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 inorganic arsenic 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 1910.1018
4.0 DEFINITIONS
4.1 Action Level – a concentration of inorganic arsenic of 5 micrograms per cubic meter of air averaged over 8 hours.
4.2 Authorized Person – any person specifically authorized by the employer whose duties require the person to enter a regulated area, or any person entering such an area as a designated representative of employees to exercise the right to observe monitoring and measuring procedures of inorganic arsenic.
4.3 Inorganic Arsenic – Copper acetoarsenite and all inorganic compounds containing arsenic except arsine.
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 inorganic arsenic.
5.2 Compliance Program
5.2.1 The facility owner shall establish and implement a written compliance program when the PEL of inorganic arsenic of 10 micrograms per cubic meter of air 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 establish and maintain an accurate record for each employee subject to medical surveillance. This record shall include:
5.3.1.2 The name, social security number, and description of the employee’s duties.
5.3.1.2 A copy of the physician’s written opinions;
5.3.1.3 Results of any exposure monitoring done for that employee and the representative exposure levels supplied to the physician: and
5.3.1.4 Any medical complaints related to exposure to inorganic arsenic.
5.3 Written Procedure
5.3.1 This written procedure shall be reviewed and updated annually, or more often if necessary, to reflect the status of the program.
5.3.2 All employees, employee representatives, and regulatory agency personnel shall have access to this written procedure and Compliance Program, should one be necessary.
6.0 HOUSEKEEPING PLAN
6.1 A written housekeeping and maintenance plan shall be kept which shall list appropriate frequencies for carrying out housekeeping operations, and for cleaning and maintaining dust collection equipment. The plan shall be available for inspection by the Assistant Secretary and shall include the following with appropriate frequencies:
6.1.1 Surfaces shall be maintained as free as practicable of accumulations of inorganic arsenic.
6.1.2 Floors and other accessible surfaces contaminated with inorganic arsenic may not be cleaned by the use of compressed air, and shoveling and brushing may be used only where vacuuming or other relevant methods have been tried and found not to be effective.
6.1.3 Where vacuuming methods are selected, the vacuums shall be used and emptied in a manner to minimize the reentry of inorganic arsenic into the workplace
6.1.4 Periodic cleaning of dust collection and ventilation equipment and checks of their effectiveness shall be carried out to maintain the effectiveness of the system and a notation kept of the last check of effectiveness and cleaning or maintenance.
7.0 PERSONAL PROTECTIVE EQUIPMENT
7.1 Where the possibility of skin or eye irritation from inorganic arsenic exists, and for all workers working in regulated areas, the employer shall provide at no cost to the employee and assure that employees use appropriate and clean protective work clothing and equipment such as but not limited to coveralls, gloves, shoes, face shield or vented goggles.
7.2 Respirators will be provided for routine use if the engineering and work practice controls are not feasible or insufficient.
7.2 The employer shall prohibit the removal of inorganic arsenic from protective clothing or equipment by blowing or shaking.
8.0 HYGIENE FACILITIES
8.1 Employees shall not eat, drink, smoke, chew gum or tobacco, or apply cosmetics in the regulated area.
8.2 Employees working in regulated areas or subject to the possibility of skin or eye irritation from inorganic arsenic, must have access to clean change rooms equipped with storage facilities for street clothes and separate storage facilities for protective clothing and equipment.
8.3 Employees must wash face and hands before eating and must shower at the end of the work shift.
8.2 The employer shall provide for employees working in regulated areas or subject to the possibility of skin or eye irritation from inorganic arsenic, shower facilities.
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 arsenic.
9.2 Training shall be provided before the initial assignment and at least annually to all employees who may be potentially exposed to arsenic.
9.3 Training materials shall be readily available to all affected employees.
9.4 Training records shall be documented and shall include:
9.4.1 Identify of the employee being trained;
9.4.2 Signature of the person who conducted the training; and
9.4.3 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