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1ST EDITION E-BOOK

7 Steps to
Industrial Hygiene Success

www.EHS.com
Contents

The Changing Face of Industrial Hygiene.................................................................................................................................3

The IH Program Management Cycle............................................................................................................................................3

STEP 1: Similar Exposure Groups (SEGs): The Foundation for a Great IH Program....................................................4

STEP 2: Q
 ualitative Exposure Assessment (QEAs): Essential Risk Assessment Methodologies for
IH Program Management...............................................................................................................................................5

STEP 3: Sampling Plans: Moving Beyond Compliance........................................................................................................8

STEP 4: Lab Analysis – Uncovering Hidden Gems of Efficiency........................................................................................10

STEP 5: IH Data Analysis: Defining Your Goals and Selecting the Best Metrics...........................................................12

STEP 6: Medical Surveillance: Strengthening Your Last Line of Defense for Worker Health..................................14

STEP 7: E valuating and Communicating Performance: The Keys to Engagement with Your IH Program........15

The Value of VelocityEHS IH Solutions........................................................................................................................................18

© 2001-2022 VelocityEHS  | 7 Steps to Industrial Hygiene Success 2 of 18


The Changing Face of Industrial Hygiene
There’s a growing trend I’ve noticed in recent years of companies downsizing or even
eliminating their in-house IH professionals and placing greater reliance on EHS generalists and
third-party consultants to manage their IH programs. Maybe the previous IH manager retired
or moved on, and now management is looking to you to run your company’s IH program. If
this sounds familiar, you’re not alone.

For non-IH professionals just stepping into the role, it can be intimidating. No bones about it,
IH is a scientific, highly technical discipline that relies on complex calculations and exposure Dave Risi, CIH, CSP
Principal Solution Strategist
data to drive critical decisions about workplace health and compliance. Even if the previous IH
for IH | VelocityEHS
program manager maintained organized data and records, where do you even begin?

For seasoned IH professionals still in the program management role, you might be struggling with how to maintain
and improve IH program performance in the face of dwindling staff and resources. You might also be wondering what
IH program strategies and best practices are out there today to help you lighten your load, reduce costs and boost
program performance.

This e-Book is a compilation of some of the most valuable insights and best practices I've gathered over more than 30
years as both a Certified Industrial Hygienist (CIH) and developer of IH software technologies. It’s intended for both the
seasoned IH professional and those new to IH program management, and offers a unique, outside-the-box approach
to IH program management that will not only help you focus and refine your program, but help you minimize program
costs, simplify compliance and improve the health of your workers.

I hope you’ll enjoy.

The IH Program Management Cycle


There are many moving parts to an effective IH program. Similar
1. Similar
exposure groups (SEGs), qualitative exposure assessments (QEAs), Exposure
Groups (SEGS)
sampling plans, lab analysis, data analytics and reporting systems,
medical surveillance and program evaluation processes all deserve
7. Evaluang & 2. Qualitave
equal focus, and should be carefully coordinated to ensure Communicang Exposure
optimum IH program performance. Performance Assessment

In reality, though, many IH’ers unfortunately manage their IH


program elements in silos, without much thought for how each
element functions in relation to the others. We need to shift our
thinking about IH toward a more holistic, process-based approach
where IH program elements are interdependent, and improvements 6. Medical 3. Sampling
Surveillance Plans
in one area support improvements across the entire program.

That's why we've created the IH Program Cycle to provide a simple,


process-based model that IH professionals at any level of expertise
can apply to IH Program Management. Not only does it offer a
sequential, common-sense approach to IH, it embeds the principle 5. Data
Analysis
4. Lab
Analysis
of continuous improvement into the IH program itself. Each time we
run through the process, the information and insights gained from
our previous runs can be systematically incorporated into the program.

In the following sections, we’ll take an in-depth look at each of the seven IH program elements and give you, the reader,
practical guidance on how to build, maintain, refine and integrate those elements to form a highly effective IH program.

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By grouping workers based on similar exposure, you’ve
STEP 1 already dramatically reduced your risk assessment and
sampling efforts by focusing on these 5 groups, rather than
on all 250 employees individually.
Similar Exposure Groups (SEGs):
The Foundation for a Great Why Are SEGs Important
IH Program Quite simply, SEGs are the foundation for your IH program.
Once established, they offer a more convenient, easier-
Numerous OSHA Standards and other workplace exposure to-understand visualization of workplace job tasks
standards require companies to evaluate the health risks of and operations, and their associated exposure risks.
their workers, and ensure they are controlled to a safe level. Additional benefits include efficiency, reduced complexity,
These evaluations are most commonly performed through and better communication.
qualitative risk assessment (QEA), or through quantitative
measures such as air monitoring/sampling of individual Efficiency
worker exposures. Perhaps the greatest advantage of SEGs is that they allow
you to optimize your sampling activities by using data from
But there's a problem: how can a company expect to
a relatively small number of samples from the exposed
accurately evaluate and manage workers’ health risks when
population to accurately predict exposures across a wider
they have 100, 1,000, or 10,000 employees? Performing risk
population of workers. The information can also be used to
assessments and sampling on each individual worker would
compare exposure risks with related SEGs at other locations.
be far too time consuming and costly, exceeding even the
largest of IH program budgets. So, how do we evaluate Once a SEG’s baseline exposure is established, the information
workplace exposures and ensure the health of all workers, allows you to more effectively allocate and prioritize exposure
while making the most efficient use of our time and resources? monitoring and control efforts, ultimately saving you
significant amounts of time and resources.
SEGs are the answer.
Reduced Complexity
What Are SEGs? SEGs can also be used to better manage risk profiles for
Similar exposure groups (SEGs) rely on the principle of workers who perform a variety of job tasks throughout the
grouping workers into job profiles and assessing the health day and may be exposed to multiple workplace stressors.
risks to those workers based on the assumption of similar For example, the average exposures for a shift (8-hour TWA)
exposure conditions. SEGs are commonly defined using any can vary widely depending on the time spent performing
combination of exposure conditions, including: specific tasks. Identifying SEGs for specific tasks provides
high-resolution visibility of which tasks present exposure
• Location • Task risks, which then provides a more accurate determination
• Job • Equipment used of what controls, if any, need to be implemented.
Let’s work through an example to help illustrate the steps in Better Communication
grouping workers into SEGs.
Creating SEGs also helps to facilitate greater transparency
Say that our Houston Refinery has 250 employees who work as and continuity of your IH program. In the past, IH programs
Operators, Administrative Staff, Maintenance and other key job relied heavily on the professional judgement or experience
roles to operate the plant. Following a facility tour and detailed of a seasoned IH professional. Over the years, these IH pros
discussions with experienced EHS professionals at the plant, became increasingly familiar with the jobs and tasks that had
we find that only 5 groups of workers have any significant the highest exposure risks, and they simply knew where to
exposures. These 5 groups are identified and formed into SEGs. prioritize their sampling and assessment activities.

