Independent Oversight Status Report on Workplace Exposure Monitoring

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Independent Oversight Status Report on Workplace
Exposure Monitoring
Chemical Safety and Lifecycle Management
Workshop March 12, 2009
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Background

• Review Conducted January 2006 - June 2007
• Included 8 Sites
• Integrated With Routine ESH Inspections
• Focused on Workplace Monitoring for
  Non-Radiological Hazards

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DOE Requirements

• DOE Order 440.1A, Worker Protection Management
  for DOE Federal and Contractor Employees, 1988,
  CRD Att.
• 10 CFR 851, Worker Safety and Health Program, May
  2007
• DOE Order 440.1B, Worker Protection Management
  for DOE Federal Organizations, May 2007

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DOE Guidance

• DOE Guide 440.1-8, Implementation Guide for Use
  With 10 CFR 851 Worker Safety and Health Program
• DOE Guide 440.1-3, Occupational Exposure
  Assessment, March 1998
• DOE-Std-6005-2001, Industrial Hygiene Practices,
  April 2001

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DOE Guidance Cont.

• Mulhausen, JR and Damiano, J. A Strategy for
  Assessing and Managing Occupational Exposures,
  AIHA Press, Fairfax, Va., 1998
• Occupational Safety and Health Administration
  (OSHA) Technical Manual, TED 01.00.015
• National Institute for Occupational Safety and
  Health, (NIOSH), Analytical Methods

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Positive Attributes

• Processes Were Established for Identifying and
  Analyzing Hazards
• All Sites Utilized Accredited Laboratories
• IH Staffs Were Knowledgeable and Experienced
• Record Keeping Generally Met Requirements With
  Noteworthy Systems at INL and NTS

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Weaknesses

• Inadequacies in Procedures, Policies or Guidance
• Baseline Exposure Monitoring Not Completed
• Exposure Assessment and Work Control Processes
  Not Linked
• Assessment Frequencies Not Based on Potential
  Risk
• Recommendations Not Incorporated Into Work
  Documents

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Weaknesses

• Subcontractors Lacked Procedures, Monitoring,
  Equipment and Trained Staff
• Some Data Contained Errors or Omissions
• Lack of Technical Basis
• Thresholds Were Too High
• Lack of Self-Assessments

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Opportunities For Improvement

• Better Define Mechanisms in Programs and
  Procedures
• Improve the Consistency of Implementation
• Integrate Feedback and Improvement Processes

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Conclusion
Much Remains to be Accomplished

• The HSS Independent Oversight Team Routinely
  Identifies Potential Hazards That Have Not Been
  Analyzed
• Some Sites Have Insufficient Resources
• Most Sites Have Not Completed Baselines
• DOE and Contractors Assessments Rarely Evaluate
  Workplace Monitoring Programs

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