Your Company Name Airborne Contaminate Policy
Airborne Contaminates #1
1.1. Overview
1.2. Purpose
1.3. Methods of Compliance
1.4. Sub-Contractor Compliance
1.5. Exposure Evaluations
1.6. Employee Exposure Assessments
1.1. Overview
It is Your Co. Policy to anticipate, plan for, control, and capture airborne contaminates and
appropriately evaluate the jobsite for effective control of airborne contaminates.
1.2. Purpose
This Policy’s primary purpose is to provide procedures to ensure airborne contaminates are
effectively controlled on the jobsite. This Policy begins with hazard recognition and risk assessment,
and continues with implementing mechanisms for elimination and control. This Policy outlines
procedures which managers can use to determine the need for and method of initiating an objective
exposure evaluation.
1.3. Methods of Compliance
Your Co. recognizes the importance of controlling airborne contaminates on the job site. This
begins during pre-job planning and involves choosing appropriate work practices as well as
incorporating appropriate engineering controls and selection and/or respirator.
Specific Your Co. Policies should be evaluated during project/job planning to assess the potential for
the creation of airborne contaminates. Specific Policies that mandate control procedures for airborne
contaminates include:
Confined Space
Flammable and Combustible Liquids
Hazardous Materials
Hot work and Compressed Gas Cylinder Safety
Portable Heaters and Salamanders
Protecting the Public
Respiratory Protection
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Your Company Name Airborne Contaminate Policy
1.3.1. It is Your Co. policy to provide effective controls for airborne contaminates during
specific work tasks. Effective controls include:
1.3.1.1. Substitution of a toxic product for a less toxic product. Replacing silica sand with
an abrasive slag is an example.
1.3.1.2. Substitution of a procedure which liberates toxic airborne contaminates. Rolling
and brushing a toxic coating instead of spray application is an example.
1.3.1.3. Negative pressure ventilation systems (mechanical ventilation) which collect and
capture the airborne contaminate. The system may also direct contaminated air to
a safe and outside location.
1.3.1.4. Personal protective equipment (respirators)
1.3.1.5. Employee rotation is an administrative control. It is often the least desirable
because the air borne contaminate is still being created and not necessarily
controlled. This control is specifically prohibited for some air contaminates.
1.3.1.6. Your Co. will verify that any “Hazardous Non-Routine Tasks” where exposures
to air-borne contaminates may occur are identified and appropriately exposure
control procedures are communicated. This includes but is not limited to dust,
fumes, gases, mists, and vapors.
1.4. Sub-Contractor Compliance
1.4.1. Your Co. Policy is to verify that its Sub-contractors comply with Your Co. policies and
procedures to minimize the creation of and effectively control airborne contaminates on
the jobsite. In addition to specific Your Co. Policies, the following procedures should be
verified on the jobsite.
1.4.2. Effective measures should be taken to prevent airborne contaminate(s) from occurring,
migrating from the work site into areas occupied by the public or other employees’ work
areas. This includes assuring outlets and paths for air return to the central HVAC system
or public access are sealed with plastic to prevent recirculation of contaminated air.
Where necessary, enclosures will be erected and Your Co. will verify that proper
mechanical exhaust ventilation is in place to remove airborne contaminates from the
enclosure.
1.4.3. Employees are to comply with the following work practices and prohibitions in order to
eliminate, minimize and/or control airborne contaminates. These work practices and
prohibitions are to control dusts, fumes, gases, mists or vapors. Employees are prohibited
from the following:
1.4.4. Disturbing any asbestos (≤1 %) or asbestos containing material (> 1 %). Employees will
be informed during orientation of asbestos on the job site or adjacent to their work areas.
Employees are expected to verify with their immediate supervisor that materials slated
for disturbance (demolition, sawing, drilling breaking) have been evaluated for asbestos.
Supervisors are to verify that “Good Faith” asbestos surveys have adequately addressed
materials slated for disturbance and will provide effective communication to employees.
1.4.5. Disturbing any painted or coated surface where lead based paint or lead bearing material
or cadmium based paint or cadmium bearing material exits. No employee will disturb
any lead bearing material or cadmium bearing material unless the material has been
tested and competent determinations have been made regarding the job tasks.
1.4.6. Conduct indoor welding or cutting of any metal which takes more than one (1) minute
without mechanical ventilation. Indoor hot work taking longer than one minute will be
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Your Company Name Airborne Contaminate Policy
undertaken with negative pressure mechanical ventilation drawing the fumes away from
the employee and safety collecting them in dry filtration media or venting these fumes
and gases away from all employees/public. This includes cutting, grinding, welding or
other hot work performed on any painted or coated metal without the utilization of
negative pressure mechanical collection systems
1.4.7. and appropriate Employee Respiratory Protection. The Hot Work Permit will be
consulted for proper engineering control selection.
1.4.8. Mechanical sawing, drilling, routing or other dust creating job task conducted on any
cementitous material with out wetting the operation and using HEPA vacuum collection
and/or negative pressure collection at the point of dust creation.
1.4.9. Dry sweeping on any construction site that occurs for more than one (1) minute
conducted without a sweep-aid (dust suppressant). HEPA vacuuming is always
preferable to dry sweeping. This is not intended to prohibit workers from cleaning up
after themselves.
