OSHA’s at the door, do you know where your data is?

It is not unusual for an employer to be aware of the employee exposure sampling requirements of standards such as 1910.95 Occupational Noise Exposure, or 1910.1026 Hexavalent Chromium.  However, many employers are unaware that this sampling triggers the documentation content and duration requirements of 1910.1020.

The records must contain sufficient data to meet the requirements of 1910.1020 Access to employee exposure and medical records which requires the following information to be retained for 30 years:

  1. The sampling results
  2. The sampling strategy
  3. Description of the analytical and mathematical methods used
    • If an employee’s exposure requires any calculation, such as the employee leaves to participate in a work activity outside the scope of his normal work so his average exposure is calculated based on what it would have been if he had remained, then that calculation must be included in the report.
  4. Background data relevant to the interpretation of the results
    • Make and model of the equipment used
    • Last factory calibration documentation
    • Pre and post calibration results for the equipment on the sampling day

Few businesses can afford to keep an Industrial Hygienist, IH, on staff, so they bring in a consultant to conduct the sampling.  The quality of consultants in the field can vary a lot which means the quality of the documentation they provide must be evaluated before you hire your consultant. 

Your best bet is hiring a Certified Industrial Hygienist, CIH, because the certification process requires the IH to prove they have, and maintain, the skills and knowledge required.  Only those who meet certain minimum requirements are allowed to take the 8 hour certification exam.  When OSHA requires a business to conduct sampling, they stipulate it be done by a CIH.

When you get a report it should contain all of the requirements listed above for 1910.1020.  Most reports will include a table comparing the results to occupational exposure limits and a discussion about them.  A CIH will usually include a description of the adverse health effects of the sampling target as well as a detailed description of the production, process, equipment, exposure source, and ambient conditions (doors open, fans on and direction of breeze), and anything directly or indirectly affecting employee exposure.

This level of detail is most important because, whether the employee is over occupational exposure limits or not, you must be able to identify changes in the production, process, equipment, exposure source, and ambient conditions that could increase or decrease employee exposures.  So, it is very important to be able to put your hands on these records at any time. 

When sampling results indicate the requirement for a written program the documentation of the results should be kept with that program, usually as an appendix or in the same electronic or paper file or notebook. 

However, when the results indicate employee exposures are below occupational exposure limits it is not uncommon for the documentation to be lost within a few years, or even months.  Especially if they are only in paper form.  Even if they are in electronic form when they are kept on the Safety Manager’s laptop they can be deleted or not make the transition to the next Safety Manager.

As a result, it is not possible to prove to OSHA or a Worker’s Compensation investigation that the employee was below occupational exposure limits and you have to pay to have the sampling repeated.  But, more importantly, it is not possible to identify potential changes in work processes or conditions that could increase employee’s exposure above the limits so you can address the problem in the planning stages.  If you missed that golden opportunity then, at least, you know you have to have the sampling done again.

By the way Simple Safety Coach, a safety management software company that I co-founded, has an electronic file cabinet right on our dashboard where sampling documentation and the most current written programs can be accessed in seconds.  Even if your Safety Manager is away on vacation you can provide the right documentation at the right time!