Unfortunately, this cumulative knowledge was not well


documented, and existed as a loose collection of sample data
and other records stored in spreadsheets or simple database
software. As IH professionals retired or transitioned away from
the role, incoming IH managers would have to painstakingly
analyze the data to figure out the status of the IH program,
including what sampling was being done, why it was being
done and where exposure risks existed.

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Creating SEGs enables continuity and transparency of the For instance, SEGs in most manufacturing environments can
knowledge gained through those years of experience— be characterized by a combination of location, job and task,
knowledge that can be easily transferred and referenced by while other industries may not require all of these attributes.
the new IH manager or EHS professional now responsible for
IH program management. Industries with highly distributed work sites, like oil and gas
pipeline transmission, typically don’t need to assign a location
When communicating the exposure risks to workers or to their SEGs. Table 1 on page 6 below includes an example
management, remember that they will prefer to have the data of a Pipeline Operator performing a blowdown of a pipeline
summarized by the job profile or the tasks being performed. containing crude oil. The potential for exposure to noise
This also enables controls to be specified at the job or task and benzene during this task is consistent regardless of the
level. For example, all Operators conducting liquid sampling in location, so it does not need to be specified. This will save you
Unit 1 should wear ½ mask respirators. Controls applied at the from having to perform air monitoring at every location where
SEG level protect all workers performing the job/task, rather the operators perform blowdown procedures on the pipeline,
than just the individual worker that was sampled. and it can help minimize the number of SEGs you ultimately
need to create.
Lastly, one of the greatest benefits of developing SEGs is
to have a consistent characterization of the workplace and If you are feeling overwhelmed by the number of potential
identify any groups of workers that have a potential for SEGs at your facility, you can break the process up into
overexposure. So, when the IH manager with 30+ years of different phases. A common approach is to start with full shift
experience and knowledge at that plant retires, they can exposures (i.e., no tasks, all full shift TWAs), then identify the
hand over the keys with all of that knowledge documented task, then maintenance activities. I have seen companies take
in a manner that can be easily used and managed. this approach until they are confident they have appropriately
assessed the full shift exposures. In reality, it may take a year
How Do I Create SEGs? or two to expand the scope of your SEGs to include tasks and
Many EHS professionals hesitate to define their SEGs without maintenance activities.
a lot of supportive quantitative sampling data. I believe this is
Again, the most important step is to just begin this process,
the wrong approach, and actually subtracts from the benefits
and continuously improve your SEGs over time. Rome wasn’t
of creating SEGs.
built in a day, and neither is a highly effective IH program.
Don't worry about being 100% accurate when identifying your
SEGs on your first go-round. Like the IH Program Cycle itself,
identifying your SEGs is an iterative process that takes time to STEP 2
fine-tune. The most important thing is to just get started. Start
developing your SEGs by first observing the workers at your
site and asking questions like: Qualitative Exposure Assessment
• What common jobs/roles are workers placed into? (QEAs): Essential Risk Assessment
(e.g., Operator, Maintenance, Electrician, Pipefitter) Methodologies for IH Program
• What tasks do they perform that create potential health Management
risks/exposures? (e.g., welding, liquid sampling, opening Once you have established your SEGs, the next step is to assess
vessels) the exposure risks to them. The industrial hygiene profession
• Are there different methods or equipment used for uses the term qualitative exposure assessment, or QEA, for
similar tasks that affect the exposure risks? (e.g., open performing a risk assessment for industrial hygiene concerns.
versus closed systems, new versus old equipment that hasn’t
been properly maintained) What Are QEAs?
• What stressors are the workers potentially exposed to at QEAs are simply an estimation of the potential health risks
their jobs or during the tasks? (e.g., noise, benzene, for each SEG. Some of your SEGs may have sampling data
asbestos, lead) to help you with quantifying exposure risk, while others
will have no hard data and require you to determine risk
If you’re familiar with your site and know the operations well, levels through other methods, including using your best
you can build an initial list of SEGs even before you go out professional judgement!
into the work environment. If you don’t have that degree
of familiarity, you will need to spend more time directly QEAs have been done informally since the 1950’s and were
observing the workers at your site. Remember, the goal is to formally recognized when AIHA published their first version of
get started, not to be 100% accurate on your first attempt. “A Strategy for Occupational Exposure Assessment” in 1991.

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Table 1: Examples of SEGs for various industries

Industry Location Job Task Equipment Stressors


Oil & Gas N/A Operator Pipeline Blowdown – Crude Noise, Benzene
Chemical Atlanta Plant - Unit 1 Operator Sampling – Liquid Benzene
Pharmaceutical NJ Plant – Manufacturing Area 01 Formulation Technician Blending Apex Mixer Isopropyl Acetate, API-2
Manufacturing Dayton Plant Painter Spray Painting Paint Booth 22A Toluene
Respirable Dust, Silica,
Mining/Metals Plant-Primary Crusher Plant Technician Routine Duties
Noise

