Environmental,

Procedure BESH - IH C-011 Safety, and Health

Occupational Exposure to Cadmium
Industrial Hygiene

Bechtel Environmental, Safety and Health

Occupational Exposure to Cadmium

Rev. 00

Industrial Hygiene

Procedure No: BESH-IH C-011

Prepared by: Approved by: Approved by:

C. LaScola, CIH, CHMM W. Whelan, CIH, CSP C. Cappello

Sr. Industrial Hygienist Manager, Manager,
Industrial Hygiene Corporate ES&H
 Environmental,
Procedure BESH - IH C-011 Safety, and Health
Occupational Exposure to Cadmium
Industrial Hygiene

Table of Contents

1.0 APPLICABILITY AND SCOPE...................................................................................................................1

2.0 RESPONSIBILITIES: ...................................................................................................................................1
2.1 Project Management.....................................................................................................................................1
2.2 Project Construction .....................................................................................................................................1
2.3 Project Engineering ......................................................................................................................................1
2.4 Legal ............................................................................................................................................................ 1
2.5 Project ES&H Manager or designee ............................................................................................................1
2.6 Global Business Unit (GBU) ES&H Manager ............................................................................................. 2
2.7 Corporate Industrial Hygiene .......................................................................................................................2
2.8 Bechtel Subcontractors.................................................................................................................................2
2.9 Examining Physician:...................................................................................................................................2
3.0 DEFINITIONS: ..............................................................................................................................................2
4.0 REQUIREMENTS .........................................................................................................................................3
4.1 Cadmium Compliance Program: ..................................................................................................................3
4.2 Hazard Identification: ...................................................................................................................................3
4.3 Airborne Exposure Monitoring: ...................................................................................................................3
4.4 Methods of Compliance: .............................................................................................................................. 5
5.0 REFERENCES ...............................................................................................................................................8

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 Procedure BESH - IH C-011
Occupational Exposure to Cadmium
1.0 APPLICABILITY AND SCOPE
This procedure provides guidance in establishing
compliance with the requirements for protecting
personnel against occupational exposure to
cadmium and cadmium-containing
compounds/substances. It applies to all Bechtel
operations worldwide. It provides guidance for
hazard identification, exposure monitoring, and
methods of compliance, respiratory protection,
protective work clothing, hygiene facilities,
housekeeping, medical surveillance, training and
hazard communication, and recordkeeping.
Compliance with this procedure does not relieve
the project of any obligation to comply with all
applicable federal, state and host country
regulations governing cadmium or cadmium
containing compounds/substances. If other
applicable legal standards are more stringent,
they take precedence.
2.0 RESPONSIBILITIES:
2.1 Project Management
Project Management is responsible for:
 providing resources necessary to
implement this procedure;
 performing management assessments to
confirm compliance; and
 stopping work to prevent unsafe practices
or exposure.
2.2 Project Construction
Project Construction is responsible for:
 identifying, with assistance from Project
ES&H and Engineering, cadmium
hazards on the project site and the
activities that will generate cadmium
fume/dust;
 identifying, with assistance from
Engineering and ES&H, engineering
controls and safe work practices to reduce
exposure to cadmium;
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Safety, and Health
 confirming that activities involving
cadmium are conducted only by trained
and qualified personnel;
 including cadmium control measures in
daily JHAs and STARRT cards; and
 stopping work to prevent unsafe practices
or exposure.
2.3 Project Engineering
Project Engineering responsibilities include:
 identifying, with assistance from
Construction and ES&H, engineering
controls and safe work practices needed to
minimize exposure to cadmium; and
 stopping work to prevent unsafe practices
or exposure.
2.4 Legal
Legal staff are responsible for:
 assisting the project as needed with
contracts and with resolution of
regulatory issues and any conflicts
between Bechtel requirements and owner,
customer, contractor, or subcontractor
criteria; and
 incorporating this procedure into contracts
to take precedence when the host country
standard is less stringent or does not exist.
2.5 Project ES&H Manager or designee
The project ES&H Manager/designee is
responsible for:
 identifying a Competent Person to project
management;
 assisting Project Engineering and
Construction with identifying cadmium
hazards on the project site and the
activities that will generate cadmium;
 assisting Project Engineering,
Management, and Construction with
developing appropriate engineering
controls and safe work practices for
specific activities;

