If you believe you have been exposed to an unknown and/or hazardous chemical and you are not involved in an ongoing emergency situation, please contact the EH&S Hotline at 310-825-9797, Mailbox 1. It is an employee’s right to request an evaluation from their employer to determine whether an exposure assessment is needed.
Cal/OSHA requires that all employers measure an employee’s exposure to any substance regulated by a standard which requires monitoring if there is reason to believe that exposure levels for that substance exceed the action level (or in the absence of an action level, the exposure limit). Repeated monitoring may be required if initial monitoring identifies employee exposure over the action level or permissible exposure limit (PEL).
Cal/OSHA regulates PELs for airborne contaminants to which nearly all workers may be exposed daily during a 40-hour workweek for a working lifetime (of 40 years) without adverse effect, and are based upon an 8-hour Time-Weighted Average (TWA) exposure. Thus, the PELs are the maximum permitted 8-hour TWA concentration of an airborne contaminant without the use of respiratory protection. Cal/OSHA has also defined Short Term Exposure Limits (STELs) as the maximum TWA exposure during any 15-minute period, provided the daily PEL is not exceeded and Ceiling (C) exposures that shall not be exceeded at any time.
Cal/OSHA has listed established PELs, STELs and Ceiling exposures for chemical contaminants identified in CCR Title 8 Section 5155 (Airborne Contaminants) Table AC-1. In the absence of a published Ceiling limit, Cal/OSHA requires employee exposure to concentrations above the PEL be controlled to prevent harmful effects. Further, Cal/OSHA has promulgated specific standards covering several regulated carcinogens, which may include an Action Level (AL), triggering medical surveillance requirements or the imposition of a specific Excursion Limit (such as for asbestos) with a unique measurement of the duration of an exposure.
Additionally, the Safe Drinking Water and Toxic Enforcement Act of 1986 requires Cal/EPA to publish annually a list of Proposition 65 chemicals known to the State to cause cancer or other reproductive toxicity.
When is an exposure assessment necessary?
All University employees require protection from exposure to hazardous chemicals above PELs, STELs and Ceiling concentrations. Exposure assessments are conducted in an event that an individual may have been potentially exposed to hazardous chemicals. Cal/OSHA requires the person supervising, directing or evaluating the exposure assessment monitoring be competent in the practice of industrial hygiene. Thus, exposure assessment should be performed only by representatives of EH&S and not the PI/Laboratory Supervisor. EH&S utilizes various methods when assessing exposure to hazardous chemicals including employee interviews, visual observation of chemical use, evaluation of engineering controls, use of direct reading instrumentation, or the collection of analytical samples from the employee’s breathing zone General questions regarding exposure assessment or the Industrial Hygiene Program can be directed to indhyg@ehs.ucla.edu or 310-794-5080.
The assessment evaluation will look at the various ways to minimize potentially harmful exposure using a combination of engineering controls, administrative controls and personal protective equipment, listed in order of priority. Personal exposure assessment will be performed under either of the following situations:
- EH&S determines an exposure assessment is warranted by reviewing chemical inventories, reviewing Standard Operating Procedures (SOPs), types of engineering controls present, laboratory inspection results and/or reviewing the annual Laboratory Hazard Assessment Tool.; or
- User of a hazardous chemical has reason to believe exposure is not minimized or eliminated through use of engineering controls or administrative practices (such as transfer of a chemical through a double needle performed entirely in a fume hood) and the potential for exposure exists. The user should then inform his or her PI/Laboratory Supervisor, who will in turn contact the EH&S Industrial Hygiene Program, EH&S Radiation Safety Division, EH&S Injury Prevention Division, or the University’s Occupational Health Facility (OHF). EH&S and OHF will then determine the best course of action in assessing employee exposure, including visual assessment, air monitoring, medical evaluation, examination, or medical surveillance.; or
- A regulatory requirement exists to perform an initial and if warranted periodic monitoring.
In the event of any serious injury or exposure, including chemical splash involving dermal or eye contact, immediately call 911 from a campus phone or 310-825-1491 from an off-campus or cell phone and obtain medical treatment immediately. Do not wait for an exposure assessment to be performed before seeking medical care.
