2.1 Exposure Assessment Process
Exposure assessments must be conducted by or under the supervision of a Certified Industrial Hygienist (CIH) and Microsoft OHS, or their designated representative. The exposure assessment process involves collecting information on the characteristics of the workplace, workforce, and environmental agents. The following flow chart demonstrates the basic process that will be used to conduct exposure assessments at all Microsoft locations.
*Taken from “A Strategy for Assessing and Managing Occupational Exposures”, Second Edition. 1998
The CIH or their designee will use the information to refine the potential exposures and create an initial sampling strategy. This is a critical step in the process, but a potentially complex one, as it requires the CIH to analyze interactions between people, workplace activities, and hazardous substances.
2.2 Basic Characterization
The basic information collected in this first step relates to:
Workplace hazards - the most common categories include:
Chemical
| Gas
Vapors
Dusts
Mists
Fumes
|
Physical
| Radiation
Noise
Ergonomic
Heat/Cold
|
Biological
| Biohazards
Microbiological
|
Workplace characterization.
The physical layout of the area or facility, including locations of equipment and individuals working on the production floor.
Description of processes completed at the facility, broken down into the component steps, if possible.
An inventory of the inputs, transfers, and outputs of materials or labor for each process, either as final products or as waste material. The inventory should include information and associated hazards on raw materials, intermediates, by-products, and support products (e.g., machine lubricants).
Workforce characterization.
Job activities or classifications of workers involved in the process.
Sensitive populations.
Characterization of agents.
Health effects data.
Occupational Exposure Limits (OELs) – where applicable.
Description of existing controls, both engineered and safe work practices. Results of past evaluations, if available.
2.3 Indoor Environmental Quality Assessments
Indoor environmental quality (IEQ) assessments are concerned with the efficiency of the building’s HVAC system to provide adequate ventilation, cooling/heating, and good quality make-up air. The following issues are commonly evaluated:
Sufficient air flow and make-up air
Filtration of outdoor pollutant sources
Temperature and humidity regulation
Water intrusion with subsequent mold growth
Assessments must be performed by trained professionals using calibrated instrumentation.
Facility maintenance contractors are limited to assessing the normal building parameters. Employees expressing concerns of symptoms believed to be related to IAQ issues should be referred to Microsoft OHS for further exposure evaluation using the methods and documentation described in this document.
2.4 Exposure Assessment
During an evaluation, the CIH or their designee will follow a systematic approach. Generally, the exposure assessment will be divided into the following five steps:
Determining the purpose and scope of the assessment.
Becoming familiar with process operations that cause hazards.
Performing the exposure assessment.
Evaluating the results and determining controls.
Communicating the results.
2.5 Quantitative Sampling
The CIH will review all the information collected during the basic characterization phase, then refine the initial sampling approach to account for the following:
Using this information, the CIH will:
Define anticipated parameters of the exposure profiles and how they should be categorized.
Evaluate the risk in relation to the exposure profile (Acceptable, Uncertain, Unacceptable) and associated OEL(s) to determine if further action is necessary.
2.6 Sampling Strategy
The sampling strategy includes:
Where and when to collect samples.
The job classification, or specific individuals, that should be sampled.
Sample collection methods.
Sample duration.
Number of samples collected, by each method.
Depending on the hazard, the hygienist may select one (or more) of the following sample collection methods, as appropriate:
Area.
Personal monitoring.
Surface wipes.
Bulk.
Biological specimen.
Validated sampling methods will be selected and used based on the hazard to be characterized.
NIOSH and OSHA have developed validated sampling methods for most methods with a Permissible Exposure Limit (PEL).
Additional guidance can be obtained through the OSHA laboratory, the American Council of Governing Industrial Hygienists (ACGIH), and ASTM International.
Sampling activities may not start as part of an exposure assessment until a sampling strategy has been approved by Microsoft OHS.
2.6.1 Instruments
Continuous monitoring or direct-reading instruments provide real-time measurements of the changes in exposure over time and according to tasks performed. However, such devices are only available for a limited number of contaminants.
Instrumentation should be carefully selected and meet the guidelines established in the sampling strategy.
Instrument users must have training on the specific instrument used.
Instruments must be maintained and operated as directed by the manufacturer.
Equipment must be calibrated and functionally tested to the manufacturer’s specifications which meet National Institute for Standards and Technology (NIST) standards.
The CIH, or the designated representatives, must be trained to operate each piece of equipment and the training must be documented.
2.6.2 Laboratory Analysis
Exposure samples may be collected by grab, passive, wipe, or bulk collection methods which must be subsequently analyzed in a laboratory.
Samples will be sent to an accredited laboratory for analysis.
The analytical results will be interpreted by the CIH using professional judgment, which must include an understanding of the material sampled, and knowledge of field observations collected during sampling.
The results should be compared to exposure limits established by international, Federal, State, or local regulations, or by health-based occupational exposure limits, such as those established by ACGIH.
2.7 Evaluation of Exposure
Once the exposure profile is defined, it should be compared with the OEL to determine whether the risk posed by the exposure is acceptable, unacceptable or uncertain. This process should be repeated for each OEL. This determination must be made by the CIH managing the assessment, in cooperation with Microsoft OHS, as appropriate.
2.7.1 Acceptable Exposures
Risk category assigned when quantitative or qualitative results indicate the exposure profile presents a low risk of an adverse health effect.
