510 EM 385-1-1 Chapters 1-8

Sections

6-8. General Requirements.

Industrial Ergonomics

Employees' activities involving physical stress must be evaluated by a Certified Professional (CP) to ensure a match with their capabilities.
Employers must identify and document hazards and controls through the associated Activity Hazard Analysis (AHA), focusing on cumulative trauma hazards.
Specific measures, such as anti-vibration tools and medical surveillance, must be implemented to minimize vibration and adhere to Threshold Limit Values (TLV).

Indoor Air Quality (IAQ) Management

IAQ issues must be addressed promptly by facility managers or lessors, following guidelines by recognized organizations like ACGIH and EPA.
Protection against Environmental Tobacco Smoke (ETS) and vaping products in work environments is mandatory, with designated smoking areas established.
Mold assessments, overseen by competent inspectors, are required when indicated, with post-remediation air sampling and employee notifications being crucial steps.

Control of Chromium (VI) Exposure

All activities with potential chromium (VI) exposure must undergo risk assessment and air sampling by an Industrial Hygienist (IH) as per OSHA/EPA standards.
Employers must avoid chromium-containing materials when possible, and if used, provide proper Personal Protective Equipment (PPE) and decontamination facilities.
Housekeeping plans and decontamination programs are essential in areas where chromium (VI) is generated or used, ensuring minimal exposure.

Crystalline Silica

Employers must ensure no employee is exposed to respirable crystalline silica above the specified limits, conducting regular exposure assessments.
Control mechanisms are required if action levels of silica exposure are exceeded, with reassessment in case of any changes in the work environment.
If the potential for silica exposure exists, a written Silica Compliance Plan must be developed and employees trained according to local and federal requirements.

6-9. Figures and Tables.

See Figures/Tables Checklists/Forms

6-10. Checklists and Forms.

Not applicable.

Knowledge Check Choose the best answer for the question.

6-11. All activities with potential chromium (VI) exposure must undergo _____.

an evaluation of control mechanisms

an Industrial Hygienist (IH) risk assessment

energy consumption analysis

an Activity Hazard Analysis (AHA)

You forgot to answer the question!

EM 385-1-1 Paragraph 6-8 (n.–q.).

6-8. General Requirements (n.–q.).

n.  Industrial Ergonomics.  (6-8.n)

(1)  Work activities that require employees to conduct lifting, handling, or carrying; rapid and frequent application of high grasping forces; repetitive hand/arm manipulations; tasks that include continuous, intermittent, impulsive, or impact hand-
arm vibration or whole-body vibration; and other physical activities that stress the body's capabilities must be evaluated by a CP to ensure the activities are designed to match
the capabilities of the employees.

(2)  When work activities include items listed in paragraph 6-8.n(1), the employer must identify and document hazards and controls via the associated AHA.  The AHA must incorporate processes that recognize cumulative trauma hazards, isolate causative factors, provide controls and train as appropriate.

(3)  Specific control measures to minimize vibration may include use of anti- vibration tools and/or gloves; implementation of work practices that keep the employee's hands and body warm/minimize vibration coupling between employee and the vibration tool; application of specialized medical surveillance to identify personnel susceptible to vibration; and adherence to TLV guidelines as specified by ACGIH in "Threshold Limit Values and Biological Exposure Indices".  For USACE only, the evaluation must be according to ER 385-1-96, ANSI S2.70, ANSI S2.73, ISO 5349, and ISO 8662.

o.  Indoor Air Quality (IAQ) Management.  (6-8.o)

(1)  Investigations.  IAQ must be brought to the attention of the facility manager/owner or other designated representative who is responsible for resolving the
IAQ complaint in a timely manner.  For leased facilities, procedures for resolving IAQ issues should ultimately be investigated and resolved by the lessor.  An IH or CP should initiate an IAQ investigation using appropriate guidelines published by ACGIH; AIHA; ANSI; American Society of Heating, Refrigeration, and Air Conditioning Engineers; EPA; OSHA; NIOSH; or other federal, DoD, state, local, and host nation requirements.

(2)  Environmental tobacco smoke (ETS) and vaping products.  Employees must be protected from involuntary exposure to ETS and vaping in working and public living environments. Smoking, to include the use of smokeless cigarettes or cigars, is prohibited inside all DoD vehicles, aircraft, vessels, and work buildings.  Provide designated smoking areas (that is, outdoors) that are at least 50 feet (15.2 m) from building entrances and in areas that are not commonly used or accessed by nonsmokers.

(3)  Mold Assessment.  Because mold can contribute to health concerns ranging from minor irritation to serious debilitation if found in high quantities or improper locations, a mold assessment must be performed when need is indicated.

(a)  Assessments/remediation must be overseen by a competent mold inspector according to paragraph 6-3.i.

(a-1)  Mold remediation should not be performed by the same entity that performed the mold assessment.

(a-2)  Employees in the immediate area of the mold contamination must be informed of the remediation, results of any testing, and symptoms of the hazard.  The employees must not be in the area during the remediation.

(a-3)  Post-remediation air sampling must be done in the immediate area and in any areas in the mold spore or vegetative air-pathway and compared to outside air samples.  Mold in areas above drop ceilings with combined air plenums must have air samples taken within the plenum as well as in air-serviced areas.  Air samples should
be taken in the immediate area of remediation and analyzed by a laboratory in the AIHA Environmental Microbiology Laboratory Accreditation Program.

(b)  A visual assessment of potential mold hazards must be performed, based on criteria in the TG 278, the EPA IAQ Management Checklists, and guidance from AIHA. Bulk and/or air samples are generally not necessary to evaluate mold hazardous environments.

