NC Sturgeon Safety Management System

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Louisa Goodwin
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Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 1 f 7 Purpse: The purpse f this prgram is t establish requirements fr the use and handling f materials that expse emplyees t

1 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 1 f 7 Purpse: The purpse f this prgram is t establish requirements fr the use and handling f materials that expse emplyees t cadmium and/r hexavalent chrmium. Scpe This prgram cvers all emplyees. Key Respnsibilities Managers/Supervisrs Shall ensure that all emplyees are aware f the prper wrk prcedures fr cadmium and hexavalent chrmium Shall ensure that initial training is cnducted fr all new emplyees and that retraining is cnducted when emplyee behavirs suggest that retraining is warranted. As part f the JSA and ther hazard evaluatin prcesses, identifies and evaluates chrmium r cadmium hazards and ptential expsures during planning and the cnduct f wrk. Reviews and apprves the Task-Specific Safety Analysis. As necessary, quantitatively determines the presence f chrmium r cadmium in materials, substrates, and ther media. This may invlve the cllectin f samples fr analysis by a qualified labratry r field testing using acceptable test methds. Prvides results f any chrmium r cadmium survey t management/supervisin, alng with infrmatin regarding hazard ptential and cntrl measures. As apprpriate, makes recmmendatins t management/supervisin t maintain, mdify, upgrade, r dwngrade cntrls accrdingly. Takes prmpt crrective measures (r supprts any Cmpetent Persn in this rle) t eliminate hazards; such as recmmending t management/supervisin t implement r mdify engineering, administrative, wrk practice, and persnal prtectin (including respiratry prtectin) cntrls. Cnducts peridic expsure assessment. As apprpriate, assists management/supervisin in ensuring that wrkers have the necessary training and medical surveillance based upn the activity and hazard. Ensures that medical mnitring is cnducted in accrdance with 29 CFR (fr chrmium) r 29 CFR (fr cadmium) including impsitin f wrk restrictins where apprpriate and reviewing results f medical mnitring. In evaluating chrmium r cadmium hazards and specifying cntrls fr a jb, (a) utilizes reliable histrical expsure mnitring data generated fr ther similar peratins r activities, (b) utilizes bjective data, and/r (c) plans and cnducts initial mnitring t determine expsures and assess the effectiveness f hazard cntrls. Cnducts initial and peridic expsure mnitring in accrdance with Natinal Institute fr Occupatinal Safety and Health (NIOSH)/OSHA methds if lacking histrical r bjective data. Maintains effective recrds f jbs mnitred, s that a histrical database can be used t specify cntrls and eliminate unnecessary and redundant mnitring fr future activities.

2 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 2 f 7 Supprts prject management/supervisin in respnding t expsures abve the PEL when wrkers were nt adequately prtected. As apprpriate, participates in pre-jb and daily wrker briefings regarding task-specific chrmium r cadmium hazards and cntrls, wrk practices/plans (such as JSAs), and ther applicable infrmatin, including any changes that are made t cntrls r t the wrk practices r plans. Emplyees Shall fllw all requirements regarding the safe wrk prcedures fr cadmium and hexavalent chrmium. Cadmium Prcedure Cmpliance Prgram A written cmpliance prgram shall be implemented when the PEL fr cadmium is exceeded at a wrk site. The fllwing areas shall be addressed within the site cmpliance prgram and t ensure emergency plans are in place shuld a release f cadmium ccur: Ptential expsure determinatin including a descriptin f each peratin where cadmium is mitted, machinery use, material prcessed, cntrls in place, crew size, emplyee jb respnsibilities and maintenance practices. Air mnitring data r develping a justificatin fr nt cnducting mnitring based n previus mnitring/histrical data r bjective data. Engineering cntrls including the specific means that will be emplyed t meet cmpliance. A reprt f technlgy cnsidered in meeting the PEL. A detailed schedule f implementatin. Cnsideratin f respiratry prtectin. A dcumented, written plan fr dealing with emergency situatins invlving a substantial release f cadmium. Wrk practice prgram. Other relevant infrmatin such as prtective clthing, husekeeping, hygiene areas and practices (including cnsideratin f shwer facilities), cnsideratin f medical surveillance, training and recrdkeeping. The written prgram must be reviewed and updated annually r mre ften t reflect significant changes in the cmpliance status fr NC Sturgen. The prgram shall be prvided fr examinatin and cpying upn request f affected emplyees, their representatives r OSHA fficials. Maintenance prcedures while wrking n ventilatin systems and changing f filters will be established. Prcedures shall be develped and implemented t minimize emplyee expsure t cadmium when maintenance f ventilatin systems and changing f filters. Examples include: Prper use f PPE, use f HEPA filtered vacuums, wet sweeping r ther methds t minimize the likelihd f expsure t chrmium. N cmpressed air shall be used t remve chrmium frm any surface. Cleaning equipment must be handled in a manner that minimizes the reentry f chrmium int the wrkplace.