Since then, AIHA has published several updates to the text It provides you with a more extensive risk profile compared
and QEAs are now widely considered a best practice for to sampling only the higher-risk SEGs.
industrial hygiene around the world.
Prioritization
The ultimate result of performing QEAs is a risk rating Once completed, QEAs make it easier to identify SEGs that
that can be used to prioritize resources for IH sampling, require additional investigation and monitoring. SEGs with
implementation of controls and inclusion of workers in sufficient data and a high degree of confidence showing
medical surveillance programs. QEAs can also help you they do not require a significant investment in additional
identify high-risk potential exposures that require immediate monitoring can be more effectively prioritized.
corrective actions, rather than taking the time and effort to
perform IH sampling and waiting for analytical results to Improved Communication
be returned from the lab before you implement controls to QEAs ultimately help you create a well-developed risk
protect worker health. matrix that standardizes risk visualization across disciplines.
They also provide a valuable tool to show workers and
In this section, we’ll cover several of the most common management your IH program activities and the value they
methods used to perform QEAs and help you set up a bring to the company.
simple risk matrix report that can be used to easily prioritize
exposure risks and communicate those risks to workers Litigation Support
and management. Well-documented QEAs, along with other IH program
information, provide faster access to supporting data without
QEAs as Part of Your IH Program needing to recall files from storage or spend weeks going
If SEGs are the foundation of a good IH program, QEAs are through old reports if requested by regulators or stakeholders.
the actionable insights which drive your IH program forward.
Once performed, they provide a comprehensive and visual Knowledge Transfer
breakdown of the potential risks in your workplace so you QEAs provide a great way to capture the knowledge gained
can get to the important work of protecting your people. through your EHS professionals’ years of experience and
integrate that knowledge into your IH program for future
Here are some of the greatest benefits of performing QEAs: IH leaders.

Simplicity How Do I Perform QEAs?


QEAs do not need to be complex, rely on complex models or Refer back to our example population of 250 workers at the
require a strong knowledge of statistics. With training, QEAs Houston Refinery, where we've already assigned workers to
can be performed by EHS staff with even limited IH expertise. similar SEGs. Then take the following steps:
Quicker and Cheaper Step 1: List any significant stressors for each SEG.
Sampling to quantify each potential exposure to each worker How do you identify what potential stressors should be listed?
could take years and be prohibitively expensive. QEAs enable Sources for this information include:
even the smallest of IH budgets to pack a punch, accurately
and comprehensively assessing risks in a fraction of the time • Walk-through surveys
and cost.
• Interviews with workers and other knowledgeable personnel
Comprehensive • Chemical inventories & SDSs
QEAs provide a tool to quickly document all potential • Previous sampling data collected
exposures, including those with minimal exposure risks. This
• Injury/illness recordkeeping logs
is commonly known as “negative exposure documentation.”

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Table 2: Similar Exposure Groups (SEGs)

Location Job Task Stressors


Alky Unit Operator Routine Work Duties Noise, Hydrofluoric Acid
Coker Unit Operator Routine Work Duties Benzene, Hydrogen Sulfide
Maintenance Pipefitter Welding Iron, Lead
Maintenance Maintenance Technician Gasket Replacement Asbestos
Reformer Unit Operator Routine Work Duties Noise, Benzene
Reformer Unit Operator Liquid Sampling Noise, Benzene
Tank Farm Operator Gauging Benzene

Once you have gathered this information, list all of the Step 3: Conduct Your QEAs
potential stressors for each SEG. An example of this is shown Break up Table 2 so each SEG and stressor are listed in a
in Table 2 above (this should be familiar from our previous unique row. Then, add columns for your Exposure Rating
section on SEGs). and Health Effect Rating variables, and one column for the
calculated Risk Rating. Table 3 on page 8 below shows how
Step 2: Define Your QEA Strategy/Formula to apply the AIHA strategy for the SEGs identified in the
After 30 years in the field of IH, I have seen some companies Houston Refinery example.
spend years perfecting their QEA model. Some spend a lot
of time modeling their QEAs around variables such as Based on information in Table 3, we see the highest risk is
frequency, duration, control technology factors, vapor benzene exposure during liquid sampling by Operators
pressures and even particle size distributions. These can at the Reformer Unit, while the lowest risks are benzene
be useful variables, but most companies do not have the exposure to Operators at the Coker Unit when performing
resources or expertise to be that thorough, especially when routine work duties.
just beginning their QEA program.
Step 4: Display Your QEA Data in a Risk Matrix
Just like when setting up your SEGs, you need to avoid The QEAs in Table 3 contain a lot of great data but are
“analysis paralysis” and just start the process. After you’ve not recommended for use when presenting QEA findings
established your baseline assessments and ultimately to workers or management. Let me explain: it can easily
accumulate years of data to help validate your model, you become overwhelming and confusing when applied to a site
may find it necessary to change your QEA model by adding containing 50-100 rows of QEA data. Instead, we recommend
additional variables that provide an even more precise summarizing the data using a standard risk matrix.
assessment. Until then, start simple.

AIHA has developed a simple model that we recommend


to our customers when they initiate their QEA programs.
The formula is:

Risk Rating = Exposure Rating x Health Effect Rating

Here are common ratings used for these variables:


Exposure Rating Health Effect Rating
1: Reversible health effects of
1: < 10% of the OEL
concern
2: Severe, reversible health effects
2: Between 10% and 50% of the OEL
of concern
3: Between 50% and 100% of the 3: Irreversible health effects of
OEL concern
4: Life-threatening or disabling
4: > 100% of the OEL
injury or illness

Source: AIHA: A Strategy for Assessing and Managing


Occupational Exposures, 3rd Edition

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Table 3: QEAs for individual SEGs by unique stressors

Exposure Health Effect Risk


Location Job Task Stressors
Rating Rating Rating
Alky Unit Operator Routine Work Duties Hydrofluoric Acid 1 3 3
Alky Unit Operator Routine Work Duties Noise 3 3 9
Coker Unit Operator Routine Work Duties Benzene 1 3 3
Coker Unit Operator Routine Work Duties Hydrogen Sulfide 2 2 4
Maintenance Pipefitter Welding Iron 2 2 4
Maintenance Pipefitter Welding Lead 2 3 6
Maintenance Maintenance Technician Gasket Replacement Asbestos 2 3 6
Reformer Unit Operator Routine Work Duties Noise 3 3 9
Reformer Unit Operator Routine Work Duties Benzene 2 3 6
Reformer Unit Operator Liquid Sampling Benzene 4 3 12
Tank Farm Operator Gauging Benzene 3 3 9

Risk matrices are already widely used by safety, quality and Step 5: Prioritize Next Steps
other departments across the organization to illustrate the After you and your stakeholders understand the exposure
status of their programs and related risks. So, why not use risks in the workplace, you can then begin an informed
the same tools to convey IH information, right? Far too many discussion about what to do next. If the risk rating is low
IH professionals believe they need to show a ton of complex (green), you should track for potential exposure risk changes,
data, statistics and fancy graphs to effectively communicate and no additional sampling may be needed. If the risk rating
exposure risks. IH practitioners should, as a whole, get out of is moderate (yellow), sampling is likely needed and controls
this “black box” mentality and simplify our messaging for both should be implemented (PPE, training, engineering controls,
employees and management. etc.). If the risk rating is high (red), immediate action is required
(typically PPE to start, then engineering and other controls,
Risk matrices also take advantage of peoples' existing visual medical surveillance, additional sampling, etc.).
and psychological cues: when presenting this data, viewers’
eyes will be almost instinctively drawn to the red items, right? We’ll talk more about taking the right actions and
They will inevitably ask: implementing controls later on.

