Industrial Hygiene:
Occupational Exposure and Health Hazards Management Program

Suggested lines of inquiry and review approach

The assessor will observe the following:

• The full spectrum of hazards associated with the scope of work, and facility operations, is identified, analyzed, and categorized. Those individuals responsible for the analysis of the industrial hygiene hazards are integrated with; the work planning team, those personnel assigned to analyze the activity processes.
• An integrated process has been established and is utilized to develop controls that mitigate identified hazards present within a facility or activity. The set of controls ensure adequate protection of the public, worker, the environment, and are established as agreed upon by DOE. These mechanisms provide integration which merge together with work being preformed.
• An integrated process has been established and is utilized to effectively plan, authorize and execute the identified work for the facility or activity. Both workers and management demonstrate a commitment to ISMS. These mechanisms demonstrate effective integration with ISMS guiding principles.
• A process has been established, is utilized, which ensures that mechanisms are in place to ensure continuous improvement are implemented through an assessment and feedback process, which functions at each level of work and at every stage in the work process.
• Clear and unambiguous roles and responsibilities are defined and maintained at all levels within the facility or activity. Facility or activity line managers are responsible and accountable for safety. Facility/activity personnel are competent commensurate with their responsibility for worker health.
• Procedures and/or mechanisms are in place, utilized for the industrial hygiene area, and require adequate planning of individual work activities to ensure that hazards are analyzed and controls are identified.
• Procedures and/or mechanisms are in place, utilized to ensure clear roles and responsibilities for industrial hygiene. Line managers as part of their responsibility for worker health; ensure that industrial hygiene functions are appropriately and effectively integrated into work planning.
• Procedures and/or mechanisms are in place, utilized for the industrial hygiene area, to ensure controls are identified, developed, implemented; and that these controls are effectively integrated and confirmed prior to performing work.
• Procedures and/or mechanisms are in place, utilized to ensure personnel assigned industrial hygiene responsibilities have a satisfactory level of competence.
• Procedures and/or mechanisms are in place, utilized to ensure feedback, continuous improvement occurs for the industrial hygiene area.
• Observe events, actual work operations, such as the development of a procedure, development of a hazards analysis such as a confined space permit, hot work permit, etc., and/or job hazard analysis, or the approval process for an individual work item, which include interactions with workers performing the task and technical experts of the subject area.

(Note: Insert your list of work activities to be observed, for example):

• Pre job activity hazard analysis and/or walk down of work activities
• Pre-Job Briefing
• Plan of the Day and Plan of the Week
• Hazard Specific Training Sessions
• Exposure monitoring
• Work location entry and egress.
• Personal Protective Equipment (PPE) use
• Work task performance.

Lines of Inquiry for Program Documentation Review:

The assessor will:

• Review the manuals of practice and selected records that define the procedures and interactions required for the industrial hygiene area at the facility or activity level.
• Assess the adequacy of the documents to meet the CRADS and determine that the industrial safety and industrial hygiene area is effectively integrated into the facility or activity procedures.
• Review any lessons learned to determine if lessons learned have been effectively used within the industrial hygiene area.
• Review training records of personnel in the industrial hygiene area to determine that they meet competency standards.
• Review the manuals of practice and selected records that define the procedures and interactions required for industrial hygiene program at the facility or activity level. The review will also consider the adequacy of the sites documents to meet the CRAD and to determine that the industrial hygiene is effectively integrated into facility or activity hazards analysis and conduct of operations.
• Review any lessons learned, occurrence reports, OSHA 300 logs that may provide an opportunity to determine if lessons learned have been effectively used, and corrective actions implemented, within the industrial hygiene area.
• Review position descriptions, training records, and qualification standards of personnel in the industrial hygiene area to determine that they meet competency standards.
• Review documents prior to the assessors arriving on-site, to the extent possible.

(Note: Insert the list of specific documents needed to be reviewed associated with the functional technical areas you have selected.)

• Occupational Health Program Document/Manuals/Guidance.
• Work Planning Hazards Analysis System
• Site Safety Management System Description
• Work Request/Work Order Process
• Facility and Occupant Emergency Management Guides and Plans
• Environmental Management Plan
• Conduct of Operations Documentation and Procedures
• Work Scheduling Procedures
• Sample Work Plans and Procedures: Preparation, Review and Approval
• Training Plans/Qualification Matrices
• Functional Position Descriptions
• ES&H and Line Manager Performance Appraisal Elements
• Craft Qualifications for Operators
• Qualifications Program and Examples for IH Technical Staff
• Lessons Learned Program Documentation
• Job Activity Hazards Analysis
• ESH Contract Clause, Annual Goals, and Award Fee Determinations
• Performance Indicator, Trending, and Goals System
• Site ES&H Budget and Program Plans
• IH Program Procedures Manual
• IH Exposure Assessment Procedures, Reports, Guides, Databases.
• OSHA 300 Logs, CAIRS, ORPS Reports.
• Internal and external IH Program Audit Reports and Findings Closure.
• HAZWOPER Site Safety and Health Plans.

Lines of Inquiry for Interviews:

The assessor will:

• Interview personnel, responsible DOE, and contractor managers in the industrial hygiene area assigned.
• Interview line managers to assess; management commitment, the establishment of accountability, clear roles, responsibilities, and the level support provided to mitigate exposures and health hazards to workers.
• Interview personnel assigned to the industrial hygiene area to assess depth and scope of practice, and the level of competence.

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