VPP OSHA Star Proven Road Map for VPP Compliance of Best Practice Execution

1. VPP OSHA StarProven Road Map for VPP Compliance of Best Practice Execution Certified Environmental Management, Ltd. A VPP STAR WORKSITE

2. Industrial Hygiene Vision Statement and Purposeall Starts with an AIHA, OSHA, and ACGIH Occupational Exposure Assessment Model • Your organizations need to be devoted to the anticipation, recognition, evaluation, and control of industrial hygiene factors arising in, or from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort among workers and team members. • Your organizations will need to evaluate on an annual basis, jobs, tasks, activities and products to determine the extent of employee exposure to hazards and decide what is needed to control these hazards to protect all team members. • In 1989 AIHA/ACGIH/OSHA Published a Model that has since been updated four times to now include dermal hazards. • The Model measures workplace hazards that can cause sickness, impaired health, or significant discomfort of workers through chemical, physical, ergonomic, or biological exposures. Our role as VPP Associates and Team Members is to identify, and quantify these conditions and help eliminate or control them through appropriate measures. • You will need to use workplace industrial hygiene monitoring and analytical methods to detect and quantify the extent of worker chemical, physical, or biological exposures and recommend engineering, work practice controls, and other methods to control potential health hazards.

3. Industrial Hygiene Goals and Objectives • Maintain Industrial Hygiene Compliance under the Occupational Safety and Health Administration (OSHA), American Conference of Governmental Industrial Hygienists (ACGIH) and National Institute of Occupational Safety and Health (NIOSH). • Address strictly Company Employees for initial baseline. • Comply with all OSHA/NIOSH/ACGIH Specific Standards and Regulations. • Monitor and Document the Quantitative 95% Statistical Confidence that measures the extent of worker exposure. • Recommend and help employ engineering, work practice controls, and other methods to control potential health hazards. • Implement numerous “Best Practices” in the Field of Industrial Hygiene So how do you implement all of this cost effectively? By understanding the current regulatory environment.

4. How do you start? By Understanding GHS • HCS – 1983: Recognized the importance of an international standard in the preamble • Build-up to current GHS • Years of bilateral trade negotiations • 1992 United Nations mandate adopted at the “Earth Summit” • Negotiations over 10 years • US supported the process and actively participated • System available for adoption by competent authorities

5. What is the GHS? • A common, coherent approach to classifying and communicating chemical hazards • Proposes: • Harmonized definitions of hazards • Specific criteria for labels • Harmonized format for safety data sheets

6. What is the GHS? • Sample Hazard Statements • Fatal if in contact with skin • May cause fire or explosion • May cause cancer • Two Signal Words: • Danger • Warning !

7. Use the New Law to Implement a Comprehensive Hygiene Program Conduct an Occupational Health Hazard Assessment. Take all SDS’s: Scan Link Enter into Database Document each of the following variables with each CAS# Evaluate all Chemical Hazards that exist as concentrations of mists, vapors, gases, fumes, or solids. Some are toxic through inhalation and some of them irritate the skin on contact; some can be toxic by absorption through the skin or through ingestion, and some are corrosive to living tissue. Need to evaluate on site every new product MSDS’s/SDS’s break down chemistry by CAS# and percent. This Occupational Health Hazard Assessment update will include evaluations of all jobs, operations, process, task, volume on site, department, closed or open system, pressurized or not, skin contact or not, PPE worn, frequency of task, number of workers involved, and duration of exposure. Compliance with 29 CFR 1910.1200 Hazard Communication.

8. Integrate Qualitative to Quantitative Quantitative Measurement of Air Contaminants. The most common particulate contaminants include dusts, fumes, mists, aerosols, and fibers. Dusts are solid particles that are formed or generated from solid organic or inorganic materials by reducing their size through mechanical processes such as crushing, grinding, drilling, abrading or blasting. Fumes are formed when material from a volatilized solid condenses in cool air. In most cases, the solid particles resulting form the condensation react with air to form an oxide. Mists are finely divided liquids suspended in the atmosphere. Mists are generated by liquids. Fibers are solid particles whose length is several times greater than their diameter. Gases are formless fluids that expand to occupy the space or enclosure in which they are confined (carbon monoxide, nitrogen dioxide, carbon dioxide). Liquids change into vapors and mix with the surrounding atmosphere through evaporation. Vapors are the gaseous form of substances which are normally in the solid or liquid state at room temperature and pressure (paints, parts cleaning solvents). 8