• What’s the job/activity in red?


• Do we have data confirming the risk levels? STEP 3
• How are we protecting these workers today?
• How do we move the risk from a red to a yellow, or
even green?
Sampling Plans: Moving Beyond
Compliance
By applying this familiar risk matrix, now we have an engaged Developing SEGs and performing QEAs are critical to
audience, one that understands and wants to work with establishing baseline assumptions around workplace exposure
you to address those risks. I can tell you, a good manager risks, but your sampling plan is the critical next step that
really doesn’t like seeing red in any of the matrices they are enables you to validate and fine-tune those assumptions.
responsible for.
What Is an IH Sampling Plan?
I have used matrices just like this one to successfully grab the
attention of management and secure approval for investment You can think of an IH sampling plan as the “to-do” list for
in workplace exposure controls. In several cases, exposure your IH sampling activities. Your sampling plan will list the
control measures were recommended for years by multiple number, type and details of samples that must be collected
EHS professionals, but only when making those risks easily for each SEG and stressor of concern. It provides a clear list
visible and understood via the risk matrix did it get the of the samples needed throughout the year. Once your plan
attention from management it deserved. is defined, it offers the added benefit of being able to track
performance against sampling plan completion.

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A well-developed sampling plan should address the The Risk Rating was previously determined when we performed
following questions: our QEA. The Uncertainty Rating is defined as follows:

• What regulatory-driven periodic sampling is required? Uncertainty Ratings


• What SEGs need additional monitoring? 0: Certain the Risk Rating is precise
• How many personal, area, wipe or other type of samples are 1: Uncertain the Risk Rating is precise
needed to improve the precision of your QEAs? 2: Highly uncertain the Risk Rating is precise
• What is the deadline to complete the samples?
In Table 4 on page 10, we added two columns to our QEA table
Like any to-do list, you want to continually re-evaluate your that will be used for the Uncertainty Rating and Info Gathering
sampling plan to ensure that the sampling activities you plan Priority Rating. We then sorted the table by highest Info
to accomplish are the ones that actually need to be completed Gathering Priority Rating.
to meet your compliance requirements and best protect worker
health. So, ask yourself these questions: The ranking of the priority items provides a good roadmap for
where resources should be focused to improve the confidence
• Are you following the same plan that was established of your QEA Risk Rating.
by a previous IH manager years ago?
Based on information in Table 4, we see the highest priority is
• Is your IH sampling simply reacting to employee or the benzene exposure while gauging a tank in the tank farm.
business concerns?
There are also four other locations with ratings greater than
• How do you know if you are you sampling too much, zero (i.e., have some degree of uncertainty) and six with a zero
or not enough? rating (i.e., a high degree of certainty).

To help you answer these questions with confidence, we Items with a zero rating have the lowest priority but should be
recommend the following three-step process you can use to periodically re-evaluated to confirm the exposure potential
define a sampling plan. This method focuses your resources hasn’t changed.
to get the most out of your sampling effort, while supporting
the overall IH program. Step 3: Document Your Sampling Plan
Once you have the regulatory-required sampling and the
How Do I Develop a Sampling Plan? prioritized list of SEGs that require additional sampling, you
Step 1: Identify any Regulatory-driven Periodic can combine them in a single table and determine the number
Sampling Requirements of samples to take and the scheduled completion date(s).
OSHA and other agency standards include regulatory-required
periodic sampling that must be considered when developing Q: How many samples are needed?
your sampling plan. One example is the Coke Oven Emissions A: There are a lot of different strategies and methods that can
Standard, 29 CFR 1910.1029. Paragraph (e)(1)(iii) of the be used to determine the appropriate number of samples
Standard requires the full-shift personal sampling for each to take—too many to discuss all of them here in this article.
battery and job classification on each shift. This sampling is Ultimately, most of these methods recommend between 3 and
to be conducted quarterly. 9 samples for each SEG/stressor. We will go into more detail on
this in the section on Data Analysis.
Start your sampling plan by making a list of the sampling
required for each SEG, stressors that must be assessed, Q: What should I set as the scheduled completion date?
how many samples are required, and the date(s) they need A: December 31st is the most common date, since most
to be completed. sampling plans are annual. However, make sure you meet
the time requirements/deadlines for any regulatory-required
Step 2: Identify Samples Necessary to Increase Confidence sampling. For example, if quarterly monitoring is required,
with Your QEAs show the line item 4 times with the end of each quarter as
AIHA has developed a simple formula that we recommend your scheduled completion date.
to our customers when determining priority for additional
investigation, including additional sampling activity. The You may also set the date earlier in the year if there is a high
formula is: potential for exposure that is not well understood, or to match
up with your production calendar when the task/process is
Info Gathering Priority Rating = Risk Rating x Uncertainty Rating being performed.

© 2001-2022 VelocityEHS  | 7 Steps to Industrial Hygiene Success 9 of 18


Once the plan is established, you can track the progress
through the year by adding columns for # Samples Taken
and % Complete. An example of a finished sampling plan
is shown in Table 5 on page 10.

