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Quantitative Occupational Exposure Monitoring Program

Ontario Operations OH-OEMP-P-01 Version: 5.5 Effective Date: 02/20/2020 Internal Use

1. PURPOSE

The purpose of this document is to define the requirements for conducting quantitative exposure
assessments.

2. SCOPE

This document addresses the development of exposure monitoring strategies to adequately characterize
employees’ potential exposures to airborne contaminants. Obtaining representative and reliable air
monitoring data that may be compared to an appropriate occupational exposure limits (OELs).
Interpreting and reporting the data. Evaluating the risks associated an exposure profile. Lastly,
establishing a periodic exposure sampling strategy and establish exposure action plans.

3. ROLES AND RESPONSIBILITIES

Occupational Health Department (OHD)

The Occupational Health Department develops and administers Occupational Health Programs and
executes the Programs at the operation sites. Responsibilities include:

Program Administration

· Develop and administer the program, validate procedures or acceptable standards for the direct
measurement or sample collection / analysis and the assessment of the data. Procedures and
instructions following from the general requirements will be established in consultation with
representatives of the Joint Health and Safety Committees (JHSC);
· Remain current with respective legislation and regulation and update the program accordingly;
· Provide advice, direction and interpretation of the program;
· Communicate legislative, regulation changes;
· Develop training and educational packages and provide new employee orientation;
· Maintain central records; and,
· Review and report on program performance.

Program Execution

· Prepare an occupational exposure monitoring annual sampling plan and review with the plant
Joint Health and Safety Committee (OHSA section 8.11b, OHSA section 11.1&2);
· Invite a JHSC Worker Representative to be present at the beginning of testing (OHSA section
8.11.b, OHSA section 11.3);
· Provide workers with monitoring results and have results posted in the workplace (OHSA
section 26.f);
· Communicate all personal exceedances to the facility and provide support for investigating
causes and recommending appropriate controls. Coordinate workers’ medical examinations
and clinical tests as required;
· On a monthly basis, present completed sampling results to the JHSC;
· Ensure that all sampling results are appropriately entered Medgate. Consult with internal and
external analytical services on the requirements for establishing and maintaining reliable
analytical procedures;
· Evaluate OEMP data to determine the extent of the hazards and associated risks and
recommend risk control options;
· Consolidate OEMP data and communicate to required and interested parties e.g. Ministry of
Labor;
· Manage the storage of documents and records related to workplace monitoring and support

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supplemental programs in accordance with legal requirements and company policy;


· Report key performance indicators within SHE quarterly report.
· Calibrate and maintain accurate records of all sampling equipment. (Follow manufacturers’
recommended calibration & maintenance procedures.);
· Record all test refusals in Medgate. Information is recorded in Medgate and the ‘VOID’ box is
checked. Enter ‘REFUSAL’ in the ‘VOID REASON’ field.
· Present an annual review of Occupational Hygiene sampling equipment technology to the
JHSC; and
· Minor Element (Reg 854, Mines and Mining Plants, Sec 267) information is gathered annually
and reporting is completed within the Occupational Hygiene Program, Designated Substances
Program and the WHMIS Program.

Plant

Identify and Investigate

· In consultation with the OHD and JHSC, identify the potential physical, chemical, and biological
hazards that may be present in the work areas. Ensure adequate controls are in place to
minimize risks;
· Facilitate workplace and personal sampling; and.
· Investigate all exceedances.

Training and Awareness

· Be aware of hazards in the workplace;


· Provide workers with workplace specific hazard training and proper use and care of personal
protective equipment; and,
· Maintain training records.

Communication and Consultation

· Participate in identifying risk based sampling requirements with OHD and JHSC;
· Inform workers, contractors and suppliers of workplace hazards and controls;
· Consult with JHSC and OHD as required regarding process changes, new products and/or
hazards, trial products, ETC…;
· Communicate legislative and program changes to line management and workers;
· Communicate engineering and/or administrative control changes to JHSC, OHD, line
management and workers; and
· Facilitate biological sampling and medical examination requirements as required.

4. PROGRAM ELEMENTS

Occupational hygiene has been defined as the science and art devoted to anticipating, recognizing, and
evaluating hazards that may be harmful to health, as well as the development of prevention and control
strategies, with the aim of protecting and promoting the health and wellbeing of workers.

Effective risk management is central to Vale’s safety, health (hygiene) and medical programs. In the field
of occupational hygiene, the terms exposure assessment/management and risk assessment/
management are often used interchangeably. For the purposes of this program, “exposure” assessment
and management refer to one half of the risk equation, the likelihood. The other half relates to the toxicity
(severity/impact) of a stressor. It is the combination of exposure and toxicity that determine the level of
risk. Occupational hygiene management encompasses (1) hazard anticipation and recognition, (2)

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evaluation (both qualitative and quantitative), (3) control, (4) monitoring, and (5) communication, as
outlined in Figure 1.

Figure1. Occupational Hygiene Program Overview

Anticipate and Recognize Health Hazards

Characterize the workplace, workforce and health hazards


Follow Management of Change Process

Evaluate Exposures and Potential Risks


Establish a Risk Assessment Strategy
Conduct Qualitative/Quantitative Assessments
Evaluate and Interpret Data

Control Communicate

Manage Exposures and Potential Risks


Hierarchy of Controls
Corrective Actions

Monitor, Measure and Set Targets for Risk Reduction


Collect and report on leading and lagging indicators.
Set targets for risk reduction and develop action plans to track progress

Exposure (and risk) assessment are the heart of the occupational hygiene management program and
provide the foundation for all the elements. Effective assessment leads to informed decision-making,
resulting in an adequately controlled exposure profile for each employee (or group of employees). The
better we understand exposures the more assurance that we have sufficient and appropriate controls in
place. Defining exposures based on similarly exposed groups allows the hygienist to focus worker training
programs, better target medical surveillance programs and define specific requirements for personal
protective equipment.

The process of anticipating, recognizing, qualitatively evaluating, controlling and monitoring health
hazards is outlined in the Occupational Hygiene Program (OH-OHP-P-01). Evaluation, specifically as it
relates to quantitative exposure assessments is the focus of this document. Four aspects of quantitative
assessment will be addressed, including (a) data collection, (b) data analysis, (c) data interpretation, and
(d) data management which are primarily carried out within the framework of a Quantitative
Occupational Exposure Monitoring Program.