9. OSHA Horizontal Chemical Laws Compliance with 29 CFR: • 1910.1000 Air Contaminants Horizontal Regulatory Laws • 1910.1001    Asbestos.1910.1002    Coal tar pitch volatiles; interpretation of term.1910.1003    13 Carcinogens (4-Nitrobiphenyl, etc.).1910.1004    alpha-Naphthylamine.1910.1006    Methyl chloromethyl ether.1910.1007    3,3'-Dichlorobenzidine (and its salts).1910.1008    bis-Chloromethyl ether.1910.1009    beta-Naphthylamine.1910.1010    Benzidine.1910.1011    4-Aminodiphenyl.1910.1023    Ethyleneimine.1910.1013    beta-Propiolactone.1910.1014    2-Acetylaminofluorene.1910.1015    4-Dimethylaminoazobenzene.1910.1016    N-Nitrosodimethylamine.1910.1017    Vinyl chloride.1910.1018    Inorganic arsenic.1910.1025    Lead.1910.1026    Chromium (VI).1910.1027    Cadmium.1910.1028    Benzene.1910.1029    Coke oven emissions.1910.1043    Cotton dust.1910.1044    1,2-dibromo-3-chloropropane.1910.1045    Acrylonitrile.1910.1047    Ethylene oxide.1910.1048    Formaldehyde.1910.1050    Methylenedianiline.1910.1051    1,3-Butadiene.1910.1052    Methylene Chloride.

10. Build from Data Collection JHA’s/JSA’s Recommendations of PPE when effective work practices and/or engineering controls are not feasible to achieve the permissible exposure limit. Personal Protective Equipment such as gloves, safety goggles, helmets, safety shoes, and protective clothing. Compliance with 29 CFR 1910.132 Personal Protective Equipment General Requirements. Compliance with 29 CFR 1910.133 Eye and Face Protection. Compliance with 29 CFR 1910.134 Personal Protective Equipment Respiratory Protection. Compliance with 29 CFR 1910.135 Personal Protective Head Protection. Compliance with 29 CFR 1910.136 Personal Protective Equipment Foot Protection. Compliance with 29 CFR 1910.137 Personal Protective Equipment Electrical Protective Devices. Compliance with 29 CFR 1910.138 Personal Protective Equipment Hand Protection. Compliance with 29 CFR 1910.95 Hearing Protection (OSHA and Also Address ACGIH 3 dbA) 10

11. Integrate all Data into an Electronic System Medical Surveillance Records and Personal Exposure Records for Every Sample Collected. Special OSHA Form Documentation for Air Contaminant Sampling. Chain of Custody Documentation. Executive Summary Reporting. Statistical Reporting. Compliance with 29 CFR 1910.1020 Access to Employee Exposure and Medical Records.

12. User-Friendly System to Manage Data Add, edit, search, and view your Quantitative and Qualitative data from the easy-to-use Web Site interface. This means: Only one interface to learn and use for all your data. All your data resides on one secured system, giving better security, data integrity, and searching capability. User friendly interface allows anyone to be able to start using the database quickly.

13. Integration with Chemical Information Access database of Chemical Information for the chemicals used in your organization. This means: See toxicology data including Health Effects, Carcinogenicity, Symptoms, etc. See recommended Personal Protective Equipment. See worldwide and historical Regulatory Limits.

14. Unlimited Perspectives with Reports Data is only as useful as your ability to search and view it. The Online Database allows you to generate reports in print and be electronically transmitted via pdf files allowing you to see your data from multiple perspectives. This means: Unlimited reports for Chemical Exposure Sampling Data. Unlimited reports for Noise Exposure Sampling Data. Unlimited reports for Hazard Assessment Data. Requested custom reports design and creation.

15. Historical Quantitative Data Graph Executive Presentation Data Generation Capabilities Ability to generate graphs to show exposure levels and historical regulatory limits. Ability to generate graphs to show modification in regulatory trends across multiple years . Ability to show limits prior to engineering controls and post installed engineering controls or administrative controls.

