Did You Know…

Did you know an employer can be cited by OSHA for a violation if they don't assess or have proper documentation of employee exposure assessments and monitoring to hazardous conditions?

Employers are obligated to provide a workplace free from recognized hazards, which includes, among other things, measuring and monitoring employee exposure to hazardous conditions. Often times initial and baseline monitoring is overlooked, which can lead to OSHA citations and penalties.

• Failure to evaluate spaces for dust-related hazards. 

• Failure to assess workplace respiratory hazards adequately. 

• Failure to test for welding fumes. 

• Failure to conduct exposure assessments for toxic substances in employee work areas where metals or compounds containing beryllium, hexavalent chromium, or lead are used. 

• Failure to monitor whether those handling lead were at any time affected by lead poisoning. 

• Failure to assess the combined impacts of multiple metals and other hazardous air.  

• Failure to assess/sample noise in the workplace. 

• Failure to assess the level of noise exposure in a manufacturing facility. 

• Failure to properly maintain or document the results of noise level monitoring conducted in the workplace. 

• Lack of testing and inspections documentation. 

Operations that typically require employee exposure monitoring include handling or working with hazardous substances like asbestos, lead, chemicals with high volatility, dust-producing activities, welding operations, spray painting, certain types of demolition, and any situation where employees might be exposed to airborne contaminants above Permissible Exposure Limits (PELs) set by OSHA or other regulatory bodies. 

Key factors indicating a need for exposure monitoring: 

• Presence of known hazardous materials:  If a workplace uses chemicals identified as potentially harmful, monitoring is likely required to ensure exposure levels remain below safety limits. 

• High exposure potential activities:  Operations involving sanding, grinding, cutting, spraying, or other activities that generate airborne contaminants often necessitate monitoring. 

• Employee complaints or symptoms:  If workers report health concerns related to potential exposures, monitoring can help identify the source and determine necessary control measures. 

• Changes in work processes:  Modifications to production methods or equipment could introduce new exposure risks, warranting reevaluation through monitoring.

Important points to note: 

• OSHA regulations:  Each hazardous substance often has specific exposure monitoring requirements outlined in OSHA standards. 

• Representative sampling:  Depending on the situation, monitoring may not need to be conducted for every employee, but representative samples can be taken to assess exposure levels for a group. 

• Medical surveillance:  In some cases, exposure monitoring may be combined with medical testing to evaluate potential health impacts. 

Although these tests can be costly, as they may require a certified Industrial Hygienist, the fees are usually less than violating OSHA regulations that require such testing and documentation to be maintained and readily accessible for inspection. 

If OSHA inspects your facility, they may request exposure assessment and monitoring reports. Will you be able to comply?  Contact ACS to learn more about your industry-specific requirements.