brookhaven science associates u.s. department of energy prioritizing air sampling needs at bnl...
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Brookhaven Science AssociatesU.S. Department of Energy
Prioritizing Air Sampling Needs at BNLPrioritizing Air Sampling Needs at BNL
BNL’s Approach to Completing an Industrial Hygiene Exposure Baseline Monitoring Program
Presented by Robert Selvey
BNL Industrial Hygiene ManagerNovember 30 2007
Brookhaven Science AssociatesU.S. Department of Energy
Hey Boss, I need to complete an IH baseline
O. K.
[long awkward pause]
Brookhaven Science AssociatesU.S. Department of Energy
I mean, WE need to complete an IH baseline
O.K.
Get to it!
Brookhaven Science AssociatesU.S. Department of Energy
That’s it ?
Get to it ?
I guess.
What’s an IH baseline anyway ?
Brookhaven Science AssociatesU.S. Department of Energy
Conducting exposure surveys of Industrial Hygiene Hazards on ALL our operations
Eeek !
Brookhaven Science AssociatesU.S. Department of Energy
Well, can I have the money and the people ?
For What ?
Brookhaven Science AssociatesU.S. Department of Energy
For the IH baseline !!!
You mean it takes resources?
Brookhaven Science AssociatesU.S. Department of Energy
You know:10 CFR 851, ISM and stuff like that
How much ?
Brookhaven Science AssociatesU.S. Department of Energy
If we don’t do it, we won’t be in compliance
How much ?
Brookhaven Science AssociatesU.S. Department of Energy
I have beenthinking a lot about the IH Baseline
I vaguely remember
Brookhaven Science AssociatesU.S. Department of Energy
You wanted to know about the resources
Oh Yeah, How much ?
Brookhaven Science AssociatesU.S. Department of Energy
Is “really big” close enough ?
What do you think ?
Brookhaven Science AssociatesU.S. Department of Energy
He doesn’t get it
He doesn’t get it
Disclaimer: The preceding presentation was fictionalized. Any resemblance to
actual persons or organization is strictly coincidental.
Brookhaven Science AssociatesU.S. Department of Energy
Prioritizing Air Sampling NeedsPrioritizing Air Sampling Needs
An Approach to completing an Industrial Hygiene
Exposure Baseline Monitoring Program
Getting Management’s commitment for the resources
Conducting a really big, technical project in a way that is achievable
Brookhaven Science AssociatesU.S. Department of Energy
What was the process BNL used to quantify the What was the process BNL used to quantify the “how much $$$” and “what to sample” ?“how much $$$” and “what to sample” ?
The Product
Completed BaselineSurvey
The mysteriousblack box
of priority, funding,
and resources
The Need
Exposure Monitoring
Tools to determine the “SIZE” of the
need
Tools to determine the “SIZE” of the
need
Need to get MANAGEMENT
to do things it FINANCIALLY hurts
to do
Need to get MANAGEMENT
to do things it FINANCIALLY hurts
to do
Tools to PLAN what to
monitor
Tools to PLAN what to
monitor
Tools to DIRECT
PROGRESSon the project
Tools to DIRECT
PROGRESSon the project
Brookhaven Science AssociatesU.S. Department of Energy
Getting management do things it financially hurts to doGetting management do things it financially hurts to do
Approaches It’s required by regulations. It’s the right thing to do- it’s impacts people’s lives. It reduces liability. It will save money in the long run (ROI). We got an audit finding, it must be corrected.
Approaches• The project was added to a Deficiency Reporting System (NTS) that has
accountability by senior management.• The project was added to high level Strategic Planning & Improvement
Commitments (Site Business Plan).• It was linked to a program already understood by senior management (ISM).• It became a “fix” in a larger corrective action plan (10CFR851 Gap Analysis).
We inserted our need We inserted our need into the thingsinto the things senior managers understand and are tracking senior managers understand and are tracking
These are reasons to do it, These are reasons to do it, but not viable approaches but not viable approaches that that Management can act on.Management can act on.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Baseline Monitoring- What is the right program ?
