2.1 Written Site-Specific NIR Site Plan
Each Microsoft location included in the scope of this program must develop a site-specific NIR Plan (“Site Plan”). The Site Plan must be made available to all affected employees and external staff, or any regulatory agency personnel. The Site Plan must include the following:
Program purpose and scope.
Site-specific regulatory requirements (State or Local).
Personnel roles and responsibilities.
A Plan Administrator must be designated for each facility to oversee implementation of the Site Plan.
Definitions of terms critical to an understanding of the Site Plan.
General safety rules for areas where NIR is present.
An inventory of all NIR sources and their locations within the facility.
A description of workplace controls including engineering, administrative controls, and PPE requirements.
Incident investigations for all accidents, incidents, and near-misses that were directly or indirectly related to NIR exposure.
Required training.
A thorough documentation and recordkeeping system.
A Site Plan template can be found in Appendix A.
2.2 Risk Assessment
A risk assessment must be conducted to identify the health and safety hazards, the acceptable exposure limits, and safe work practices. The Plan Administrator and the NIRSO will work with Managers/Supervisors and Program/Project Managers to complete a risk assessment for each piece of equipment that uses NIR sources.
Each Site must complete a risk assessment for all identified NIR sources.
2.2.1 Purpose
The purpose of the risk assessment is to identify the type of NIR, hazard potential based upon the Occupational Exposure Limit (OEL), and the controls necessary to minimize employee exposure. Risk assessments must be reviewed and updated periodically and, as necessary, when conditions change. Risk assessments must be reviewed by the NIRSO.
Risk assessments will usually include:
Inventory of NIR sources
Interviewing supervisors, employees, and external staff.
Observing work practices.
Reviewing supporting documents that may include applicable regulations, consensus standards, technical data sheets, guidelines and SOPs.
Identifying OELs for employees or locations.
Conducting sampling (dosimetry and calculations), where OELs are in question or as otherwise necessary.
Engaging process experts to review the tasks and develop safe work practices for operation and maintenance.
Managers/Supervisors must notify the Plan Administrator to:
2.2.2 Scope
The risk assessment process applies to all NIR sources purchased, leased, designed or assembled at Microsoft. All NIR sources must obtain NIRSO approval.
For equipment designed or assembled at Microsoft, the Plan Administrator or Microsoft OHS must be included in all phases of the design process.
For more information on the risk assessment process, consult the Microsoft Risk Assessment Program.
2.2.3 Establish OELs
As part of risk assessment OELs must be established. The identification of potential OELs will include a review of current and historical records, NIR source inventories, interviews with NIR equipment users, and prior risk assessments.
If no specific OEL is provided, the site may refer to OELs issued by the ICNIRP. ICNIRP Tables are presented in Appendix F.
2.2.4 Measuring and Calculating Potential OEL Exceedances
If employee exposure to potential NIR sources would result in exceedance of the OELs, sampling must be performed.
Prior to sampling, the following information regarding the NIR source is required to select the proper sampling equipment:
Type.
Frequency.
Distance.
Wavelength.
The following should be considered in selecting sampling equipment:
The presence of several frequencies dictates the use of a broadband device with true root-mean-square response.
For UVR sampling, direct-reading UVR radiometers exist, however, spectroradiometric measurements of UVR source can be used with the S(λ) weighting function to calculate the effective radiance, Eeff. Spectroradiometric measurements are often necessary to collect measurements that are more accurate than those with simple, direct-reading safety meters. Whichever measurement technique is applied, the geometry of measurement is important.
The ICNIRP provides guidance for assessing the sampling data and calculating employee exposure (See Appendix F).
2.3 NIR Source Approval
Prior to the purchase, lease, design, or assembling of any new NIR source, the following must be completed:
An NIR Source Acquisition Form (Appendix B) must be reviewed and signed by the NIRSO. The NIR Source Acquisition Form documents: the type of NIR equipment/source, the use/storage, registration/licensing, risk assessment, and approval requirements.
Once an NIR source is approved, develop a Site Plan.
Examples of NIR sources that will require approval include:
The NIR source of a device or product that will be manufactured or assembled for sale by Microsoft. Note: The final product will need to meet product safety certification requirements per Microsoft policies and programs and national and international laws, regulations and standards.
Test equipment or other sources that emit NIR exceeding specific OELs (i.e., OSHA, ICNIRP exposure limits, or other industry standards).
Test equipment or other sources that emit NIR where the exposure is unknown. Except for the below-referenced excluded sources, the NIR source will require approval and measurement and calculation of the OEL during the risk assessment process.
Examples of sources excluded from NIR approval include typical devices or test equipment such as televisions, computer monitors, commercial devices, unintentional radiators, and visible illuminators similar to commonly distributed products in the market place.
Managers/Supervisors, Program/Project Mangers, Contract Liaisons, Employees and external Staff who are uncertain if a device, product, equipment or other NIR source requires NIR approval should contact the Plan Administrator for further information.
2.4 NIR Source Inventory
An inventory of NIR sources at Microsoft locations must be conducted. An NIR Inventory Form (Appendix C) must be completed and include all sources that require approval.
The Plan Administrator and NIRSO will assess the workplace to develop a current listing of the devices which emit NIR.
2.5 Registration and Licensing
NIR emitting equipment may be regulated through licenses issued by the jurisdictional authority (i.e., state, local or area). Each Site must determine if there are local, state, or area requirements that require licensing and/or registration to operate NIR equipment.
Each site is expected to control OEL of NIR according to local, state/provincial, country-specific (Appendix G), and international levels.
