B4. Industrial Hygiene

Code 7.0

Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the hierarchy of controls. If any potential hazards were identified, participants shall look for opportunities to eliminate and/or reduce the potential hazards. If elimination or reduction of the hazards is not feasible, potential hazards are to be controlled through proper design, engineering and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge. Protective programs shall be ongoing and include educational materials about the risks associated with these hazards.

Elements to Demonstrate Compliance to RBA Code

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.
• 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. All required industrial hygiene permits, licenses and testing reports for potential industrial hygiene exposures are in place, available for review and valid, and a documented process is in place to ensure permits and licenses are renewed before they expire.
• b. 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, identifying, evaluating, and controlling worker exposure according to the hierarchy of controls.

NOTE: Risk assessment must include exposure to multiple chemicals.

• c. The risk assessment is updated when a Significant Change occurs. A health risk assessment, with associated industrial hygiene sampling and testing, is completed when a new chemical, biological, or physical agent is introduced into the work environment, or when an existing process is changed that may trigger an employee health risk.
• d. The facility has implemented controls to reduce or eliminate worker exposure to chemical, biological and physical agents:
  • i. Proper design (elimination and/or substitution).
  • ii. Engineering controls (e.g. exhaust ventilation, enclosures, etc.) are designed to reduce worker exposure to chemical, biological and physical agents.
  • 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. During normal working hours, the workplace is free from obvious odor, visible fumes, dust, and other conditions leading to potentially unhealthy feelings.

NOTE: If obvious odor, visible fumes, dust, and other conditions leading to potentially unhealthy feelings exist, the auditor should perform detailed interview and inspections.

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 major 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.
• c. The hierarchy of hazard control is applied from most effective to least effective: 1. Elimination, 2. Substitution, 3. Engineering controls, 4. Administrative controls, 5. PPE.

4. Records

Records are maintained including:

• a. All required industrial hygiene permits and licenses are in place, available for review and valid.
• b. Industrial hygiene testing reports and sampling records for the past three years, including sampling performed by government agencies as part of a regulatory inspection, are available for review.
• c. Medical surveillance records are available for review pertaining to respiratory evaluations to determine if the worker is being harmed from exposure to agents, or determining hearing loss or any other medical concerns related to specific job activities.

NOTE: Surveillance records are not limited to respiratory, but various exposures, such as skin contact, hearing loss, radiation, etc.

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

• No health risk evaluation process has been implemented.
• Required permits, licenses or testing reports missing.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Industrial Hygiene (RBA Code of Conduct 7.0): Earliest imported version of the criterion. Identification, evaluation, and control of worker exposure to chemical, biological and physical agents according to the hierarchy of controls. Includes a standalone permits/licenses/testing-reports provision (B4.1) with a documented renewal process, a risk-assessment process updated on Significant Change, controls via elimination/substitution/engineering/administrative measures and PPE, a 3-year control-effectiveness evaluation cycle, and medical-surveillance records. No Industry Focus Process Chemicals (IFPC) requirements and no numeric pass/fail thresholds existed at this release.