General Requirements
Controls
If employees are exposed above allowable limits as established by the Occupational Safety and Health Administration (OSHA), EHS will work with the employees' department to determine if engineering, administrative, or work practice controls can be implemented to reduce employee exposures. Medical surveillance will be provided for affected employees while these controls are being implemented, or if they fail or are not feasible.
Entrance Methods
EHS is responsible for reviewing all new hires and all current employee exposure conditions to determine entrance eligibility. Departments have the responsibility of notifying EHS whenever changes are made to employees' job duties, and whenever employees, such as graduate student workers, are placed in exposure situations. EHS will determine if employees are or may be exposed above limits by performing workplace and process evaluations and/or by actually monitoring employee exposures.
Volunteers, wage employees, and persons working on stipend will be provided access to medical services if they are performing work in an 'employee-like' capacity. 'Employee-like' means the person is performing work on behalf of the university, is being directly supervised by a university employee, and can be dismissed for cause.
Entrance Criteria
Medical surveillance services will be provided if employees are exposed above allowable limits to certain chemicals, dusts or physical agents. Medical surveillance services, including vaccinations and titers, will also be provided if employees are exposed to bloodborne pathogens, are employed as animal handlers or who have significant animal exposure, or if they work with infectious agents, select agents or toxins. The entrance criteria and medical services provided are listed in Table 1 and Table 2.
Frequency of Medical Evaluations
Depending on the Entrance Criterion, the evaluations will be offered by EHS at any combination of the following times:
- Time of Assignment . "Time of Assignment" is the thirty day period following EITHER the first day of employment in a position, OR the first day of assignment to new working conditions where an employee will be exposed to a health hazard covered in Table 1.
- Periodic . "Periodic" evaluation frequency is typically annual; however it may be greater or less. The frequency is specified in the applicable regulation for the hazard to which the employee is exposed and is generally outlined in Table 1 of the written program.
- Emergency Exposure . "Post Exposure" evaluations are to be given as soon as possible after a known exposure incident has occurred, or after an employee develops signs or symptoms of that may be related to a work-related exposure.
- Exit Evaluations "Exit Evaluations" are required by many regulations (see Table 1 of the written program) and are to be provided within a sixty day period before the date that the employee leaves the position/work environment that posed the health risk. The supervisor is responsible for notifying EHS when an employee is planning to leave a position where an Exit Evaluation must be offered.
Table 1 - Entrance Criteria for Chemicals, Dusts and Physical Agents
Exposure of Concern is: | Occupations Where Exposures May Occur: | Employees are enrolled if: |
Acrylonitrile | Manufacture of acrylic and modiacrylic fibers, acrylic plastics and resins, specialty polymers, nitrile rubbers, and other organic chemicals. Application as a fumigant. | They are exposed > the Action Level without regard for the use of respirators |
Arsenic (Inorganic) | Use/manufacture of pesticides, rodenticides, or wood preser-vatives. Certain soldering operations. Can be formed by roasting or smelting of sulfide minerals. | They are exposed above the Action Level, without regard for the use of respirators, at least 30 days per year. (Other requirements may apply. Please contact EHS for further information.) |
Asbestos | Remove or repair of asbestos materials including: cement, plaster, fire proofing, insulation, floor tile, floor tile glue, pipe, pipe insulation, brake and clutch linings, pipe and boiler insulation materials. | They are exposed above Permissible Exposure Limits |
Benzene | Laboratory operations. Use or application of gasoline or certain lacquer solvents and paint removers. | They are exposed > the Action Level for 30 days per year or above the Permissible Exposure Limit for 10 days per year. (Other requirements may apply. Please contact EHS for further information.) |
1, 3-Butadiene |
Production of styrene-butadiene rubber and polybutadiene rubber, copolymer latexes, resins and polymers, and in the production of such chemicals as fungicides | They are exposed > the Action Level for 30 days per year or above the Permissible Exposure Limit for 10 days per year |
Cadmium |
Ore smelting operations, mist from cadmium-containing electroplating baths, drying of cadmium pigments, machining of cadmium coated or containing materials. | They are exposed > the Action Level for 30 days per year |
Carcinogens (a) |
Any operation using the materials listed in footnote (a), below. | They work in a location where covered materials (see footnote a, below) are handled, used or stored |
Chromium (VI) |
Chromate production, use of chromate pigment and chrome electroplating. Welding of stainless steel. Tanning of hides using Chromium (VI). | They are exposed > the Action Level for 30 days per year, or are experiencing signs or symptoms of exposure |
1,2-Dibromo-3-chloropropane |
Application as a soil fumigant or use outside of a laboratory fume hood. | They are exposed above the Permissible Exposure Limit |
Ethylene Oxide |