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5. DEVELOPMENT OF THE EXPOSURE MONITORING STRATEGY

One of the key objectives of a hygiene program is to accurately assess employees’ exposure to health
hazards, including chemical, physical and biological hazards. This is often completed through the
collection of exposure measurements (e.g. air samples, noise samples, etc.) which provide an estimate of
exposure.

Effective measurement strategies should be developed to provide unbiased sampling results and
sufficient data to represent worker exposure. A measurement strategy should be developed prior to the
collection of any samples and will vary depending on the type of information that is sought, refer to OH-
OEMP-SPI-03 Sampling.

Figure 2 – Exposure Assessment Process

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An appropriate strategy ensures the workforce, workplace and agents are looked at in detail, they are
assessed qualitatively and if applicable quantitatively, assigned to an exposure profile and lastly a
determination for action is outlined such ongoing assessment, periodic assessment, further information
gathering or immediate implementation of control measures (Figure 2).

The monitoring strategy that is used will vary depending on the type of information that is required. The
most frequently applied strategy is random sampling of groups of employees. Worst-case (or
maximum risk) sampling is another method that will be reviewed. Individual sampling surveys will
likely fall into either the random or worst-case strategies. The goal of a survey may be to validate an
engineering control, to demonstrate compliance with an OEL (usually a worst-case scenario
approach), to establish a baseline for an SEG (random measurement approach) or conduct periodic
monitoring (random measurement approach). Each of these may demand a slightly different survey
type.

In cases where it is expected that exposure levels are either well below or well above an OEL, these
situations can sometimes be confirmed by measurement techniques which are easily performed but may
provide less accuracy. Where is it not possible to collect the recommended minimum number of samples
(e.g. infrequent job, short duration process), worst-case sampling may be required. In this case, workers
anticipated of having the highest exposures would be sampled. Worst-case monitoring may also be
required to verify the adequacy of existing or interim control measures, such as respiratory protection. In
cases where exposures are suspected to be close to the OEL, then it becomes necessary to apply more
accurate methodologies to ensure a high degree of confidence in the results and decisions made based
on these results.

This program focuses on a comprehensive exposure assessment approach which emphasizes


characterization of all exposures for all workers on all days (or groups of workers) as opposed to focusing
only on the maximum risk employees to determine whether exposures are above or below the OEL.
There will be instances where this worst-case approach is required for reasons noted above, however
sampling only the perceived maximum employees may skew the data.

The main quantitative assessment types described in this program include;

1) Baseline Assessment - an exposure profile is established and compared to an occupational


exposure limit (OEL).

2) Periodic Monitoring - verify that exposure conditions established in the baseline have not
changed.

3) Worst Case Monitoring - evaluate a control or when only minimal samples can be collected.

6. DATA COLLECTION

A quantitative exposure assessment involves the collection of air and noise samples to determine
whether exposures are acceptable or need to be further controlled.

Prior to sampling, it is important answer the following questions, what to sample, when to sample, how to
sample, who to sample and where to sample.

Refer to OH-OEMP-SPI-03 Sampling.

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7. ANNUAL SAMPLING PLAN

Monitoring plans must be developed on an annual basis for each plant.

The annual monitoring plan will be established based on the baseline assessments requirements (section
8) and periodic sampling requirements (section 9).

Baseline and periodic sampling should be prioritized based on risk level. When similar risks scores exist,
other factors for prioritization include:

i. number of workers exposed;


ii. frequency and duration of exposure;
iii. confidence in the exposure profile; and
iv. severity of the agent.

The plan will indicate the SEGs to be sampled, the agents to be sampled, and the number of samples to
be taken.

A monthly review of sampling results will be presented to the JHSC.

As additional sampling requests are received, a review of the plan will be required to determine priorities.
Adjustments in the plan may be required based on operational changes. Any changes should be made in
consultation with the JHSC.

8. BASELINE ASSESSMENT

8.1. Personal Baseline Assessment

Monitoring is performed to establish an exposure profile for a Similar Exposure Group. Similar exposure
groups (SEG) are groups of workers having the general exposure profile for a specific agent because of
the similarity and frequency of the tasks they perform, the material and processes with which they work,
and the similarity of the way they perform the task (Bullock, 2006). The exposure profile essentially
provides information about the agent(s) present, a picture of the exposures experienced by a group of
employees, including average concentrations and the variability of exposures. If the group is defined
accurately, it can represent exposures for all workers. Once the exposure profile for an agent is
established, it can be compared to an occupational exposure limit (OEL).

Establishing an occupational exposure baseline can be achieved following the assignment of workers into
similar exposure groups and randomly monitoring each group, for each hazard identified. Establishing a
baseline exposure profile involves collecting a minimum number of samples for full-shift or task-based
exposure monitoring. The grouping of workers into SEGs has the practical advantage defining groups of
similar exposures and making interpretations about the group based on results obtained from a subset of
these individuals. This approach risks missing the inclusion of highly exposed individuals from this sub-
population. By applying a statistical strategy, one can ensure that the sample set is representative of the
group. This approach has been incorporated into the sample numbers specified for both baseline and
periodic monitoring in this document.

Baseline assessments must be completed within a 2-year period and the data collected over this 2-year
period will be used for statistical analysis. Due to measurement and statistical error it is unlikely that a
single measurement will give you a true average exposure. A minimum of 6-10 random personal samples
are required to complete the statistical analysis and establish a baseline exposure profilei. There are two
exceptions where a smaller number of samples is acceptable, provided that the data are also from
random personal samples. Refer to the Quantitative Exposure Assessment Decision Tree (Appendix 1) to
determine when 3 random personal samples may be acceptable to establish a baseline exposure profile.

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The number of samples will depend on the size and variability of the data set and the proximity of
exposures to the OEL. As the group size (e.g. >50) and variability increase (GSD>3) the upper boundary
of samples may be required. The same is true as the exposures approach the OEL. The number of
samples required may need to be adjusted based upon increasing risk and uncertainty.

