Hazwoper (Sec. 1910.120(h)) requires employers to conduct air monitoring of concentrations of hazardous substances to ensure employees aren’t exposed beyond PELs or published exposure levels and ensure appropriate protection. Here’s an overview of what to do.
Click here for Model Employee Exposure Monitoring Policy to include in your HASP.
Air Monitoring Before Initial Entry
Representative air monitoring must be conducted at initial entry to identify any IDLH conditions, exposures above PELs or published exposure levels, exposure to radioactive materials over dose limits or other dangerous conditions such as flammable atmospheres or oxygen deficiency.
Periodic monitoring is required where there’s a possibility of IDLHconditions or flammable atmosphere develop or there’s an indication that exposure may have rise above PELs or published exposure levelssince the previous monitoring took place. Situations where employers must consider the possibility that exposure increases have occurred include:
Monitoring of High-Risk Employees
After the actual clean-up phase of any hazardous waste operation begins, the employer must monitor employees likely to have the highest exposures to hazardous substances and health hazards likely to be present above their PELs or published exposure levels via use of personal sampling frequent enough to characterize employee exposures.
You can utilize a representative sampling approach by documenting that the employees and chemicals chosen for monitoring are based on likely presence of hazardous substances and health hazards above their PELs or published exposure levels.
If employees likely to have the highest exposure are over PELs or published exposure levels, monitoring must continue to determine all employees likely to be above those limits, which may utilize a representative sampling approach.
You don’t have to monitor employees engaged in site characterization operations described above (See Step 2)