Procedure BESH - IH C-011
Occupational Exposure to Cadmium
 communicating Bechtel requirements and
providing oversight of contractor and
subcontractor activities, as appropriate;
 confirming compliance with this
procedure; and
 stopping work to prevent unsafe practices
or exposure.
2.6 Global Business Unit (GBU) ES&H
Manager
The GBU ES&H Manager’s responsibilities
include:
 working with Project Management and
assisting projects with implementing this
procedure;
 providing guidance for identification and
management of cadmium hazards;
 working with the BESH Corporate
Industrial Hygiene Representative in
performing functional reviews as needed;
and
 stopping work to prevent unsafe practices
or exposure.
2.7 Corporate Industrial Hygiene
Corporate IH is responsible for:
 reviewing project cadmium compliance
programs, as requested;
 assisting projects with compliance, as
needed; and
 performing periodic functional technical
reviews to confirm the adequacy of the
cadmium compliance program.
2.8 Bechtel Subcontractors
Subcontractor responsibilities include:
 complying with applicable legal standards
and contractual requirements governing
cadmium, including requirements in this
procedure; and
 stopping work to prevent unsafe practices
or exposure.
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Industrial Hygiene
2.9 Examining Physician:
Examining physician responsibilities include:
 determining the fitness of an individual to
work in a cadmium environment and to
wear personal protective equipment (PPE;
and
 providing the ES&H Representative with
a Physician’s Statement in compliance
with CP-301, Medical Surveillance, and
notifying employees of the examination
results.
3.0 DEFINITIONS:
 Action Level: An airborne concentration of
cadmium of 2.5 micrograms per cubic meter
(µg/m3) of air measured as an 8-hour time-
weighted average (TWA) in an employee’s
breathing zone.
 Body Burden: The level of cadmium in the
blood or urine above the acceptable limits.
 Breathing Zone (BZ): An area within 18
inches (46 cm) of the nose and mouth of an
individual. The air in this area is
representative of what an individual is
breathing.
 Clean Change Room: A hygiene facility
where employees remove street clothing and
put on protective work clothing. This facility
is adjacent to a shower, has containers for
storing street clothing, and is designed to
prevent cadmium contamination of the street
clothing.
 Competent Person: An individual designated
by Environmental, Safety, and Health
Department who has the technical knowledge
and expertise to identify existing and potential
cadmium hazards in the workplace and the
proper methods to control exposure. This
individual will have the authority to take
prompt corrective actions to control exposure
to cadmium and will know how to establish
regulated areas, evaluate engineering controls,
develop sampling strategies, train employees,
select appropriate personal protective clothing
and equipment, and require medical
surveillance.

Procedure BESH - IH C-011
Occupational Exposure to Cadmium
 Dirty Change Room: A room adjacent to a
shower where an employee removes
contaminated protective clothing and puts it
inside impermeable bags or other containers
used to seal the contamination. This room is
meant to isolate cadmium contamination from
the clean change room and has direct access to
a shower room.
 Exposure: The airborne contamination to
which an individual would be subjected if that
person were not wearing a respirator.
 High-Efficiency Particulate Air (HEPA)
Filter: An air filter capable of trapping and
retaining 99.97 percent of mono-dispersed
airborne particles that are 0.3 micrometer or
greater in diameter.
 Occupational Exposure Limits (OEL): An
8-hour TWA exposure of 5 µg/m3. Employees
shall not be exposed to airborne levels of
cadmium exceeding this level. This level will
be decreased based on time worked in excess
of an 8-hour day or 40-hour week.
 Time-Weighted Average (TWA): An
airborne concentration of cadmium that has
been averaged over a period of time (generally
8 hours).
4.0 REQUIREMENTS
The requirements for an acceptable program to
prevent occupational exposure to cadmium are as
follows:
4.1 Cadmium Compliance Program:
Each project will identify locations where
cadmium is present and implement a written
cadmium exposure control program.
The purpose of this program will be to protect
employees from cadmium exposure at or above an
OEL of 5 µg/m3 or from ingesting cadmium. In
addition to listing the locations of cadmium-
containing materials, the cadmium exposure
control program will define:
 Training requirements for employees
potentially exposed to cadmium.
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Industrial Hygiene
 Engineering controls, such as local exhaust,
general ventilation, substitution, or other
methods to reduce exposure to below the
OEL.
 Safe work practices and techniques, including
prohibited activities to reduce exposure.
 Respiratory protective equipment and clothing
requirements to reduce exposure.
 The requirements for regulated areas.
 Medical surveillance requirements, including
bioassay tests and frequency.
 Air surveillance requirements.
The cadmium exposure control program will be
incorporated into the ES&H Execution Plan
and/or site-specific safety and health plans.
This program will be reviewed and updated as
required when significant technologies or project
conditions change.
4.2 Hazard Identification:
Before any construction work is done, an ES&H
Representative or designee (competent person)
will review past reports, work plans, chemical
inventories, blueprints, drawings, material safety
data sheets, subcontract documents, and
characterization reports to determine the location
and type of cadmium that may be present on the
project.
When complete, an ES&H Representative will
consult with individuals, employers, and others as
necessary. If cadmium is identified, an ES&H
Representative will assess the potential for
exposure from both inhalation and ingestion to
assure compliance.
4.3 Airborne Exposure Monitoring:
An action level of 2.5 µg/m3 has been established
as the level to initiate certain compliance
activities, such as exposure monitoring, training,
and medical surveillance.
Air surveillance monitoring will be conducted in
accordance with CP-313, Air Surveillance. Data
will be collected on the form provided in CP-313,