10CFR851 Section 6: “Contractor must implement…
Initial or baseline surveys and periodic resurveys and/or exposure
monitoring as appropriate of all work areas or operations to identify and
evaluate potential worker health risks.”
10CFR851 Section 6: “Contractor must implement…
Initial or baseline surveys [and periodic resurveys and/or exposure
monitoring as appropriate] of all work areas or operations to identify and
evaluate potential worker health risks.”
10CFR851 Section 6: “Contractor must implement…
[Initial or baseline surveys and periodic resurveys and/or exposure
monitoring] as appropriate of all work areas or operations to identify and
evaluate potential worker health risks.”
Everything gets monitored
Only the big stuff gets monitored
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Baseline Monitoring
10CFR851 Section 6: “Contractor must implement…
Initial or baseline surveys [and periodic resurveys and/or exposure
monitoring as appropriate] of all work areas or operations to identify and
evaluate potential worker health risks.”
AIHA: A Strategy for Assessing and Managing Occupational Exposures:
“Ideal strategy for defining the exposure profile ...monitor each worker’s exposure each day… generally not possible, a subset of workers and days … is chosen
Representative Sampling Approach
Everything gets monitored
BNL: Everything [every type of operation] gets monitored using a Representative Sampling Approach
Brookhaven Science AssociatesU.S. Department of Energy
Making the program technically sound to regulators
Fundamental Guidance Documents
AIHA: A Strategy for Assessing and Managing Occupational Exposures
NIOSH: Occupational Exposure Sampling Strategy Manual
We balanced the cost to implement (i.e. reality)
with
“performance based” regulator expectations
by giving BNL a Risk based prioritization of
representative sampling.
The highest risk gets monitored first.
Brookhaven Science AssociatesU.S. Department of Energy
The process in use at BNL
Action 1
BNL IH SMEs envisioned what the final “acceptable” product should be = statistically valid,
representative sampling of all exposure scenarios- facility operations, services, and science.
BNL IH SMEs created a program and developed options for the line organizations to use.
Action 2
The IH SMEs met with the line organization to explain the program and give them options to
meet a commitment: They would complete an IH baseline.
The size of the effort in each organization was determined by the line organization.
The resources needed to met the “size of the effort” for each organization was calculated.
Action 3
The search for the funds to implement the program was done.
Multiple pathways are being used- existing IH staff (reassigned), newly trained technicians, line
organization staff, contractors.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Technical Part of the Project
Step 1 Define Scope: Identify Hazard Categories- Done by the site IH SMEs
Welding/Cutting/Brazing Noise Silica Asbestos Beryllium Biohazards Cadmium Chemicals Heat Stress Lead Radiofrequency (RF/MW) Reproductive Hazards Soldering Static Magnetic Fields Confined Space Lasers Ergonomics
Excluded:• Bloodborne Pathogens• Indoor Air Quality
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Scope
Step 1b Create a Monitoring Priority for the site- Done by the site IH SMEs
Welding/Cutting/Brazing Noise Silica
Asbestos Beryllium Biohazards Cadmium Chemicals Heat Stress Lead Radiofrequency (RF/MW) Reproductive Hazards Soldering Static Magnetic Fields
Confined Space (handled on an entry event basis by line organizations) Lasers (handled with centralized SME evaluation program) Ergonomics (handled with centralized SME evaluation program)
Sampling targeted for every event(based on feedback from previous monitoring)
Monitoring Planned (Representative Sampling, based on exposure potential rating & Feedback from previous monitoring)
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Baseline Monitoring- Overview
IH Baseline Monitoring Program
IH Hazard Matrix
IH Needs Calculator
IH Scheduler
Internal ResourcesS&H Rep & line organizations
External ResourcesContractor
Identify Hazards Categories in each line organization
Identify Monitoring Resources needs in each line organization
Identify Specific Monitoring Events, Risk, & Date
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Resource Determination
Step 2
IH Matrix Identification of Hazards & the applicability in each department
Used in the initial conceptualization of the program
[Has be replaced with other databases and is not
maintained]
Hazards
Organizations
What this Tool did:
• Let line organization’s senior managers grasp the size of the needs in their area / operations.