In some circumstances it may be difficult or impractical to implement random sampling (e.g., assessing
non-routine operations). In such instances, every attempt should be made to collect independent
samples that are as close to being “random” as possible.

In those situations where the process, operation, activity, and/or control technology has changed, or there
is a noticeable upward or downward moving trend in the average airborne concentration or GSD,
monitoring should be conducted to re-establish a new baseline to properly characterize the exposure
profile.

Refer to the Quantitative Exposure Assessment Decision Tree, see Appendix 1.

8.2. Area Baseline Assessment

Establishing an area baseline assessment begins with the identification of key sources of contamination
such as fixed plant processes and equipment. The intention to conduct an area baseline assessment is to
provide additional information which relates to factors which may be impacting a SEG as well as ensuring
adequate controls are in place for other personnel entering the work area.

Professional judgement plays a significant role in determining when area monitoring is appropriate and
value added. Area monitoring is conducted at fixed positions and therefore, usually does not accurately
reflect the exposure of individuals. Area measurements can be used in time trend analysis to detect
variation, process cycling, trend control improvements over time, or changes in efficiency of ventilation
controls etc.

Descriptive statistics will be used for area sampling data analysis, trending increases and/or decreases
over time or analyzing the arithmetic mean can also provide insight regarding the sources of
contamination in an area.

9. PERIODIC MONITORING

Following the establishment of a baseline assessment, routine sampling should be conducted to verify
exposures and the effectiveness of controls. As with baseline exposure monitoring, a random sampling
approach should be applied.

In general, more frequent exposure monitoring is required for increased health effect severity, exposure
rating or combination of the two (risk).

9.1. FREQUENCY OF PERSONAL PERIODIC MONITORING AND MINIMUM SAMPLING


REQUIREMENTS

Table 1 and 2 outline the guidance related to the number of samples required and frequency of re-
assessment. These numbers may need to be adjusted based upon the above reasons and sampling may
need to be prioritized.

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For SEGs that have a pre-existing baseline and have been place on periodic monitoring, sampling data
within a 5-year period can be used for statistical analysis. This will improve the accommodation of smaller
group SEG and infrequent monitoring frequencies (Section 12.1).

To determine frequency of monitoring, identify the severity rating of the agent (Table 3) and the exposure
rating based on the exposure data from the baseline assessment (relative to the applicable OEL). Apply
the severity rating and exposure rating to Table 1 below to determine the periodic monitoring frequency.
To determine the minimum sampling number requirements, apply Table 2.

Table 1. Periodic Sampling Frequency

Exposure Rating

Frequent Likely Occasional Unlikely Rare Rare


Severity
Rating 95th≥ 5 X OEL - ≥1 – 5 X
95th 95th≥
50–100% 95th≥
25–50% 95th <25% OEL 95th <10% OEL
TWA/STEL/C OEL - OEL - OEL - -TWA/STEL/C -TWA/STEL/C
TWA/STEL/C TWA/STEL/C TWA/STEL/C
Not required
5 (E) (32) Annually 1 Annually 1 Annually 1 Every 2 years Every 3 years or
Every 5 years 3

Not required
4 (D) (16) Annually 1 Annually 1 Annually 1 Every 2 years Every 3 years or
Every 5 years 3

3 (C) (8) Annually 1 Annually 1 Annually 1 Every 3 years3 Not Required 2 Not Required 2

2 (B) (4) Annually 1 Annually 1 Every 2 years Every 3 years3 Not Required 2 Not Required 2

1 (A) (2) Annually 1 Annually 1 Every 2 years Every 3 years 3 Not Required 2 Not Required 2

1 Annual monitoring is not required in situations where engineering control measures have been identified, planned for, and are in the process of being
implemented. The expectation is that a new baseline will be established following implementation.
2 Exposure monitoring is not required unless indicated by regulatory requirement, by a change in process or work method or indicated by a review of

the qualitative exposure assessment. The rationale for this decision should be documented.
3 If the work environment is reasonably stable, periodic monitoring for Critical or Catastrophic Severity agents can be reduced or eliminated until a

significant change occurs. E.g. 95th% <10% OEL: periodic monitoring every 5 years and/or periodic monitoring not required, based upon professional
judgement.

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Table 2. Minimum Sample Number for Periodic Monitoring.

Required Sample Size for Periodic Monitoring

Number of Employees in SEG GSD of Data Number of Samples

<3 1
1-≤2
>3 2

<3 2
3-≤5
>3 3

<3 3
6 - ≤ 30
>3 5

≤3 7
>30
>3 9
*Modified Damiano & Hewett ii.

Table 3. Severity Categories for agent’s effects to health.

Effects to
Severity Safety Example Agents
Health

Low Concern Calcium, Inhalable Dust, Oil Mist, Respirable Dust,


reversible effects or Incident requiring only Methanol, Gasoline, Acetone, Copper, Magnesium
MINOR (A) (2)
without known first-aid Oxide, Chromium III, Metallic Elemental Nickel,
adverse effects Tellurium, Selenium, Silver, Barium,

Incidents without
Nickel Insoluble (as Pentlandite), Chlorine, Sulfur
MODERATE (B) Reversible effects absence (requiring work
Dioxide, Hydrochloric Acid, Toluene, Aluminum, Iron
(4) causing concern restriction, medical
Oxide, Zinc Oxide, Bismuth,
treatment)

Ammonia, Carbon Monoxide, Nitrogen Dioxide,


Severe reversible Hydrogen Sulfide, Carbon Disulfide, Sodium Cyanide,
SERIOUS (C) (8) Incident with absence
effects Mercury, Cobalt, Oleum, Manganese, Noise,
Phosphorous, Platinum, Formaldehyde

Silica, Asbestos, Arsenic, Lead, Cadmium, Chromium


Irreversible effects
CRITICAL (D) Permanent disabling VI, Elemental Carbon, Nickel Compounds (except
or disabling
(16) incidents or one fatality insoluble as Pentlandite), Sulfuric Acid Mist, Benzene,
disease
Beryllium, Isocyanates (all forms)

CATASTROPHIC Incident resulting in


Life Threatening Nickel Carbonyl, Arsine, Hydrogen Cyanide
(E) (32) multiple fatalities

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9.2. FREQUENCY OF AREA PERIODIC MONITORING AND MINIMUM SAMPLING REQUIREMENTS

Once an area baseline assessment has been completed for key sources of contamination, it is
recommended to conduct periodic area monitoring every 3 - 5 years in the areas/locations where; 1)
contaminants are generated, 2) SEG’s are potentially impacted due to failure of controls, and/or 3) if
significant control changes occur.