2.6 Safe Work Practices
Safe work practices must be implemented for NIR sources subject to this Program. The following safe work practices are summarized below: signage, employee exposure monitoring, eliminating or controlling hazards, and PPE.
2.6.1 Signage
Signage is required to inform employees of potential NIR exposure and to inform employees of the entry requirements for the area. In order to maintain exposure to below OEL or As Low As Reasonable Achievable (ALARA), signage will be used to restrict personnel access to areas or devices where IR, UVR, RF, MW and ELF exposure exceed the OEL.
All areas that must be restricted due to potential NIR exposure must be posted with a sign to warn personnel of the risk associated with the restricted area.
Appendix D provides guidance on signage requirements.
2.6.2 Employee Exposure Monitoring
Employee exposure to NIR sources or areas must be conducted if exposure meets or exceeds the OEL.
Dosimetry will be conducted for employees who may have occupational exposures that meet or exceed the OEL.
For more information on exposure assessments, please reference the Microsoft Exposure Assessment Program.
Only qualified professionals can perform maintenance activities on NIR emitting equipment and must control energy when working on such equipment in accordance with the Microsoft Hazardous Energy Control Lockout Tagout (LOTO) Program.
2.6.3 Eliminating or Controlling Hazards
If employee exposures exceed the applicable OEL as evidenced by dosimetry or calculation, Supervisors/Managers must reduce the employee exposure below the OEL by utilizing the following hierarchy of controls:
Elimination of the use of the equipment
Substitution of equipment
Engineering controls (e.g., enclosure, shielding)
Administrative controls (e.g., duration of tasks, signage, and training)
Personal Protective Equipment (PPE)
2.6.4 Personal Protective Equipment (PPE)
Before determining the appropriate PPE for the specific task, refer to the Microsoft Personal Protective Equipment Program, and complete the Certified PPE Hazard Assessment.
PPE must be suited for the specific type of NIR (e.g., IR, UVR, RF, MW and ELF). PPE for bright light sources and UVR may include eye protection with filter/shaded or tinted lenses and protective clothing. PPE for RF/MW may include insulated gloves, clothing and shoes.
PPE must be inspected prior to use and worn in accordance with manufacturer requirements.
Complete the Certified PPE Hazard Assessment located in the PPE Program.
2.6.5 Special Populations
If planning a pregnancy, employees with exposures to NIR should seek advice from a physician or other licensed health care provider (PLHCP). If an employee becomes pregnant, she is strongly encouraged to declare her pregnancy in writing to the Plan Administrator. The Plan Administrator can assist in reducing exposures even further. During pregnancy, a woman’s exposure must remain ALARA.
Persons with biomedical devices (i.e., pacemakers, metal implants) should consult with their PLHCPs to discuss any concerns about NIR in the workplace. Employees should contact the Plan Administrator and their Benefits Business Partner with requests for accommodations related to biomedical devices and exposure to NIR.
2.6.6 Training
Each location must train employees and external staff who use or are in proximity of NIR equipment. Training must be provided for:
Personnel and external staff who use NIR equipment at initial assignment.
Retraining for employees and external staff when changes in procedures or work assignments occur.
Retraining for employees and external staff if there is reason to believe they do not possess the required skills, or as a corrective action following an incident or near-miss.
Microsoft OHS has defined training to meet regulatory requirements for personnel and external staff who use NIR equipment.
To obtain training, contact Global OHS.
Any training program must include the following information:
An overview of NIR and hands-on instruction of the applicable Site Plan.
Applicable federal, state, or local regulations.
A review of the hazards associated with NIR.
Summary of the NIR Program and how to access the written Program.
Hands-on instruction in the use of site-specific equipment, including controls (shields and enclosures).
A review of the manufacturer's operating instructions.
Details of the PPE requirements for using NIR equipment.
Requirements for maintaining records of all training, including the name of the instructor, the trainees (names and signatures), the material covered, and the date.
Procedures for responding to and reporting an incident.
2.6.7 Periodic Reviews and Audits
The NIR Program at a Site must be reviewed and audited periodically. At a minimum, the Site Plan must be reviewed every three years or immediately whenever any of the following events occur:
Regulatory change that affect implementation of the program.
Injury/illness/Incident occurs at the site related to exposure to NIR.
Audit, regulatory inspection, or internal suggestion reveals a deficiency in the Site Plan or its implementation at the Site.
During the review, the Plan Administrator or NIRSO should conduct the following activities:
Review the content of the Site Plan and compare with regulatory requirements and requirements in this document.
Review incidents that are related to actual or potential NIR exposures.
Review relevant training records and risk assessments.
Request feedback from managers and supervisors regarding program improvement opportunities.
After each review, the Site Plan must be updated if a deficiency is found.
Audits may be conducted to assess implementation of the NIR program at the Site, compliance with local regulatory requirements, alignment with the requirements of this document, or other needs as determined by the Site.
2.6.8 Injury and Illness Investigation
Work-related injury or illness associated with NIR sources must be reported to the Plan Administrator. Refer to Microsoft Incident Reporting and Investigation Program
The affected employee must report a work-related injury or illness to Plan Administrator via submittal of the Incident Report Form.
Upon receipt of the Incident Report form, the Plan Administrator will review the case and determine the next steps in the investigation of the incident, as required in the Injury and Illness Investigation Program. Supervisors/Managers must notify the Plan Administrator whenever a regulatory agency conducts on-site inspections or inquiries involving employee concerns.
Once the investigation of the incident is complete, communication of the results of the investigation will be shared with those groups with similar hazards or risks.
