B4. Industrial Hygiene

Code 8.0

Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, and controlled according to the Hierarchy of Controls. When hazards cannot be adequately controlled, workers shall be provided with and use appropriate, well-maintained, personal protective equipment free of charge. Participants shall provide workers with safe and healthy working environments, which shall be maintained through ongoing, systematic monitoring of workers' health and working environments. Participants shall provide occupational health monitoring to routinely evaluate if workers' health is being harmed from occupational exposures. Protective occupational health programs shall be ongoing and include educational materials about the risks associated with exposure to workplace hazards.

Elements to Demonstrate Compliance to RBA Code

Elements to Demonstrate Compliance to RBA Code are here below and, in the health, & Safety Checklist "Industrial Hygiene: Hierarchy of Controls" later in this document.

1. Policy

Ensure company's health and safety policy includes industrial hygiene elements including:

• a. Workers' exposures to chemical, biological, and physical hazards will be identified, evaluated, and adequately controlled in accordance with the hierarchy of controls, which is maintained through ongoing, systematic monitoring of worker's health.
• b. Ensure that there is proper budget and staffing allocated to conduct risk assessment, medical evaluations, provide PPE as well as training of individuals and coordination with local authorities as appropriate.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. The facility has conducted a risk assessment using established methodology to evaluate the risk of exposure to biological, chemical, and/or physical agents at the facility. This is sometimes referred to as a qualitative exposure assessment to determine if there is a risk of exceeding exposure limits.
• b. The need for exposure monitoring/air sampling is based on the results of the qualitative assessment and should occur if appropriate. Some countries require routine exposure monitoring regardless of the level of exposure.

NOTE: Risk assessment must include exposure to multiple chemicals.

• c. Where there is risk that the exposure may be significant, or when required by local regulations, the facility conducts baseline (initial) and routine exposure monitoring/sampling to determine exposure levels to biological, chemical, and/or physical agents at the facility.
• d. The facility has implemented controls to reduce or eliminate worker exposure to chemical, biological and physical agents:
  • i. Engineering controls (e.g. exhaust ventilation, enclosures, etc.) are designed to reduce worker exposure to chemical, biological and physical agents.
  • ii. Substitution of less hazardous chemicals and processes.
  • iii. Administrative controls (limiting worker exposure time; job rotation) are designed to reduce worker exposures to chemical, biological and physical agents.
  • iv. Appropriate Personal Protective Equipment (PPE) is issued to all workers only when engineering or administrative controls do not reduce exposures to acceptable levels.
• e. PPE
  • i. Minimum PPE requirements for entering or working in any production area with open surface tanks of hazardous chemicals where there is a risk of contact with or exposure to the contents of the tank include respirators appropriate to the level and type of inhalation exposure, safety shoes, long sleeves, chemically resistant gloves, and eye protection.
  • ii. Workers have been trained to use PPE as intended.
  • iii. PPE is free to workers.
  • iv. PPE is properly maintained and/or replaced at appropriate intervals to ensure effectiveness in reducing exposures.
  • v. Use of PPE is enforced.
• f. Chemicals (including hazardous substances, IFPCs⁵) are adequately and effectively.
  • i. Categorized
  • ii. Handled
  • iii. Stored
  • iv. Moved within a single facility/ multiple facility.
  • v. Access is controlled.
  • vi. Potential employee exposure control methods are adequate and effective, such as
    1. Segregation
    2. Secondary containment
    3. Ventilation
    4. Fire protection
    5. Appropriate storage cabinets
  • vii. Proper marking of all chemical, biological, and physical agents to the stricter of regulations, GHS, or customer standards.
  • viii. SDSs are available in local languages for workers or a language that they can understand.

NOTE: SDSs may be in physical form (e.g., paper) and available near to the area where the chemical is present or online. If they are online, workers must be trained and able to easily access the most current SDS.

⁵ IFPC (Industry focus process chemicals) include chemical mixtures that contain any of the following ingredients:

• a) 1-Bromopropane (CAS 106-94-5)
• b) Benzene (71-43-2)
• c) Dichloromethane (Methylene Chloride) (75-09-2)
• d) Methanol (67-56-1)
• e) n-Hexane (110-54-3)
• f) N-Methyl-Pyrrolidone (NMP) (872-50-4)
• g) Tetrachloroethylene (127-18-4)
• h) Toluene (108-88-3)
• i) Trichloroethylene (79-01-6)

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Regular evaluation plan to verify the effectiveness of implemented controls and corrective actions if required. The frequency should be at least every 3 years unless a Significant Change requires re-evaluation.
• b. The facility carries out risk assessments when new chemicals are introduced into the facility's operations or whenever modifications to the facility's processes could change worker exposure levels. The facility carries out exposure monitoring/sampling when the risk of exposure may be significant or when the exposure assessment is required by local regulations.
• c. An adequate and effective mitigation process for all significant actual and potential occupational health and safety risks identified, tracking implementation, and resulting adverse impact.
• d. Approval is required for the purchase and use of hazardous chemicals and for all new purchases of hazardous chemicals before use.
• e. Evaluations of chemicals (including hazardous chemicals) of less hazardous or non-hazardous alternatives, including Greenhouse Gas and ozone depletion impact.
• f. Engineering controls are implemented to mitigate worker exposure effectively and adequately to substances containing IFPC List chemicals, which is demonstrated by industrial hygiene records.
• g. IFPCs
  • i. An adequate and effective process for all hazardous chemicals to track, review, approve for use, and approve all new purchases of IFPCs before use.
  • ii. An adequate and effective recorded program to control the identified potential hazards to chemical, biological, or physical agents is in place and follows the hierarchy of controls in a documented gated process, demonstrating that each hierarchy level has been fully evaluated and reasons why it could not address the risk fully before proceeding to the next hierarchal level.
  • iii. A prioritized review and selection process to eliminate, substitute or isolate workers from all IFPCs.

NOTE: Administrative controls or PPE are used as designed controls for substances containing IFPCs only in temporary circumstances or in supplement to engineering controls.

• h. Monitoring, testing, alarm, and reporting equipment is available, well-maintained, calibrated, and operational.

4. Records

Records are maintained including:

• a. Copies of hazardous substances inventory, manifests, and shipping papers are maintained and accurate.
• b. Accurate chemical inventory records are maintained and accurate.
• c. Inspection records of hazardous substances and their points of storage and use are maintained and accurate.
• d. Worker testing, surveillance records to determine if the worker is being harmed from exposure to agents, respiratory, hearing loss or any other medical concerns related to specific job activities.
• e. Equipment monitoring, testing, calibrating, and repair records.
• f. Any other testing reports such as sampling records including sampling performed by government agencies as part of a regulatory inspection; all for the last three years.

5. Leading Practices

• a. Ongoing monitoring / air sampling even if not determined to be necessary or required by law.

6. Serious conditions that will result in a severe finding

• Not considering the COMBINED exposure to multiple chemicals that may occur.

1.0.0 (2024-01-01)

Initial release.