• Educated them on what Industrial Hygiene is.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Resource Determination
Step 3 The IH SMEs developed the IH Needs Calculator, an Excel® spreadsheet to further define the RESOURCES required for regulatory compliance.
For each line organization and each hazard category, an entry was made for:
number of monitoring events x estimate of time for each event =
RESOURCES NEED FOR EACH DEPARTMENT
With existing personnel, the IH Needs Calculator estimated: 11 years to conduct full characterization. -Rejected by Management -
The IH Needs Calculator was used to estimate the number of new term FTE to complete the program in 5 years, 2 years, and 1 year.
Senior management selected and committed resources for 2 year completion.
What this Tool did:
Allowed the line organization and site senior managers to know the
amount of resources needed to characterize their operations and
the site. They could choose to: • Do it themselves with their staff.• Rely on the overhead service providers.• Buy their own expert.• Accept the risk.
Brookhaven Science AssociatesU.S. Department of Energy
Step 3:
Estimate of the resource needs (per line organization)
# of monitoring events (not total samples) needed to characterize exposure
Determined the resource (personnel hours) to conduct monitoring & reporting.
[Has be replaced with other databases and is not maintained]
Feedback and Improvement
Industrial Hygiene Baseline Monitoring- IH Needs Calculator
Estimate was made for number of events for:• Source inventory• Area Characterizations- air and surface sampling• Inventory of exposed workers• Personnel Exposure monitoring events
The service provider could be split among various organizations
Hazard
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- IH Scheduler
Step 4. The IH Scheduler is a tool BNL developed (Access® database) to define Exposure Characterization, Hazard Ranking and Sampling Frequency.
The IH Scheduler: • lists planned and completed monitoring events. • assigns a health risk to each events to be monitored.• establishes the frequency for routine monitoring events based on the risk.• determines the date of next monitoring event.• documents the resource to conduct monitoring (by name and estimate hours per event).
It is maintained by line organization units and contains:• Location of the hazard• Operation• Hazard (e.g. noise, chemicals)• Risk Rating• Date of Sampling• Monitoring Resource
What this Tool does:
• Targets the higher hazards operations
• Gives attention to PROACTIVE monitoring
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- IH Scheduler
BNL Risk Ranking - Exposure Monitoring Data
Risk Category
Exposure Level Relative Risk Frequency of Monitoring
A
Worker exposure exceeds OEL on TWA8
Significant risk All workers in SEG during each job until PPE requirements characterized, then all workers quarterly
B
Area exposure level exceeds OEL but worker exposure is <TWA8 based on
duration in area
May be at significant risk. Needs further evaluation: compliance with OEL uncertain
25% of workers in SEG, quarterly
CArea/worker exposure is >10%
of OEL to OEL levelModerate risk 10% of workers once per year
DArea/worker exposure <10% of
OEL. Low risk 1 representative sample per year
for three years, then one sample per 3 year cycle
UUnknown area/personal
exposureRisk assigned on best available
guidanceSample on next operation(s) until
characterized as A-D
Exposure Potential is based on:
• Historic Monitoring Data- feedback
• Recently Completed Monitoring- feedback (re-assign rating as needed)
• Professional Judgment Estimate of an IH Professional (based on quantity in use, vapor pressure, potential for aerosolizing, engineering controls, etc.)
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- IH Scheduler
IH Scheduler
• Identifies specific tasks to monitor- organization and location
• Assesses the hazard and risk
• Tracks sample date information
LocationLocation HazardHazard & Risk Resources & TimeResources & Time
What is Tool does:
• Allows tracking of the status of:
monitoring completed – versus- monitoring needed.
• Plan for future monitoring based on risk
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Status
How is BNL doing on completing the baseline
IH Scheduler is tracking 600+ monitoring events (1 per day for 2 yr project). At 13 months, the project is 45+% complete.
