IHFOM Chapter 2 Industrial Hygiene Surveys and Survey Reports

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Chapter 2 – Industrial Hygiene Surveys and Survey Reports

General

Industrial hygiene (IH) surveys are conducted to accurately assess personnel exposures to

chemical, physical and biological agents in the workplace; to provide recommendations for

their reduction or elimination; recommend controls; and to recommend enrollment in

specific medical surveillance programs. Periodic workplace evaluations are made to assure

the effectiveness of the implemented controls and determine the need for continued

medical surveillance. If there is a significant production, process, material or control change

for a particular work operation, that operation must be reevaluated. The procedures in this

chapter, along with chapters 3, 4, and 5 should be followed to evaluate employee

exposures, determine compliance with standards regulating occupational exposures, and to

assess the effectiveness of controls. An exposure assessment strategy, detailed in Chapter

4, should be developed to define acceptable and unacceptable exposures as related to

exposure standards and guidelines.

NOTE: Bureau of Medicine and Surgery (BUMED) field industrial hygienists and other Navy

medicine occupational health personnel do not determine personnel exposures to

chemicals from an environmental source (except during spill events where first responder

safety is the primary medical concern (as specified in reference 2-1). See section 3.g., Areas

Specifically Excluded from IH Surveys, of this chapter for more information.

Definitions

a. Action Level (AL). One-half the 8-hour Time Weighted Average (TWA) value designated

as the Occupational Exposure Limit (OEL) unless a specific AL is established in an

Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL)

adopted by the Navy (e.g., 60% of the OSHA standard for inorganic lead). The AL may

initiate the implementation of specific actions, such as periodic monitoring, training or

medical surveillance if specified by a Navy Safety and Occupational Health (SOH) or

OSHA standard.

b. Employee Exposure. Exposure that occurs without consideration of the use of personal

protective equipment (PPE).

c. Experienced Industrial Hygienist. For the purposes of this chapter, an experienced

industrial hygienist is a civil service General Schedule 0690 Series employee GS-12 and

above, or a military Industrial Hygiene Officer (IHO) (Medical Service Corps subspecialty

1861) Lieutenant (O-3) and above. Additionally, a Certified Industrial Hygienist (CIH®) is

considered experienced at any grade or rank.

d. Industrial Hygienist. Those professionals classified in the civil service as General

Schedule 0690 Series, or military IHO (Medical Service Corps subspecialty 1861).

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e. Occupational Exposure Limit (OEL). Limits established to protect workers from

workplace exposure to certain chemical substances or physical agents. An exposure

assessment cannot be made without an OEL.

f. Occupational Exposure Limits for Chemical Contaminants. It is recognized that OSHA

PELs may be less protective than exposure standards that reflect more recent medical

evidence and promulgated by reputable organizations devoted to occupational health.

Industrial hygienists are ethically bound to evaluate all recognized occupational health

risks and provide professional recommendations to minimize or eliminate those risks.

The Navy shall use the following hierarchy of OELs:

(1) OSHA PELs.

(2) Navy developed or adopted OELs. When both the Navy and OSHA have standards

applicable to a given situation, commands, activities, and units will use the more

stringent of the two.

(3) American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit

Values® (TLVs) where OSHA PELs or Navy OELs do not exist. Use of TLVs represent

best practices, i.e., risk management goals to achieve using risk management

practices. When the OSHA PEL is less stringent, the ACGIH TLVs will be included in

reports of data to supplement the OSHA PEL and provide additional context to aid

the risk management process. However, the OSHA PEL remains the legally binding

standard.

(4) Nationally recognized IH best practices may be used to supplement the OEL

hierarchy. The industrial hygienist will use professional judgement to recommend

OEL guidelines, when appropriate, to aid the risk management process in a given

situation. Sources include but are not limited to:

(a) California Occupational Safety and Health Administration (Cal/OSHA) PELs.

(b) National Institute for Occupational Safety and Health (NIOSH) recommended

exposure limits (RELs) or risk management limits for carcinogens (RMLs-CA).

Exposure Levels (WEELs).

For further guidance on the appropriate applications of OELs, Industrial Hygiene

Program Offices (IHPO) should contact their respective regional command or Navy and

Marine Corps Public Health Center (NMCPHC) for assistance.

g. Occupational Medical Surveillance (OMS). A system of programs to assist in either

assessing an individual's ability to perform specific job functions and tasks and/or to

assess and monitor employees exposed or potentially exposed to occupational

stressors. It is based on the systematic collection, analysis and evaluation of the data

necessary to assess an individual’s current state of health with respect to employment

requirements and to define the presence of disease patterns that may be associated

with exposure to chemical, biological and physical stressors in the workplace. The

various OMS exposure program assessments monitor individuals for adverse health

effects and determine the effectiveness of control measures. An OMS program includes

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the analysis of both individual health and aggregate surveillance data over time in order

to reduce or prevent occupational illness and injury.

h. OMS and Controls Criteria Based on the Navy OEL Hierarchy.

(1) The OSHA PEL is regulatory and the BUMED industrial hygienist lists required (vice

recommended) controls and medical surveillance. Medical surveillance is required

in accordance with the OSHA substance specific standards or for Tables Z-1, Z-2, and

Z-3 when an employee is exposed at or above the PEL for more than 30 days per

year. When the IHPO does not have sufficient sampling data to determine the 95

percentile, then one-half of the PEL (AL) will be used as the medical surveillance

criteria. IHPOs will prioritize sampling efforts to collect the additional samples

necessary to determine the 95

percentile and will then use the PEL as the criteria.

(2) TLVs are the required OEL when OSHA PELs are not available. The BUMED industrial

hygienist lists required (vice recommended) controls and medical surveillance.

Medical surveillance is required when an employee is exposed at or above the TLV

for more than 30 days per year.

(3) When the OSHA PEL is less stringent, the ACGIH TLVs will be included in reports of

data to supplement the OSHA PEL and provide additional context to aid the risk

management process. These exposure assessments should include the following

wording:

"An alternate OEL exists for this stressor (give alternate OEL). Whenever possible,

work to reduce exposures to this level through the use of engineering and work

practice controls. See Control Section for recommendations. Contact your IH

program office for assistance as needed."

