How to Comply with PEL Requirements

Yesterday, we explained how to calculate PELs. Today, we talk  about how to comply with them.

To achieve compliance with PELs, OSHA says a facility must determine and then implement administrative or engineering controls whenever feasible.

Engineering controls involve the use of:

• Exhaust and general ventilation
• Enclosure of the source of emissions
• Process and equipment modifications that reduce emissions
• Substitution of nonhazardous or less hazardous chemicals

Administrative controls would include steps such as limiting the amount of time employees can work in an area with exposures above the PEL or restricting entry into these areas to employees equipped with the appropriate respirator.

These methods may be used alone or in combination. Competent industrial hygienists or other technically qualified personnel must approve any equipment and technical control measures.

If the controls do not achieve full compliance, PPE (see 1910 Subpart I, particularly Respiratory Protection, 1910.134) or any other protective measures must be used to keep the exposure levels within the limits prescribed in Tables Z-1, Z-2, and Z-3 and through the computation formulas we reviewed in yesterday’s Advisor.

Review These Issues

The following questions can help assure that your workplace is in compliance with OSHA’s air contaminants standard and PEL requirements:

• Have all hazardous air contaminants in the workplace been identified?
• Have contaminant levels been monitored?
• Are air contaminant levels maintained below those given in the Z tables?
• If contaminant levels rise above the PEL are appropriate respirators provided?
• If respirators are provided, are they used in accordance with the requirements of the respiratory protection standard?
• Are employees exposed to any materials that have their own specific standards (see Subpart Z, Toxic and Hazardous Substances)?
• If so, do you have a program or guidance that addresses the following compliance concerns, where applicable, of a particular toxic or hazardous substance?
• Permissible exposure limit
• Air monitoring
• Regulated areas
• Compliance program
• Respiratory protection
• Protective clothing
• Hygiene
• Hazard communication
• Housekeeping
• Medical surveillance
• Medical removal
• Recordkeeping
• Reporting
• Standard operating procedures
• Contamination
• Emergencies

Ready-Made Checklists

BLR’s Safety Audit Checklists provides 9 sections on Hazardous Substances and Materials, including a section that covers 1910.1000, Air Contamination, and monitoring for compliance with OSHA PELs. Most of these sections supply you with a compliance checklist highlighting key provisions of OSHA’s various hazardous materials standards in addition to a second checklist with important safety information on the topic that can be circulated to supervisors and posted for employees.

All told, this best-selling program provides you with more than 300 separate safety checklists keyed to three main criteria:

• OSHA compliance checklists, built right from the government standards in such key areas as HazCom, lockout/tagout, electrical safety, and many more.
• “Plaintiff attorney” checklists, built around those non-OSHA issues that often attract lawsuits.
• Safety management checklists that monitor the administrative procedures you need to have for topics such as OSHA 300 Log maintenance, training program scheduling and recording, and OSHA-required employee notifications.

Make as many copies as you need for all your supervisors and managers, and distribute. What’s more, the entire program is updated annually. And the cost averages only about $1 per checklist.

If this method of ensuring a safer, more OSHA-compliant workplace interests you, we’ll be happy to make Safety Audit Checklists available for a no-cost, no-obligation, 30-day evaluation in your office. Just let us know, and we’ll be pleased to arrange it.

More Articles on Chemical Safety