Procedure BESH - IH C-011
Occupational Exposure to Cadmium
Exhibit C or equivalent providing the same
information.
4.3.1 Air Sampling:
The ES&H Representative will ensure that a
competent person conducts or oversees air
sampling for cadmium whenever there is a
potential to exceed the AL of 2.5 µg/m3 of air as
an 8-hour TWA.
At least one breathing zone air sample will be
collected in the area of highest exposure for each
task in each work area.
A representative number of employees will be
sampled in areas where many employees are
conducting similar tasks.
Air sampling will be conducted initially,
periodically, and whenever there has been a
change in raw materials, equipment, personnel, or
work practices.
When two consecutive samples collected 7 days
apart indicate that airborne levels of cadmium are
below the AL, air sampling may be discontinued,
unless there is a change in the process as specified
above.
Air sampling will be conducted within 5 working
days from the time a change in equipment,
process, or personnel occurs. The OEL-TWA
should be adjusted for longer work shifts.
4.3.2 Employee Notification of Air Sample
Results:
The ES&H Representative or designee will notify
affected employees in writing of air sampling
results no later than 5 working days after the
receipt of the results of the sampling.
Whenever sampling results indicate that employee
exposure exceeds the OEL, regardless of the use
of respiratory protection, the written notice shall
include a description of corrective actions being
taken.
In addition, all air sampling results will be posted
in an appropriate location accessible to all
employees.
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Industrial Hygiene
4.3.3 Subcontractor Notification of Air Sample
Results:
All subcontractors will be responsible for
monitoring cadmium exposure for their
employees.
Subcontractors will be required to notify their
employees of air monitoring results in compliance
with Section 4.3.2 of this procedure.
4.3.4 Regulated Areas:
Each project or facility will establish a Regulated
Area with boundaries clearly delineated from
other work locations if there is a potential to
exceed the OEL.
Access to the Regulated Area will be limited to
authorized personnel and established in such a
manner that will protect individuals outside the
area from incidental exposure.
Special work practices and controls, including
engineering controls, protective clothing, and
respiratory protection, will be required for
working inside cadmium-regulated areas.
Each person entering shall be supplied with and
required to use a respirator selected in accordance
with Section 4.4.2 of this procedure.
Employees will not be allowed to eat, drink,
smoke, chew gum or tobacco, or apply cosmetics
while inside a regulated area.
Warning signs for cadmium-regulated areas will
be posted and shall read as follows:
DANGER
CADMIUM
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS AND
KIDNEYS
WEAR RESPIRATORY PROTECTION IN
THIS AREA
AUTHORIZED PERSONNEL ONLY
Shipping and storage containers containing
cadmium or cadmium compounds shall be labeled
in accordance with hazard communication
requirements.