Final Thoughts on Sampling Plans


Remember, a sampling plan is just a plan. There will be
times when you need to adjust the plan or collect
additional samples. Your plan needs to remain flexible
to adjust for changes to processes and stressors, or to
validate the effectiveness of exposure controls. Additionally,
sampling plans may need to be altered in response to Which Laboratory Should I Use?
employee concerns that may factor into your information- IH labs come in all shapes and sizes. Some are large and
gathering priorities. provide a lot of additional services, while some are smaller
local labs that specialize in certain analytical methods.
To help determine the best fit for you and your company,
consider the following key factors:
STEP 4
Analysis Capabilities
Reach out to prospective IH labs with a list of the physical
Lab Analysis – Uncovering Hidden and chemical stressors for which you may be asking them
Gems of Efficiency to analyze samples to ensure that they offer the necessary
analytical capabilities to process those samples. Make sure you
Before jumping into our discussion on how to increase
ask if they outsource the analysis, and if so, make sure you’re
efficiency when working with your IH lab, it’s important
comfortable with that. There’s no sense selecting a lab that
to make sure you are working with right one.
only does a small fraction of the analysis methods you need.

Table 4: Extension of QEAs for determining Information-Gathering Priority Rating

Information-
Exposure Health Effect Uncertainty
Location Job Task Stressors Risk Rating Gathering
Rating Rating Rating
Priority Rating

Tank Farm Operator Gauging Benzene 3 3 9 2 18

Hydrogen
Coker Unit Operator Routine Work Duties 2 2 4 2 8
Sulfide

Maintenance Pipefitter Welding Lead 2 3 6 1 6

Maintenance Pipefitter Welding Iron 2 2 4 1 4

Hydrofluoric
Alky Unit Operator Routine Work Duties 1 3 3 1 3
Acid

Alky Unit Operator Routine Work Duties Noise 3 3 9 0 0

Coker Unit Operator Routine Work Duties Benzene 1 3 3 0 0

Maintenance Gasket
Maintenance Asbestos 2 3 6 0 0
Technician Replacement

Reformer Unit Operator Routine Work Duties Noise 3 3 9 0 0

Reformer Unit Operator Routine Work Duties Benzene 2 3 6 0 0

Liquid
Reformer Unit Operator Benzene 4 3 12 0 0
Sampling

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Table 5: Sample plan example

# Sampled Scheduled
Location Job Task Stressors # Samples Taken % Complete
Planned Completion Date

Tank Farm Operator Gauging Benzene 8 7/1/2021 2 25%

Routine Work Hydrogen


Coker Unit Operator 4 12/31/2021 2 50%
Duties Sulfide

Maintenance Pipefitter Welding Lead 4 12/31/2021 1 25%

Maintenance Pipefitter Welding Iron 4 12/31/2021 0 0%

Routine Work Hydrofluoric


Alky Unit Operator 3 12/31/2021 1 33.3%
Duties Acid

One or Multiple Labs? Additional accreditations are available for specific stressors
Based on analytical requirements, you may ultimately need to including lead (ELLAP), mold and other microbiological
use multiple labs. Using the methodology prescribed below, samples (EMLAP). If you are a global corporation, consider
you will ensure you address the highest priorities with respect looking for laboratories that are also ISO/IEC 17025 accredited.
to your annual budget for monitoring.
Depending on the state(s) you operate in, you may also need
Price to consider state accreditations. Some states that have their
Sampling effort should be focused on the items that need own accreditations include Louisiana, New York, New Jersey
additional data and investigation. For example, those annual and Texas.
noise surveys you conduct every year that show noise levels
are consistently above 95 dBA can be removed or greatly Streamline Your Process
reduced. Remember, the overall number of samples you One of the most intensive administrative tasks when working
collect should be minimized over time, saving you money and with IH labs is creating your chain of custody (COC) form. It
giving you back time to focus on more important projects. can be a time-consuming task, one that most of us don’t look
forward to at the end of a long day of sampling. However,
On-Staff CIH several IH laboratories are now offering online services to
Several of the larger labs offer free or low-cost consultation complete your COCs online. Some labs like SGS Galson even
with their on-staff CIHs. This comes in handy if you need provide a convenient web portal to help you easily complete
additional support to determine the best sampling methods and submit your COCs.
or just want an IH expert to review your work.
Several labs also offer direct access to their sampling and
Equipment Loan and Rental analysis guides (SAGs). Your lab’s SAG is essentially a catalog
Several labs offer air sampling pumps for free and will often of the analytical services they offer and includes information
rent noise dosimeters and other direct reading equipment. such as analysis methods, limits of detection, flow rates and
This offers a great cost-saving option if you’re not taking required sample volumes. Having SAG information readily
enough samples to justify purchasing your own equipment. available helps ensure your planned sampling is performed
according to proper procedures, and it helps minimize
Location questions or the need to resample.
For most, lab location is not an issue. Sample media can easily
be shipped next day air to and from most places. However, Challenges with Lab Interfaces
location becomes important if you need to swing by their Most IH software systems include interfaces that provide the
office to pick up sampling media on short notice, or when ability to send COCs to labs and upload analytical results.
analyzing a highly volatile agent and you don’t want to deal However, the challenge with many of these lab interfaces
with packing it in dry ice or some other cooled packaging. is implementing them properly and keeping them working
as analytical parameters and methods change. It can be an
Accreditation administrative nightmare requiring months to set up, plus
Most IH laboratories are AIHA LAP accredited. We recommend additional support every time there is a change with the lab
this level of accreditation for analysis of most stressors. SAGs or any time you add a new stressor to your database.