3 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 3 f 7 Cnstructin wrk activities that result in expsure t chrmium r cadmium may include, but are nt limited t, the fllwing: Demlitin r salvage f structures where chrmium r cadmium, r materials cntaining chrmium r cadmium, are present. Remval r encapsulatin f materials cntaining chrmium r cadmium. New cnstructin, alteratin, repair, r renvatin f structures and substrates that cntain chrmium r cadmium. Installatin f prducts cntaining chrmium r cadmium. Wrking with/arund Prtland cement (in pwder r dust frm chrmium nly). Trch-cutting chrmium/cadmium cntaining paints. Transprtatin, dispsal, strage, r cntainment f chrmium r cadmium, r materials cntaining chrmium r cadmium. Maintenance peratins assciated with cnstructin activities. Welding, cutting, burning, r grinding stainless steel, chrmium-/cadmium-cntaining ally steel, and chrmium/cadmium cntaining allys. Nte!!! Expsure t chrmium (especially hexavalent chrmium) has als ccurred when the welding rd r wire in use cntains chrmium. The permissible expsure limit (PEL) fr cadmium and hexavalent chrmium is five (5) micrgrams calculated as an 8-hur time-weighted average ver a wrk shift. The actin level (AL) f 2.5 micrgrams triggers the fllwing requirements: Pre-jb planning includes, as needed, a thrugh identificatin f chrmium r cadmium materials. Identificatin may include the prduct name, a Material Safety Data Sheet (MSDS) with the MSDS number (if available) r a sample cntent analysis. Sampling data includes lcatin, sampling methd, sampling dates, labratry identificatin, and analytical methd. If dcumentatin is nt feasible r has been determined by the prject engineer t be unavailable r unreliable, chrmium r cadmium cntent sufficient t exceed the actin level fr chrmium r cadmium is assumed. Results f bulk sampling, calculatins f ptential chrmium r cadmium expsure, and ther data that demnstrate cmpliance with this practice (as well as the pertinent standards) are attached t the wrk package. Where chrmium r cadmium expsure abve the actin level is suspected, and in the absence f mnitring data, interim prtective measures are established that are equal t r greater than the assumed expsure level. Hexavalent Chrmium Prcedure Welding, Cutting, and Grinding Certain welding and cutting activities have been shwn t expse the welder/cutter, and ptentially helpers, t hexavalent chrmium abve the actin level when exhaust ventilatin is nt used. The activities have included the fllwing:

4 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 4 f 7 Shielded metal arc welding, Gas metal arc welding Flux cred arc welding, Sub arc welding Trch cutting thrugh chrmate-cntaining paints, grinding chrmium-cntaining metals. The types f metal invlved have been stainless steel, chrmium-cntaining ally steel, and chrmium-cntaining nnferrus allys. Expsure has als ccurred when the welding rd r wire in use cntains chrmium, and exhaust ventilatin is nt used. Therefre, exhaust ventilatin is always prescribed as a cntrl measure when activities with the materials mentined abve are in use unless histrical persnal mnitring data perfrmed when similar materials, using similar methds, under similar envirnmental cnditins are used shws cnclusively that the welder/cutter and helper (if applicable) are nt expsed abve the actin level withut regard t respiratry prtectin. N emplyee shall be expsed in excess f the PEL f 5 micrgrams per cubic meter f air as an 8-hur TWA. Emplyees shall nt be expsed in excess f the permissible expsure level. Plasma and Air Arc Cutting and Guging Plasma and air arc cutting and guging peratins have been shwn t expse the wrker and helpers within 10 feet f the wrk t levels f hexavalent chrmium abve the permissible expsure limit (PEL) under mst circumstances and cnditins. Exhaust ventilatin and respiratry prtectin (at least a half-face, tight-fitting respiratr with a HEPA filter/cartridge) are always prescribed as cntrl measures when activities with the materials mentined abve are in use; a higher level f respiratry prtectin may be prescribed, depending n cnditins. Nte!!! Each discrete task must begin with ventilatin and respiratry prtectin cntrl measures in place. Respiratry prtectin may be dwngraded nly upn cnclusive results f breathing zne mnitring f the emplyee(s) invlved in each discrete task shwing expsure t be less than 50 percent f the prtectin factr f the respiratr relative t the cncentratin and PEL f hexavalent chrmium. Respiratry prtectin may be eliminated nly upn cnclusive results f breathing-zne mnitring f the emplyee(s) invlved in each discrete task shwing expsure t be less than the PEL as an 8-hur time-weighted average. Additinal cntrls may als be apprpriate t be in cmpliance with 29 CFR , depending n the results f evaluatins f the materials t be used, envirnmental cnditins, length f the wrk prcess/activity, etc. Medical Surveillance Medical surveillance must be prvided t emplyees wh are expsed abve the PEL fr 30 days r mre per year r expsed in an emergency. Medical surveillance shall be prvided when an emplyee experiences signs r symptms f the adverse health effects f Hexavalent Chrmium (dermatitis, asthma, brnchitis, etc.). Medical evaluatins will be prvided at n cst t emplyees. Examinatins will be perfrmed by r under the supervisin f a physician r ther licensed health care prfessinal. Hygiene Persnal hygiene is very imprtant while wrking with chrmium r cadmium prducts. T avid accidental ingestin f chrmium r cadmium, emplyees wash thrughly (regardless f ther cntrls) prir t eating, chewing, smking, r drinking.

5 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 5 f 7 Practices NC Sturgen Management/supervisin supprted by safety prfessinal(s), the medical cntractr and training prviders cnduct the fllwing basic steps t cntrl expsure t chrmium r cadmium: Determine the types f prjects, activities, and peratins that culd invlve chrmium r cadmium, r chrmium r cadmium-cntaining materials. Fr thse jbs, cnduct hazard identificatin as part f the wrk design, planning, and cntrl prcess. If chrmium r cadmium materials are invlved, ensure that prject safety (fr chrmium) r a cmpetent persn (fr cadmium) cnducts a hazard evaluatin t determine the ptential expsure and t recmmend initial cntrls. Develp and implement a Task-Specific Safety when expsure is r is likely t be abve the PEL. The JSA (r equal) addresses the scpe f wrk activities; prvides initial expsure assessment; and prescribes expsure cntrls, air-mnitring requirements, wrk practices, persnal prtective equipment and additinal infrmatin as required. Incrprate recmmendatins frm prject safety fr chrmium r cadmium hazard cntrl measures int any JSA and wrk cntrl dcuments. Expsure Mnitring Peridic mnitring shall be cnducted at least every 6 mnths if initial mnitring shws emplyee expsure. Air mnitring will be perfrmed at the beginning f each jb task. If expsure mnitring results indicate expsure is abve the PEL, a written ntificatin must be included with the crrective actin being taken t reduce expsure t r belw the PEL. Ntify each affected emplyee, in writing, f the results f mnitring within five (5) wrking days. Air mnitring fr chrmium r cadmium may be waived prvided the fllwing cnditins are met: Mnitring has been perfrmed in the last 12 mnths. Data frm histrical mnitring riginates frm wrk peratins that clsely resemble the planned wrk peratins. Wrkplace and envirnmental cnditins (such as indrs r utdrs, temperature, wind speed, ventilatin, and space cnfiguratin) are similar t thse when the mnitring was perfrmed. The prcesses, types f material, cntrl methds and wrk practices are similar. Justificatin fr waving initial mnitring shall be included in the Task-Specific Safety Analysis r equal. Emplyees invlved are briefed regarding the existence f such data. Surveillance Medical surveillance shall be prvided when an emplyee experiences signs r symptms f the adverse health effects f Hexavalent Chrmium (dermatitis, asthma, brnchitis, etc.). Medical evaluatins will be prvided at n cst t emplyees. Examinatins will be perfrmed by r under the supervisin f a physician r ther licensed health care prfessinal. Changing and Hygiene Facilities Are Prvided fr Decntaminatin NC Sturgen must prvide change rms fr decntaminatin and ensure facilities prevent crsscntaminatin. Washing facilities shall be readily accessible fr remving chrmium frm the skin. Wrkers must wash their hands and face r any ther ptentially expsed skin befre eating, drinking r smking.