Professional judgement plays a significant role in determining when area monitoring is appropriate and
value added.

10. WORST-CASE (OR MAXIMUM RISK EMPLOYEE SAMPLING) MONITORING

Where is it not possible to collect the recommended minimum number of samples (e.g. infrequent job,
short duration process), worst-case sampling may be required. In this case, workers anticipated of having
the highest exposures should be sampled. In this approach, when a qualitative assessment estimates
that an employee’s exposure is likely to exceed an exposure limit the “employee believed to have the
greatest exposure” or maximum risk employee (MRE) is sampled.

In this approach, it was not necessary to sample those employees believed to have lower exposures. This
approach was designed to reduce sampling burden. Selection of the MRE (or group of employees) is a
judgment decision based on information collected in the characterization stage and observation of the
workplace. MRE from different processes should each be selected. Through observation, usually
employees closest to the source would be considered highest exposed (not always the case though so
need to examine air movement patterns). Other factors to focus on include worker mobility, work
practicesiii. The worst-case strategy is directed at ensuring compliance with exposure limits. Although it is
an effective strategy, worst case data do not reflect the magnitude and variation in day-to-day exposures.
Worst case samples also tend to overestimate average exposures and should be used with caution when
interpreting historical exposure data ii. It has also been noted that in many cases, it will be difficult to
determine the worst-case exposure.

Worst-case monitoring may be required in some cases, to verify the adequacy of existing or interim
control measures, such as respiratory protection.

11. DATA ANALYSIS

Statistical analysis is used to determine data accuracy and precision as well as exposure trends. By not
sampling every employee on every occasion, we are making inferences and statistical analysis can be
used to draw conclusions about the samples and assign some level of confidence iii. This program is
designed to use statistical analysis to both develop sampling strategies and to analyze sampling results.
Statistical analysis is not a substitute for professional judgment but is an additional tool used to provide a
better characterization of employee exposure.

Two data distribution types are important to industrial hygienists: the normal and lognormal distribution.
Occupational exposure data tend to be lognormal because: (a) exposure data cannot be less than zero,
which compresses the left tail of the curve and (b) there are usually some “high” results which skew the
curve to the right.

Even though most hygiene air monitoring data are lognormally distributed, it is good practice to evaluate
the data statistically to confirm lognormality. However, in the absence of such an analysis, the lognormal
distribution should be assumed. It is important to note that lognormality may be difficult to achieve with
small data sets (e.g. less than 3 samples) and may result in a higher GSD.

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It is important to verify that the established SEGs have been properly selected. This can only be verified
once sufficient occupational monitoring data has been collected. Moreover, if there has been a significant
change in controls one of two decision need to occur; 1) a new baseline is required or 2) only the data
relevant and representative of the current controls may be used for data analysis.

Prior to analyzing data, it is important to ensure that the data is properly reviewed and sorted. Regardless
of the type of monitoring performed (personal task-based, full-shift, area, etc.), only “like” data are to be
combined to perform statistical analysis. In other words, only data with similar populations, similar sample
types and similar averaging times should be combined for statistical analysis (e.g., segregate similar
duration task-based sample results from full-shift sample results and segregate similar duration personal
sample results from area samples). Short-term exposure monitoring data is typically more variable that
full-shift data, resulting in higher geometric standard deviations. Mixing data with different averaging
times will result in inaccurate estimates of the mean exposure and its variance, and preclude the use of
various statistical tools, and can lead to false conclusions concerning employees’ exposures.

The underlying population being sampled must not change during the exposure assessment period.
Examples of changes in populations that can affect the distribution of exposures include: changes in
process or parameters, work practices, control measures, or performance of engineering controls. The
data can be checked for population stability simply by plotting the monitoring data chronologically by the
monitoring date to see if any trends are apparent.

If there is a significant change over the random sampling period (i.e. change to process, operation,
activity, and/or control technology, expected to affect employees’ exposures to an agent) only simple
descriptive statistics should be applied (AM, GSD, minimum and maximum exposures) and decision
making based on professional judgment should be made regarding reestablishing a new baseline
assessment.

11.1. Collection duration of samples to be used for statistical analysis

The collection duration of samples to be used for statistical analysis is important to ensure that the
appropriate number of samples have been collected over the appropriate duration of time.

Data used for a baseline assessment statistical analysis must be collected within a 2-year period.

Once a periodic monitoring frequency has been established, sampling data within a 5-year period can be
used for statistical analysis. This information is also outlined within section 8 (baseline assessments) and
section 9 (periodic monitoring).

If there has been a significant change in controls one of two decision need to occur; 1) a new baseline is
required or 2) only the data relevant and representative of the current controls may be used for data
analysis.

11.2. Handling Non-Detect Airborne Concentrations

When sample concentrations are less than the analytical method limit of detection, results are reported as
“Non-detected” (ND) or less than “<” the Detection Limit (<DL) or Limit of Detection (LOD).

In order to calculate statistics for a dataset containing non-detectable results, a numerical value must be
assigned to each non-detectable data. A variety of approaches have been developed including
substitution of the ND value with one-half of the sampling and analytical method detection limit (Hewitt).

11.3. Task-Based Samples

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Careful consideration needs to be given to those situations where task-based data have been collected,
but not necessarily consecutively over the course of the shift or on the same worker. In such cases, full-
shift exposure estimates should be based on realistic ‘worst case’ exposure scenarios (i.e., task-based
data) to evaluate the adequacy of control measures (e.g., respiratory protection) for the duration of the
task. In most cases, it can be difficult to collect enough representative task-based samples to conduct
descriptive or lognormal statistical analysis on the data.

11.4. Data Analysis Criteria

The following descriptive and inferential statistics should be used to evaluate airborne concentrations
associated with an SEG’s exposure distribution (or profile), in comparison to the applicable exposure limit.
These different statistics are used to form a more complete characterization of the SEG’s exposure
profile. An overview of these criteria, their applications and limitations are summarized below.