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Due to the level of effort required to maintain many lab Ask the Right Questions
interfaces, these capabilities have traditionally been limited Whichever analysis methods you use, there are some common
to the larger labs and corporations. The average facility simply IH questions they should answer.
doesn’t have the IT resources or personnel required to keep
these interfaces functional and up to date. The result is that Are exposures in SEGs consistent?
only a small minority of companies and laboratories have a Even our best professional judgement is not always 100%
functioning interface to help streamline their COC submittals accurate. In many cases, SEGs are formed based on our
and upload of analytical results… until now. qualitative observations and previous experience, but it is
good practice to validate those exposure assessments to verify
Optimize Your Lab Interface our qualitative assessments for those stressors.
VelocityEHS has built an IH solution that eliminates all of the
COC and lab interface barriers and makes flexible lab interface Two of the more common methods for this include analysis
capabilities available to companies and labs of any size. The of variance (ANOVA) and scatter diagrams. ANOVAs are very
core feature that makes this all possible is our Global Chemical precise but are complex to perform, can be time-consuming
& OEL Database. and may not be practical to perform for every SEG. A simpler
method would be to use a scatter diagram and look for
Laboratories can easily map their laboratory information clusters of data. This is more subjective but can provide a quick
management system (LIMS) to our master list of stressors. glance at how similar the exposure data is within the SEG.
Once mapping is complete, we can provide direct access to
any number of companies in a matter of minutes, with no Are the exposure ratings accurate?
additional effort required by the labs. This simplified process If your exposure ratings include quantitative data such as
enables smaller labs to offer the interface services that used to “Percent of OEL,” it is good practice to confirm your exposure
be limited to only the larger, more sophisticated labs. risk ratings using IH sample data. The challenge is deciding
which statistic to use. Before spending time generating a lot of
VelocityEHS also gives users the ability to directly order statistics, it is important to first determine which statistics to
analytical services via in-app access to each lab’s SAG when use for confirming your exposure ratings. Common examples
building your surveys. Once the services are identified, we include:
provide the lab’s SAG information directly to users to ensure
they know key sampling parameters like detection limits, flow • 95th Percentile • % > OEL
rates, minimum sample collection volumes and times, etc. • 95% / 95% UTL • Geometric Mean & Standard
• 90% or 95% UCL Deviation
The result of having all of this information at your fingertips is
more accurate sampling and a more accurate COC that can be
When using precise statistical analysis, it matters if the data
quickly generated at the end of a long day of sampling. Since
set follows a normal or log-normal distribution.
you are essentially ordering directly from the lab’s catalog,
the COC will be accurate. This all but eliminates questions and
What’s the likelihood of exceeding the OEL?
confusion between you and your laboratory, saving you time
This is similar to the previous question. Again, you should
and money from any sampling errors or having the wrong
first determine if your distribution is normal or log-normal. It
analytical services performed.
is important to first determine which statistics to use. Again,
common examples are:

STEP 5 • 95th Percentile • % > OEL


• 95% / 95% UTL • Geometric Mean & Standard
• 90% or 95% UCL Deviation
IH Data Analysis: Defining Your Goals
and Selecting the Best Metrics Are the control measures working as designed
Before diving into statistical analysis of your data, it is critical (control verification)?
to define why you are performing an analysis in the first place, Measuring the effectiveness of exposure risk controls is
and what conclusions you hope to confirm or reject through generally a simple task, but you should have an idea of what
that data. There's a wide array of different statistics, graphs the expected results are. If a process was changed from an
and analysis methods you can use based on the questions open process to a closed-loop process, it may be fair to assume
you’re trying to answer, and the data set being assessed. Some the exposure should be less than the limit of detection. If
analyses can be done quickly using a simple Microsoft Excel the control was designed to reduce exposures, it should be
formula or calculator, while others may require more complex estimated by how much, or at least designed to reduce the
statistical analysis tools. exposure to below a certain threshold.

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Either way, there should be a clear metric to measure the HYGINIST
effectiveness of your controls. HYGINIST calculates similar statistics as the IHSTAT tool but is
a bit more complicated to use. It is free and offers additional
Do we have sufficient sample data, or how much more statistics such as the 70% confidence for help with EN689
sampling is needed? compliance testing. It can be downloaded here.
Unfortunately, this is a question that is much too complex to
answer here. Luckily, there are several reliable models you can EXPOSTATS
follow to help make this determination. Some regulations have EXPOSTATS is a Bayesian analysis tool developed by Jérôme
specific quarterly monitoring that is required, while others, Lavoué of the University of Montreal and is available in English
such as Europe’s EN689, provide a very defined methodology and French. The tool is available online and offers several
for collecting a small set of data and performing supplemental different analysis tools and nice graphic outputs. These tools
sampling when exposures exceed their parameters. The are available for use here.
regulation also provides a strategy for reassessments, with
time intervals ranging from one to three years, depending on Keep It Simple…
the levels of exposure. As industrial hygienists, we love to play with data. You’d be
amazed by the amount of great statistics that can be quickly
The EAS Bayesian tool discussed below is another tool you
generated using any of the tools mentioned above. While
can use to help reduce the number of samples needed
these are informative tools for advanced EHS professionals
by combining a smaller data set with your professional
and provide a very detailed view of your IH data, effective
judgement. The combination of your professional judgement
IH management doesn’t have to be that complex.
and hard data provides a high level of confidence as to the
true level of exposure. For example, when determining if the exposures for a SEG
are consistent, you can perform an ANOVA or simply create
Common Statistical Tools a scatter diagram and look for clusters.
There are a variety of tools available to help you assess
exposure data. While most are free, some require a license Formulas for Analysis of Variance (ANOVA)
to be purchased. Here’s a few of the most commonly
used resources:

IHSTAT
IHSTAT is a free Microsoft Excel worksheet that checks for log-
normalcy and provides several common statistical analyses of
IH data and compliance testing. This commonly used tool was
developed by AIHA and is available for free.

EAS Bayesian
Dr. Paul Hewett of Exposure Assessment Solutions developed Unfortunately, the formulas used for ANOVA can be
the market-leading Bayesian analysis tool. He provides intimidating, let alone the time it takes to perform one.
training sessions and webinars throughout the year on the Alternatively, the scatter diagram can be quickly generated
software and other statistical topics. The Bayesian software using Excel.
has a free version (IHDA-Student), which is intended for use by
students or EHS professionals in training. The IHData Analyst Example of a Scatter Diagram
Professional version is intended for organizations looking to
use it in their IH programs. Both versions are available here.

BWStat
BWStat is a Microsoft Excel tool developed by Tom Geens
and hosted by the Belgium Society of Occupational Hygiene.
It allows the estimation of compliance with OELs, taking
into account the intra- and inter-individual variation in
repeated measurements. It was built to help facilitate the
implementation of the BOHS-NVvA Guidance. You can
download BWStat here.

