure to Operators at the Coker Unit when performing routine work duties.

Step 4: Display Your QEA Data in a Risk MatrixThe QEAs in Table 3 contain a lot of great data but are not recommended for use when presenting QEA findings to workers or management. Let me explain: it can easily become overwhelming and confusing when applied to a site containing 50-100 rows of QEA data. Instead, we recommend summarizing the data using a standard risk matrix.

Location Job Task Stressors

Alky Unit Operator Routine Work Duties Noise, Hydrofluoric Acid

Coker Unit Operator Routine Work Duties Benzene, Hydrogen Sulfide

Maintenance Pipefitter Welding Iron, Lead

Maintenance Maintenance Technician Gasket Replacement Asbestos

Reformer Unit Operator Routine Work Duties Noise, Benzene

Reformer Unit Operator Liquid Sampling Noise, Benzene

Tank Farm Operator Gauging Benzene

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Risk matrices are already widely used by safety, quality and other departments across the organization to illustrate the status of their programs and related risks. So, why not use the same tools to convey IH information, right? Far too many IH professionals believe they need to show a ton of complex data, statistics and fancy graphs to effectively communicate exposure risks. IH practitioners should, as a whole, get out of this “black box” mentality and simplify our messaging for both employees and management.

Risk matrices also take advantage of peoples' existing visual and psychological cues: when presenting this data, viewers’ eyes will be almost instinctively drawn to the red items, right? They will inevitably ask:

• What’s the job/activity in red?

• Do we have data confirming the risk levels?

• How are we protecting these workers today?

• How do we move the risk from a red to a yellow, or even green?

By applying this familiar risk matrix, now we have an engaged audience, one that understands and wants to work with you to address those risks. I can tell you, a good manager really doesn’t like seeing red in any of the matrices they are responsible for.

I have used matrices just like this one to successfully grab the attention of management and secure approval for investment in workplace exposure controls. In several cases, exposure control measures were recommended for years by multiple EHS professionals, but only when making those risks easily visible and understood via the risk matrix did it get the attention from management it deserved.

Step 5: Prioritize Next StepsAfter you and your stakeholders understand the exposure risks in the workplace, you can then begin an informed discussion about what to do next. If the risk rating is low (green), you should track for potential exposure risk changes, and no additional sampling may be needed. If the risk rating is moderate (yellow), sampling is likely needed and controls should be implemented (PPE, training, engineering controls, etc.). If the risk rating is high (red), immediate action is required (typically PPE to start, then engineering and other controls, medical surveillance, additional sampling, etc.).

We’ll talk more about taking the right actions and implementing controls later on.

Sampling Plans: Moving Beyond ComplianceDeveloping SEGs and performing QEAs are critical to establishing baseline assumptions around workplace exposure risks, but your sampling plan is the critical next step that enables you to validate and fine-tune those assumptions.

What Is an IH Sampling Plan?You can think of an IH sampling plan as the “to-do” list for your IH sampling activities. Your sampling plan will list the number, type and details of samples that must be collected for each SEG and stressor of concern. It provides a clear list of the samples needed throughout the year. Once your plan is defined, it offers the added benefit of being able to track performance against sampling plan completion.

STEP 3

Location Job Task Stressors Exposure Rating

Health Effect Rating

Risk Rating

Alky Unit Operator Routine Work Duties Hydrofluoric Acid 1 3 3

Alky Unit Operator Routine Work Duties Noise 3 3 9

Coker Unit Operator Routine Work Duties Benzene 1 3 3

Coker Unit Operator Routine Work Duties Hydrogen Sulfide 2 2 4

Maintenance Pipefitter Welding Iron 2 2 4

Maintenance Pipefitter Welding Lead 2 3 6

Maintenance Maintenance Technician Gasket Replacement Asbestos 2 3 6

Reformer Unit Operator Routine Work Duties Noise 3 3 9

Reformer Unit Operator Routine Work Duties Benzene 2 3 6

Reformer Unit Operator Liquid Sampling Benzene 4 3 12

Tank Farm Operator Gauging Benzene 3 3 9

Table 3: QEAs for individual SEGs by unique stressors

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A well-developed sampling plan should address the following questions:

• What regulatory-driven periodic sampling is required?