Since these are supplemental, best practice OELs, the BUMED industrial hygienist

lists recommended (vice required) controls. OMS will be based on the OSHA PEL.

Recommending medical surveillance for exposures below the OSHA PEL or at the

supplemental TLV will be addressed on a case-by-case basis where situations may

require medical surveillance to protect workers (e.g., employee health effects at

lower concentrations), or where due to lack of data a 95

percentile of exposures

cannot be calculated, but professional judgement determines recommending OMS.

This decision will be made in consultation with the occupational medicine physician.

i. Shop Walk-through Survey Date. The date the walk-through survey is performed for a

particular shop.

j. Significant Hazard. A hazard is considered significant based on the level of harm it will

cause to workers in the occupational setting due to exposure level, route(s) of entry,

and/or frequency and duration of exposure. A significant hazard can be chemical,

physical, or biological. Industrial hygienists shall deem a hazard significant based on

acute and/or chronic effects. Common significant hazards can include:

(1) Inhalation and physical hazards that have an expanded OSHA health standard.

(2) Hazards that could reasonably exceed 10 percent of the OEL.

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(3) Corrosives.

(4) Quantifiable physical hazards such as noise.

(5) Blood and body fluids.

(6) Hazardous drugs.

(7) Have special notations such as:

(a) Carcinogen

(b) Ototoxin

(d) Respiratory and/or dermal sensitizer

(e) Skin notation

k. Survey. A workplace evaluation to determine employee exposures to chemical,

biological and physical hazards and to recommend procedures for reducing or

eliminating those exposures. The following categories of IH surveys exist:

(1) Initial IH Survey. The first comprehensive survey of a workplace. A workplace will

have only one initial survey.

(2) Periodic Industrial Hygiene Survey (PIHS). Scheduled cyclic surveys following an

initial survey.

(3) Shop Specific Supplements to a Periodic Industrial Hygiene Survey (SPIHS). Shop

specific supplements are used for shop-specific evaluations that are reported

independently of the PIHS to ensure that all shops are evaluated at the required

frequency based on Defense Occupational Environmental Health Readiness System-

Industrial Hygiene (DOEHRS-IH) shop priorities.

(4) Other (Special) IH surveys. Surveys that focus on a specific hazard evaluation or

generated in response to a customer’s special request (e.g., indoor air quality

survey, illumination survey).

l. Survey Completion Date. The date the cover letter of the survey is signed out. This date

is used as the survey completion date for initial, periodic, shop specific supplements,

and special IH surveys for the purpose of metrics and determining periodic survey due

dates; and as the master schedule shop survey close date in DOEHRS-IH.

m. Work Operation/Process. A specific job, duty or function. In each work

operation/process, the location, ventilation, materials and equipment used should be

considered. For example, welding in a confined space is a different exposure situation

than in the open air. A work operation/process might include specific tasks.

For years, Navy IH Operations/Operation Codes (OPCODEs) have been used to denote

work operations and have been documented on IH sampling forms. These OPCODEs

were provided in tabular format as the Navy IH Operation Codes Dictionary. With the

advent and use of DOEHRS-IH, processes now need to be defined in two basic ways: a

user defined Process Name and the DOEHRS-IH Process Category/Common

Process/Process Method pick lists. DOEHRS-IH requires the choice of a Process Name for

each work operation. The Process Name is user defined and is what the user typically

sees. Since Process Name is user defined, care must be taken to use a business practice

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that ensures accurate and consistent Process Names are created. The DOEHRS-IH

Process Category/Common Process/Process Method pick lists are in the form of a three

tiered process pull down pick list. The DOEHRS-IH Process Methods from the pick list are

the equivalent of the old OPCODEs. It is very important that proper selections are made

from these DOEHRS-IH pick lists and that they are accurate and consistent for the

process under consideration in order to facilitate future data mining. A spreadsheet of

the entire DOEHRS-IH Process pick list is available on the NMCPHC DOEHRS-IH webpage.

While the old OPCODEs can be used in house by IH groups, the applicable DOEHRS-IH

Process Name and the Process Method picklist choice should be included on any

sampling forms in the Operation field.

n. Workplace.

(1) Command (major/parent). The entire unit, command or activity where a type of

work is performed, typically under one Unit Identification Code (UIC). Examples

include shipyards, fleet readiness centers (FRCs) and naval facilities (NAVFAC)

activities/public works centers. Workplace for afloat commands is defined as the

entire ship. In this chapter the term command will also be used generically for unit,

command or activity.

(2) Detachments. There may be instances where a local IHPO provides support to a

detachment (e.g., Construction Battalions) from a parent command that receives IH

services from a different IHPO (i.e., parent IHPO). The detachment may or may not

have a unique UIC from its parent command. Detachments should receive their IH

services and support from the nearest Navy IHPO that is within the Area of

Responsibility (AOR) in which the detachment is located. There may also be

instances in which IH services are needed to support DoD personnel that are

deployed on a rotational basis to a non-U.S. facility. In these instances, coordination

between services and development of a Memorandum of Agreement (MOA) may be

required in order to establish IH support requirements and responsibilities. The local

IHPO (providing support to a detachment), and the parent IHPO (that provides

support to the detachment’s parent command), should effectively communicate

and coordinate so that the detachment and personnel receive the necessary IH

support and so that necessary data is collected and correctly entered in to DOEHRS-

IH per section 3.h. below. The local IHPO shall be responsible for:

(a) Entering “detachment” data in to DOEHRS-IH

(b) Informing the detachment to provide a copy of their survey assessment reports,

exposure monitoring results, and medical surveillance recommendations to their

parent command

monitoring results, and medical surveillance recommendations that have been

given to the supported command, to the IHPO that supports the detachment’s

parent command.

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o. Worksite. The shop, code or workcenter where a specific work operation/process is

performed within a workplace. In this chapter the term shop will also be used

generically for shop, code or workcenter.

