Calvin College Chemical Hygiene Plan
Exposure Assessments, Medical Consultations, and Examinations
Suspected Exposures to Toxic Substances
There may be times when employees or supervisors suspect that an employee has been exposed to a hazardous chemical to a degree and in a manner that might have caused harm to the victim. If the circumstances suggest a reasonable suspicion of exposure, the victim is entitled to a medical consultation and, if so determined in the consultation, also to a medical examination. All medical examinations and consultations shall be provided without cost to the employee, without loss of pay, and at a reasonable time and place.
Criteria for Reasonable Suspicion of Exposure
It is the policy of Calvin College to promptly investigate all employee-reported incidents in which there is even a remote possibility of employee overexposure to a toxic substance.
Events or circumstances that might reasonably constitute overexposure include:
- A hazardous chemical leaked or was spilled or was otherwise rapidly released in an uncontrolled manner.
- A laboratory employee had direct skin or eye contact with a hazardous chemical.
- A laboratory employee manifests symptoms, such as headache, rash, nausea, coughing, tearing, irritation or redness of eyes, irritation of nose or throat, dizziness, loss of motor dexterity or judgment, etc., and some or all of the symptoms disappear when the person is taken away from the exposure area and breathes fresh air, and the symptoms reappear soon after the employee returns to work with the same hazardous chemicals.
- Two or more persons in the same laboratory work area have similar complaints.
Exposures
All exposure complaints and their disposition, no matter what the ultimate disposition may be, are to be documented by the Chemical Hygiene Officer using the Employer's First Notice of Injury Form and Employee Exposure Report Form. Copies of these forms shall be sent to Human Resources. If no further assessment of the event is deemed necessary, the reason for that decision shall be included on the Employee Exposure Report Form. If the decision is to investigate, a formal exposure assessment will be initiated by the Chemical Hygiene Officer.
Exposure Assessment
In cases of emergency, exposure assessments are conducted after the victim has been treated, otherwise exposure assessments should be completed BEFORE medical consultations are undertaken. NOTE: It is not the purpose of an exposure assessment to determine that a failure on the part of the victim, or others, to follow proper procedures was the cause of an exposure. The purpose of an exposure assessment is to determine that there was, or was not, an exposure that might have caused harm to one or more employees and, if so, to identify the hazardous chemical or chemicals involved. Other investigations might well use results and conclusions from an exposure assessment, along with other information, to derive recommendations that will prevent or mitigate any future overexposures. However, exposure assessments determine facts; they do not make recommendations.
Unless circumstances suggest other or additional steps, these actions constitute an exposure
assessment:
- Interview the complainant and also the victim, if not the same person.
- List the essential information about the circumstances of the complaint, including:
- The chemical under suspicion.
- Other chemicals used by victim.
- All chemicals being used by others in the immediate area.
- Other chemicals stored in that area.
- Symptoms exhibited or claimed by the victim.
- How these symptoms compare to symptoms stated in the materials safety data sheets for each of the identified chemicals.
- Were control measures, such as personal protective equipment and hoods, used properly?
- Were any air sampling or monitoring devices in place? If so, are the measurements obtained from these devices consistent with other information?
- Monitor or sample the air in the area for suspect chemicals.
- Determine whether the victim's symptoms compare to the symptoms described in the MSDS or other pertinent scientific literature.
Notification of Results of Monitoring
Within 15 working days of receipt of the results of any monitoring, notify affected employees of
those results.
Medical Consultation and Examination
If employees feel that they have been exposed to hazardous chemicals, employees are required to contact the Chemical Hygiene Officer who will assist them in arranging for an Exposure Assessment if necessary. The Exposure Assessment will be utilized by the consulting physician to determine if further medical consultations and examinations are warranted.
The details of medical consultations and examinations are determined by the physician.
The purpose of a medical consultation is to determine whether a medical examination is warranted. When, from the results of an Exposure Assessment, it is suspected or known that an employee was overexposed to a hazardous chemical or chemicals, the employee should obtain medical consultation from or under the direct supervision of a licensed physician. When warranted, employees also should receive a medical examination from or under the direct supervision of a licensed physician who is experienced in treating victims of chemical overexposure. The medical professional should also be knowledgeable about which tests or procedures are appropriate to determine if there has been an overexposure; these diagnostic techniques are called "differential diagnoses."
These provisions apply to medical consultations and examinations:
- All employees who work with hazardous chemicals must be provided an opportunity to receive medical consultation and examination when:
- The employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory.
- Monitoring, routine or otherwise, suggests that there could have been an exposure above the action level, or OSHA PEL if there is no action level, for a chemical for which an OSHA substance-specific standard has been established.
- There is a spill, leak, or other uncontrolled release of a hazardous chemical.
Provide the physician with:
- The identity of the hazardous chemical or chemicals to which the employee may have been exposed (Formal Exposure Assessment if available).
- The exposure conditions.
- The signs and symptoms of exposure the victim is experiencing, if any
.
Ordinarily, physicians will furnish to the Calvin College Human Resources in written form:
- Recommendations for follow-up, if determined to be pertinent.
- A record of the results of the consultation and, if applicable, of the examination and any tests that were conducted.
- Conclusions concerning any other medical condition noted that could put the employee at increased risk.
- A statement that the employee has been informed both of the results of the consultation or examination and of any medical condition that may require further examination or treatment.
These written statements and records should not reveal specific findings that are not related to an occupational exposure.
Documentation: All memos, notes, and reports related to a complaint of actual or possible exposure to hazardous chemicals are to be maintained as part of the record.
Notification: Employees shall be notified of the results of any medical consultation or examination with regard to any medical condition that exists or might exist as a result of overexposure to a hazardous chemical.
Return to the Chemical Hygiene Plan Index.
Last updated by Brian K. Dokter on
May 12, 1997.