16. Best Practice Web-Based IH System Implemented to Help Us Work Efficiently/Safely Industrial Hygiene Total Solution System Field Reference Guide - Regulated Chemicals Toxicology and Sampling Methods Reference Data Bases – OSHA & ACGIH Limits (since 1987) International Limits for 50+ Countries Material Data Sheet – Internet Based Management and Retrieval Active and Archive Data Bases Selective Search by Name, Job Title, etc Prescreen New Chemicals – By Requestor or by Vendor Chemical Hazard Assessment – by Industrial Hygienist User Friendly Data Entry (Historical Data) Chemical Inventory Adjust Weighting of 17 Parameters in Model Exposure Ranking Model (prioritize exposures) Report Preparation - Workplace Characterization - Workforce Characterization - Chemical Agents - Chemical Exposure Ranking - Top 10 % Sampling Plan by department, site, etc - Dermal Assessment Recommendation Field Data Entry – Air and Noise Monitoring IH Data Worksheet JSA/JHA documentation Chain of Custody Industrial Hygiene Total Solution System Data Query Tools – Hazard Assessment Reports by 30+ search topics Laboratory Analysis Quantitative Results Reports by 50+ topics - AIHA Quantitative Results - Field Sampling Documentation - Report Writing Helper - Medical Surveillance/Personnel Records - Exposures as Per Cent of Limits - Respiratory Protection Factor (APF with PPE) Industrial Hygiene Query Tools - ACGIH BEI Limits ACGIH TLV Limits ACGIH Notice of Intended Changes ACGIH Carcinogenicity List Homeland Security Chemicals of Interest Chemical Inventory by multiple parameters Multiple Sampling Plans ACGIH Ototoxic Chemical List Chemicals with Horizontal Standards Toxicology Reference Data - AIHA ERPG’s - Chemicals with Reproductive Impairments - Health Effects Codes - Germ Cell Mutagens - ACGIH Critical Toxicology Effects EPA Tier II Report Submittal SARA Titles EPA Tier II Report

17. Updates and Upgrades Ensure that the system is up-to-date and fully-featured. This means: You have access to new chemical information and regulatory limits from more than 52 worldwide agencies as soon as possible after it is published. This number of worldwide agencies can fluctuate based upon our clients business needs. -Notification of these updates with explanations given via e-mail to your requested e-mail address. Allows for full understanding of the impact to your facilities

18. Accessible from Any Computer Any computer with Internet access and a current supported Web browser can access the Total IH System Databases. This means: Access the Online Database anywhere in the North American Continent at any time. No need to upgrade Software or Hardware to meet the on going requirements of an installed Database system.

19. Complete Data Integration Integrate all your Industrial Hygiene data into one database system and unlock your data’s full potential. This means: Easily share data between multiple users, locations and departments. Your data is always synchronized across your entire organization. Search and find trends in your data. Data is only as useful as your ability to query and organize into a professional format. Once new onsite data has been entered, a confirmation is required in writing from the designated user/manager to allow for permanent integration of data into database for query possibilities.

20. List of Reports Available for Hazard Assessment (Qualitative)

21. List of Reports Available for Hazard Assessment (Quantitative)

22. Free Chemical List of World-Wide Regulatory Limits with Technical Information to all Registered Web-Based Users

23. List of World-Wide Regulatory Bodies

24. Example of Toxicological Data Availablewww.cemih.com

25. Comprehensive MSDS Search

26. Examples of Technical Tools Audits IH Sampling Plan for Chemical Monitoring Execute Occupational Health Hazard Assessments Baseline Noise Glove Research JHA/JSA Evaluations Mixture Effects Calculation Prescreening of Chemicals Total IH Solution System = Best Practice Solution Qualitative to Quantitative

27. Web Based IH Solution System– “Not Just a Slice – The Whole Pie”

28. Conclusionsand Recommendations Conduct Occupational Health Hazard Assessments Evaluate Mixture Effects of Chemistry Ensure Awareness of ACGIH NIC’s Integrate Safety Audit, JSA, JHA, Noise, IH Monitoring into One Campaign Provide Medical Surveillance Records and Archive On-Line Prescreen Chemical MSDS/SDS’s before a Chemical Comes on Site. Continue to Look at Engineering Controls and Document Findings and Evaluations Establish an IH Monitoring Campaign Annually for Horizontal Chemicals Maximize Data Collected in Every Facet Possible! Establish JHA’s or JSA’s Prepare for GHS Impact Prepare I2P2 Impact Integrate all IH Sites into Web Based System Feel free to sign in to view toxicological data and DOT data on 1000’s of chemicals at no cost through our www.cemih.com site.