• What SEGs need additional monitoring?

• How many personal, area, wipe or other type of samples are needed to improve the precision of your QEAs?

• What is the deadline to complete the samples?

Like any to-do list, you want to continually re-evaluate your sampling plan to ensure that the sampling activities you plan to accomplish are the ones that actually need to be completed to meet your compliance requirements and best protect worker health. So, ask yourself these questions:

• Are you following the same plan that was established by a previous IH manager years ago?

• Is your IH sampling simply reacting to employee or business concerns?

• How do you know if you are you sampling too much, or not enough?

To help you answer these questions with confidence, we recommend the following three-step process you can use to define a sampling plan. This method focuses your resources to get the most out of your sampling effort, while supporting the overall IH program.

How Do I Develop a Sampling Plan?Step 1: Identify any Regulatory-driven Periodic Sampling RequirementsOSHA and other agency standards include regulatory-required periodic sampling that must be considered when developing your sampling plan. One example is the Coke Oven Emissions Standard, 29 CFR 1910.1029. Paragraph (e)(1)(iii) of the Standard requires the full-shift personal sampling for each battery and job classification on each shift. This sampling is to be conducted quarterly.

Start your sampling plan by making a list of the sampling required for each SEG, stressors that must be assessed, how many samples are required, and the date(s) they need to be completed.

Step 2: Identify Samples Necessary to Increase Confidence with Your QEAsAIHA has developed a simple formula that we recommend to our customers when determining priority for additional investigation, including additional sampling activity. The formula is:

Info Gathering Priority Rating = Risk Rating x Uncertainty Rating

The Risk Rating was previously determined when we performed our QEA. The Uncertainty Rating is defined as follows:

Uncertainty Ratings

0: Certain the Risk Rating is precise

1: Uncertain the Risk Rating is precise

2: Highly uncertain the Risk Rating is precise

In Table 4 on page 10, we added two columns to our QEA table that will be used for the Uncertainty Rating and Info Gathering Priority Rating. We then sorted the table by highest Info Gathering Priority Rating.

The ranking of the priority items provides a good roadmap for where resources should be focused to improve the confidence of your QEA Risk Rating.

Based on information in Table 4, we see the highest priority is the benzene exposure while gauging a tank in the tank farm. There are also four other locations with ratings greater than zero (i.e., have some degree of uncertainty) and six with a zero rating (i.e., a high degree of certainty).

Items with a zero rating have the lowest priority but should be periodically re-evaluated to confirm the exposure potential hasn’t changed.

Step 3: Document Your Sampling PlanOnce you have the regulatory-required sampling and the prioritized list of SEGs that require additional sampling, you can combine them in a single table and determine the number of samples to take and the scheduled completion date(s).

Q: How many samples are needed?A: There are a lot of different strategies and methods that can be used to determine the appropriate number of samples to take—too many to discuss all of them here in this article. Ultimately, most of these methods recommend between 3 and 9 samples for each SEG/stressor. We will go into more detail on this in the section on Data Analysis.

Q: What should I set as the scheduled completion date? A: December 31st is the most common date, since most sampling plans are annual. However, make sure you meet the time requirements/deadlines for any regulatory-required sampling. For example, if quarterly monitoring is required, show the line item 4 times with the end of each quarter as your scheduled completion date.

You may also set the date earlier in the year if there is a high potential for exposure that is not well understood, or to match up with your production calendar when the task/process is being performed.

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Once the plan is established, you can track the progress through the year by adding columns for # Samples Taken and % Complete. An example of a finished sampling plan is shown in Table 5 on page 10.

Final Thoughts on Sampling PlansRemember, a sampling plan is just a plan. There will be times when you need to adjust the plan or collect additional samples. Your plan needs to remain flexible to adjust for changes to processes and stressors, or to validate the effectiveness of exposure controls. Additionally, sampling plans may need to be altered in response to employee concerns that may factor into your information-gathering priorities.