Surveys

Workplace evaluations to identify and quantify health hazards are accomplished through IH

surveys and will be completed under the supervision of an experienced industrial hygienist.

IH technicians or exposure monitors (both military and civilian) may assist in the monitoring

portion of a survey as long as technical direction is provided by an industrial hygienist.

Under no circumstances will they independently conduct IH surveys, interpret IH data or

recommend control methods.

Copies of all technical assist visits and/or IH surveys shall also be forwarded to the

appropriate Regional IH by the cognizant BUMED activity or the carrier/tender IHO.

a. Initial IH Survey. Since all subsequent surveys will be compared to this survey, it is

critical that all aspects of the workplace are evaluated and findings are fully

documented.

(1) The initial walk-through survey gathers information for workplace characterization.

This typically includes documenting information for each shop in the command,

including:

(a) Based on best practices and requirements from references 2-2, 2-3, and 2-4:

1. Location information for work operations/processes, equipment and

controls, including shop diagrams, as needed.

2. Personnel assigned, including total number, number of males and females,

numbers by worker classification and numbers for each work

operations/process. Rosters need to be obtained from the shop so that

individual personnel can be associated to the particular shop and to the

specific processes within the shop, and to the particular Similar Exposure

Groups (SEGs).

3. Work operation/process descriptions, including tasks, work practices and

procedures, locations, frequencies and durations of the work

operations/processes, material and equipment usage, hazards involved,

controls used, number of personnel assigned and individual personnel

assigned to the specific processes.

4. Equipment descriptions for significant equipment used by the shop.

Associate any equipment to all work operations/processes.

5. Potential chemical hazards in the workplace that present significant risk,

including those used, stored, handled or produced, as well as a description of

how they are used, amount on hand, and estimated consumption rates. (The

command's Hazardous Materials Authorized Use List (HM AUL), as required

by reference 2-2, provides some of this information.) Also, specifically

identify hazards that are reproductive or developmental hazards,

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carcinogens, or ototoxins, as such. Associate any chemical hazards and

hazardous materials to any work operations/processes.

NOTE: Per references 2-2 and 2-3, industrial hygienists shall have access to a

copy of the authorized use list for the workplaces being surveyed.

6. Potential physical hazards (e.g., noise, ionizing and non-ionizing radiation,

ergonomic risks, temperature, vibration) in the workplace that present

significant risk, including a brief description of their source(s). Also,

specifically identify hazards that are reproductive or developmental hazards

or carcinogens, as such. Associate any physical hazards and sources to any

work operations/processes.

7. Biological/infectious agents (e.g., in laboratories) in the workplace that

present significant risk. Also, specifically identify hazards that are

reproductive or developmental hazards or carcinogens, as such. Associate

any biological hazards and sources to any work operations/processes.

8. Existing controls such as substitution, isolation, engineering controls,

administrative controls and PPE. Include evaluations of the controls’

effectiveness. Associate any controls to any work operations/processes and

specific hazards, as appropriate.

(b) Other information gathered, as appropriate:

1. Direct reading screening measurements for each shop or work area where

applicable.

2. Interviews with any employees reporting complaints, symptoms or related

safety and health problems.

3. Any other information necessary to accurately describe command and shop

conditions.

(2) Exposure assessments are to be performed and documented for all significant

hazards based on its health effects, likelihood of exposure, and regulatory

requirements. See the definition of significant hazards in section 2(i) for examples.

Exposure assessments are to be made by an industrial hygienist who is familiar with

the shops and work operations/processes being evaluated. Details on exposure

assessment can be found in chapter 4. Based on best practices and requirements

from references 2-2 and 2-3:

(a) Identify/Define SEGs. Definition of a SEG includes associating specific shops,

processes, hazards and personnel to the SEG.

(b) Characterize each SEGs exposure profile, estimating personal exposures using

qualitative or quantitative data. Representative personal exposure monitoring is

the primary means of quantifying exposures for use in assessing exposure

profiles.

SEG. For quantitative exposure assessments, consult Chapter 4 for information

on statistical tests (e.g., 95

percentile, Upper Tolerance Limit 95/95). Judge the

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SEG’s exposure profile as unacceptable, acceptable or uncertain. An

unacceptable determination indicates personnel exposures exceed (or are

expected to exceed) the OEL. An acceptable determination indicates that

personnel exposures do not exceed (or are not expected to exceed) the OEL for

current/normal or foreseeable operating conditions. An acceptable

determination is not permitted if personnel are required to wear respirators to

control exposures to the hazard being assessed. All determinations must be fully

and accurately documented to support the decisions. Any designated ALs should

also be taken into consideration. Lastly, exposure assessment could lead to the

decision of uncertain. (i.e., there is insufficient information available for an

immediate unacceptable or acceptable determination with high confidence.) In

that case, further information gathering is needed to assess exposures.

NOTE: DOEHRS-IH does not have the option of choosing uncertain for the SEG

assessment. The IH will need to use professional judgment based on the

observations and limited data available to choose unacceptable or acceptable

with Needs More Data when completing a SEG assessment in DOEHRS-IH.

(d) Evaluate and determine the effectiveness of existing controls.

(e) Make medical surveillance recommendations based on the outcome of the SEG

assessment.

(3) Make appropriate control strategy recommendations based on the exposure

assessments, using accepted IH practices, which comply with appropriate regulatory

requirements. (Per references 2-2 and 2-3.)

(4) Further information gathering may be quantitative or qualitative. This might be

performed as part of the initial IH survey or later. Based on best practices and

requirements from references 2-2 and 2-3:

(a) Representative quantitative exposure monitoring, especially personal exposure

monitoring, is the primary means of assessing personnel exposures, the need to

control exposures, and the effectiveness of controls. If exposure monitoring is to

be conducted, an exposure assessment strategy should be developed (see

chapter 4).

(b) Qualitative exposure decisions might involve using exposure modeling,

professional judgement, etc.

