Prioritizing Air Sampling Needs at BNL

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Prioritizing Air Sampling Needs at BNL

• BNLs Approach to Completing an
• Industrial Hygiene Exposure
• Baseline Monitoring Program
• Presented by
• Robert Selvey
• BNL Industrial Hygiene Manager
• November 30 2007

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Hey Boss, I need to complete an IH baseline
O. K. long awkward pause
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I mean, WE need to complete an IH baseline
O.K. Get to it!
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I guess. Whats an IH baseline anyway ?
Thats it ? Get to it ?
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Conducting exposure surveys of Industrial
Hygiene Hazards on ALL our operations
Eeek !
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Well, can I have the money and the people ?
For What ?
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For the IH baseline !!!
You mean it takes resources?
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Duh !! I mean Yes sir
How much ?
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Well, its required by DOE OSHA
How much ?
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You know 10 CFR 851, ISM and stuff like that
How much ?
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If we dont do it, we wont be in compliance
How much ?
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We can get PAAA fines
How much ?
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We can get audit findings
How much ?
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• Time goes by Weeks later

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I have been thinking a lot about the IH Baseline
I vaguely remember
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You wanted to know about the resources
Oh Yeah, How much ?
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Is lots close enough ?
What do you think ?
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How big is this project anyway ?
Ummm
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Is really big close enough ?
What do you think ?
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Sigh
Sigh
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He doesnt get it
He doesnt get it
Disclaimer The preceding presentation was
fictionalized. Any resemblance to actual persons
or organization is strictly coincidental.
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Prioritizing Air Sampling Needs

• An Approach to completing an
• Industrial Hygiene
• Exposure Baseline Monitoring Program
• Getting Managements commitment for the resources
• Conducting a really big, technical project in a
  way that is achievable

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What was the process BNL used to quantify the
how much and what to sample ?
The mysterious black box of priority, funding,
and resources
Need to get MANAGEMENT to do things it
FINANCIALLY hurts to do
The Product Completed Baseline Survey
The Need Exposure Monitoring
Tools to determine the SIZE of the need
Tools to PLAN what to monitor
Tools to DIRECT PROGRESS on the project
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Getting management do things it financially hurts
to do

• Approaches
• Its required by regulations.
• Its the right thing to do- its impacts peoples
  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 into the things senior
managers understand and are tracking
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Feedback and ImprovementIndustrial 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.
Everything gets monitored
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.
Only the big stuff gets monitored
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Feedback and ImprovementIndustrial 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.
Everything gets monitored
AIHA A Strategy for Assessing and Managing
Occupational Exposures Ideal strategy for
defining the exposure profile ... monitor each
workers exposure each day generally not
possible, a subset of workers and days is
chosen
Representative Sampling Approach
BNL Everything every type of operation gets
monitored using a Representative Sampling Approach
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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.
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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.

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Feedback and ImprovementIndustrial 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

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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)

Monitoring Planned (Representative Sampling,
based on exposure potential rating Feedback
from previous monitoring)
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Feedback and ImprovementIndustrial Hygiene
Baseline Monitoring- Overview
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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

• What this Tool did
• Let line organizations senior managers grasp the
  size of the needs in their area / operations.
• Educated them on what Industrial Hygiene is.

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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.

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Feedback and ImprovementIndustrial Hygiene
Baseline Monitoring- IH Needs Calculator
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

• Estimate was made for number of events for
• Source inventory
• Area Characterizations- air and surface sampling
• Inventory of exposed workers
• Personnel Exposure monitoring events

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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

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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 ltTWA8 based on duration in area May be at significant risk. Needs further evaluation compliance with OEL uncertain 25 of workers in SEG, quarterly
C Area/worker exposure is gt10 of OEL to OEL level Moderate risk 10 of workers once per year
D Area/worker exposure lt10 of OEL. Low risk 1 representative sample per year for three years, then one sample per 3 year cycle
U Unknown area/personal exposure Risk assigned on best available guidance Sample 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.)

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Feedback and Improvement Industrial Hygiene
Sampling Needs- IH Scheduler
Location
Hazard Risk
Resources Time

• IH Scheduler
• Identifies specific tasks to monitor-
  organization and location
• Assesses the hazard and risk
• Tracks sample date information

• What is Tool does
• Allows tracking of the status of
• monitoring completed versus-
  monitoring needed.
• Plan for future monitoring based on risk

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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.

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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.

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Feedback and Improvement Industrial Hygiene
Sampling Needs- Status

• Contractors 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.

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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.

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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.

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Conclusions

• IH Baseline Project
• SMEs answered managements 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.

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• Thank you for your attention
• Questions??