Lab Analysis – Uncovering Hidden Gems of Efficiency

Before jumping into our discussion on how to increase efficiency when working with your IH lab, it’s important to make sure you are working with right one.

STEP 4

Which Laboratory Should I Use?IH labs come in all shapes and sizes. Some are large and provide a lot of additional services, while some are smaller local labs that specialize in certain analytical methods. To help determine the best fit for you and your company, consider the following key factors:

Analysis CapabilitiesReach out to prospective IH labs with a list of the physical and chemical stressors for which you may be asking them to analyze samples to ensure that they offer the necessary analytical capabilities to process those samples. Make sure you ask if they outsource the analysis, and if so, make sure you’re comfortable with that. There’s no sense selecting a lab that only does a small fraction of the analysis methods you need.

Location Job Task Stressors Exposure Rating

Health Effect Rating Risk Rating Uncertainty

Rating

Information- Gathering

Priority Rating

Tank Farm Operator Gauging Benzene 3 3 9 2 18

Coker Unit Operator Routine Work Duties Hydrogen Sulfide 2 2 4 2 8

Maintenance Pipefitter Welding Lead 2 3 6 1 6

Maintenance Pipefitter Welding Iron 2 2 4 1 4

Alky Unit Operator Routine Work Duties Hydrofluoric Acid 1 3 3 1 3

Alky Unit Operator Routine Work Duties Noise 3 3 9 0 0

Coker Unit Operator Routine Work Duties Benzene 1 3 3 0 0

Maintenance Maintenance Technician

Gasket Replacement Asbestos 2 3 6 0 0

Reformer Unit Operator Routine Work Duties Noise 3 3 9 0 0

Reformer Unit Operator Routine Work Duties Benzene 2 3 6 0 0

Reformer Unit Operator Liquid Sampling Benzene 4 3 12 0 0

Table 4: Extension of QEAs for determining Information-Gathering Priority Rating

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One or Multiple Labs?Based on analytical requirements, you may ultimately need to use multiple labs. Using the methodology prescribed below, you will ensure you address the highest priorities with respect to your annual budget for monitoring.

PriceSampling effort should be focused on the items that need additional data and investigation. For example, those annual noise surveys you conduct every year that show noise levels are consistently above 95 dBA can be removed or greatly reduced. Remember, the overall number of samples you collect should be minimized over time, saving you money and giving you back time to focus on more important projects.

On-Staff CIHSeveral of the larger labs offer free or low-cost consultation with their on-staff CIHs. This comes in handy if you need additional support to determine the best sampling methods or just want an IH expert to review your work.

Equipment Loan and RentalSeveral labs offer air sampling pumps for free and will often rent noise dosimeters and other direct reading equipment. This offers a great cost-saving option if you’re not taking enough samples to justify purchasing your own equipment.

LocationFor most, lab location is not an issue. Sample media can easily be shipped next day air to and from most places. However, location becomes important if you need to swing by their office to pick up sampling media on short notice, or when analyzing a highly volatile agent and you don’t want to deal with packing it in dry ice or some other cooled packaging.

AccreditationMost IH laboratories are AIHA LAP accredited. We recommend this level of accreditation for analysis of most stressors.

Additional accreditations are available for specific stressors including lead (ELLAP), mold and other microbiological samples (EMLAP). If you are a global corporation, consider looking for laboratories that are also ISO/IEC 17025 accredited.

Depending on the state(s) you operate in, you may also need to consider state accreditations. Some states that have their own accreditations include Louisiana, New York, New Jersey and Texas.

Streamline Your ProcessOne of the most intensive administrative tasks when working with IH labs is creating your chain of custody (COC) form. It can be a time-consuming task, one that most of us don’t look forward to at the end of a long day of sampling. However, several IH laboratories are now offering online services to complete your COCs online. Some labs like SGS Galson even provide a convenient web portal to help you easily complete and submit your COCs.

Several labs also offer direct access to their sampling and analysis guides (SAGs). Your lab’s SAG is essentially a catalog of the analytical services they offer and includes information such as analysis methods, limits of detection, flow rates and required sample volumes. Having SAG information readily available helps ensure your planned sampling is performed according to proper procedures, and it helps minimize questions or the need to resample.