Procedure BESH - IH C-011
Occupational Exposure to Cadmium
The warning labels for containers of cadmium-
contaminated protective clothing, equipment,
waste, scrap or debris shall include at least the
following information:
DANGER
CONTAINS CADMIUM
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS AND
KIDNEYS
AVOID CREATING DUST
4.4 Methods of Compliance:
The following describes acceptable methods for
complying with cadmium exposure control
requirements:
4.4.1 Engineering and Work Practice Controls:
Whenever feasible, engineering and work practice
procedures will be the primary methods for
controlling exposure to cadmium. The ES&H
Representative or designee will monitor the
effectiveness of engineering controls within 5
working days from the time of their
implementation. Cadmium-contaminated air will
not be recycled unless it has been filtered with a
HEPA filter. Whenever feasible, vacuums with
HEPA filters will be used to remove
contamination from surfaces, equipment, or
protective clothing.
Engineering controls are not necessary when air
sampling results indicate that:
 Exposure is intermittent.
 Exposure does not exceed the OEL for 30
days or more during 12 consecutive months.
Whenever engineering controls are not feasible to
reduce exposure to cadmium, special work
practices and/or respiratory protection will be
used.
Work practices will not use rotation as a method
of controlling exposure.
Air blowing, shaking, and other dust removal
methods that create airborne dust will be
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Industrial Hygiene
prohibited for removing cadmium from surfaces,
protective clothing, or equipment.
4.4.2 Respiratory Protective Equipment:
Respiratory protective equipment will be used in
accordance with the guidance specified in CP-
311, Respiratory Protective Equipment.
The ES&H Representative or designee will ensure
respiratory protection is used under the following
conditions:
 Sampling data indicate that the airborne levels
of cadmium exceed the OEL-TWA.
 Potential for exposure above the OEL exists
and an exposure assessment has not yet been
conducted.
 Engineering controls fail to reduce exposure
to cadmium to below the OEL.
 Employees are responding to emergencies.
 Exposed employees request a respirator.
The ES&H Representative or designee will ensure
that the project provides powered air-purifying
respirators (PAPRs) in lieu of an air-purifying,
negative-pressure respirator upon employee
request.
Qualitative or quantitative respirator fit testing
will be conducted initially and annually for
negative or positive pressure, air-purifying
respirators. Quantitative fit testing will be
required initially and annually for tight fitting,
negative-pressure, air purifying, full face
respirators with an assigned protection factor
greater than 10.
4.4.3 Protective Clothing:
The ES&H Representative will ensure that the
project provides protective clothing to employees
exposed to cadmium above the OEL or when skin
and eye irritation occur at any exposure level.
Protective clothing will include the following
items:
 Coveralls or similar full body work clothing
 Gloves, head coverings, and shoe coverings

Procedure BESH - IH C-011
Occupational Exposure to Cadmium
 Face shield, protective goggles, or other
appropriate protective equipment
The ES&H Representative will ensure that
employees remove protective clothing in
approved change rooms and do not allow
contamination to be taken offsite.
Contaminated disposable or reusable clothing will
be stored in sealed impermeable containers.
Contaminated clothing taken offsite will bear
cadmium labels.
Laundry facilities will be notified in writing of the
presence of cadmium and the potential hazards of
cadmium exposure, and of the need to maintain
exposure below the OEL.
4.4.4 Hygiene Areas and Practices:
The ES&H Representative will ensure that the
project provides clean and dirty change rooms and
a shower, lunchroom, and hand/face washing
facilities whenever the cadmium OEL is
exceeded, without regard to the use of respirators.
These facilities will be designed to prevent
dispersion of cadmium to street clothing and
exposure by ingestion.
 Change Rooms and Shower: Clean and
dirty change rooms will be designed to prevent
dispersion of cadmium dust to street clothing.
Separate storage facilities will be available for
street clothing. The change rooms will be located
at opposite sides of a shower, facilitating the use
of the shower before entering the clean room. Use
of these facilities will be required when the OEL
has been exceeded or is expected to be exceeded.
 Hand/Face Washing Facility: The ES&H
Representative will ensure that the project
provides readily accessible hand/face washing
facilities for employees subjected to cadmium
at any level. Employees will use these
facilities before they eat, drink, smoke, or
chew gum or tobacco.
 Lunchroom: The ES&H Representative will
ensure that the project provides lunchrooms
that are readily accessible to employees; that
tables for eating are maintained free of
cadmium, and that no employees are exposed
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Industrial Hygiene
to cadmium in lunch rooms at or above the
AL. No employee will be allowed in the
lunchroom wearing protective clothing and/or
with equipment that has been in a cadmium
environment unless surface cadmium has been
removed from the clothing and equipment by
HEPA vacuuming.
4.4.5 Housekeeping:
The ES&H Representative will ensure that the
project complies with the following housekeeping
requirements:
 Maintain all surfaces as free as practical of the
accumulation of cadmium contamination.
 Use HEPA vacuums or other equally effective
filtration systems to remove contamination
from surfaces or equipment.
 Clean up spills and other releases of cadmium
as soon as practicable.
 Seal waste, scrap, debris, bags, containers,
personal protective clothing, and equipment
designated for disposal in impermeable bags
or other impermeable containers.
 Use shoveling, dry or wet sweeping, and
brushing or scraping only when vacuuming
and/or other dust prevention methods are
found to be ineffective.
 Do not use compressed air to remove
cadmium-contaminated dust or debris.
4.4.6 Medical Surveillance:
Medical surveillance will comply with
requirements defined in CP-301, Medical
Surveillance, and the medical surveillance
requirements of this procedure. Each project or
facility will provide medical surveillance for all
employees who:
 Are or may be exposed to cadmium above the
AL more than 30 days per year and all
employees who perform the following tasks
more than 30 days per year:
 Electrical grounding with cadmium welding.