(5) Reports and records of workplace characterizations, exposure profiles, exposure

assessments, findings, control recommendations or other recommendations

(including medical surveillance) are critical elements of the exposure assessment

process. Reports and records are needed to ensure effective communication of

workplace findings and successful continuity of the IH survey, per references 2-2 and

2-3. The basic elements of IH survey reports are detailed in Appendix 2-A, and

summarized in Appendix 2-B. DOEHRS-IH is the mandated system of record for IH

survey information, sampling, exposure assessments, and recommendations per

references 2-2 and 2-3.

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(6) The recommendation to enroll an individual in to a medical surveillance program

should be based on OSHA regulatory requirements, and/or the

qualitative/quantitative exposure assessments of the various occupational chemical,

biological, and/or physical hazards. Although enrollment in an exposure based

medical surveillance program can occur based on qualitative assessment results, it

usually occurs once a quantitative exposure assessment has been performed where

results indicate exposures above action level or OEL, or if OSHA has identified

specific requirements in their substance specific standards.

NOTE: The industrial hygienist’s role is to recommend stressor/hazard based medical

surveillance and exposure based respirator user certification examination. It is not

the role of the industrial hygienist to recommend medical surveillance for job

certifications unrelated to IH exposure assessments since it is a command supervisor

or human resources’ responsibility to provide that information. To help commands

identify medical surveillance requirements for job certifications, this section could

include a reference to the Medical Surveillance Procedures Manual and Medical

Matrix,” NMCPHC-TM OM 6260.

(7) Exposure Monitoring Plans (EMP) are prepared and implemented to collect

sampling/measurements required by regulation, or necessary to statistically assess

exposures, determine trends or validate professional judgement of unchanged

exposure assessments, per reference 2-2. The plan should also include monitoring

necessary to document the need for controls and the effectiveness of existing

controls (e.g., ventilation measurements or other sampling/measurements to assess

engineering or administrative controls). Reference 2-3 requires the establishment of

EMPs and completion of monitoring by industrial hygienists and industrial hygiene

officers (for ships with industrial hygiene officers assigned).

(8) Detachments will receive their IH support directly from the nearest IHPO that is

within the AOR in which the detachment is located. This initial survey shall be

considered the baseline for the detachment. A copy of the survey should be

provided to the parent IHPO and added as an addendum to the parent command’s

initial IH survey.

(9) NMCPHC established a ship IH survey repository. Initial and periodic afloat IH

surveys should be forwarded by the cognizant BUMED activity to NMCPHC IH

Department to assist enterprise IH technical and policy solutions. Such reports

should also be forwarded to the Regional IH and TYCOM IHOs. Available afloat IH

surveys for specific ships can be obtained by e-mailing NMCPHC IH Department.

b. PIHS. Once the initial survey has been completed, it is updated on a regular basis with

the PIHS (in combination with shop specific supplements discussed in paragraph 3.c).

The PIHS process provides a review of available exposure monitoring results,

information on new work operations/processes/hazards, changes in on-going work

operations/processes/hazards, and evaluates and documents the current effectiveness

of existing controls (e.g., PPE, ventilation). Changes in personnel associated to the

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particular shop, processes and SEGs are documented. Additionally, findings of other

surveys or consultations made during the specified period are summarized. Exposure

assessments need to be performed for hazards in each new SEG, or updated for existing

SEGs based on further information gathering or changes in policy or OELs. Monitoring

may not be needed for the PIHS. If no sampling/measurements are needed in the EMP

and there are no additional work operations/processes or significant changes to existing

work operations/processes, a walk-through survey documenting these findings is

adequate. Requirements for periodic surveys are discussed in references 2-2 and 2-3.

Command hazard categories are outlined in Appendix 2-C.

(1) Category I (CAT I) PIHS reports will include all Priority 1 shop evaluations every year

as a minimum, and any applicable Priority 2 and 3 shops as determined by the IHPO

so as to ensure these reassessments do not exceed the two/three and four year

shop survey periodicity cycles, respectively. In some cases it might be

administratively simpler to include all category shops (i.e., Priority 1, 2 and 3 shops)

in the annual report every year for smaller CAT I commands with predominantly

Priority 1 shops. However, workload and administrative efficiencies should be

realized by using the shop specific supplemental approach for larger CAT I

commands (e.g., shipyards, FRCs).

(2) Category II (CAT II) PIHS reports will include all Priority 2 shop evaluations every two

years for ashore commands and every three years for afloat commands as a

minimum, and include applicable Priority 3 shops as determined by the IHPO so as to

ensure Priority 3 shop evaluations do not exceed the four year shop survey

periodicity. Additionally, all Priority 1 shops shall be reassessed annually and

reported as discussed in paragraph 3.c below as part of the shop specific

supplement to the PIHS. When an IHPO sub-categorizes CAT II command survey to

apportion workload, the IHPO will ensure Priority 1, 2 and 3 shops are evaluated and

results reported in accordance with applicable intervals.

(3) Category III (CAT III) PIHS reports will include all Priority 3 shop evaluations every

four years as a minimum. In addition, Priority 1 shops shall be reassessed annually

and Priority 2 shops biennially (ashore) or triennially (afloat), respectively, and

reported per the shop specific supplement report discussed in paragraph 3.c below.

When an IHPO sub-categorizes CAT III command survey to apportion workload, the

IHPO will ensure Priority 1, 2 and 3 shops are evaluated and results reported in

accordance with applicable intervals.

(4) Detachments will receive their IH support directly from the nearest IHPO that is with

the AOR in which the detachment is located to include surveys and any workplace

monitoring. A copy of the detachment’s PIHS along with any exposure monitoring

results, and associated letters of notification should be provided to the parent IHPO

and added as an addendum to the parent command’s PIHS. The local IHPO should

also provide the local supporting Occupational Health office with copies of any

notification letters associated with personal exposure monitoring results.