Challenges with Lab InterfacesMost IH software systems include interfaces that provide the ability to send COCs to labs and upload analytical results. However, the challenge with many of these lab interfaces is implementing them properly and keeping them working as analytical parameters and methods change. It can be an administrative nightmare requiring months to set up, plus additional support every time there is a change with the lab SAGs or any time you add a new stressor to your database.

Location Job Task Stressors # Sampled Planned

Scheduled Completion Date # Samples Taken % Complete

Tank Farm Operator Gauging Benzene 8 7/1/2021 2 25%

Coker Unit Operator Routine Work Duties

Hydrogen Sulfide 4 12/31/2021 2 50%

Maintenance Pipefitter Welding Lead 4 12/31/2021 1 25%

Maintenance Pipefitter Welding Iron 4 12/31/2021 0 0%

Alky Unit Operator Routine Work Duties

Hydrofluoric Acid 3 12/31/2021 1 33.3%

Table 5: Sample plan example

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Due to the level of effort required to maintain many lab interfaces, these capabilities have traditionally been limited to the larger labs and corporations. The average facility simply doesn’t have the IT resources or personnel required to keep these interfaces functional and up to date. The result is that only a small minority of companies and laboratories have a functioning interface to help streamline their COC submittals and upload of analytical results… until now.

Optimize Your Lab InterfaceVelocityEHS has built an IH solution that eliminates all of the COC and lab interface barriers and makes flexible lab interface capabilities available to companies and labs of any size. The core feature that makes this all possible is our Global Chemical & OEL Database.

Laboratories can easily map their laboratory information management system (LIMS) to our master list of stressors. Once mapping is complete, we can provide direct access to any number of companies in a matter of minutes, with no additional effort required by the labs. This simplified process enables smaller labs to offer the interface services that used to be limited to only the larger, more sophisticated labs.

VelocityEHS also gives users the ability to directly order analytical services via in-app access to each lab’s SAG when building your surveys. Once the services are identified, we provide the lab’s SAG information directly to users to ensure they know key sampling parameters like detection limits, flow rates, minimum sample collection volumes and times, etc.

The result of having all of this information at your fingertips is more accurate sampling and a more accurate COC that can be quickly generated at the end of a long day of sampling. Since you are essentially ordering directly from the lab’s catalog, the COC will be accurate. This all but eliminates questions and confusion between you and your laboratory, saving you time and money from any sampling errors or having the wrong analytical services performed.

IH Data Analysis: Defining Your Goals and Selecting the Best MetricsBefore diving into statistical analysis of your data, it is critical to define why you are performing an analysis in the first place, and what conclusions you hope to confirm or reject through that data. There's a wide array of different statistics, graphs and analysis methods you can use based on the questions you’re trying to answer, and the data set being assessed. Some analyses can be done quickly using a simple Microsoft Excel formula or calculator, while others may require more complex statistical analysis tools.

STEP 5

Ask the Right QuestionsWhichever analysis methods you use, there are some common IH questions they should answer.

Are exposures in SEGs consistent?Even our best professional judgement is not always 100% accurate. In many cases, SEGs are formed based on our qualitative observations and previous experience, but it is good practice to validate those exposure assessments to verify our qualitative assessments for those stressors.

Two of the more common methods for this include analysis of variance (ANOVA) and scatter diagrams. ANOVAs are very precise but are complex to perform, can be time-consuming and may not be practical to perform for every SEG. A simpler method would be to use a scatter diagram and look for clusters of data. This is more subjective but can provide a quick glance at how similar the exposure data is within the SEG.

Are the exposure ratings accurate?If your exposure ratings include quantitative data such as “Percent of OEL,” it is good practice to confirm your exposure risk ratings using IH sample data. The challenge is deciding which statistic to use. Before spending time generating a lot of statistics, it is important to first determine which statistics to use for confirming your exposure ratings. Common examples include:

• 95th Percentile

• 95% / 95% UTL

• 90% or 95% UCL

• % > OEL

• Geometric Mean & Standard Deviation

When using precise statistical analysis, it matters if the data set follows a normal or log-normal distribution.

