Conducting IH Exposure Assessments in CCA Operations Mike Cooley Eltaneice Bolden Bob Chapman

What We Will Cover 1.Review of IHT Roles and Responsibilities – CCA Focus 2.CCA site IH-related programs 3.IH exposure assessments in CCA environment –Chemical exposure –Noise Exposure 4.Investigation of Initial Work-Related Medical Cases

Review of IH Technician Roles and Responsibilities Air Sampling Air Sampling The primary responsibility of the UAW Industrial Hygiene Technician (IHT) is to collect air samples under the direction of the Local Joint Health and Safety Committee (LJHSC) and the technical supervision of a GM Industrial Hygienist (IH). To function in this capacity, the UAW IHT must maintain a close working relationship and open communication with the LJHSC, the GM IH, local union leadership, and both hourly and salaried facility personnel. The collection of Air Samples involves the following key job elements:

Review of IH Technician Roles and Responsibilities Assisting in the review and update of the Air Sampling Plan (ASP) ASP not required at most CCA sites based on site assessments IHT assists with annual review to determine need for ASP

Review of IH Technician Roles and Responsibilities Calibration and maintenance of Air Sampling equipment Collection of Air Samples in line with an established Air Sampling Plan Submission of samples for analysis in accordance with established procedures No IH test equipment at most CCA sites

Review of IH Technician Roles and Responsibilities Maintenance of records (e.g., ASP data collection sheets, complaint sampling data collection sheets, intermittent exposure monitoring data collection sheets, equipment calibration documents, memos and formal reports related to Air Sampling studies, etc.) Most CCA sites not collecting air samples Most CCA sites not collecting air samples

Review of IH Technician Roles and Responsibilities Participation in the discussion of sampling results with the LJHSC and the GM IH Participation in the discussion of sampling results with the LJHSC and the GM IH Attendance at required training classes (CCA IHTs participate in Basic IH Training Class at CHR and take other IH related classes at conferences)

Review of IH Technician Roles and Responsibilities It is imperative that the Industrial Hygiene Technician develops and maintains proficiency in technical matters related to Industrial Hygiene, especially in the discipline of Air Sampling. It also is important that the technician maintain professionalism while working in this capacity.

Review of IH Technician Roles and Responsibilities Air Sampling performed by the UAW IHT outside the scope of the established ASP should involve prior consultation with the LJHSC and the GM IH.

Review of IH Technician Roles and Responsibilities The 1999 contract added the following responsibilities: The UAW IHT will become a member of the facility Hazardous Materials Control Committee. In place at all CCA sites

Review of IH Technician Roles and Responsibilities The UAW IHT will become a member of the facility Noise Control Committee and assist with plant noise abatement programs. No formal noise committee at most CCA sites; most don’t have hearing conservation programs based on Sound Survey results

Review of IH Technician Roles and Responsibilities The UAW IHT will be listed as a qualified and primary resource for Confined Space Testing. Pre-planned atmospheric testing will be scheduled in advance to provide effective utilization of the UAW IHT when scheduled to work. Most CCA sites do not conduct in-house confined space entries

Review of IH Technician Roles and Responsibilities The 2003 National Contract added the following responsibilities: The 2003 National Contract added the following responsibilities: The UAW IHT will assist in the assessment of intermittent exposures in skilled trades jobs and non- routine tasks. These tasks, when appropriate, will be added to the facility Air Sampling Plan Applicable to CCA; follow UAW-GM CHR written process for addressing intermittent exposures

Review of IH Technician Roles and Responsibilities Appropriate Local Exhaust Ventilation (LEV) Performance Checks will be identified and the UAW IHT will conduct these tests at least annually on local exhaust systems in conjunction with Industrial Hygiene Air Sampling studies. Most CCA sites do not have LEV systems The following [LEV] records must be maintained by the UAW IHT: LEV Performance Check Data Collection sheets, LEV System Evaluation Data Collection sheets, calibration data on all LEV test equipment, memos and formal reports related to LEV Performance Checks and system evaluations

Review of IH Technician Roles and Responsibilities The UAW IHT will receive notice of initial work related medical cases reporting symptoms such as headache, nausea, skin problems and respiratory complaints. This applies at all CCA sites

Review of IH Technician Roles and Responsibilities The 2007 National Contract added the following responsibilities: The 2007 National Contract added the following responsibilities: The UAW IHT will assist with data collection in the annual sound survey and will be involved in the subsequent analysis of the data as a member of the plant noise committee. This applies to all CCA sites; 5 year sound survey cycle

Review of IH Technician Roles and Responsibilities The UAW IHT and the Industrial Hygienist will be involved in the identification and development of evaluation and control methods for confined spaces and participate in the annual program review. IHT must participate in the identification of spaces and in annual review of spaces and updates of Hazard Analysis

CCA Site UAW-GM IH Related Programs Hazard Communication Applies to all CCA sites IHT participates on site HMCC IHT participates in annual review of program

CCA Site UAW-GM IH Related Programs Asbestos Safety Applies only in older Michigan sites with asbestos in building materials IHT participates in annual review of Site Asbestos Safety Program

CCA Site UAW-GM IH Related Programs Confined Space Entry Applies at all CCA sites; however, not all sites conduct in- house entries IHT participates evaluations of new spaces (all sites) IHT participates in annual review of program (all sites)

CCA Site UAW-GM IH Related Programs Hearing Conservation and Noise Control Most CCA sites do not have need for hearing conservation programs based on Sound Survey data Must assist in evaluating noise levels in new and rebuilt equipment and respond to employee noise concerns

IH Exposure Assessments in CCA Sites Chemical Exposure CCA sites (Flint is exception) have no air sampling equipment or ASP Simple test methods not requiring IH equipment are available to address certain chemical-related employee concerns that arise (e.g., passive monitors) GM IH support is available to assist with these investigations

IH Exposure Assessments in CCA Sites Qualitative Exposure Assessments Preliminary exposure assessments can be conducted without collecting air samples Requires gathering information on employee concern and on potential for exposure

IH Exposure Assessments in CCA Sites Use Industrial Hygiene Exposure Assessment Form Obtain information on chemical materials used from MSDS/SDS Obtain information on potential exposure Pass this information on to GM IH for review

IH Exposure Assessments in CCA Sites Noise Sampling Most CCA sites do not have noise dosimeters Not much in the way of noise concerns; mostly intermittent impact noise from unloading/loading train cars and trailers Sound Survey conducted every 5 years (see 2015 Phase To Schedule)

2015 Sound Survey Schedule  6/2015 CCA Philadelphia  6/2015 CCA Martinsburg  8/2015 CCA Denver  5/2015 CCA Flint  9/2015 CCA Reno

IH Exposure Assessments in CCA Sites How to address an employee noise concern? Quantitative Approach: 1.Phase To (Sound Survey contractor) visit with collection of noise samples 2.Cell phone Apps – very rough approximation of noise levels 3.IH visit with collection of noise samples

IH Exposure Assessments in CCA Sites Qualitative Approach: Gather background information in advance for Phase To or IH: Use Industrial Hygiene Exposure Assessment Form

CCA IH Exposure Assessment Form

Investigation of Work Related Medical Cases Site IHT/JETs are now investigating ergo-related medical cases Industrial Hygiene (IH) Medical Referral Form can be used to collect information

Investigation of Work Related Medical Cases

Key Take Home Points 1.IHT involvement in IH-related programs is required when applicable 2.Qualitative IH Exposure Assessments and Investigation of Medical Referrals provide useful information 3.GMIH support is available to review assessments and assist with collection of samples when required