CADMIUM AWARENESS 7.1 PURPOSE 7.1.1 The purpose of this policy is to provide guidelines for safely working with cadmium. It includes provisions for training, PPE guidelines, monitoring, medical surveillance, housekeeping and general safety related work practices. 7.2 RESPONSIBILITIES 7.2.1 Safety department 7.2.1.1 Ensuring that ANSI approved PPE and supplies are available to protect employees from cadmium exposure. 7.2.1.2 Coordinate the required training for affected employees. Designate a competent person for those work activities affected by this safety policy and procedure. 7.2.1.3 Provide training, expertise and guidance to qualified persons to perform cadmium exposure assessments. 7.2.1.4 Make the written cadmium policy available to employees, OSHA and NIOSH representatives. 7.2.1.5 Maintain all medical records for the specific time periods outlined in this policy. 7.2.2 Supervisors 7.2.2.1 Ensure that no cadmium related operation is performed without the appropriate controls being in place as prescribed in this safety policy and procedure. 7.2.2.2 Assist competent and qualified persons as requested. 7.2.3 Competent person 7.2.3.1 Responsible for identifying existing and potential cadmium hazards in the workplace. 7.2.3.2 Responsible for and have complete authority to, take prompt corrective measures to eliminate or control cadmium hazards. 7.2.3.3 Determine, prior to beginning a job, whether cadmium is present in the workplace. 7.2.3.4 Establish regulated areas and ensure that access to and from those areas is limited to authorized employees. 7.2.3.5 Ensure adequacy of any employee exposure monitoring required by the standard. 7.2.3.6 Ensure that all employees exposed to airborne cadmium levels above the PEL wear appropriate PPE and trained to use appropriate methods to control cadmium exposure. 1 Prepared especially for PSC CRANE & RIGGING by
7.2.3.7 Ensure that proper hygiene facilities are provided and that workers are trained to use these facilities. 7.2.3.8 Ensure that required engineering controls are implemented, maintained in proper operating condition and function properly. 7.2.4 Qualified person 7.2.4.1 Responsible for conducting cadmium exposure assessments in accordance with this safety policy and procedure and established exposure assessment protocols. 7.2.5 Employee 7.3 MONITORING 7.2.5.1 Comply with all applicable guidelines contained in this safety policy and procedure. 7.2.5.2 Report unsafe acts associated with this safety policy and procedure to their supervisor. 7.2.5.3 Maintain PPE in good working order at all times and have them replaced when they become worn or unsafe. 7.2.5.4 Personnel employed by PSC CRANE & RIGGING and all contractors and subcontractors working at any and all construction sites operated by PSC CRANE & RIGGING are required to comply with the procedures and work practices outlined in this cadmium policy. 7.3.1 If cadmium may be present in any operation, then an initial exposure assessment must be made to determine whether an employee s exposure exceeds the action level. 7.3.2 Cadmium may be present if: 7.3.2.1 Any information, observations or calculation that would indicate employee exposure to cadmium (ex. SDSs, past reports, relevant plans) 7.3.2.2 Any previous measurements of airborne cadmium 7.3.2.3 Any employee complaints or symptoms that may be attributable to cadmium exposure 7.3.3 The initial assessment will document the exposure an employee would have without the use of a respirator. 7.3.4 If PSC CRANE & RIGGING can reduce the airborne concentration of cadmium in the air and two consecutive measurements collected seven days apart confirm cadmium exposures are below the action level, monitoring can be discontinued for each employee whose exposure is represented by this monitoring. Employee exposures below the action level require no further monitoring. 7.3.5 PSC CRANE & RIGGING will conduct additional monitoring wherever there has been a change in raw materials, personnel, equipment, work practices or finished products that may result in an employee being exposed to cadmium above the PEL. 2 Prepared especially for PSC CRANE & RIGGING by
7.3.6 Each employee monitored will be notified of the results within 15 working days after receipt of the results. 7.3.7 Employees or their designated representatives may observe cadmium monitoring procedures at the worksite. Employees or their designated representatives who observe the cadmium air monitoring are entitled to an explanation of the measurement procedure and to record the results that are obtained. Employee or their designated representatives must be provided with appropriate PPE during the cadmium monitoring. 7.4 EXPOSURE 7.4.1 Operations at PSC CRANE & RIGGING s worksites that may include exposure to cadmium include, but are not limited to: 7.4.1.1 Cutting, brazing, grinding or welding on surfaces that are painted with cadmium containing paints 7.4.1.2 Cadmium is found in some industrial paints and may represent a hazard when spray applied 7.4.1.3 Transporting, storing and disposing of cadmium or cadmium containing materials at the worksite. 7.4.1.4 Cutting, brazing, grinding or welding on surfaces that are painted with cadmiumcontaining paints. At the high temperatures reached in these operations, metals often form metal fumes, which have different health effects and exposure standards than the original metal or metal compound and require specialized controls. 