Acceptable exposures may not need further immediate action. However, using professional judgment, the CIH may choose to collect exposure measurements to verify the acceptability or to ensure the assessed hazard has not increased.
2.7.2 Unacceptable Exposures
Risk category assigned when the results of the sampling indicate an exposure exceeds regulatory or health-based standards and therefore presents an unacceptable health risk.
For employees in this category, Microsoft OHS will work with the appropriate parties to determine next steps, including additional sampling and/or implementation of controls.
Unacceptable exposures must be controlled utilizing the hierarchy of controls as follows:
Elimination of the process, equipment, or material
Substitution of a less hazardous process, equipment, or material
Engineering controls (e.g., process modification, exhaust ventilation, etc.)
Work practice controls and employee training
Administrative controls
Use of PPE
Confirmation sampling may be conducted to reassess the exposures and confirm the effectiveness of controls, once implemented.
2.7.3 Uncertain Exposures
Risk category assigned to profiles that cannot be deemed either acceptable or unacceptable.
Uncertain exposures can be resolved in two ways:
Further data can be gathered; or
The exposure can be classified as unacceptable (the most conservative approach).
Resolution of risk for uncertain exposures requires the collection of additional sampling data.
This could include returning to the workplace for more descriptive or quantitative data.
If uncertain exposures cannot be resolved, then corrective actions for those profiles must be approached and controlled in the same manner as unacceptable exposures.
2.8 Medical Surveillance and Removal
Medical screening and exposure assessments are components of a comprehensive medical surveillance program. The fundamental purpose of screening is early diagnosis and treatment of the individual and thus has a clinical focus. The fundamental purpose of surveillance is to detect and eliminate the underlying causes such as hazards or exposures of any discovered trends and thus has a prevention focus.
2.8.1 US Federal Standards with Medical Surveillance
1910.95, Occupational noise exposure
1910.120, Hazardous waste operations and emergency response
1910.134, Respiratory protection
1910.1001, Asbestos (Non-mandatory)
1910.1003, 13 Carcinogens (4-nitrobiphenyl, etc.)
1910.1004, alpha-Naphthylamine
1910.1006, Methyl chloromethyl ether
1910.1007, 3,3'-Dichlorobenzidine (and its salts)
1910.1008, bis-Chloromethyl ether
1910.1009, beta-Naphthylamine
1910.1010, Benzidine
1910.1011, 4-Aminodiphenyl
1910.1012, Ethyleneimine
1910.1013, beta-Propiolactone
1910.1014, 2-Acetylaminofluorene
1910.1015, 4-Dimethylaminoazobenzene
1910.1016, N-Nitrosodimethylamine
1910.1017, Vinyl chloride
1910.1018, Inorganic Arsenic
1910.1025, Lead
1910.1027, Cadmium
1910.1028, Benzene
1910.1029, Coke oven emissions
1910.1030, Bloodborne pathogens
1910.1043, Cotton dust
1910.1044, 1,2-dibromo-3-chloropropane
1910.1045, Acrylonitrile
1910.1047, Ethylene oxide (Non-mandatory)
1910.1048, Formaldehyde
1910.1050, Methylenedianiline (MDA)
State and local regulations may have additional standards that require medical surveillance.
2.8.2 Medical Removal
Requirements for medical removal, accommodation, and reinstatement of a Microsoft employee from the workplace include the following:
If an examining physician includes a medical finding, determination, or opinion that the employee has a medical condition which places the employee at increased risk of material health impairment from exposure, then the employee must be removed from exposure.
Recommendations for special protective measures for a worker (e.g., use of PPE) or limitations on a worker’s exposure that are made by a physician should be incorporated into the worker accommodation process.
The return of the employee to his or her former job status, or the removal of special protections or limitations, depends upon an examining physician’s determination that that the employee is no longer at increased risk of material impairment or that special measures are no longer needed.
Coordination of the medical removal and work accommodation process will be conducted by the Benefits Business Partner.
2.9 Communication of Results
2.9.1 Sampling Documentation
Standard forms will be used to collect information for all exposure assessments.
Forms must be legible and completed in ink. Corrections should be made by striking items with a line and noting the CIH’s (or designated representatives) initials and date.
These forms should be included as supporting documentation to the written report as they must be maintained as part of the exposure assessment records.
For examples of standard forms related to exposure monitoring, please reference Appendix A – E.
2.9.2 Report Requirements
Written reports must be completed for all exposure assessments that are reported against a required standard.
Reports must include the following information:
Summary.
Purpose.
Environmental agents.
Exposure assessment strategy.
Exposure assessment data.
Monitoring data and analytical results (if applicable).
Observations and conclusions.
Recommendations.
Written reports must be communicated to the affected employee(s) as directed in Employee Notification below.
2.10 Employee Notification
Employees will receive notification of the results of their exposure assessment within 15 business days of receiving results, unless a shorter notification period is required, such as lead and hexavalent chromium results, which both require a five-day notification period.
Microsoft OHS will communicate the results back to employees and supervisors, in compliance with regulations, and type of contaminant.
During this time, employees can meet and discuss the results with Microsoft OHS.
Employees may at any time request copies of exposure assessment results through Human Resources/Microsoft OHS.
Requested exposure assessment records should be made available to the employee within 15 business days. If the request cannot be fulfilled in the 15-business-day time frame, the employee will be informed of the anticipated delivery date before the 15-business-day deadline.
For a complete list of standards with notification requirements, please reference Appendix F.