(c-1)  Description of the area assessed including size (footprint), ventilation, and occupancy.

(c-2)  Name and qualifications of the individual completing the assessment.
(c-3)  Results of samples taken, including location of the sample result, date and time of the sample, temperature, and humidity at the time of the sample, and laboratory procedure used to analyze the sample.

(c-4)  Drawing of the area showing location of samples, location of visible mold or mildew and the type of substrate it is growing on, ventilation sources in the room, and other information thought to be important.

(c-5)  Potential sources of the moisture which has caused the mold growth.
(c-6)  Recommendations for controlling the problem and remediating the mold. (d)  Causes of mold (for example, water leakages, seepages, drainage,
HVAC/insulation damage) must be addressed before completing mold remediation.

(e)  If the assessment indicates remediation is required, a Mold Remediation Plan must be developed according to paragraph 6-7.h.

p.  Control of Chromium (VI) Exposure.  (6-8.p)

(1)  General.  All activities which could generate chromium (VI) fumes, mists, or dusts must be evaluated by an IH to determine potential personnel exposure over the OEL.  Typical operations where chromium exposures are high include cutting or breaking up of cement surfaces made from Portland cement with a high chromium content, painting or paint removal operations, welding using rods or wire with a chromium coating, heating or welding on stainless steel, and handling or applying anti- corrosive substances or coatings.

(a)  The evaluation must include a risk assessment of the type and frequency of exposure and breathing zone air sampling in the work and surrounding area according to applicable OSHA/EPA standards.

(b)  The evaluation must be added as an appendix to the APP or the Project SOH Plan.  Individual sample results must be provided to the employee and add to their official occupational health record and a summary of the sample results should be posted in the work area.

(2)  To prevent exposure to chromium (VI), the use of paints with chromium pigments, Portland cement with greater than 0.002% chromium, or chromium/arsenic treated lumber must be avoided when possible.  Should chromium (VI) containing products be required, a justification and similar non-chromium (VI) product evaluation must be conducted and submitted for review by the local SOHO/USACE supervisor/KO or COR.

(3)  If chromium containing compounds are used and the objective determination is inconclusive, before air sampling confirms the level of exposure, the employer must
comply with the requirements of 29 CFR 1910.1026 (29 CFR 1910 Subpart Z), 29 CFR
1915.1026 (29 CFR 1915 Subpart Z), or 29 CFR 1926.1126 (29 CFR 1926 Subpart Z), whichever is applicable.  At a minimum, employers must provide appropriate PPE, respirators, decontamination facilities, and a lunchroom/area clean from chromium (IV) dust and/or fume.

(4)  If air sampling confirms chromium (VI) exposure over the OEL, and there is no adequate substitute or work practice change (for example, use of argon instead of carbon dioxide (CO2) when arc welding), then the employer must provide appropriate engineering controls (for example, local HEPA filtered ventilation systems, medical surveillance, housekeeping, and air sampling as required by the applicable chromium (VI) standard).  If adequate engineering controls are not feasible or appropriate due to the length of the task, then PPE must be provided.

(5)  In areas where chromium (VI) is generated or used, there must be a housekeeping plan according to applicable OSHA/EPA standards and decontamination program instituted.

(a)  Maintain surfaces as free as practicable of accumulations of chromium (VI), as required by the applicable OSHA standard.

(a-1)  The employer will ensure that surfaces contaminated with chromium (VI) are cleaned by HEPA-filter vacuuming or other methods that minimize the likelihood of exposure to chromium (VI).

(a-2)  The employer will ensure cleaning equipment is handled in a manner which minimizes the reentry of Chromium (VI) into the workplace.

(b)  At a minimum all exhaust and ventilation systems must be cleaned and filters changed according to manufacturer’s recommendations.

(c)  Workers will not enter eating and drinking areas with protective work clothing or equipment unless surface chromium (VI) has been removed from the clothing and equipment by methods that do not disperse chromium (VI) into the air.

q.  Crystalline Silica.  (6-8.q)

(1)  The employer must ensure no employee is exposed to an airborne concentration of respirable crystalline silica more than 25 micrograms (ACGIH) per cubic meter of air, as calculated as an 8-hour TWA.

(2)  All exposures to respirable crystalline silica, except where employee exposure will remain below 25 micrograms per cubic meter of air as an 8-hour TWA, will be regulated by applicable OSHA/EPA standards.
(3)  The employer must assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level (12.5 micrograms per cubic meter of air as an 8-hour TWA).

(a)  If initial monitoring indicates employee exposures are below the action level, the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring.

(b)  Where the most recent exposure monitoring indicates employee exposures are at or above the action level, but at or below the OEL, the employer must repeat such monitoring within six months of the most recent monitoring.

(c)  Where the most recent exposure monitoring indicates employee exposures are above the OEL, the employer must repeat such monitoring within three months of the most recent monitoring.

(d)  Where the most recent (non-initial) exposure monitoring indicates employee exposures are below the action level, the employer must repeat such monitoring within six months of the most recent monitoring until two consecutive measurements, taken seven or more days apart, are below the action level, at which time the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring.

(e)  The employer must reassess exposures whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected
to result in new or additional exposures at or above the action level, or when the employer has any reason to believe new or additional exposures at or above the action level have occurred.

(4)  Control mechanisms must be implemented to reduce employee exposures if exposure data indicates action levels are exceeded.

(5)  If the evaluation shows the potential for activities to generate an occupational exposure to silica exceeding the action level, a written Silica Compliance Plan must be developed according to paragraph 6-7.i and employees trained according to paragraph
6-3.h. If regulations in local jurisdictions exceed federal requirements, the most stringent will apply.

510 EM 385-1-1 Chapters 1 - 8