(1) Arithmetic mean (AM)


(2) Geometric Standard Deviation (GSD)
(3) 95th percentile

1) Arithmetic Mean

The arithmetic mean (AM) has been found to be the best measure of cumulative exposure over a
biologically relevant time period (i.e. best measure for chronic hazards). For these chronically toxic
agents (i.e., asbestos, silica, or nickel) health effects are related to an accumulation over a long
time period and transient spikes do not affect the body burden significantly.

The AM is an average exposure estimate that is directly related to the average dose and cumulative
dose. Even though nearly all industrial hygiene data are lognormally distributed, the AM of a
lognormal exposure distribution, and not the geometric mean (GM), is the parameter that best
represents an estimate of the average exposure level.

When the AM is at or near the OEL-TWA or OEL-STEL, a fraction of an exposure profile (e.g. ~
40%) may lie above the OELiv. Therefore, a more appropriate comparison approach is the one-
sided 95% upper confidence limit (UCL) on the AM, denoted as 95% UCL AM. This value can be
calculated and is considered to a more stable statistic for small sample sizes than the variance, or
upper percentiles iv.

Two different comparisons of confidence limits on the AM are typically performed to gauge the
effectiveness of controls to limit employees’ full-shift exposures. The first is direct comparison of
the one-sided 95% upper confidence limit (UCL) on the AM to the applicable OEL-TWA.

Once the 95% UCL AM is calculated, an evaluation needs to be made to compare this value to the
OEL-TWA or OEL-STEL. Individual exposures in excess of the applicable OEL need further
investigation and possibly controlled.

2) Geometric Standard Deviation (GSD)

GSD is the parameter used to relate the variability of the exposure data (i.e. spread and skewness).
Hygiene research supports that most occupational environments will have distributions with GSD
ranging from 1.5 to 3.5. A GSD of less than 2 is considered well-controlled.

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The way that the workforce is defined (i.e. broken down into SEGs) will impact the GSD. The more
similar the groups are in relation to the tasks they perform and the controls that exists the lower the
variability in the data.

GSD ≥ 3.0 is considered out of control or the SEG is poorly defined.

3) The 95th Percentile

The 95th percentile provides a "picture" of the exposure profile's upper tail and is especially
important when evaluating the health hazard of agents with acute health effects or when evaluating
compliance to an OEL (since many of these limits are maximum allowed values that are not to be
exceeded.). It represents an exposure which is greater than 95% of the exposures within a group
(e.g. SEG). 5% of the exposure distribution would be expected to lie above this value. In the case of
an acute agent, the average exposure is not as important as understanding how high the exposure
may get because those few high exposures might pose a more important risk to health than
average exposures at lower levels.

When the AM is at or near the OEL, a fraction of an exposure profile (e.g. ~ 40%) may in fact lie
above the limit. Therefore, consideration needs to be given to the upper tail of the exposure profile
to ensure that exposure is truly controlled below the exposure limit. We have at times, referred to
these as outliers, but they need to be considered as part of the potential exposures. History has
shown that OELs never increase. As new research becomes available they may however,
decrease. By controlling the upper tail of exposure, we are on the safe side relative to any future
findings that the currently OEL is inadequate. This is consistent with most regulatory requirements
and professional standards.

Once the 95th percentile is calculated, an evaluation needs to be made to determine whether the
value is greater or less than the applicable OEL(s) (e.g., OEL-TWA, OEL-STEL, etc.).

12. EXPOSURE MONITORING DATA INTERPRETATION & DECISION CRITERIA

The final step in evaluating the workplace to which a worker is exposed is the interpretation of the
sampling results. During this step, the personal sampling results are compared with the relevant
standards, regulations or guidelines (example: Ontario Reg. 833, 490, 854, American Conference of
Governmental Industrial Hygienist (ACGIH)).

Because the number of measurements are often too small to permit conclusive determinations and most
workplaces are rarely stable (i.e., exposures change due to seasonal changes, production levels vary,
personnel change in role, etc.), experience and professional judgment always play a role in the
interpretation of exposure measurements. There is no substitute for a sound knowledge of the process
and good observational skills. The classification of each work environment as acceptable or unacceptable
requires numerous judgments.

There will always be uncertainty in the estimation of an exposure profile for an individual or exposure
group, particularly if historical or surrogate exposure data are used.

12.1. EXPOSURE PROFILE DECISION CRITERIA

Once an exposure profile is defined, it should be compared to an OEL to determine the acceptability of
the risk level. Separate exposure assessments are required for each OEL (i.e. if there is a TWA and
STEL for an agent with established acute and chronic health effects).

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It is important to understand that no exposure situation is risk-free. Because there are many factors that
will cause exposures to vary, there is always some chance, no matter how small, that an employee will be
exposed to concentrations above a standard. Human variation of response to chemical exposures is
large, individual responses can vary from day to day, and chemical exposure concentrations vary with
time, production, process, and other factors.

Regardless of how simple or complicated exposure assessment strategy decisions may be, there will
always be exceptions and unusual circumstances. Professional judgment must be also used to make
decisions about required action.

All SEG and agent scenarios must be classified as one of the following exposure profile
conclusions:

Qualitative

Ø Qualitative Low Risk (see Occupational Hygiene Program)


Ø Qualitative Medium Risk (see Occupational Hygiene Program)
Ø Qualitative High Risk (see Occupational Hygiene Program)
Ø Qualitative Very High Risk (see Occupational Hygiene Program)

Quantitative

Ø Quantitatively Acceptable
Ø Quantitatively Unacceptable

If an exposure profile cannot be concluded quantitatively (completing the baseline assessment or cannot
establish the baseline assessment) and additional monitoring will be conducted, the qualitative exposure
profile must be assigned and further defined to be under evaluation (continuing the quantitative
assessment).

Refer to the Quantitative Exposure Assessment Decision Tree, see Appendix 1.

Quantitatively Acceptable Exposure Profile

An ‘acceptable’ exposure profile is usually one where such ‘over-exposures’ occur infrequently. The
exposure parameter most often mentioned in the industrial hygiene literature for rating the acceptability of
an exposure profile is the 95th percentile exposure.