What’s the likelihood of exceeding the OEL?This is similar to the previous question. Again, you should first determine if your distribution is normal or log-normal. It is important to first determine which statistics to use. Again, common examples are:

• 95th Percentile

• 95% / 95% UTL

• 90% or 95% UCL

• % > OEL

• Geometric Mean & Standard Deviation

Are the control measures working as designed (control verification)?Measuring the effectiveness of exposure risk controls is generally a simple task, but you should have an idea of what the expected results are. If a process was changed from an open process to a closed-loop process, it may be fair to assume the exposure should be less than the limit of detection. If the control was designed to reduce exposures, it should be estimated by how much, or at least designed to reduce the exposure to below a certain threshold.

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Either way, there should be a clear metric to measure the effectiveness of your controls.

Do we have sufficient sample data, or how much more sampling is needed?Unfortunately, this is a question that is much too complex to answer here. Luckily, there are several reliable models you can follow to help make this determination. Some regulations have specific quarterly monitoring that is required, while others, such as Europe’s EN689, provide a very defined methodology for collecting a small set of data and performing supplemental sampling when exposures exceed their parameters. The regulation also provides a strategy for reassessments, with time intervals ranging from one to three years, depending on the levels of exposure.

The EAS Bayesian tool discussed below is another tool you can use to help reduce the number of samples needed by combining a smaller data set with your professional judgement. The combination of your professional judgement and hard data provides a high level of confidence as to the true level of exposure.

Common Statistical ToolsThere are a variety of tools available to help you assess exposure data. While most are free, some require a license to be purchased. Here’s a few of the most commonly used resources:

IHSTATIHSTAT is a free Microsoft Excel worksheet that checks for log-normalcy and provides several common statistical analyses of IH data and compliance testing. This commonly used tool was developed by AIHA and is available for free.

EAS BayesianDr. Paul Hewett of Exposure Assessment Solutions developed the market-leading Bayesian analysis tool. He provides training sessions and webinars throughout the year on the software and other statistical topics. The Bayesian software has a free version (IHDA-Student), which is intended for use by students or EHS professionals in training. The IHData Analyst Professional version is intended for organizations looking to use it in their IH programs. Both versions are available here.

BWStatBWStat is a Microsoft Excel tool developed by Tom Geens and hosted by the Belgium Society of Occupational Hygiene. It allows the estimation of compliance with OELs, taking into account the intra- and inter-individual variation in repeated measurements. It was built to help facilitate the implementation of the BOHS-NVvA Guidance. You can download BWStat here.

HYGINISTHYGINIST calculates similar statistics as the IHSTAT tool but is a bit more complicated to use. It is free and offers additional statistics such as the 70% confidence for help with EN689 compliance testing. It can be downloaded here.

EXPOSTATSEXPOSTATS is a Bayesian analysis tool developed by Jérôme Lavoué of the University of Montreal and is available in English and French. The tool is available online and offers several different analysis tools and nice graphic outputs. These tools are available for use here.

Keep It Simple…As industrial hygienists, we love to play with data. You’d be amazed by the amount of great statistics that can be quickly generated using any of the tools mentioned above. While these are informative tools for advanced EHS professionals and provide a very detailed view of your IH data, effective IH management doesn’t have to be that complex.

For example, when determining if the exposures for a SEG are consistent, you can perform an ANOVA or simply create a scatter diagram and look for clusters.

Formulas for Analysis of Variance (ANOVA)

Unfortunately, the formulas used for ANOVA can be intimidating, let alone the time it takes to perform one. Alternatively, the scatter diagram can be quickly generated using Excel.

Example of a Scatter Diagram

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The example scatter diagram above shows short-term exposure limit (STEL) samples conducted in a nice cluster, while the full-shift exposures around 480 minutes show two different clusters of sample results. At this point, investigation should be done to determine why there are two clusters. Was it due to equipment the worker used? Their location? Their work practices? Whatever the cause, the SEG in this example may need to be split into two different SEGs based on the data.