7.4.2 PSC CRANE & RIGGING will assure that no employee is exposed to an airborne concentration of cadmium in excess of five micrograms per cubic meter of air (5 ug/m 3 ), calculated as an eight hour time weighted average exposure (TWA). 7.4.3 Where the PEL is exceeded, a written compliance program will be established and implemented to reduce employee exposure to or below the PEL by means of engineering and work practice controls. 7.5 CONTROLS AND SAFE WORK PRACTICES 7.5.1 Use of HEPA-filtered exhaust systems at the source of the fumes or, if this is not feasible, within the general work area. 7.5.2 Materials containing cadmium will not be applied by spray methods, if exposures are above the PEL, unless employees are protected with certain specified respirators and measures are taken to limit overspray and prevent contamination of adjacent areas. 7.5.3 All surfaces will be maintained as free as practicable of accumulated cadmium. 7.5.4 Floors and other surfaces where cadmium accumulates may not be cleaned by the use of compressed air. High efficient particulate air (HEPA) or other equally effective filtration system should be considered for use in cleaning contaminated surfaces. 3 Prepared especially for PSC CRANE & RIGGING by
7.5.5 Shoveling, dry or wet sweeping and brushing may be used only where vacuuming or other equally effective methods have been tried and found not to be effective. 7.5.6 Use of exhausted power tools with HEPA filters. 7.5.7 Where vacuuming methods are selected, the vacuums will be used and emptied in a manner which minimizes the re-entry of cadmium into the workplace. 7.5.8 Employees are responsible for washing hands and face prior to breaks and lunch. 7.5.9 Lunch areas will be maintained free of cadmium so that no employee in the lunch area is exposed at any time to cadmium. Employees are required to wash their hands and face prior to eating, drinking, smoking, chewing tobacco or gum or applying cosmetics. Employees will not enter the lunchroom facilities with protective work clothing unless surface lead dust has been removed by HEPA vacuuming or some other method that removes cadmium dust without dispersing it. 7.5.10 Establishment of a regulated area that will keep unprotected employees out and prevent the spread of cadmium dust beyond the boundaries of the area. For work inside buildings, this will involve erection of critical barriers over ventilation system vents, doors, open areas and other possible points of penetration. Further, it may be necessary to arrange the ventilation system to place the work area under negative pressure relative to the surrounding areas. 7.5.11 PSC CRANE & RIGGING has established regulated areas in all areas where employee exposures to cadmium exceeds the PEL. Access to these areas is restricted to authorized personnel only. Smoking, eating, drinking, chewing tobacco or gum or applying cosmetics are prohibited in the regulated areas. 7.5.12 Each employee will be required to wear the appropriate PPE and respiratory protection required to enter the regulated area. 7.5.13 Signs are posted in the regulated area as well as the approaches to the regulated area. The signs are illuminated and cleaned so they are readily visible. 7.6 PERSONAL PROTECTIVE EQUIPMENT DANGER CADMIUM - CANCER HAZARD CAN CAUSE LUNG AND KIDNEY DISEASE RESPIRATORS REQUIRED AUTHORIZED PERSONNEL ONLY 7.6.1 PSC CRANE & RIGGING provides PPE to each employee exposed to cadmium above the PEL. PSC CRANE & RIGGING also provides PPE to employees where skin or eye irritation is associated with cadmium exposure at any level. 7.6.2 Employees will not remove cadmium from protective clothing or equipment by blowing, shaking or any other means that disperses cadmium into the air. 7.6.3 Employees will use change rooms and separate storage facilities for protective work clothing and equipment and for street clothes to prevent cross contamination. 4 Prepared especially for PSC CRANE & RIGGING by
7.6.4 Employees will not be allowed to remove contaminated clothing from the facility. Contaminated protective clothing will be placed in marked containers. These containers will be closed immediately. 7.7 RESPIRATORY PROTECTION 7.7.1 Respirators must be used when the concentration of cadmium is at or above the PEL after engineering and work practice controls have not been sufficient to reduce exposures. 7.7.2 Respirators will be selected by the safety director in conformance with this policy. Fit testing for respirators must be conducted within 6 months prior to any cadmium related work. 7.7.3 Where the potential exists for exposure over the action level, employees will use a MSHA/NIOSH approved supplied air respirator with a full face piece operated in a pressure demand or other positive pressure mode. For increased protection use in combination with an auxiliary self-contained breathing apparatus operated in a pressure demand or other positive pressure mode. 7.7.4 If requested by the employee, a powered air purifying respirator must be provided in lieu of a negative pressure respirator. 7.7.5 Respirators, like all PPE are provided at no cost to the employee. 