An exposure profile is ‘acceptable’ if the 95th percentile is equal to or less than the OEL.

Exposures judged as acceptable should be documented and assessed periodically to verify that the
status remains. Exposures judged an unacceptable must be controlled. Uncertain exposures should be
prioritized for further assessment. Interim controls should be established.

If the substance/agent poses an unacceptable risk, or the risk level is unknown, further action is required.
Hazards that pose an acceptable level of risk will not be addressed further.

In the case the data is not lognormal, a review of the data to determine at least 6 samples have been
collected and if the arithmetic mean is less than 10% of the OEL the exposure profile can be classified as
quantitatively acceptable.

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A minimum of 6-10 random personal samples are required to complete the statistical analysis and
establish a baseline exposure profile. There are two exceptions where a smaller number of samples is
acceptable, provided that the data are also from random personal samples. Refer to the Quantitative
Exposure Assessment Decision Tree (Appendix 1) to determine when 3 random personal samples may
be acceptable to complete a baseline assessment and come to a quantitative exposure profile
conclusion.

In the case the 95th percentile is >25% OEL and <150% of the OEL, collection of at least 6 - 10 samples
must be collected to complete a baseline assessment and come to a quantitative exposure profile
conclusion.

Refer to the Quantitative Exposure Assessment Decision Tree, see Appendix 1.

Quantitatively Unacceptable Exposure Profile

An ‘Unacceptable’ exposure profile is usually one where such ‘over-exposures’ may occur periodically.
The exposure parameter most often mentioned in the industrial hygiene literature for rating the
acceptability of an exposure profile is the 95th percentile exposure. There is general agreement that an
exposure profile is ‘Unacceptable’ if the 95th percentile is equal to or greater than the OEL.

A minimum of 6-10 random personal samples are required to complete the statistical analysis and
establish a baseline exposure profile. There are two exceptions where a smaller number of samples is
acceptable, provided that the data are also from random personal samples. Refer to the Quantitative
Exposure Assessment Decision Tree (Appendix 1) to determine when 3 random personal samples may
be acceptable to complete a baseline assessment and come to a quantitative exposure profile
conclusion.

In certain cases, a quantitative exposure profile conclusion cannot be made and therefore additional
samples may need to be collected to acquire the data necessary to complete the baseline assessment,
and therefore would remain under evaluation. When a SEG and agent scenario remains under
evaluation, a qualitative exposure profile conclusion must be made.

Refer to the Quantitative Exposure Assessment Decision Tree, see Appendix 1.

Under Evaluation (Quantitative Assessment)

When attempting to complete a baseline assessment and the GSD is greater than 3, with 3 or less
samples taken no quantitative conclusion can be made. Also, the data may not be lognormal which does
not allow the 95th percentile to be used. Lastly, significant data variability and/or significant less than
detectable results will affect the distribution and GSD which can impact the ability to come to a
quantitative conclusion.

Under these conditions a review of the SEG for the similarity of tasks, frequency of tasks, materials and
process and way of performing tasks to ensure the SEG is properly classified.

Additional data will need to be collected to complete the baseline assessment. The collection of additional
samples (6-10 samples) may be required to further refine the SEG and reduce data variability.

If more than 6 sample have been collected in the attempt to complete the baseline assessment and
because of the data distribution is not being lognormal, a quantitative conclusion cannot be made.

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Continue to collect additional samples for this SEG and continue with ongoing review and interpretation of
the data. If quantitative conclusions cannot be made, a review of the SEG for the similarity of tasks,
frequency of tasks, materials and process and way of performing tasks to ensure the SEG is properly
classified., include details in comments section of the exposure assessment. Add task SEG line items if
deemed required and proceed with monitoring tasks (may not be able to establish baseline since tasks
can be infrequent and short in duration).

Refer to the Quantitative Exposure Assessment Decision Tree, see Appendix 1.

12.2.AREA MONITORING DATA INTERPRETATION

Descriptive statistics will be used for area sampling data analysis, trending increases and/or decreases
over time or analyzing the arithmetic mean can also provide insight regarding the sources of
contamination in an area.

Recommendations for Respiratory Protection will be required following area sample elevations (compared
to the OEL). Additional samples may be required to validate concentrations.

Removal of respiratory protection required areas/locations must be evaluated to ensure controls are
sustainable prior to removal of respiratory protection requirements. The collection of a minimum of 3
random samples, representative of the conditions and must be collected over a period of time to ensure
that controls are sustainable and maintained. All samples must be below the respective and applicable
OEL’s.

12.3.COMPLIANCE WITH OCCUPATIONAL EXPOSURE LIMITS AND INVESTIGATION OF


OVEREXPOSURES

Refer to OH-OEMP-SPI-02 Exceedances of the Exposure Limit in the case of personal, area or task
exceedances of the OEL.
All OEL’s are modified in accordance with the applicable shift length in accordance with local regulations.

(a) Compliance with Time Weighted Average (TWA)

When determining the eight-hour time-weighted average exposure concentrations, the test
duration should be as close to a full shift as possible. This can be done as one sample or as
several samples in sequence. A shorter sampling time may be used if the results reflect
representative exposure levels. For example, if conditions are uniform thought the entire
work-shift, a two-hour sample might provide an accurate indication of exposure for that shift. If
shifts are longer than eight hours, the relevant standard must be recalculated, because the
total time exposed is increased (see Appendix 1 for calculation for extended shifts).

Recommendations for respiratory protection will be required following area monitoring


elevations (compared to the OEL). Additional samples may be required to validate
concentrations.

(b) Compliance with Short Term Exposure Limit (STEL)

When determining compliance for contaminants with a 15-minute short-term exposure limit,
15-minute samples should be taken when worst case conditions exist.

When analysing datalogger data, peaks are considered one-minute averages not instantaneous
readings.

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(c) Compliance with a Ceiling Exposure Limit (CEL)

When determining compliance for contaminants with a ceiling exposure limit, samples should be
taken under worst-case conditions using a grab sampler or instantaneous monitor. For peak
exposures, comparisons must be made to the applicable Ceiling Value (OEL-C) or
appropriate excursion limit. In other words, the maximum airborne concentration should be
compared to the OEL-C or excursion limit.