Procedure BESH - IH C-011
Occupational Exposure to Cadmium
 Cutting, brazing, burning, grinding or welding
on surfaces that were painted with cadmium-
containing paints.
 Electrical work using cadmium-coated
conduit.
 Use of cadmium containing paints.
 Cutting and welding cadmium-plated steel.
 Brazing or welding with cadmium alloys.
 Fusing of reinforced steel by cadmium
welding.
 Maintaining or retrofitting cadmium-coated
equipment and, wrecking and demolition
where cadmium is present.
 May have previously been exposed to
cadmium before the implementation of this
procedure and/or while conducting tasks
covered by this procedure, unless there is
proof that the employee did not perform the
tasks for more than 12 months.
 Exposure and medical records should be
obtained from previous employers for each
employee who had pre-Bechtel potential
exposure to cadmium. If these records are not
available, a medical examination should be
provided for the affected employee.
 Periodic medical examinations shall be
provided within one year after the initial
examination, and thereafter at least biennially.
Biological sampling shall be provided at least
annually as part of a periodic medical exam.
 Each project or facility will develop a medical
surveillance program. At a minimum, the
program must address the following elements:
o Who must receive the medical surveillance.
o Frequency of medical examinations.
o Frequency of bioassay tests.
o Medical examination criteria.
o Actions triggered by bioassay results
o Medical removal requirements
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o Employee removal benefits
o Employee notifications
o Recordkeeping requirements
4.4.7 Training:
Where there is a potential for exposure to
cadmium, the ES&H Representative will ensure
that cadmium is included in the project’s Hazard
Communication program as required by CP-202.
Where there is a potential for exposure to
cadmium, the ES&H Representative will ensure
that the project conducts training (and maintains a
record of such training) that meets the following
criteria:
 Training is conducted before an employee’s
assignment to work in an area where there is a
potential for exposure above the AL to
cadmium and at least annually thereafter.
 Training is conducted in an understandable
format for affected employees.
 Training covers the hazards of cadmium.
 Training includes location, quantity, and
manner of use, release, and storage of
cadmium in the workplace that could result in
exposure, especially above the OEL.
 Training includes engineering controls and
work practices to reduce the potential for
exposure for each employee’s job assignment.
 Training includes measures that employees
may take to protect themselves from exposure
to cadmium, such as modification of smoking
habits, hygiene practices, work practices,
emergency procedures, and provisions for
personal protective clothing and equipment.
 Training discusses the purpose, proper
selection, use, and limitations of respiratory
protection and protective clothing.
 Training covers medical surveillance program
requirements.
 Training covers employees’ rights of access to
records.
 Environmental,
Procedure BESH - IH C-011 Safety, and Health
Occupational Exposure to Cadmium
Industrial Hygiene

4.4.8 Recordkeeping:
All hard copy/electronic records generated as a
result of this procedure will be forwarded to the
project document control center (PDCC) and to
the project environmental, safety, and health
supervisor (ESHS). These records will be
maintained for at least 75 years past the affected
employee’s employment with Bechtel in
accordance with the Corporate Record Retention
Schedule.

All medical records maintained by the project

must be maintained confidentially and in a fire
prof locked cabinet with authorization only to
those individuals with a need to know (e.g.,
employee or authorized representative, project IH,
record custodian, Competent Person, Project
ES&H Lead, and medical personnel).

All air sampling data that is collected in

accordance with this procedure shall be entered
into the Bechtel Industrial Hygiene Sampling
electronic database.

Records will be made available to the affected

employee upon request.

5.0 REFERENCES
CP-317: Occupational Exposure to Carcinogens,
Mutagens, Teratogens
CP-202: Hazard Communication
CP-301: Medical Surveillance
CP-311: Respiratory Protective Equipment
CP-313: Air Surveillance Program

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