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NOTE: Priority 1, 2 and 3 shop classification guidance and re-evaluation frequencies are

contained in Appendix 2-D.

c. SPIHS. SPIHS are used for shop-specific evaluations that are reported independently of

the PIHS to ensure that all shops are evaluated at the required frequency based on the

shop’s priority. For example, this type of report would be used annually for Priority 1

shop evaluations conducted at CAT II or CAT III commands during the non-periodic

survey year. See Appendix 2-B for a summary of the basic elements for both PIHS and

SPIHS reports.

d. Notification of Changes. A statement should be included in the executive summary of IH

survey reports asking that the cognizant IHPO be notified of any changes in the shops

(e.g., location, facility) or processes (e.g., process procedure, materials or equipment

used, work practices, personal protective equipment, engineering controls such as

ventilation system performance issues or degradation) between surveys.

e. Design Review Requests. A statement should be included in the executive summary of

IH survey reports which requests that new engineering designs, operating procedures,

purchasing transactions/contracts relevant to IH be sent to the cognizant IHPO for

review.

f. Shop Priority Exceptions. All afloat command shops will be designated as Priority 2

shops but will receive a singular command-based PIHS every three years as outlined in

Appendix 2-C. All Reserve Center shops will typically be designated as Priority 3 shops

and will receive a singular command based PIHS every four years as outlined in

Appendix 2-C. Reserve Centers with industrial work operations/processes, work

operation/process changes, changes to work practices, or other occupational health

concerns should contact their supporting IHPO for consultation or possible evaluation

outside of the four year periodicity.

g. Areas Specifically Excluded from IH Surveys.

(1) Industrial hygiene personnel that certify BSCs need to be properly trained and equipped.

Especially in CONUS, such personnel also need to be accredited under the

National

Sanitation Foundation (NSF) International Field Certification of BSC Program. Unless

personnel are specifically trained, equipped and preferably certified, IH surveys

should not include evaluation of BSCs. Refer to Chapter 6 for a more detailed

discussion of BSC ventilation measurements.

(2) BUMED field industrial hygienists and other Navy medicine occupational health

personnel do not determine personnel exposures to chemicals from an

environmental source (except during spill events where first responder safety is the

primary medical concern (as specified in reference 2-1)).

(a) Environmental exposure assessments and sampling are based on environmental

(generally Environmental Protection Agency (EPA)) standards, screening levels

and risk assessment processes and not on occupational health standards, OELs

and exposure assessment strategies.

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1. Occupational health standards and OELs are intended to protect adult

employees from workplace health hazards eight hours a day, five days a

week for 20-30 years. Environmental standards and screening levels may be

produced looking at risk for exposure across the entire general population

for a lifetime. These differences in assessment can result in an environmental

standard or screening level being several orders of magnitude lower than an

OEL for the same chemical.

2. Since environmental and occupational exposure assessments and standards

are so different, sampling and analytical methods to quantify those

exposures are also different.

3. Certification differs for laboratories performing analyses for environmental

versus occupational sampling.

4. Environmental concerns regulated by the EPA such as: concerns from

environmental source exposures, environmental restoration situations, etc.

shall not be treated as occupational exposures using occupational health

standards and OELs to measure risk and determine compliance.

(b) Navy Medicine assets are not intended, prepared, equipped or funded for

assessments of exposures to chemicals from an environmental situation

regulated by the EPA. Such situations are best addressed by qualified

environmental professionals.

by Installation Commanders, Naval Facilities Engineering Command

(NAVFAC)/Public Works Center (PWC), or base tenants, Medical Treatment

Facility (MTF) Commanding Officers and Officers-In-Charge need to inform the

appropriate Navy Medicine Region Environmental Program Manager (NAVMED

REPM) before committing to a response.

1. The NAVMED REPM shall assist the MTF in coordinating the response,

ensuring the participation of all needed subject matter experts.

2. Early coordination is exceptionally important because environmental issues

might involve the health of family members, union employees, the public and

media.

h. Survey Report Format. Appendices 2-A, 2-B and 2-E provide guidance for survey report

organization and content. The composition of survey reports for a command (i.e., what

shops are included) might vary each year depending upon the DOEHRS-IH priorities of

individual shops. Criteria for assigning DOEHRS-IH shop priorities is summarized in

Appendix 2-D.

i. Survey Report Tracking. Survey report completion will be tracked according to DOEHRS-

IH shop priorities. Survey reports for each shop will be considered current if the last

survey completion is within 12, 24 (36 for all afloat command shops) or 48 months of

the current date for Priority 1, 2 and 3 shops, respectively. Appendix 2-F provides

guidance to identify and define IHPO responsibility for performing IH surveys, creating

IH survey reports and entering data into DOEHRS-IH. This appendix also provides

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guidance for managing or transferring DOEHRS-IH data between BUMED IHPOs when a

command/organization relocates from one IHPO’s AOR to a different IHPO’s AOR.

j. Data Collection in DOEHRS-IH. DOEHRS-IH is a DoD/Defense Health Agency (DHA), tri-

service, multi-agency, comprehensive, automated information system for assembling,

comparing, using, evaluating, and storing IH survey data on shops, processes, SEGs,

hazards, personnel, controls, observations, monitoring, recommendations, occupational

exposure assessments and environmental health surveillance. DOEHRS-IH is a key

enabling technology within the presidentially mandated Force Health Protection Plan

and is further supported by Public Law 105-85. Reference 2-4 mandates the use of

DOEHRS-IH for BUMED IHPOs. Local IHPOs that provide support to detachments will be

responsible for entering all unit information including, but not limited to, shops,

processes, SEGs, rosters, and sample results. A copy of the survey and/or sampling

results should be provided to the parent IHPO and added as an addendum to the parent

command’s initial/PIHS.

k. Records Retention. Records of surveys, evaluations, and monitoring shall be retained for

a minimum of 40 years, as required in reference 2-2, except where specific applicable

standards require retention for a longer time. Also, refer to reference 2-5, which

dictates longer retention times for some records. For example, Section SSIC 6200.2a of

reference 2-5 dictates some occupational health, industrial and environmental control

program records not be destroyed until after 75 years.

(1) Because of turnover and the transfer of personnel, records should be maintained in

a manner to ensure that an industrial hygienist who is unfamiliar with the workplace

can access the records and be reasonably confident he/she has all the pertinent

information (past and present) on the command, individual shops and the work

operations/processes being performed therein.

