RL Facility Representative Program April 10, 1995
Surveillance Guide OSS-19.9 Revision 0
Industrial Hygiene Page of 6
The objective of this surveillance is to evaluate the effectiveness of programs implemented by the contractor to anticipate, recognize, evaluate, and control environmental factors or stresses that may adversely affect the health of the Department's workers. The Facility Representative conducts walkthroughs, observes activities, and reviews records to determine if the implementation of the contractor's Industrial Hygiene Program is achieving required results. The Facility Representative evaluates compliance with DOE requirements and implementation of best practices.
2.1 DOE 5480.4, Environmental Protection, Safety and Health Protection Standards
2.2 DOE 5480.10, Contractor Industrial Hygiene Program
2.3 DOE 5483.1A, Occupational Safety and Health Program for DOE Contractor Employees at Government-Owned Contractor-Operated Facilities
2.4 29 CFR 1910, Occupational Safety and Health Standards for General Industry
3.0 Requirements Implemented
This surveillance implements requirements OS-0025 and OS-0027 from the RL S/RID. These requirements are drawn from DOE 5483.1A and DOE 5480.4 that commit the Department to follow requirements established by the Occupational Safety and Health Administration.
4.0 Surveillance Activities
In performing this surveillance, the Facility Representative performs the following activities:
1. Review selected health hazard assessments for the facility.
2. Observe work involving health hazards to workers.
3. Examine Health Hazard Assessment and Control Records.
Activity 1 - Review Health Hazard Assessments
Health hazard assessments are performed periodically to anticipate, recognize, evaluate, and control occupational health hazards. The Facility Representative reviews the most current health hazard assessment for one or more areas of the Facility.
Yes No N/A
___ ___ ___ 1. Has the hazard assessment been conducted within the following time frames?
a. Within one year for industrial areas, research and development facilities, craft shops, etc.?
b. Within three years for low-hazard areas such as offices and non-hazardous facilities?
c. Within the frequency specified by the senior industrial hygienist for changing work sites such as construction sites and hazardous waste sites?
___ ___ ___ 2. Does the hazard assessment include analyses of all new designs, operations, processes, materials, and equipment?
___ ___ ___ 3. Does the hazard analysis encompass all changes (both proposed and completed) for operations, processes, materials, controls, and work practices with any potential to cause new or additional hazards?
___ ___ ___ 4. Does the hazard analysis include a comprehensive industrial hygiene survey with:
a. An inspection of the work place?
b. Observations of work practices?
c. Results from monitoring to measure actual or potential exposure of employees to hazardous activities?
Yes No N/A
___ ___ ___ 5. Have the results from the health hazard assessment been reviewed and approved by the senior industrial hygienist and a representative for facility management?
___ ___ ___ 6. For significant or potentially significant hazards identified in the assessment, have actions been initiated to abate the hazard?
___ ___ ___ 7. Have actions to abate hazards been appropriately prioritized and entered into the contractor's work breakdown structure?
The Facility Representative selects work in progress such as routine operations, maintenance, decontamination or decommissioning, construction, or deconstruction for observation. The Facility Representative should select activities that entail occupational health risks such as exposure to hazardous, toxic, or carcinogenic materials or exposure to other physiological hazards such as extreme cold. A separate surveillance, OSS 19.8 provides for evaluating work activities that may involve exposure to heat stress. Before beginning this activity, the Facility Representative should obtain and review documents governing the work such as work packages, administrative procedures, and program documents.
___ ___ ___ 8. Do the governing documents identify the occupational health hazards that will be encountered by the workers while performing these tasks?
___ ___ ___ 9. Do the work documents specify appropriate hazard prevention and control measures to protect the health of workers?
___ ___ ___ 10. In specifying hazard prevention and control measures, has adequate consideration been given to the following:
a. Changing process or work conditions to use less hazardous materials?
b. Isolation or enclosure of work to prevent exposure to hazards?
c. Ventilation controls or other engineering controls to prevent or reduce exposure?
d. Establishing rigorous procedures to reduce or eliminate exposure?
e. Use of personal protective equipment?
f. Isolating the work area or conducting work during periods of reduced occupancy?
Yes No N/A
___ ___ ___ 11. If personal protective equipment such as use of respirators has been mandated, are work conditions such that it is not feasible to limit worker exposure by some other means such as engineering controls or alternative work practices?
___ ___ ___ 12. Are workers complying with hazard prevention and control measures specified in the work documents?
___ ___ ___ 13. If employees are using respirators, have they:
a. Been medically qualified to use the respirator?
b. Been fit-tested for the respirator?
c. Received required training on use of respirators?
___ ___ ___ 14. Are respirators used by employees approved by the National Institute of Occupational Safety and Health or accepted in accordance with acceptance testing performed by the Los Alamos National Laboratory?
___ ___ ___ 15. Is monitoring performed in accordance with requirements established in the work documents?
___ ___ ___ 16. Is equipment used to perform monitoring within the established calibration interval?
Activity 3 - Examine Records
The Facility Representative selects specific records regarding recent work projects for examination. As a minimum, the Facility Representative should select work activities that involve personnel monitoring for airborne contaminants, specific surveys to detect hazardous chemicals, and training records.
___ ___ ___ 17. Are records available documenting the results of exposure monitoring for employees including a description of sampling, analytical methods, and interpretation of results?
___ ___ ___ 18. Do records substantiate that employees were informed of the results of exposure monitoring within 10 working days of receipt of monitoring results?
___ ___ ___ 19. Do exposure monitoring results verify that total exposure to employees was below the applicable threshold limit value for hazardous substances?
Yes No N/A
___ ___ ___ 20. Do records document the basis for selecting specific employees for exposure monitoring?
___ ___ ___ 21. Do records of surveys for hazardous chemicals identify sampling techniques, areas sampled, and results?
___ ___ ___ 22. Do records of surveys note conditions that may have affected sample results?
___ ___ ___ 23. Do training records substantiate that a sample of workers have received training in the following:
a. Methods and observations that may be used to detect the presence of occupational health hazards?
b. Physical and health hazards of hazardous chemicals, harmful physical agents, and harmful biologic agents?
c. Measures to protect employees from hazards?
___ ___ ___ 24. Do training records substantiate that a sample of line managers and supervisors have received training in the following:
a. Management responsibilities for implementing industrial hygiene requirements?
b. Recognizing occupational health hazards that employees under their direction may encounter?
c. Content of the contractor's industrial hygiene program?
CONTRACTOR MANAGEMENT DEBRIEFED AND RESULTS:
Signature: ___________________________________ Date: _____/_____/_____