Manufacture of ethylene glycol, surfactants, ethanolamines, glycol ethers, and other organic chemicals outside of a laboratory fume hood. Used as a sterilant and fumigant. | They are exposed > the Action Level for 30 days per year |
Formaldehyde |
Embalming or preserving of biological specimens. Used in certain manufacturing operations. Used in textile manufacturing. | They are exposed > the Action Level or Short Term Exposure Limit, or develop sign or symptoms of exposure. (Other requirements may apply. Please contact EHS for further information.) |
Hazardous Waste Operations |
Non-laboratory scale chemical spill response. Employees involved in chemical bulking operations outside of a chemical fume hood. | Hazardous materials emergency response or waste management personnel; covered employees who develop signs of symptoms of exposure or who have a known exposure to a covered hazard (a) |
Laboratory Exposure to Chemicals |
Operations where chemicals found on this table are used outside of a fume hood or other control. | An employee develops signs or symptoms associated with a chemical used in a laboratory, or exposure is above permissible limits for a chemical where surveillance is required |
Lasers (Non-Ionizing Radiation) |
Research operations using covered laser systems. | They routinely use Class 3b, 3r or Class 4 lasers |
Lead |
Metal smelting, casting, refining. Soldering and welding. Remove or apply lead paint or products. | They are exposed > the Action Level for 30 days per year |
Methylenedi-aniline (MDA) |
Manufacture of 4,4' Methylene-diphenyl diisocyanate; as a precursor in the manufacture of plastic fibers, antioxidants, dyestuff intermediates, corrosion preventatives, special polymers. Purified MDA: manufacturing epoxy resin curing agents, wire coating applications, polyurethane co-reactants, pigments/dyes, and defense applications. | They are exposed > the Action Level for 30 days per year or have dermal contact > 15 days per year |
Methylene Chloride |
Paint stripping, polyurethane foam manufacturing, cleaning/ degreasing | They are exposed > the action level for 30 days/year, or at or above the Permissible Exposure Limit or Short Term Exposure Limit for 10 days/year. Above the 8-TWA PEL or STEL for any time period where an employee has been identified by a physician or other licensed health care professional as being at risk from cardiac disease or from some other serious MC-related health condition and such employee requests inclusion in the medical surveillance program; |
Noise |
Construction, shops, vehicle work areas, maintenance operations, mechanical shops or research | The exceed an 8-hour time weighted average of 85 decibels |
Respiratory Protection |
Any situation where employee exposures are not adequately controlled by other means | They wear a respirator of any type including N95, N99 and N100 filtering facepiece. Note that single-strap disposable dust masks are not respirators. |
Silica |
Grinding, cutting or sanding of concrete, masonry, stone; abrasive blasting. | They are exposed above Permissible Limits |
Vinyl Chloride |
Manufacture of poly vinyl chloride. | Exposed > the action level without regard for the use of respirators |
(a) Covered carcinogens include: 4-Nitrobiphenyl, alpha-Naphthylamine, methyl chloromethyl ether, 3,3'-Dichlorobenzidine (and its salts), bis- Chloromethyl ether, beta-Naphthylamine, Benzidine, 4-Aminodiphenyl, Ethyleneimine, beta-Propiolactone, 2-Acetylaminofluorene, 4-Dimethylaminoazo-benzene, and N-Nitrosodimethylamine. Certain exemptions apply. Please contact EHS for further information.
For detailed information on the medical services provided for each enrollment criteria, please reference the Written Program.
Table 2 - Entrance Criteria for Other Agents
Exposure of Concern is: | Occupations Where Exposures May Occur: | Employees are enrolled if: |
Infectious organisms that can be transmitted between an animal and man (zoonotic disease). Exposure to animal dander or other tissue that are of allerginic importance. | Farm personnel; persons who work with unfixed animal tissue; veterinarians and support staff; persons who work with, trap or handle wild or domesticated animals including certain insects, fish and mammals. | They work with animals that may carry zoonotic diseases, that have been intentionally infected with zoonotic organisms, or that represent a serious risk for animal-related allergies. |
Bloodborne Pathogens | Clinical staff; medical staff; housekeepers; plumbers; police; rescue squad personnel; atheletic trainers and support staff. | They work with or are potentially exposed to unfixed blood, tissue or bodily fluids of human origin |
Infectious Agents (Including Select Agents and Toxins) | Employees who work in BSL2 or BSL3 laboratories; employees who work with certain infectious organisms. Please reference the Infection Control Program for more information. | They work with organisms or agents that are capable of causing disease in humans. All employees working with BSL2 or BSL3 organisms must enroll in this program. Employees working with Tier 1 Select Agents or Toxins as defined by HHS or USDA will be provided expanded medical services as outlined in the written program to include a fitness for duty evaluation. |
Field Research (Including international travel) | Employees who perform field research where a zoonotic disease is endemic or travel internationally to conduct research in a country where vaccinations are recommended by the CDC | They perform field research with animals where zoonotic diseases are a concern, in an area where certain zoonotic diseases are endemic, or travel to a country where vaccinations are recommended or required by the Centers for Disease Control. |
For detailed information on the medical services provided for each enrollment criteria, please reference the Written Program.