(2) Reference 2-5 provides guidance in the disposition of all records, including records

no longer in active use, records of disestablished shore activities, records of

decommissioned ships and records of armed conflicts. This reference provides

information on naval records retention standards (by standard subject identification

code (SSIC) or type of record) and procedures for record disposition, including:

disposal, local record retirement (to a storage area within a command) and record

transfer (for storage outside a command, as in a Federal Records Center).

Occupational health, industrial and environmental control records are specifically

discussed in Section SSIC 6200.2 of reference 2-5. Additional information on Federal

Records Centers can be found at http://www.archives.gov/frc/.

Creating and Updating EMPs.

a. Per reference 2-2, as part of the IH survey, an EMP (OPNAV Form 5100/14 or equivalent

or as part of the IH survey report) will be completed for required or necessary

sampling/measurements. This includes sampling/measurements required by regulation,

or samples necessary to statistically assess exposures, determine trends or validate

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professional judgement of unchanged exposure assessments. The plan should also

include monitoring necessary to document the need for controls and the effectiveness

of existing controls (e.g., ventilation measurements or other sampling/measurements to

assess engineering or administrative controls). Reference 2-3 requires the establishment

of EMPs and completion of monitoring by industrial hygienists and industrial hygiene

officers (for ships with industrial hygiene officers assigned).

(1) Monitoring required by regulation includes such sampling/measurements as OSHA

required initial, quarterly, or semiannual substance specific monitoring is to be listed

as required on the EMP.

(2) Monitoring results necessary to assess exposures are typically used in statistical

quantitative exposure assessment. However, even if a certain number of results for

the statistical assessment are needed, it is not necessary to collect them all at once

during a year’s exposure monitoring; they can be gathered over time. For example,

rather than stating to collect the needed six samples on the EMP, it might be more

realistic and attainable to include only one or two of the samples for the work

operation/process or SEG as required on the yearly EMP, and then continue to have

that sampling as required on the subsequent yearly EMPs, until enough results to

statistically assess the exposures for the SEG for that work operation/process have

been collected.

(3) The EMP should generally contain just the required or necessary

sampling/measurements. If additional monitoring is included for informational

purposes or to add to existing statistical assessments, those should be marked as

“Optional”. Such optional monitoring should not be included when determining

counts for required sampling/measurements for the EMP annual self-reported fiscal

year (FY) IH metrics. If the optional monitoring is completed, it can be counted with

completed sampling/measurements conducted outside the EMP in the annual self-

reported FY IH metrics.

(4) When creating an EMP, the way the individual sampling task items are written

should be reflective of the way you will need to count your EMP or outside EMP

sampling tasks when your IHPO reports their annual self-reported FY IH metrics.

(Consult the latest BUMED self-reported FY IH metrics purpose, definitions and

directions document for the counting directions.)

b. During the periodic survey (either shop-based or command-based) the EMP must be

updated to reflect current findings. Qualitative or quantitative negative determinations

will permit the EMP to be amended to eliminate unnecessary monitoring and redirect

resources. New work operations/processes; significant changes to existing work

operations/processes; or changes to standards, instructions, or directives might

necessitate new evaluations and possible additions to the EMP.

c. It is important to remember that the EMP is to reflect an annual FY timeframe, as

opposed to the timeframe of the survey based on shop priority or command hazard

category.

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References.

2-1. OPNAV M-5090.1 Series Environmental Readiness Program Manual

2-2. OPNAVINST M-5100.23 Navy Safety and Occupational Health Manual

2-3. OPNAVINST 5100.19 Series NAVSOH Program Manual for Forces Afloat

2-4. BUMEDINST 5100.13 Series BUMED Safety and Occupational Health Program

2-5. SECNAV M-5210.1 Series

2-6. PubChem, U.S. National Library of Medicine. Bethesda, MD

2-7. NMPHC Technical Manual NMCPHC-TM-OEM 6260.01D. Reproductive and

Developmental Hazards: A Guide for Occupational health Professionals. 2019.

2-8. ACGIH. TLVs® and BEIs®, Threshold Limit Values for Chemical Substances and

Physical Agents and Documentation of the TLVs® and BEIs®. Cincinnati, OH:

American Industrial Hygiene Association. Latest edition.

2-9. Preventing Hearing Loss Caused by Chemical (Ototoxicity) and Noise Exposure,

Occupational Safety and Health Administration Safety and Health Information

Bulletin 03-08-2018.

2-10. DoDM 6055.18 Safety Standards for Microbiological and Biomedical Laboratories

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Appendix 2-A, Page 1

Appendix 2-A – Industrial Hygiene Survey Reports

1. General

IH survey reports document the interpretation of data collected during the walk-through

survey, the quantification phase of a comprehensive IH survey, and the resultant exposure

assessment. The survey reports also provide a command with the current status of

occupational health hazards, recommendations for: hazard control, PPE, administrative

controls and enrollment in exposure-based medical surveillance programs. The survey

report is a historical document that shows the work operations/processes conducted at

given locations and the hazards present at the time of the survey. A survey report must be

able to withstand close scrutiny and, as much as possible, be a self-supporting document.

Comprehensive initial IH survey reports should be issued within 90 calendar days after the

last day of the walk-through portion of the survey. PIHS reports should be issued within 45

days after the last day of the walk-through portion of the survey. Every effort should be

made to meet these timeframes so that the serviced command can get the reports in a

timely manner.

2. Style

IH survey reports are technical in nature and use terms and language characteristic of the

profession. However, each part of the survey report has a target audience who will have

varying degrees of IH background. Consider your target audience when writing reports.

3. Survey Report Types

There are essentially four principle types of IH survey reports: initial (or baseline) surveys,

periodic surveys, shop specific supplements and special surveys. The basic elements of the

initial and periodic survey reports are presented in Section 5 of this appendix. The SPIHS are

for specific shops that are reported independently of the main PIHS. An example where a

SPIHS report might be used is for a Priority 1 shop in a CAT II command in a year when the

reports for the Priority 2 shops in the command are not due. The purpose of the SPIHS is to

ensure that all shops are evaluated at the required frequency as discussed in Section 4. The

SPIHS reports may include fewer elements than the PIHS, as outlined in Appendix 2-B.