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The example scatter diagram above shows short-term the exposure before further damage to worker health occurs.
exposure limit (STEL) samples conducted in a nice cluster, IH program managers should be notified any time adverse
while the full-shift exposures around 480 minutes show two health effects are discovered, while ensuring compliance
different clusters of sample results. At this point, investigation with HIPAA privacy laws and any company privacy policies.
should be done to determine why there are two clusters. Was it IH can then use this data to target specific workplace risks for
due to equipment the worker used? Their location? Their work additional assessment and control measures.
practices? Whatever the cause, the SEG in this example may
need to be split into two different SEGs based on the data. For example, workers with an abnormally high level of
blood lead must be immediately removed from the work
Whatever method(s) you use to analyze the sample data, think environment causing the exposure. IH should assess the
carefully about what statistics or methods are most helpful in hygiene procedures of workers and ensure they are
making decisions and communicating information about your |using their PPE appropriately. Additional air monitoring
IH program. Far too many EHS professionals try to present and an assessment of other exposure controls may also be
and communicate complex statistics to workers and deemed necessary.
management. This is a common mistake that only succeeds
in confusing them, at which point they completely lose Who Defines the Requirements for MSPs?
interest. The data needs to be presented in a simplified Standards set forth by regulatory agencies such as OSHA
manner that’s easy to understand. are the most common source of MSP requirements. However,
companies may choose to establish their own MSP policies,
including employee wellness programs to manage risks
STEP 6 from non-work-related health conditions such as diabetes
or high blood pressure. Regardless of the source of the
requirement, an occupational health professional should
Medical Surveillance: Strengthening be involved in defining any necessary medical activities and
Your Last Line of Defense for Worker their frequencies.
Health A great resource that summarizes the OSHA regulations for
MSPs is “Medical Screening and Surveillance Requirements
in OSHA Standards: A Guide.”

Who Needs to Be Included in Medical


Surveillance Programs?
Most regulations specify a threshold of exposure that, if
exceeded, requires workers be placed into an MSP. Keep
in mind that once there’s an exceedance, there are direct
exposure controls and other actions that must be taken to
minimize or eliminate the exposure and protect the worker.
When it comes to MSPs, you are looking at the worst-case
exposures and not statistics.

Before diving into best practices for medical surveillance, let’s Methods for Setup and Maintenance of Medical
first have a quick refresher of the basics. Surveillance Programs
There are a few fundamental steps necessary to set up and
What Is a Medical Surveillance Program (MSP)? maintain your MSPs and ensure workers are enrolled in the
An MSP is defined as the set of medical activities that must be right programs based on exposures.
performed on workers when exposures to workplace stressors
exceed a certain level. The program will list what the stressor of Step 1: Define Applicable MSPs and Their Required
concern is, the threshold at which workers need to be tested, Medical Activities
and the medical activities and their frequencies that need to Looking at your locations and assessment of potential
be conducted. exposures, you can determine which MSPs may be required
under any applicable regulations. For example, a list of
Why Are MSPs Needed? potential stressors at your locations may include noise,
benzene and silica, all of which are regulated by OSHA
The purpose of the MSP is to evaluate workers exposed
and have MSP requirements.
to stressors above a set threshold and quickly identify any
adverse health effects early-on, so they may be removed from

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Step 2: Define Thresholds
For each MSP, determine the threshold level at which workers STEP 7
need be enrolled in that MSP. For example, OSHA standards
state that noise exposure exceeding an 8-hour TWA of 85 dBA
would necessitate enrollment in the MSP. Evaluating and Communicating
Performance: The Keys to Engagement
Step 3: Evaluate Who Needs to be Enrolled in MSPs
with Your IH Program
To determine who needs to be enrolled, you can take a
look at one or both of the following:

Risk Ratings
These are obtained through your qualitative exposure
assessments. If the risk rating is above the threshold set
by the MSP, all members of the SEG should be enrolled.

IH Sample Data
At a minimum, all persons for which sampling shows
exposures exceeding the defined threshold should be enrolled
in the MSP. An important determination is whether to enroll
all workers that do the same job (i.e., are in the same SEG) or
to assess each worker’s potential exposure independently.
Most professionals would apply the enrollment to the entire
SEG. However, you may be able to justify individual worker If you were to ask business managers what the status of their
enrollments/de-enrollments if you can reliably demonstrate business is, they would discuss their profit margin, EBITA,
that those workers experience different exposures due to percent growth in revenue or other common financial metrics.
unique work procedures and conditions.
If you were to ask safety managers, they’d probably tell you
Step 4: Automate Enrollment and De-enrollment of about the number of days without a recordable injury or their
workers in MSPs incident rate and how it compares with last year.
Manually updating the lists of workers that are enrolled and
As an IH professional, how would you answer the question:
de-enrolled in MSPs is a time-consuming task. IH software
“What’s the status of your IH program?” Would you pull up a
can make this job not just easy, but virtually effortless. The
bunch of statistics? A list of SEGs? Perhaps you would show
key is to be able to get accurate employee data from your HR
them your sampling plan for the year?
department and map it to the requirements for who needs to
be included in each MSP. If you are having a hard time identifying the best data points,
statistics, tables or diagrams to show, you’re not alone. This
The best method is to map HR information specifying workers’
has been a long-running challenge for IH professionals and a
jobs and locations on to each SEG. With HR data being
big reason, I believe, why most stakeholders don’t understand
continually updated in the background, workers can be moved
what IH is or the value we bring to the business.
in and out of SEGs automatically as job roles and locations
change. If you define who is required for your MSPs at the
SEG level, workers will automatically move in and out of MSP
Documentation and Communication
enrollment as they move in and out of SEGs. Industrial hygienists are very good at documentation, but
most of us need to improve our communication. We generate
Unfortunately, there are limitations to most HR systems and employee notification letters, tables and charts of sample
records, and getting a 100% accurate, real-time account of all results and include them in quality reports that are sent to
workers’ job roles and locations is very difficult. That said, even management, but is there any two-way communication?
a 50% automation of MSP enrollment saves enough time and Do we present our findings in person and make time for
resources to make it worth the effort. dialogue, discussion or Q&A? What happens with the reports
we generate for data users? Are they just filed and eventually
shipped to a salt mine for long-term storage without providing
any real value for the business?