Whatever method(s) you use to analyze the sample data, think carefully about what statistics or methods are most helpful in making decisions and communicating information about your IH program. Far too many EHS professionals try to present and communicate complex statistics to workers and management. This is a common mistake that only succeeds in confusing them, at which point they completely lose interest. The data needs to be presented in a simplified manner that’s easy to understand.

Medical Surveillance: Strengthening Your Last Line of Defense for Worker Health

Before diving into best practices for medical surveillance, let’s first have a quick refresher of the basics.

What Is a Medical Surveillance Program (MSP)?An MSP is defined as the set of medical activities that must be performed on workers when exposures to workplace stressors exceed a certain level. The program will list what the stressor of concern is, the threshold at which workers need to be tested, and the medical activities and their frequencies that need to be conducted.

Why Are MSPs Needed?The purpose of the MSP is to evaluate workers exposed to stressors above a set threshold and quickly identify any adverse health effects early-on, so they may be removed from

STEP 6

the exposure before further damage to worker health occurs. IH program managers should be notified any time adverse health effects are discovered, while ensuring compliance with HIPAA privacy laws and any company privacy policies. IH can then use this data to target specific workplace risks for additional assessment and control measures.

For example, workers with an abnormally high level of blood lead must be immediately removed from the work environment causing the exposure. IH should assess the hygiene procedures of workers and ensure they are |using their PPE appropriately. Additional air monitoring and an assessment of other exposure controls may also be deemed necessary.

Who Defines the Requirements for MSPs?Standards set forth by regulatory agencies such as OSHA are the most common source of MSP requirements. However, companies may choose to establish their own MSP policies, including employee wellness programs to manage risks from non-work-related health conditions such as diabetes or high blood pressure. Regardless of the source of the requirement, an occupational health professional should be involved in defining any necessary medical activities and their frequencies.

A great resource that summarizes the OSHA regulations for MSPs is “Medical Screening and Surveillance Requirements in OSHA Standards: A Guide.”

Who Needs to Be Included in Medical Surveillance Programs?Most regulations specify a threshold of exposure that, if exceeded, requires workers be placed into an MSP. Keep in mind that once there’s an exceedance, there are direct exposure controls and other actions that must be taken to minimize or eliminate the exposure and protect the worker. When it comes to MSPs, you are looking at the worst-case exposures and not statistics.

Methods for Setup and Maintenance of Medical Surveillance ProgramsThere are a few fundamental steps necessary to set up and maintain your MSPs and ensure workers are enrolled in the right programs based on exposures.

Step 1: Define Applicable MSPs and Their Required Medical ActivitiesLooking at your locations and assessment of potential exposures, you can determine which MSPs may be required under any applicable regulations. For example, a list of potential stressors at your locations may include noise, benzene and silica, all of which are regulated by OSHA and have MSP requirements.

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Step 2: Define ThresholdsFor each MSP, determine the threshold level at which workers need be enrolled in that MSP. For example, OSHA standards state that noise exposure exceeding an 8-hour TWA of 85 dBA would necessitate enrollment in the MSP.

Step 3: Evaluate Who Needs to be Enrolled in MSPsTo determine who needs to be enrolled, you can take a look at one or both of the following:

Risk RatingsThese are obtained through your qualitative exposure assessments. If the risk rating is above the threshold set by the MSP, all members of the SEG should be enrolled.

IH Sample DataAt a minimum, all persons for which sampling shows exposures exceeding the defined threshold should be enrolled in the MSP. An important determination is whether to enroll all workers that do the same job (i.e., are in the same SEG) or to assess each worker’s potential exposure independently. Most professionals would apply the enrollment to the entire SEG. However, you may be able to justify individual worker enrollments/de-enrollments if you can reliably demonstrate that those workers experience different exposures due to unique work procedures and conditions.