Special IH surveys are used to capture other IH related evaluations for specific hazards,

subjects, engineering systems, etc., and may have variable survey formats.

4. Survey Report Periodicity, Composition, Distribution and Tracking

a. IH surveys will be performed, reported and tracked at periodicities according to both

command hazard categories as outlined in Appendix 2-C, and DOEHRS-IH shop priorities

as outlined in Appendix 2-D.

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b. The composition of each survey report (i.e., which shops are included) may vary

according to the shop priorities. The basic elements of IH survey reports are detailed in

Section 5 of this appendix and summarized in Appendix 2-B.

c. Survey reports for a command may be distributed in a single document or in separate

documents based upon organizational sub-unit (e.g., directorate, department, division).

If the survey reports are in separate documents in the applicable reporting period, a

command IH survey report index should be prepared. This index references the

provided IH survey reports and lists the included shops in each report, as discussed in

Section 6 of this appendix. Detachments will receive their IH support directly from the

nearest IHPO that is within the AOR in which the detachment is located. The local IHPO

will enter the necessary data into DOEHRS-IH for the detachment. A copy of the survey

should be provided to the parent IHPO and added as an addendum to the parent

command’s initial or PIHS.

d. Survey report completion will be tracked according to DOEHRS-IH shop priorities. Survey

reports for each shop will be considered current if the last survey completion date is

within 12, 24 (36 for all afloat command shops) and 48 months of the current date for

Priority 1, 2 and 3 shops, respectfully.

5. Survey Report Elements

The comprehensive initial and periodic IH survey reports contain the following elements:

a. Cover Letter. A concise letter designating the survey as initial or periodic, naming the

command where the survey took place, and giving the range of walk-through survey

dates. This letter also identifies the individual(s) responsible for the survey report and

credits contributions to the report, including the surveyed command's efforts.

b. Table of Contents.

c. Executive Summary. This one to two page summary gives the Commanding Officer of

the surveyed workplace an overview of the status of command occupational health

programs, and identifies those problems that need command level attention for

resolution. If it is a periodic survey, ensure that repeat findings are annotated.

d. Program Findings and Recommendations. This is a sub-section of the executive

summary and can summarize overall findings and recommendations to the command's

major occupational health programs. Per reference 2-2, the respiratory protection

program of ashore commands requires formal written evaluation by BUMED IH. Reviews

of other Occupational Health programs (e.g., lead, asbestos, hearing conservation,

engineering controls, ergonomics and medical surveillance) may also be summarized in

this section at the discretion of the IHPO. Applicable references should be provided

when noting significant findings. The purpose of this section is to provide information

for the Safety Office to effectively manage the occupational health aspects of the Navy

and Marine Corps SOH programs. The command receiving the survey report is

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encouraged to ensure the report is reviewed and recommendations incorporated into

command hazard tracking system (hazard abatement logs) for documented follow-up

actions. Information presented should come from the survey. (Detailed command-wide

summary tables, rolled up from information from individual shop survey sections that

support the program findings and recommendations can be presented here or included

as appendices to the survey report.)

e. Worksite Evaluations, Exposure Assessments, Findings and Recommendations and

References, and EMP. This section documents the field findings from the walk-through

survey; discusses monitoring results; evaluates health risk and exposure assessments;

and provides recommendations for improvement, suggestions for enrollment in medical

surveillance programs, and exposure monitoring required for each shop. If it is a

periodic survey, this section also documents changes to the initial survey for each of the

sub-sections, as appropriate. Based on best practices and requirements from references

2-2, 2-3, and 2-4, include at least the following information:

(1) Worksite Evaluation by Shop.

(a) Location. Identify the shop location and the locations of the work

operations/processes, equipment, controls or contaminant sources. When

appropriate (e.g., for clarifying or detailing the locations of the work

operations/processes, engineering controls or contaminant sources), create a

diagram. Make the diagram detailed enough to graphically describe the locations

of the work operations/processes, engineering controls or contaminant sources

(by room number or work station) and the physical relationship of the shop and

work operations/processes to the surroundings. For periodic surveys, update the

previous information with any changes such as relocated equipment, hazards or

controls.

(b) Personnel Assigned. The number of personnel, including total assigned to the

shop, number of males and females, numbers by worker classification and

numbers for each work operations/process. Individual personnel need to be

associated to the particular shop and to the specific processes within the shop,

and to the particular SEGs. Make any updates as needed for periodic surveys.

operations/processes by task, work practices and procedures, locations,

frequencies and durations of the work operations/processes (including the

amount of time spent on each task [time course of events]), material and

equipment usage, hazards involved, controls used and number of personnel

assigned. Include individual personnel assigned to the specific processes and

worker classification if appropriate (e.g., welder, carpenter, etc.). The work

operations/processes descriptions would also include a description of the

equipment used in the shop for the work operations/processes. For periodic

surveys, if a work operation/process changes, the description must detail the

changes, including additions of any new work operations/processes or changes

in personnel.

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(d) Chemical Hazards. List chemical hazards in the workplace that present significant

risk associated with each work operation/process. Make any updates as needed

for periodic surveys.

1. Hazards that are reproductive or developmental hazards, carcinogens, or

ototoxins must be specifically identified and annotated in the survey.

Compare the hazards present with the reproductive and developmental

hazards found in references 2-6 and 2-7. Compare the hazards present with

the carcinogen listings published by OSHA, National Toxicology Program

(NTP), the International Agency for Research on Cancer (IARC) and ACGIH. For

the carcinogens, specifically include those listed as OSHA Carcinogens; NTP

Known and Reasonably Anticipated to be Human Carcinogens; IARC Groups 1-

Carcinogenic to Humans, 2A-Probably Carcinogenic to Humans, and 2B-

Possibly Carcinogenic to Humans; ACGIH Categories A1-Confirmed Human

Carcinogen and A2-Suspected Human Carcinogen. Additionally, compare the

hazards present with the ototoxins listed in references 2-8 and 2-9.

