1.0 PURPOSE
The purpose of this program is to establish and implement practices and procedures for protecting the health of Nitro Construction Services’ employees exposed to cadmium and cadmium compounds in the workplace.
2.0 RESPONSIBILITY
It is the responsibility of the site manager/superintendent to implement the requirements of this procedure.
3.0 COMPLIANCE
29 CFR 1910.1027
29 CFR 1926.1127
4.0 DEFINITIONS
4.1 Authorized Person – any person authorized by the employer and required by work duties to be present in regulated areas or any person authorized by the OSH Act or regulations issued under it to be in regulated areas.
4.2 Employee Exposure – The exposure to airborne cadmium that would occur if the employee were not using a respirator.
4.3 Permissible Exposure Limit (PEL) – The employer shall ensure that no employee is exposed to an airborne concentration of cadmium over 5 micrograms per cubic meter of air, calculated as an 8-hour time-weighted average (TWA).
4.4 Regulated Area – an area demarcated by the employer where an employee’s exposure to airborne concentrations of cadmium exceeds, or can reasonably be expected to exceed the permissible exposure limit (PEL).
5.0 PROCEDURE
5.1 Scheduled Monitoring
5.1.1 The facility owner shall perform monitoring to determine the 8-hour TWA exposure for each employee, for each job classification, in each work area. This shall be a full shift personal sample representative of the employee’s regular, daily exposure to cadmium.
5.2 Compliance Program
5.2.1 The facility owner shall establish and implement a written compliance program where the PEL of cadmium is exceeded to reduce employee exposure to or below the PEL using engineering and work practice controls.
5.2.2 Where engineering and work practice controls cannot reduce exposures to or below the PEL, the employer shall include in the written compliance program the use of appropriate respiratory protection to achieve compliance with the PEL.
5.3 Medical Surveillance
5.3.1 The employer shall institute a medical surveillance program for all employees who are or may be exposed to cadmium at or above the action level unless the employer demonstrates that the employee is not, and will not be, exposed at or above the action level on 30 or more days per year (twelve consecutive months); and,
5.3.2 The employer shall also institute a medical surveillance program for all employees who before the effective date of this section might previously have been exposed to cadmium at or above the action level by the employer unless the employer demonstrates that the employee did not before the effective date of this section work for the employer in jobs with exposure to cadmium for an aggregated total of more than 60 months.
5.3 Written Procedure
5.3.1 This written procedure shall be reviewed and updated annually, or more often if necessary, to reflect significant changes in the employer’s compliance status.
5.3.2 All employees and employee representatives shall have access to this written procedure and Compliance Program, should one be necessary.
6.0 MAINTENANCE PROCEDURES
6.1 Procedures shall be developed and implemented by the facility owner to minimize employee exposure to cadmium when maintenance of ventilation systems and changing of filters is being conducted.
6.2 This procedure shall address all personal protective equipment, including respiratory protection, that is required to be worn during maintenance activities.
7.0 EMERGENCY PROCEDURES
7.1 The facility owner shall develop and implement a written plan for dealing with emergencies involving a substantial release of airborne cadmium. The use of appropriate respiratory protection and other required personal protective equipment shall be addressed.
7.2 Employees not essential to correcting the emergency shall be restricted from the area and normal operations halted in that area until the emergency is abated.
8.0 CADMIUM INFORMATION
8.1 Appearance – The appearance of Cadmium is metal-soft, blue-white, malleable, lustrous metal, or grayish-white powder. Some cadmium compounds may also appear as a brown, yellow, or red powdery substance.
8.2 Routes of Exposure – Cadmium can cause local skin or eye irritation. Cadmium can affect your health if you inhale it or swallow it.
8.3 Effects of Overexposure
8.3.1 Short-term (acute) exposure – Cadmium is much more dangerous by inhalation than by ingestion. High exposures to cadmium that may be immediately dangerous to life or health occur in jobs where workers handle large quantities of cadmium dust or fume; heat cadmium-containing compounds or cadmium-coated surfaces; weld with cadmium solders or cut cadmium-containing materials such as bolts.
8.3.2 Severe exposure – may occur before symptoms appear. Early symptoms may include mild irritation of the upper respiratory tract, a sensation of constriction of the throat, a metallic taste, and/or a cough. A period of 1-10 hours may precede the onset of rapidly progressing shortness of breath, chest pain, and flu-like symptoms with weakness, fever, headache, chills, sweating, and muscular pain. Acute pulmonary edema usually develops within 24 hours and reaches a maximum by three days. If death from asphyxia does not occur, symptoms may resolve within a week
8.3.3 Long-term (chronic) exposure – repeated or long-term exposure to cadmium, even at relatively low concentrations, may result in kidney damage and an increased risk of cancer of the lung and of the prostate.
8.4 Employee Requirements
8.4.1 There is no smoking, eating, drinking, chewing gum or tobacco, or applying cosmetics while working with cadmium in regulated areas.
8.4.2 Do not carry or store tobacco products, gum, food, drinks, or cosmetics in regulated areas because these products easily become contaminated with cadmium from the workplace and can, therefore, create another source of unnecessary cadmium exposure.
8.4.3 If an employee has been potentially exposed to cadmium during the workday, that employee will change out of work clothes and shower at the end of the day, as part of their workday, to wash cadmium from skin and hair.
8.4.4 Handwashing and cadmium-free eating facilities shall be provided by the employer and proper hygiene should always be performed before eating.
9.0 EMPLOYEE INFORMATION AND TRAINING
9.1 The employer shall ensure that each employee is trained on this procedure who are potentially exposed to cadmium.
9.2 Training shall be provided before the initial assignment and at least annually to all employees who may be potentially exposed to cadmium.
9.3 Training records shall be documented and kept for one year. The record must include:
9.3.1 Identify of the employee being trained;
9.3.2 Signature of the person who conducted the training; and
9.3.3 Date of the training.
10.0 RECORDKEEPING
10.1 The employer shall maintain an accurate record of all air monitoring conducted to comply with the requirements of this procedure.