Step 4: Automate Enrollment and De-enrollment of workers in MSPsManually updating the lists of workers that are enrolled and de-enrolled in MSPs is a time-consuming task. IH software can make this job not just easy, but virtually effortless. The key is to be able to get accurate employee data from your HR department and map it to the requirements for who needs to be included in each MSP.

The best method is to map HR information specifying workers’ jobs and locations on to each SEG. With HR data being continually updated in the background, workers can be moved in and out of SEGs automatically as job roles and locations change. If you define who is required for your MSPs at the SEG level, workers will automatically move in and out of MSP enrollment as they move in and out of SEGs.

Unfortunately, there are limitations to most HR systems and records, and getting a 100% accurate, real-time account of all workers’ job roles and locations is very difficult. That said, even a 50% automation of MSP enrollment saves enough time and resources to make it worth the effort.

Evaluating and Communicating Performance: The Keys to Engagement with Your IH Program

If you were to ask business managers what the status of their business is, they would discuss their profit margin, EBITA, percent growth in revenue or other common financial metrics.

If you were to ask safety managers, they’d probably tell you about the number of days without a recordable injury or their incident rate and how it compares with last year.

As an IH professional, how would you answer the question: “What’s the status of your IH program?” Would you pull up a bunch of statistics? A list of SEGs? Perhaps you would show them your sampling plan for the year?

If you are having a hard time identifying the best data points, statistics, tables or diagrams to show, you’re not alone. This has been a long-running challenge for IH professionals and a big reason, I believe, why most stakeholders don’t understand what IH is or the value we bring to the business.

Documentation and CommunicationIndustrial hygienists are very good at documentation, but most of us need to improve our communication. We generate employee notification letters, tables and charts of sample results and include them in quality reports that are sent to management, but is there any two-way communication? Do we present our findings in person and make time for dialogue, discussion or Q&A? What happens with the reports we generate for data users? Are they just filed and eventually shipped to a salt mine for long-term storage without providing any real value for the business?

STEP 7

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We all learned in school or from our supervisors how to write great IH reports, but most of us have not received any real training on how to engage and collaborate with workers and management to communicate IH data in a meaningful way. We’re unfortunately all too content to keep the details in our black box and just document our findings.

The problem with just documenting our findings and not having meaningful dialogue about them is that workers and management will not understand why you conducted the monitoring or performed the risk assessments in the first place. If they don’t understand the why, they surely won’t understand the value you or the IH program brings to the business.

If It Ain't Broke, Don't Fix It!I am big believer in leveraging what works within your company’s culture. For most companies, important safety, quality and other risk information is already being summarized using a standard risk matrix, and stakeholders are likely accustomed to referencing other types of risk matrices to quickly understand the presence of risks in the workplace.

As we talked about earlier, a risk matrix is a valuable tool already in your toolbox that can also be used to summarize exposure and worker health risks. In the case of IH risks, rather than using severity and likelihood as our key risk variables, the IH risk matrix uses health effect ratings and exposure ratings to rank and prioritize risks.

Improving the Resolution of Your Risk AssessmentsTo get the full picture of the status of your IH program, you also need to identify and illustrate your level of confidence with your QEAs. This is best indicated by an uncertainty rating assigned to each QEA.

In Table 6, line items with an uncertainty rating of zero indicate a high degree of confidence, while those with a 1 (uncertain) or 2 (highly uncertain) need additional investigation (thus, a higher information-gathering priority rating).

Using the information in Table 6, we can quickly show stakeholders some key IH program insights, including:

• The current number of risk assessments and what level of risk they each have (e.g., high, medium, low)

• Details of the jobs, tasks, location and stressors that make up the health risks

• The degree of certainty with our health risk ratings

• Where additional resources are needed to improve the degree of confidence in the health risk ratings

To ensure effective communication of risks, these values should be discussed with workers and management, giving them ample opportunity to ask questions and have an open dialogue on the data. Ideally, this will instill greater understanding and appreciation of what IH is and its value to the business, and ultimately strengthen engagement with your IH program.

Tools and Skills for Communicating Control MeasuresRisk matrices can also be used to help build support for risk control measures. It’s very common for management to ask, “How can we reduce the red (high risk) items to yellow or green?” You can easily illustrate the answer to this question by using two matrices: one to show risk before controls are implemented and one to show risk after controls are put in place. This will tell you the initial and residual risk.