1.5. Exposure Evaluations
1.5.1. It is Your Co. policy to maintain employee exposures below the Permissible Exposure
Limits (PEL). Permissible Exposure Limits (PELs) have been established for most
airborne contaminates on the jobsite. An airborne contaminate may have one or more of
the following exposure limits.
Eight hour time weighted averages TWA8
Short term exposure limits (STEL)
Ceiling or instantaneous limits
1.5.2. The Safety Department will respond to any Your Co. Supervisor’s written or voice
notification of an airborne contaminate problem on a jobsite. When necessary the Safety
Department will arrange for a visit to the jobsite for further evaluation. The Safety
Department may utilize any one or more evaluation techniques. Where necessary the
Safety Department may coordinate an industrial hygiene assessment to accomplish the
employee exposure evaluation.
1.5.3. An Industrial hygiene evaluation of objective data is at times necessary if potentially
significant airborne contaminate exposures exist and/or controls are not effective. An
industrial hygiene evaluation can utilize many methods to objectively evaluate airborne
exposures. These may include:
Review of manufacturer’s safety data sheets
Review of work practices and review of engineering controls
Instantaneous monitoring
Personal air monitoring (dosimetry) to determine employee exposure(s)
Area air monitoring
Note: In cases where air monitoring occurs, a determination of fifty (50) percent of a PEL will
be the definition of significant airborne exposure.
1.5.4. Until such time that personal dosimetry can be conducted on those job tasks with the
greatest potential for creating airborne contaminate(s), those job tasks will require the use
of mechanical ventilation and/or respirators.
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1.6. Employee Exposure Assessments
During job tasks outlined in the Air Contaminates Decision Logic Chart (see end of Policy), it may
be necessary to objectively derived, employee exposure assessments. In the event this need arises,
the Safety Department will be notified and direct the exposure assessment.
Objective exposure evaluations may include:
1.6.1. Personal air monitoring or dosimetry, achieved by sampling the air in the employees’
breathing zone. Sampling techniques are sometimes specific to the airborne contaminate.
The sample is typically captured on a filter, adsorped onto or into (media) and then
analyzed by a laboratory technician.
1.6.2. Some employee exposure assessments can be accomplished instantaneously or real time,
such as confined space and enclosed space evaluations of oxygen, (O2), combustible
gases (lower explosive level, LEL), carbon monoxide (CO), hydrogen sulfide (H2S).
1.6.3. Employees may request and are entitled to receive exposure records for job tasks to
which they have been assigned and that have been evaluated.
1.6.4. Supervisors are encouraged to evaluated job tasks for the creation of air borne
contaminates. When work practices are not effective in the control of airborne
contaminates further evaluation is necessary. Employees are instructed to verify that job
tasks controls are in place and operating properly. If the job site conditions continue to
demonstrate poor control of an airborne contaminate the supervisor will be informed.
1.6.5. Supervisors will demonstrate effective control of all airborne contaminates on the job site.
Supervisors are encouraged to request assistance from the Safety Department when
normal control procedures are not effective.
1.6.6. Employees may be informed that air monitoring will occur and that they have the right
and responsibility to participate. The Your Co. process for conducting employee
exposure evaluations (personal dosimetry) is as follows:
1.6.7. The Safety Manager will verify the scope and conditions of the job task prior to initiating
an exposure assessment.
1.6.8. Supervisors and the Safety Department will coordinate when personal air monitoring is
planned.
1.6.9. Manufacturer’s Safety Data Sheets (MSDSs) will be identified and sent to the lab for
appropriate selection of sampling media.
1.6.10. Supervisors will follow the instructions provide by the analytical lab specific to sample
chain-of-custody, sampling procedures, sampling documentation and sample submission.
1.6.11. Employees will be asked to cooperate in personal exposure evaluations including wearing
sampling media during job tasks.
1.6.12. Sampling results will be communicated to effected employees within five (5) days of
receipt of results. This communication will also involve an evaluation of control
measures and PPE used during the personnel monitoring. Necessary changes will be
communicated at this time.
1.6.13. Exposure data will be used in training, made available to employees and their
representatives and maintained for thirty (30) years past last date of employment.
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Your Company Name Airborne Contaminate Policy
AIR CONTAMINATES
DECISION LOGIC CHART
Identify Construction Tasks which Create Airborne Contaminates
Identify Appropriate Controls (substitution, engineering controls & respirators)
Conduct Objective Assessment (Air Monitoring) to Evaluate Effectiveness of Control(s)
Evaluate Air Monitoring Results and Modify Controls as Necessary
YES Airborne Contaminates are
NO
Effectively Controlled?
Continue to
Are Employees
Evaluate Effective
Control Exposed?
NO
Are other people
exposed
Can Contaminate Control or Protection NO
be Achieved by:
Materials Substitution
Implement Control or Is there
Respiratory Protection YES Environmental
VERIFY COMPLIANCE Process Change
Impact
Engineering Control
NO
Respirators
NO Continue to
Regularly
CONTACT Evaluate
SAFETY DEPARTMENT
for
ASSISTANCE
The following job tasks have reliable and effective air contaminate
engineering control mechanisms:
Hot Work (Welding, Gas Cutting)
Abrasive Blasting, Boring, Grinding, Sanding, Sawing, Drilling, Routing
Flammable and Combustible Liquids/Materials Application
Internal Combustion Engine Operation, Burning of Combustible Fuels
Sweeping (Manual/Powered)
Materials Handling (Powered, Pneumatic, Manual Conveyance)
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