Wednesday, June 11, 2014

Exposure Control FAQs continued

Q11. Does the exposure control plan need to be a separate document?

A11. No. The exposure control plan may be part of another document, such as the facility's health and safety manual, as long as all components are included. However, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document which states the overall policy and goals and references the elements of existing separate policies that comprise the plan. For small facilities, the plan's schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document how the provisions of the standard are implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.

Q12. How often must the exposure control plan be reviewed?

A12. The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect, or create new occupational exposure, the existing plan must be reviewed and updated accordingly.

Q13. Must the exposure control plan be accessible to employees?

A13. Yes, the exposure control plan must be accessible to employees, as well as to OSHA and NIOSH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during the workshift. If the plan is maintained solely on computer, employees must be trained to operate the computer.
A hard copy of the exposure control plan must be provided within 15 working days of the employee's request in accord with 29 CFR 1910.1020.

Q14. What should be included in the evaluation of an exposure incident?

A14. Following an exposure incident, employers are required to document, at a minimum, the route(s) of exposure, and the circumstances under which the exposure incident occurred. To be useful, the documentation must contain sufficient detail about the incident. There should be information about the following:
  • The engineering controls in use at the time and work practices followed;
  • Description of the device in use;  
  • The protective equipment or clothing used at the time of the exposure incident;
  • Location of the incident and procedures being performed when the incident occurred; and
  • Employee’s training.
  • The source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law.
The employer should then evaluate the policies and "failures of controls" at the time of the exposure incident to determine actions that could prevent future incidents.

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