Note: In some areas, the levels of a hazardous substance may vary so greatly that a
combination of both long-term and short-term sampling may be necessary to allow a
complete exposure picture to be obtained.

When analysing datalogger data, peaks are considered one-minute averages not instantaneous
readings.

(d) Compliance with Excursion Limit

All applicable excursion limits apply as outlined in Regulation 833. Action must be initiated
in on TWA, STEL, CEL or excursion limits exceedances or elevations.

When analysing datalogger data, peaks are considered one-minute averages not instantaneous
readings.

12.4.EXPOSURE ACTION PLAN

The Quantitative Occupational Exposure Monitoring process is focused on the development,


implementation and evaluation of effective and sustainable controls through the implementation of plant
level exposure action plans. The implementation of the exposure action plan has one goal in mind,
reduce the number of employee’s exposed to concentrations greater than the OEL. This is for all
exposure profiles that are deemed “unacceptable”.

For every unacceptable SEG, conduct a root cause analysis (5-WHY), identify 1 - 2 controls per
unacceptable SEG that; 1) impacts the root cause of over exposure, 2) will significantly impact the
exposure to workers, 3) will significantly impact the greatest number of workers. Controls must be an act,
object, or system (ICMM) and focus on the control hierarchy via elimination, substitution or engineering
controls. If an administrative control is selected, a minimum of 2 administrative controls per unacceptable
SEG must be committed and implemented.

Exposure Action Plans are to be developed with the plant JHSC. All agreed upon action items must be
summarized in a tracking sheet (including action item descriptions, people who are responsible and
deadlines for completion). Exposure Action Plan status must be review monthly with the plant JHSC.

When establishing actions, it is recommended to review and identify existing controls. Often controls are
already identified within existing company documents such as internal risk assessments, internal
maintenance procedures and standard operating procedures and legislation that may contain general
control advice. Secondly, identify potential new controls which may positively impact the likelihood of
exposure. Outline each control and determine if the control meets the following requirements to ensure
the control is effective and sustainable. A control is an act, object (engineered) or system (combination of
act and object) intended to prevent or mitigate an unwanted event and is performance specified,
observable, measurable and auditable (see Figure 3).

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Following the completion or implementation of significant controls, this may warrant a new baseline
assessment for the SEG to confirm if the controls were effective to reduce the likelihood of exposure.

SEG can be removed from an Exposure Action Plan if the new baseline assessment is completed and the
SEG is determined to have a Quantitative acceptable exposure profile. SEG should remain on the
Exposure Action Plan until all outstanding actions have been completed or finalized.

12.5.RISK ASSESSMENT

The outcome of the exposure assessment process should feedback into the overall risk assessment
process. By combining the likelihood of exposure with the potential severity of the agent, a relative risk
rating can be defined. The relative risk rating (i.e., Very Low (≤ 16), Low, Medium, High or Very High)
shall be determined as a function of the health effects rating for the agent, the exposure rating, the
controls in place, and the adequacy and/or effectiveness of these control. The results of the risk
assessment can be used to define periodic monitoring requirements and to prioritize further data
collection and the implementation for controls.

When utilizing personal exposure monitoring data to assess the Risk of exposure to a contaminant, the
likelihood table below can be used to determine a likelihood of exposure rating. Following the collection of
data, it can be analyzed statistically to determine the 95 th percentile which is a determination of the
likelihood of exposure, refer to table 1.

When utilizing data collected during task related work or personal data that is conducted infrequently, the
95th percentile of the exposure data and the frequency of when the task is conducted e.g. annually, could
be used to determine the probability of exposure if the data is available, refer to table 5. This typically
applies to maintenance occupations and/or contracted out work that is required irregularly.

When assigning severity category to an agent, it must be assigned based on the agent’s effects to health,
refer to table 3.

Table 5. Probability (Frequency of Exposure X Likelihood of Exposure)

DAILY WEEKLY MONTHLY QUARTERLY ANNUALLY

95th%<25% Rare (2) Rare (2) Rare (2) Rare (2) Rare (2)

95th%25-50% Unlikely (3) Unlikely (3) Unlikely (3) Rare (2) Rare (2)

95th%50-100% Occasional (5) Occasional (5) Occasional (5) Unlikely (3) Unlikely (3)

95th%>100% Likely (8) Likely (8) Likely (8) Occasional (5) Unlikely (3)

95th%>500% Frequent (13) Frequent (13) Likely (8) Occasional (5) Occasional (5)

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13. HEALTH SURVEILLANCE

Health surveillance is the ongoing systematic collection, analysis, and dissemination of exposure and
health data on groups of workers where the risk of exposure is present and the initiation of health
surveillance is sensible to protect workers’ health.

Health surveillance protocols by agent/contaminant outlining the type and frequency of medical
examinations/clinical tests will be define by Vale’s medical director and documented by Vale’s
occupational medicine service provider.

Eligibility for health surveillance will be defined as similar exposure groups with a Quantitatively
Unacceptable Exposure Profile (see section 12), employees defined to the applicable similar exposure
groups will be eligible to participate in health surveillance (if applicable for the specific
agent/contaminant). There may be other occurrences of exposure which may warrant the need for health
surveillance that do not align with this eligibility criteria, these will be reviewed on a case by case basis to
determine eligibility.

14. RECORD KEEPING AND MANAGEMENT

All Occupational Hygiene data must be maintained in the exposure monitoring database (Medgate). The
documentation is needed to demonstrate that:

• work has been conducted in accordance with professional standards;


• legislation compliance has been met;
• trend analysis; and
• Support WSIB claims management.

The Annual Plan Worksheet shall be used to summarize the analysis of data and statistical information
gather from such data as well as outline the exposure profile, periodic monitoring frequency, number of
samples planned for the year and outline if an Exposure Action Plan is required for the SEG. The
quarterly summary and sample summary must be kept up to date for reporting purposes.

All personal sampling results must be recorded in the Medgate Database under sample type as ‘Personal’
if representative of the full shift or ‘Task’ if the monitoring was conducted during the task only.

All area sampling results (which represent where workers are located) must be recorded in the Medgate
Database under sample type as ‘Area’.