Exposure assessment protocol – Notification to employees or employee representatives and right to observe monitoring
The EH&S Industrial Hygiene Program conducts exposure assessments for members of the campus community. Employees have a right to observe testing, sampling, monitoring or measuring of workplace exposures. They are also allowed access to their records and reports related to their exposure assessment. Exposure assessments may be performed for hazardous chemicals, as well as for physical hazards including noise and heat stress, to determine if exposures are within PELs or other appropriate exposure limits that are considered safe for routine occupational exposure. General protocol in conducting an exposure assessment may include any of the following:
- Employee interviews;
- Visual observation of chemical usage and/or laboratory operations;
- Evaluation of simultaneous exposure to multiple chemicals;
- Evaluation of potential for absorption through the skin, mucus membranes or eyes;
- Evaluating existing engineering controls (such as measuring face velocity of a fume hood);
- Use of direct reading instrumentation; and
- Collection of analytical samples of concentrations of hazardous chemicals taken from the employees breathing zone, or noise dosimetry collected from an employee’s shirt collar or various forms of radiation dosimetry.
Medical surveillance provisions are followed when exposure monitoring exceeds the action level (or the PEL) for a hazard for which OSHA has developed a specific standard (e.g., lead). It is the responsibility of the PI/Laboratory Supervisor to ensure that any necessary medical surveillance requirements are met. When necessary, EH&S will make recommendations regarding adjustments to engineering controls or administrative procedures to maintain exposure below any applicable PEL. Where the use of respirators is necessary to maintain exposure below PELs, the Principal Investigator will provide, at no cost to the employee, the proper respiratory equipment and training. Respirators will be selected and used in accordance with the requirements of CCR Title 8 Section 5144 and UCLA’s Respiratory Protection Program.
In assessing exposure to hazardous chemicals for which Cal/OSHA has not published a PEL, STEL or Ceiling exposure, EH&S defers to the Threshold Limit Values (TLVs) established by the American Conference of Governmental Industrial Hygienists (ACGIH) or the Recommended Exposure Limits (RELs) established by the National Institute of Occupational Safety & Health (NIOSH).
Notification
The Industrial Hygiene Program will promptly notify the employee and his/her PI/Laboratory Supervisor of the results in writing (within 15 working days or less when required by regulation) after receipt of the monitoring results. The Industrial Hygiene Program will establish and maintain an accurate record of any measurements taken to monitor exposures for each employee. Records, including monitoring provided by qualified vendors, will be managed in accordance with CCR Title 8 Section 3204 “Access to Employee Exposure and Medical Records”.
Exposure Assessment Used to Determine and Implement Controls
EH&S and OHF will use any of the following criteria to determine required control measures to reduce employee’s occupational exposure:
- Verbal information obtained from employees regarding chemical usage;
- Visual observations of chemical use or laboratory operations;
- Evaluation of existing engineering control measures or administrative practices;
- Recommendations expressed in Safety Data Sheets;
- Regulatory requirements of Cal/OSHA;
- Recommendations from professional industrial hygiene organizations;
- Direct reading instrumentation results;
- Employee exposure monitoring results; and/or
- Medical evaluation, examination and/or surveillance findings.
Particular attention shall be given to the selection of safety control measures for chemicals that are known to be extremely hazardous. Per Cal/OSHA CCR Title 8 Section 5141 “Control of Harmful Exposure to Employees”, the control of harmful exposures shall be prevented by implementation of control measures in the following order:
- Elimination
- Substitution
- Engineering controls, whenever feasible;
- Administrative controls whenever engineering controls are not feasible or do not achieve full compliance and administrative controls are practical; and
- Personal protective equipment, including respiratory protection, during:
- the time period necessary to install or implement feasible engineering controls
- when engineering and administrative controls fail to achieve full compliance
- in emergencies
Medical Evaluation
All employees, student workers, medical health services volunteers, or laboratory personnel who work with hazardous chemicals shall have an opportunity to receive an employer-provided medical evaluation, including supplemental examinations which the evaluating physician determines necessary, under the following circumstances:
- Whenever an employee develops signs or symptoms associated with a hazardous chemical to which an employee may have been exposed in a laboratory;
- Where personal monitoring indicates exposure to a hazardous chemical is above a Cal/OSHA Action Level (AL) or Permissible Exposure Limit (PEL) or recommended exposure levels established by the National Institute for Occupational Safety & Health (NIOSH) or the American Conference of Governmental Industrial Hygienists (ACGIH) in the event Cal/OSHA has not established an AL or PEL for a particular hazardous chemical;
- Whenever an uncontrolled event takes place in the work area such as a spill, leak, explosion, fire, etc., resulting in the likelihood of exposure to a hazardous chemical; or
- Upon reasonable request of the employee to discuss medical issues and health concerns regarding work-related exposure to hazardous chemicals.