7.5 FTE assigned at least part time to the project (from the central IH office).
1.5 FTE are participating from line organization or other service providing groups.
BNL has hired an IH Monitoring Contractor to supplement these resources.
BNL committed to completing 1 round of sampling by the Close of FY08.
If resources remain as committed- BNL will meet the project completion date.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Status
Details on the IH Monitoring Contractor supplementing existing staff
Best Value Contract: A nationally recognized expert with extensive experience in research lab environment IH monitoring and hazard assessments.
Scope Of Work • Contractor interacts directly with departments to establish monitoring schedules,
conduct monitoring & prepare employee notification of monitoring results and individual project reports.
• Contractor reviews all ESRs to determine need for IH monitoring ~ 200 ESRs.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Status
Contractor’s Progress
FY07 May-September 59 monitoring events completed in 4 months (about 0.75 event per day)
– Small quantities of chemicals in small science labs manipulated in hoods (Primary emphasis)
– Area/Personal Noise monitoring for plant engineering– Area surveys for mercury in old labs– Surface wipe sampling around balances and soldering stations
Feedback: Barriers to performance by a contractor hired for a limited period Difficulty in ‘catching’ work in progress in bench scale science. ADS funding process releases money too late in the year: funds only arrive in the
Summer, the season for: grant proposal writing, vacations, etc.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback from bench scale research exposure monitoring
It is a difficult to capture exposure monitoring data on this type of work:• Little advanced notice is provided by researchers.• Work is highly temporal in nature.• Work is highly variable in what is done on any given day.• Work changes nearly every day.• Interval between similar operations being conducted can be very long.• Duration of most operation is typically minutes, making collecting adequate
sample volume difficult.
Subjective• “Faking work” (i.e. simulations for the sake of collecting data) is blasphemy
for most researcher.• The researcher who “get safety” are usually willing and easy to monitor,
those that view safety as a “necessary evil” are more difficult to successfully connect up with for monitoring.
Brookhaven Science AssociatesU.S. Department of Energy
Feedback and Improvement
Industrial Hygiene Sampling Needs- Status
IH Monitoring Contractor Phase 1 Monitoring in “Small Science” Final Report
“Without exception, [bench scale chemistry work] exposures did not approach ACGIH, BNL and /or OSHA exposure limits for chemical tasks performed within functioning chemical fume hoods.”
“[Future] Sampling priority would likely be low for compounds with vapor pressure up to 200-mm mercury and quantities up to 6-liters when used in a chemical fume hood or a closed system.”
“An exception could include a material with a very low exposure limit, i.e., 1-ppm or less, and reasonably high vapor pressure, i.e., 100-mm of mercury, when handled in quantities greater than 100-mls.”
Conclusion BNL draws for this effort:
• An “independent” ESH expert on laboratory-scale science confirms the logical expectation that bench-scale experimentation exposures are low.
• BNL will now target the bulk of our monitoring resources (when staffing drop in FY09) on “facility operations”, “services” and “construction”, with a continued but lower emphasis on “bench scale science”.
Conclusion BNL draws for this effort:
• An “independent” ESH expert on laboratory-scale science confirms the logical expectation that bench-scale experimentation exposures are low.
• BNL will now target the bulk of our monitoring resources (when staffing drop in FY09) on “facility operations”, “services” and “construction”, with a continued but lower emphasis on “bench scale science”.
Brookhaven Science AssociatesU.S. Department of Energy
Conclusions
IH Baseline Project
SMEs answered management’s question of “How Much $”- [FTE / time frame].
SMEs packaged the project into programs the senior managers were already tracking.
Line organizations understood their needs and commitment.
Creativity was used to fund the program by multiple pathways.
Prioritizing IH Monitoring Needs
A representative sampling, risk based sampling strategy is used- that makes the program
realistic, attainable, and justifiable.
Feedback was constantly used to refine both processes-
Revised resource estimates.
Revised risk rankings.
Revised planned date of future monitoring events.
New operations were constantly added as more field work discovered needs.