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Table 6: Extension of QEAs for determining Information-Gathering Priority Rating

Looks great, huh? But it’s never quite that simple. You must be armed with data to show what it takes to reduce those red items. When communicating control activities and effectiveness, we strongly recommend the following:

Present Multiple AlternativesIf you present only one control option, the only possible responses are yes or no. If you present multiple options, stakeholders are much more likely to assess the options in relation to each other and choose one of them rather than taking no action. They will appreciate the amount of work you did to provide options, and that you are not putting them into the position where they are simply approving or disapproving a control measure for which they had no input.

Present a Financial AnalysisMost of us are not experts on financial analysis, but we still should be able to provide some basic information about control alternatives, including:

• Price

• Return on Investment (ROI) – percent cost savings or benefits in dollars above the cost of the control, over a specified time period

• Break-even point – how long it takes for the benefits from installing the control to pay for themselves. Every day after the break-even point translates to a cost savings for the company.

When gathering financial information, remember to add items such as increased production, improved quality, decreased loss of product, reduced PPE expense, fewer days away, etc. Sometimes these additional items have the biggest influence on supporting the investment for the control.

Location Job Task Stressors Exposure Rating

Health Effect Rating

Risk Rating Uncertainty Rating

Information- Gathering

Priority Rating

Tank Farm Operator Gauging Benzene 3 3 9 2 18

Coker Unit Operator Routine Work Duties

Hydrogen Sulfide 2 2 4 2 8

Maintenance Pipefitter Welding Lead 2 3 6 1 6

Maintenance Pipefitter Welding Iron 2 2 4 1 4

Alky Unit Operator Routine Work Duties

Hydrofluoric Acid 1 3 3 1 3

Alky Unit Operator Routine Work Duties Noise 3 3 9 0 0

Coker Unit Operator Routine Work Duties Benzene 1 3 3 0 0

Maintenance Maintenance Technician

Gasket Replace-ment Asbestos 2 3 6 0 0

Reformer Unit Operator Routine Work Duties Noise 3 3 9 0 0

Reformer Unit Operator Routine Work Duties Benzene 2 3 6 0 0

Reformer Unit Operator Liquid Sampling Benzene 4 3 12 0 0

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Industrial Hygiene SimplifiedVelocityEHS Industrial Hygiene solutions help you assess and control workplace stressors, automate time-consuming IH tasks and maintain a world-class IH program, no matter what your level of IH expertise. Contact us to learn more!

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Learn more at www.EHS.com

The Value of VelocityEHS IH SolutionsVelocityEHS Industrial Hygiene Software gives you industry-leading IH program capabilities built on AIHA best practices, right out of the box. Our time-saving suite of solutions enables you to quickly get up and running, with little to no training needed, so you can more efficiently protect worker health, maintain compliance and drive long-term program performance.

Benefits of VelocityEHSSimplicityWe believe that well-designed, intuitive software ultimately gets used, and when your people are engaged, you get the greatest possible value from your IH software purchase.

SpeedNot only does our IH solution provide valuable time-saving capabilities, but our implementations require less time, cost less, and are more successful than other IH software systems on the market.

Unparalleled Customer SupportOur in-house IH experts and Customer Support Team stand ready to deliver the guidance, consultation and best-practice approaches you need to solve your most complex IH management challenges.

Holistic IH Program ManagementVelocityEHS gives you a comprehensive IH program management platform that integrates your IH sampling data, SEGs, QEAs, sampling plans, database of stressors and OELs, analysis, reporting and other IH functions into a single, easy-to-use system.

ValueThe IH experts at VelocityEHS are continuously developing the system enhancements and innovative new features you need to achieve greater levels of IH program efficiency throughout the life of your purchase.

Helping You Do Your Job BetterThe fundamental purpose of our IH solutions, besides helping you create a safer and healthier workplace, is to eliminate time-consuming manual IH program tasks and give you back time to focus on your goals.