Approved 11/09/98 REQUIREMENT A. Occupational Illness/Injury Unusual Occurrence (4) Personnel exposures to sufficient levels of hazardous substances or hazards that require the administration of medical treatment on the same day as the exposure and are above limits established by the Occupational Safety and Health Administration (refer to 29 CFR 1910) or American Conference of Governmental Industrial Hygienists (ACGIH), whichever is lower. These should include: (a) Noise (b) Non-ionizing radiation (c) Chemical Agents (d) Physical Agents (e) Biological Agents Off-Normal (3) Personnel exposure in a single event to hazardous substances or hazards in excess of limits, as established by the Occupational Safety and Health Administration (refer to 29 CFR 1910), or American Conference of Governmental Industrial Hygienists (ACGIH), whichever is lower. These should include: (a) Noise (b) Non-ionizing radiation (c) Chemical Agents (d) Physical Agents (e) Biological Agents INTERPRETATION The term "exposure" can be viewed in two different aspects. Specifically: 1. Is the term "personnel exposure" in this paragraph intended to reflect the OSHA definition of employee exposure? OSHA defines exposure as the ambient concentration that an employee is exposed to regardless of personal protective equipment (PPE), such as respirators (thereby assessing the effectiveness of engineering or administrative controls). This would require reporting whenever a Permissible Exposure Limit (PEL) or Threshold Limiting Value (TLV) is exceeded, regardless of PPE. OR 2. Does the term "exposure" relate to the exposure an employee receives when accounting for the personal protection equipment worn? This criterion, as written, does not reflect the application of protection factors afforded by respirators. But clearly this would represent the person's exposure from an inhalation aspect. I would like clarification on this reporting criterion as related to ORPS reporting and what is to be reported as off-normal. Intent: The sense of the term "exposure" as used in the second example above is the accurate meaning in this instance. Exposure relates to the exposure that an employee receives when accounting for the personal protection equipment worn. Additional Information: In this context, the appropriate interpretation of the term "exposure" may be best described as an incident of contact or encounter with a hazardous chemical, physical, biological, or energetic agent at one of the exchange boundaries of the organism (e.g., skin, respiratory system, eyes, ears, or digestive system). "Exposure" does not refer to a situation where personnel, protected by appropriate personal protective equipment, are subjected to an environment whose ambient conditions present a harmful level of any one, or combination of, the hazards (a) through (e) above. When personnel exposures to the aforementioned hazards are eliminated, or at least diminished to levels not exceeding mandated limits, through the use of appropriate administrative or engineering controls, or PPE, then there is no exposure occurrence. It is not necessary to file an occurrence report for situations in which there is no occurrence. A decision to report an "off-normal" occurrence should be prompted by the identification of an abnormal or suspected abnormal event or condition in which personnel exposure exceeded, or is suspected to have exceeded, a PEL or TLV. |
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