7.8 EMERGENCY PLAN 7.8.1 If cadmium comes in contact with eyes, immediately flush with large amounts of water for at least 15 minutes, occasionally lifting upper and lower lids. Seek medical attention immediately. 7.8.2 If cadmium comes in contact with skin, remove contaminated clothing. Wash contaminated skin with soap and water. 7.8.3 Persons not wearing respiratory protection and PPE will be restricted from areas of releases until all cleanup has been completed. 7.8.4 If potentially hazardous amounts of cadmium fume are inadvertently released, ventilate the area of the release to disperse the fume. 7.8.5 If cadmium dust is released in hazardous concentrations, the following steps should be taken: 7.8.5.1 Remove all ignition sources. 7.8.5.2 Ventilate area of release. 7.8.5.3 Collect released material in the most convenient and safe manner for reclamation or for disposal in sealed containers in a secured sanitary landfill. 7.8.6 Cadmium dust may be disposed of in sealed containers in a secured sanitary landfill. 7.9 MEDICAL SURVEILLANCE 7.9.1 PSC CRANE & RIGGING has implemented a medical surveillance program for all employees exposed or may be exposed to cadmium above the OSHA AL for more than 30 days per year. The medical surveillance program examinations will be performed under the supervision of a licensed 5 Prepared especially for PSC CRANE & RIGGING by
physician. Medical surveillance is available for each affected employee and is provided at no cost to the employee and at a reasonable time and place. The medical surveillance program also includes biological monitoring. Medical examinations are made available at least annually and more often if required. The medical examinations and biological monitoring requirements for pre-employment, surveillance and medical removal as outlined in the medical surveillance section of the cadmium standard are the minimal examination criteria to be followed by the licensed physician performing the medical surveillance. 7.9.2 PSC CRANE & RIGGING provides an examination for those employees assigned to an area where a respirator is required. The examination is performed by the licensed physician. The examining physician will determine if employee can wear a respirator. 7.9.2.1 If the employee cannot wear a respirator, the employee will be assigned to an area where cadmium exposures are below the OSHA PEL. 7.9.3 The company y will also provide examinations to those employees acutely exposed to cadmium during an emergency procedure and at the time of termination. 7.9.4 The following information will be provided to the physician: 7.9.4.1 A copy of the policy 7.9.4.2 Description of affected employees former, current and anticipated duties as relate to occupational exposure to cadmium 7.9.4.3 Employees former, current and anticipated future levels of occupational exposure to cadmium 7.9.4.4 Description of PPE and respiratory protection used and how long used or anticipated to be used by employee 7.9.4.5 Results of previous biological monitoring and medical examinations 7.9.5 The physician will provide a written medical opinion for each medical examination performed on each employee. The medical opinion will contain the following information: 7.9.5.1 Physician s diagnosis for employee 7.9.5.2 Physician s opinion of any detected medical condition(s) that would place employee at increased risks of impairment to health from further exposure to cadmium including any indications of potential cadmium toxicity 7.9.5.3 Results of biological, other testing or related evaluations that directly assess employee s absorption of cadmium 7.9.5.3.1 The physician has been instructed to not reveal specific findings or diagnoses unrelated to cadmium exposure 7.9.5.4 Any recommended removal from, or limitation of activities or duties of employee or restriction on use of personal protective equipment 6 Prepared especially for PSC CRANE & RIGGING by
7.10 RECORDKEEPING 7.9.5.5 A statement that physician has clearly and carefully explained results of medical evaluation including biological monitoring and medical conditions related to cadmium exposure to the employee 7.10.1 PSC CRANE & RIGGING maintains records of exposure monitoring, medical surveillance and training. 7.10.2 Medical surveillance information on each employee will be maintained on file for the duration of employment plus 30 years. 7.10.3 Employees can request a copy of their medical records. These records will be provided to the employee within 15 days of the request. 7.10.4 This written program will be reviewed and updated annually (or more often to reflect significant changes in employer's compliance status). 7.11 TRAINING 7.11.1 PSC CRANE & RIGGING will provide training for all employees who are potentially exposed to cadmium, assure employee participation and maintain a records of this training. 7.11.2 Employees will be trained prior to their initial job or reassignment. Refresher training will be provided annually. 7.11.3 All levels of employees with potential job related cadmium exposure and competent persons must be trained in: 7.11.3.1 Cadmium hazards and health effects 7.11.3.2 Sources of cadmium exposure 7.11.3.3 Acceptable work practices to reduce exposure and PPE 7.11.3.4 Cadmium spill response and disposal 7.11.3.5 Medical surveillance 7.11.3.6 Employee rights under this policy and the OSHA construction standard on cadmium 7 Prepared especially for PSC CRANE & RIGGING by