6 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 6 f 7 Regulated Areas Regulated areas shall be established when expsure t an emplyee is r is expected t be in excess f the PEL. Regulated areas shall be marked with warning signs t alert emplyees and access is restricted t authrized persns nly. Cntrls NC Sturgen is respnsible fr implementing effective engineering and wrk practice cntrls if the expsure level is abve the permissible limit fr mre than 30 days per year. Engineering and wrk practice cntrls shuld be prvided t reduce expsure t the lwest feasible level. If emplyees can demnstrate that such cntrls are nt feasible, NC Sturgen shall use engineering/wrk cntrls t reduce emplyee expsure t the lwest levels achievable, and shall supplement them by the use f respiratry prtectin. Recrdkeeping NC Sturgen is required t maintain and make available an accurate recrd f all emplyee expsure mnitring, medical surveillance and training recrds. Respiratry Prtectin is Required & PPE Respiratrs must be used when engineering cntrls and wrk practices cannt reduce emplyee expsure, during wrk peratins where engineering cntrls and wrk practices are nt feasible, and emergencies. Respiratrs shall be prvided in accrdance with (Respiratry Prtectin) (see NC Sturgen Respiratry Prtectin Prgram). Specific requirements cntained within (Cadmium) regarding respiratry prtectin shall als be fllwed including: Prviding emplyees with full face piece respiratrs when they experience eye irritatin. Prviding HEPA filters fr pwered and nn-pwered air-purifying respiratrs. Prviding a pwered air-purifying respiratr instead f a negative-pressure respiratr when an emplyee entitled t a respiratr chses t use this type f respiratr and such a respiratr will prvide adequate prtectin t the emplyee. PPE will be prvided at emplyees at n cst. PPE must be prvided when there is a hazard frm skin r eye cntact. Glves, aprns, cveralls, gggles, ft cvers etc. Cntaminated PPE will be remved at the end f the wrk shift. NC Sturgen must clean, launder, repair and replace prtective clthing as needed. Husekeeping Surfaces shall be maintained as free as practicable f accumulatin f chrmium. All spills and releases f chrmium shall be cleaned prmptly. Methds f cleaning include HEPA filtered vacuums, dry r wet sweeping, shveling r ther methds t minimize expsure. N cmpressed air shall be used t remve chrmium frm any surface unless the cmpressed air is used in cnjunctin with a ventilatin system designed t capture the dust clud created by the cmpressed air r n alternative methd is feasible. Cleaning equipment must be handled in a manner that minimizes the reentry f chrmium int the wrkplace.

7 Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 7 f 7 Training f Emplyees NC Sturgen shall prvide apprpriate types f training fr emplyees wh are ptentially expsed t chrmium r cadmium prir t their initial assignment and annually thereafter. NC Sturgen will assure emplyee participatin and maintain a recrd f the training cntents. This training includes: Hazard cmmunicatin training fr ptentially expsed emplyees. Chrmium hazards, cntrl methds and medical surveillance. Training specified by the applicable chrmium r cadmium standard fr wrkers expsed at the actin level fr any ne day, r wh are expsed t chrmium r cadmium cmpunds that are skin irritants. Respiratr training if respiratrs are t be used. Prvide infrmatin t wrkers regarding task-specific chrmium r cadmium hazards and cntrl methds, the JSA, wrk practices, medical surveillance and ther applicable infrmatin, including any changes that are made t these cntrls. Prvide training annually, as apprpriate, t wrkers wh cntinue t have expsure t chrmium r cadmium at r abve the actin level n any ne day. All training will be recrded and include the identity f the emplyee trained, the signature f the persn wh cnducted the training and the date f the training. Training recrds must be kept fr ne year.

RESPIRATORY PROTECTION PROGRAM UW-GREEN BAY

UWGB Respiratry Plan RESPIRATORY PROTECTION PROGRAM UW-GREEN BAY Table f Cntents: I. Purpse II. III. IV. Prgram Administratin Wh Is Cvered Prgram Elements V. Designated Respnsibilities VI. Fit Test Prtcls