All work-related medical evaluations and examinations will be performed under the direction of UCLA’s OHF by licensed physicians or staff under the direct supervision of a licensed physician. Evaluations and examinations will be provided without cost to the employee, without loss of pay, and at a reasonable time and place.
Any researcher who exhibits signs and symptoms of adverse health effects from work-related exposure to a hazardous chemical should report immediately for a medical evaluation to either:
- Employees- UCLA’s Occupational Health Facility
- Students- Arthur Ashe Student Health and Wellness Center.
Refer to your Department’s Injury & Illness Prevention Program (IIPP) for procedures on how to obtain medical evaluation under the above-listed circumstances.
Information to Provide to the Clinician
At the time of the medical evaluation, the following information shall be provided to OHF:
- Personal information such as age, weight and University employee ID number;
- Common and/or International Union of Pure and Applied Chemistry (IUPAC) name of the hazardous chemicals to which the individual may have been exposed;
- A description of the conditions under which the exposure occurred;
- Quantitative exposure data, if available;
- A description of the signs and symptoms of exposure that the employee is experiencing, if any;
- A copy of the Safety Data Sheet (SDS) of the hazardous chemical in question;
- History of exposure including previous employment and non-occupational (recreational) hobbies; and
- Any additional information helpful to OHF in assessing or treating an exposure or injury such as a biological component of exposure or existence of an antitoxin.
Physician’s Written Opinion
For evaluation or examinations required by Cal/OSHA, the employer shall receive a written opinion from the examining physician which shall include the following:
- Recommendation for further medical follow-up;
- Results of the medical examination and any associated tests, if requested by the employee;
- Any medical condition which may be revealed in the course of the examination which may place the employee at increased risk as a result of exposure to a hazardous chemical found in the workplace; and
- A statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination or treatment.
Confidentiality & Individual’s Access to Personal Medical Records
All patient medical information is protected by California and federal law and is considered strictly confidential. OHF is prohibited from disclosing any patient medical information that is not directly related to the work-related exposure under evaluation and will not reveal any diagnosis unrelated to the work-related exposure. Any patient information disclosed by OHF to the employee’s supervisor will be limited to information necessary in assessing an employee’s return to work, including recommended restrictions in work activities, if any. Any patient information disclosed by OHF to EH&S will be limited to information necessary to develop a course of exposure monitoring, or perform hazard assessments and incident investigations, if appropriate. OHF will otherwise disclose patient medical information only as required by California and Federal law, such as for Worker’s Compensation Insurance claims. Each employee has the right to access his/her own personal medical and exposure records. OHF will provide an employee with a copy of his/her medical records upon written request.
Medical Surveillance
Medical surveillance is the process of using medical examinations, questionnaires and/or biological monitoring to determine potential changes in health as a result of exposure to a hazardous chemical or other hazards. Certain Cal/OSHA standards require clinical examination as part of medical surveillance when exposure monitoring exceeds an established Action Level or PEL.
OHF and/or outside vendors may provide medical surveillance services. Medical surveillance is required of employees who are routinely exposed to certain hazards as part of their job description (such as asbestos) and may be offered to other employees based upon quantifiable or measured exposure.
Examples of hazards that are monitored through the medical surveillance program may include:
- Asbestos
- Beryllium
- Formaldehyde
- Lead
- Methylene Chloride
- Noise (Hearing Conservation Program)
- Radioactive Chemicals (Bioassay Program)
- Respirator Use (Respirator Protection Program)
- Other Particularly Hazardous Substances
Individuals with questions regarding work-related medical surveillance are encouraged to contact OHF at 310-825-6771 or the EH&S Hotline at 310-825-9797 for more information.