Source sampling data must be entered into the Medgate Database under sample type as ‘Source’.
Source samples are like area samples, but would usually be located where you would not normally expect
to find a worker in this area. This sampling technique is mostly used to measure the effectiveness of
engineering controls.

All workers who have refused to be monitored must be recorded in Medgate. Enter the information
pertaining to the refusal and ‘void’ the sample with ‘Refusal’ as the reason.

All personal and task samples must have a SEG assigned as the “Exposure Group” to the sample in
Medgate. This will ensure additional ease when running reports to conduct statistical analysis of the
data. These SEG’s and SEG numbers should also be reference in the Annual Plan Worksheet.

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The appropriate sample method must be chosen when entering a sample into Medgate. This will
ensure that the results are being compared to the appropriate OEL. The options are TWA, TWA10,
TWA12, STEL, and CEILING. Area samples are simply a measure of the concentration and must be
entered as TWA. The result will then not be compared to an adjusted OEL for extended shifts. In
addition, Medgate will ‘compress’ a sample greater than 8 hours into an 8- hour TWA equivalent.

All samples must be ‘APPROVED’ after the information in the sample and the uploaded results have
been verified as correct.

Contaminants inadvertently entered a sample must be removed. Otherwise, any reports generated will
indicate the substance with blank results.

Accurate records must be kept for the proper interpretation of sampling results. The following are
examples of some of the data that must be recorded:

• Date
• Sample Type
• Total time sampled
• Pump Flow rates – start and finish
• Location
• Name of worker
• Controls (Engineering, Admin, PPE, Work & Hygiene Practices)
• Observations of work practices
• Description of the process
• Other processes

A sampling form is available which captures all the above information.

15. COMMUNICATION AND CONSULTATION

Disclosure of Information

Employees that participate in personal industrial hygiene sampling must receive a report detailing the
sampling results with comparison to current occupational exposure limits.

Posting of Sampling Results

Personal and area sampling data shall be posted by the employer, as soon as the results are
available, in a conspicuous place or places at the workplace where they are most likely to come to
the attention of the workers, for a period of fourteen days.

Summaries of Results

Summaries of each set of personal and area monitoring results shall be communicated as they
become available and will also be presented at monthly JHSC meetings. Annual Monitoring Plans
will be prepared in consultation with JHSC and presented annually to the JHSC. These summaries
must include such information as, the contaminant, exposure group, and exposure incidents by
sample types.

Posting for Hearing Protection

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Those areas that exceed 85 dBA must be posted as single (muff or plugs) hearing protection area. If
area noise levels exceed 105 dBA, then these areas must be posted as double (muffs and plugs)
hearing protection.

Posting for Respirator Protection

Areas that require the mandatory wearing of respirators must be posted. These areas would
normally be those areas having concentrations of contaminants at or above the Occupational
Exposure Limit. The results or data used to identify these areas represent concentrations of the
contaminant and are not representative of personal exposures.

16. TRAINING

The Occupational Health Department (OHD) will provide periodic training (as specified) and program
review to site supervision and training personnel.

The OHD will provide an annual review presentation of workplace sampling equipment technology
to the JHSC.

17. EMERGENCY RESPONSE PROTOCOLS

Occupational exposure and workplace sampling may be required in the event of a plant emergency
such as fire, chemical spills or fugitive emissions. Procedural instructions have been developed to
provide guidance for sampling in such events.

• Possible impact on fresh air supply to underground mine operations;


• Ambient air contaminant sampling (gases); and
• Release of asbestos fibers.

18. PROGRAM AUDIT AND EVAULATION

The OHD will conduct annual self-audits to determine whether the elements of the program have
been implemented in accordance with established procedures, and where these procedures have
been effective in achieving their goal.

19. REPORTING LEADING AND LAGGING INDICATORS

Reporting must be organized by Ontario operations and by GM managerial area (e.g. Mines,
Milling and Smelting, Refining, Production Services and other Service Groups).

15.1 LEADING INDICATORS

1. Report on the number of similar exposure groups.


2. Report on the number of similar exposure groups and agent scenarios identified.
3. Report on the number of employees assigned to each scenario identified.
4. Report on the number of exposure profiles that have been evaluated qualitatively low,
medium, high and very high.

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5. Report on the number of exposure profiles quantitatively acceptable and unacceptable.


6. Report on the number of exposure profiles actively under evaluation and/or assigned to
periodic assessment.
7. Report on the number of exposure actions plan items committed to, initiated and
completed.
8. Report the number of samples scheduled for the year (e.g. personal and area samples).
9. Report on the number of samples collected (include personal, area and task).

15.2 LAGGING INDICATORS

1. Report number of samples that were planned versus unplanned.


2. Report number of samples that were unplanned.
3. Report on monitoring schedule forecast and completion.
4. Report the number of occupational exposure limit (OEL) exceedances.

Appendix 1 - Quantitative Exposure Assessment Decision Tree

Microsoft Word
Document

REFERENCES:
i
Hewett, P.: Industrial Hygiene Exposure Assessment - Data Collection and Management.
Chapter 15 in Handbook of Chemical Health and Safety. Alaimo, R.J. (editor), American
Chemical Society; Oxford University Press (2007).

ii
Damiano, J. Quantitative exposure assessment strategies and data in the Aluminum Company
of America. Appl Occup Environ Hyg 10, 289-298 (1995).

iii NIOSH (1977). Occupational Exposure Sampling Strategy Manual. US Department of Health,
Education, and Welfare. National Institute for Occupational Health and Safety.

iv
Jahn, SD (Editor) (2015). A Strategy for Assessing and Managing Occupational Exposures, 4th
edition. American Industrial Hygiene Association.

GENERAL REFRENCES:

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American Conference of Governmental Industrial Hygienists


Canadian Association for Environmental Analytical Laboratories
Fundamentals of Industrial Hygiene, 5th Edition, National Safety Council
Hearing Conservation Program
Occupational Health and Safety Act & Regulations 833, 490, 854
Respiratory Protection Program
OH-OEMP-SPI-02 Exceedance of Occupational Exposure Limits
British Standard. (1996). Workplace Atmospheres – Guidance for the Assessment of Exposure by
Inhalation to Chemical Agents for Comparison with Limit Values and Measurement Strategy, Report #:
BS EN 689:1996.

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