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We all learned in school or from our supervisors how to write Improving the Resolution of Your Risk
great IH reports, but most of us have not received any real Assessments
training on how to engage and collaborate with workers and To get the full picture of the status of your IH program, you
management to communicate IH data in a meaningful way. also need to identify and illustrate your level of confidence
We’re unfortunately all too content to keep the details in our with your QEAs. This is best indicated by an uncertainty rating
black box and just document our findings. assigned to each QEA.
The problem with just documenting our findings and not In Table 6, line items with an uncertainty rating of zero indicate
having meaningful dialogue about them is that workers a high degree of confidence, while those with a 1 (uncertain)
and management will not understand why you conducted or 2 (highly uncertain) need additional investigation (thus, a
the monitoring or performed the risk assessments in the higher information-gathering priority rating).
first place. If they don’t understand the why, they surely
won’t understand the value you or the IH program brings Using the information in Table 6, we can quickly show
to the business. stakeholders some key IH program insights, including:

If It Ain't Broke, Don't Fix It! • The current number of risk assessments and what level of
I am big believer in leveraging what works within your risk they each have (e.g., high, medium, low)
company’s culture. For most companies, important safety, • Details of the jobs, tasks, location and stressors that make up
quality and other risk information is already being summarized the health risks
using a standard risk matrix, and stakeholders are likely
• The degree of certainty with our health risk ratings
accustomed to referencing other types of risk matrices to
quickly understand the presence of risks in the workplace. • Where additional resources are needed to improve the
degree of confidence in the health risk ratings
As we talked about earlier, a risk matrix is a valuable tool
already in your toolbox that can also be used to summarize To ensure effective communication of risks, these values
exposure and worker health risks. In the case of IH risks, rather should be discussed with workers and management, giving
than using severity and likelihood as our key risk variables, the them ample opportunity to ask questions and have an
IH risk matrix uses health effect ratings and exposure ratings to open dialogue on the data. Ideally, this will instill greater
rank and prioritize risks. understanding and appreciation of what IH is and its value
to the business, and ultimately strengthen engagement with
your IH program.

Tools and Skills for Communicating Control


Measures
Risk matrices can also be used to help build support for risk
control measures. It’s very common for management to ask,
“How can we reduce the red (high risk) items to yellow or
green?” You can easily illustrate the answer to this question
by using two matrices: one to show risk before controls are
implemented and one to show risk after controls are put in
place. This will tell you the initial and residual risk.

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Table 6: Extension of QEAs for determining Information-Gathering Priority Rating

Health Information-
Exposure Uncertainty
Location Job Task Stressors Effect Risk Rating Gathering
Rating Rating
Rating Priority Rating
Tank Farm Operator Gauging Benzene 3 3 9 2 18

Routine Work Hydrogen


Coker Unit Operator 2 2 4 2 8
Duties Sulfide

Maintenance Pipefitter Welding Lead 2 3 6 1 6


Maintenance Pipefitter Welding Iron 2 2 4 1 4
Routine Work Hydrofluoric
Alky Unit Operator 1 3 3 1 3
Duties Acid
Routine Work
Alky Unit Operator Noise 3 3 9 0 0
Duties
Routine Work
Coker Unit Operator Benzene 1 3 3 0 0
Duties
Maintenance Gasket Replace-
Maintenance Asbestos 2 3 6 0 0
Technician ment
Routine Work
Reformer Unit Operator Noise 3 3 9 0 0
Duties
Routine Work
Reformer Unit Operator Benzene 2 3 6 0 0
Duties
Reformer Unit Operator Liquid Sampling Benzene 4 3 12 0 0

Looks great, huh? But it’s never quite that simple. You must Present a Financial Analysis
be armed with data to show what it takes to reduce those Most of us are not experts on financial analysis, but we still
red items. When communicating control activities and should be able to provide some basic information about
effectiveness, we strongly recommend the following: control alternatives, including:

Present Multiple Alternatives • Price


If you present only one control option, the only possible • Return on Investment (ROI) – percent cost savings or
responses are yes or no. If you present multiple options, benefits in dollars above the cost of the control, over a
stakeholders are much more likely to assess the options in specified time period
relation to each other and choose one of them rather than
taking no action. They will appreciate the amount of work you • Break-even point – how long it takes for the benefits from
did to provide options, and that you are not putting them into installing the control to pay for themselves. Every day after
the position where they are simply approving or disapproving the break-even point translates to a cost savings for the
a control measure for which they had no input. company.

When gathering financial information, remember to add items


such as increased production, improved quality, decreased
loss of product, reduced PPE expense, fewer days away, etc.
Sometimes these additional items have the biggest influence
on supporting the investment for the control.

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The Value of VelocityEHS IH Solutions
VelocityEHS Industrial Hygiene Software gives you industry-
leading IH program capabilities built on AIHA best practices,
right out of the box. Our time-saving suite of solutions enables
you to quickly get up and running, with little to
no training needed, so you can more efficiently protect
worker health, maintain compliance and drive long-term
program performance.

Benefits of VelocityEHS
Simplicity
We believe that well-designed, intuitive software ultimately
gets used, and when your people are engaged, you get the
greatest possible value from your IH software purchase.

Speed
Not only does our IH solution provide valuable time-saving
capabilities, but our implementations require less time, cost
less, and are more successful than other IH software systems Industrial Hygiene Simplified
on the market. VelocityEHS Industrial Hygiene solutions help you
assess and control workplace stressors, automate
Unparalleled Customer Support time-consuming IH tasks and maintain a world-class
Our in-house IH experts and Customer Support Team IH program, no matter what your level of IH expertise.
stand ready to deliver the guidance, consultation and best- Contact us to learn more!
practice approaches you need to solve your most complex
IH management challenges. VelocityEHS
Toll free: 1.866.919.7922
Holistic IH Program Management
VelocityEHS gives you a comprehensive IH program Australia: +61 2 9098 4332
management platform that integrates your IH sampling
data, SEGs, QEAs, sampling plans, database of stressors and United Kingdom: +44 (0) 1737 812718
OELs, analysis, reporting and other IH functions into a single,
easy-to-use system.
Learn more at www.EHS.com
Value
The IH experts at VelocityEHS are continuously developing the
system enhancements and innovative new features you need
to achieve greater levels of IH program efficiency throughout
the life of your purchase.

Helping You Do Your Job Better


The fundamental purpose of our IH solutions, besides helping
you create a safer and healthier workplace, is to eliminate
time-consuming manual IH program tasks and give you
back time to focus on your goals.

© 2001-2022 VelocityEHS  | 7 Steps to Industrial Hygiene Success 18 of 18

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