NOTE: References 2-8 and 2-9 do not identify all known ototoxicants and

additional research may be necessary. Additionally, these ototoxin references

are currently recommended to be used only to aid the industrial hygienist in

identifying ototoxins for annotation in the IH survey. This manual is not

directing the implementation of any additional medical surveillance or other

policies and guidance specific for ototoxins from these references.

2. Chemicals that are skin sensitizers, respiratory sensitizers, or absorbed

through the skin should also be specifically identified and annotated in the

survey.

(e) Physical Hazards. List any physical hazards that present significant risk, including

a brief description of their source(s), associated with each work

operation/process. Physical hazards include but are not limited to noise, ionizing

or non-ionizing radiation, ergonomic risks, temperature, and vibration. Make any

updates as needed for periodic surveys. Hazards that are reproductive or

developmental hazards, or are carcinogens must be specifically identified and

annotated in the survey. Compare the hazards present with the reproductive and

developmental hazards found in references 2-6 and 2-7, and with the carcinogen

listings published by OSHA, NTP, the IARC and ACGIH. For the carcinogens,

specifically include those listed as OSHA Carcinogens; NTP Known and Reasonably

Anticipated to be Human Carcinogens; IARC Groups 1-Carcinogenic to Humans,

2A-Probably Carcinogenic to Humans, and 2B-Possibly Carcinogenic to Humans;

ACGIH Categories A1-Confirmed Human Carcinogen and A2-Suspected Human

Carcinogen.

(f) Biological Hazards. List any biological/infectious agents (e.g., in laboratories),

that present significant risk associated with each work operation/process. Make

any updates as needed for periodic surveys. Hazards that are reproductive or

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developmental hazards, or are carcinogens must be specifically identified and

annotated in the survey. Compare the hazards present with the reproductive and

developmental hazards found in references 2-6 and 2-7, and with the carcinogen

listings published by OSHA, NTP, IARC and ACGIH. For the carcinogens, specifically

include those listed as OSHA Carcinogens; NTP Known and Reasonably

Anticipated to be Human Carcinogens; IARC Groups 1-Carcinogenic to Humans,

2A-Probably Carcinogenic to Humans, and 2B-Possibly Carcinogenic to Humans;

ACGIH Categories A1-Confirmed Human Carcinogen and A2-Suspected Human

Carcinogen.

(g) Existing Controls. Describe any controls, their use, and their effectiveness for

each work operation/process. Controls can be hazard specific. Controls can

include substitution, isolation, engineering controls, administrative controls and

PPE. Include any sampling/measurements (e.g., ventilation measurement),

comparing the results to any standards or guidelines. Reference any standards or

guidelines used when discussing the controls’ adequacy. For periodic surveys,

record any changes in the controls, their use, or effectiveness.

(h) Any other information or issues noted during the survey necessary to accurately

describe command and shop conditions.

(i) HM AUL. List any hazardous materials used in the work operations/processes

that are not on the command’s HM AUL. This will provide the command with the

information needed to update the HM AUL. For a periodic survey, any changes in

the HM AUL triggers an update in listed hazards and an updated comparison

with the reproductive and developmental hazard, carcinogen, and ototoxin

listings.

(2) Exposure Assessments by Shop and SEG. Exposure assessments are to be performed

and documented for all significant hazards to the worker based on its health effects,

likelihood of exposure, and regulatory requirements. See the definition of significant

hazards in section 2(i) for examples. The exposure assessment section documents

the analysis of the collected data and the health risk of affected personnel for each

work operation/process and hazard by SEG for each shop. For periodic surveys, if

there are previous monitoring results, the survey should include the analysis of

collected data relative to previous surveys. Also, for periodic surveys, if the

assessment changes, make a statement about the resultant change in personnel

exposure. Additionally, for periodic surveys, if there are SEG definition changes, the

description must detail the changes, including changes or additions of any shops,

work operations/processes, hazards, or personnel for the SEG, and make a

statement about the resultant change in personnel exposure. Periodic surveys must

also include description and assessment of any new SEGs.

(a) Present qualitative and quantitative exposure assessments, the basis of the

exposure assessment, the determination, the rationale for the determination,

any data used, any statistical tests used and the OELs or guidelines used, as

appropriate. Consult Chapter 4 for information on qualitative and quantitative

exposure assessments and statistical tests used for quantitative assessments.

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1. If monitoring is performed, discuss the results as part of the quantitative

exposure assessment. Tables summarizing monitoring results should be

included, especially sound pressure levels, personal noise dosimetry and

personal air sampling.

2. If historical monitoring results from the same location or results from similar

operations at other locations are used as part of the assessment, the source

of the monitoring results need to be cited.

3. Include appropriate citations of any referenced standards or guidelines.

4. Include a thorough discussion of the basis of the exposure assessment, the

determination and the rationale of the determination.

a. An exposure assessment can be based on:

(1) Sample results of the actual work operation/processes.

(2) Results from similar work operations/processes at other commands

or locations.

(3) The hazards of the materials used, amounts used, frequency and

duration of the work operation/process, work practices and available

engineering controls, etc.

b. However, an acceptable determination cannot be based on respiratory

protection provided.

c. Short duration of the work operation/process is usually not a valid

rationale for substances with ceiling or short term exposure limits.

(b) Ensure that thorough hazard assessments of all identified and annotated

reproductive or developmental hazards and carcinogens are also included.

Reference 2-2 requires that the industrial hygienist specifically address a

reproductive or developmental hazard assessment (including acceptable

determinations) as part of the routine evaluation in the IH survey.

exposure assessment status for each significant work operation/process. The list

should (as a minimum) contain the following elements: shop, SEG, work

operation/process, pertinent tasks, hazard, exposure assessment status and

basis, and rationale for the determination.

(3) Findings, Recommendations, and References by Shop and SEG.

(a) Findings. Present the field findings for each work operation/process by SEG for

each shop. Findings can be hazard specific. Findings may be positive or negative.

For periodic surveys, make any updates as needed regarding the findings and

any resultant change in personnel exposure. Also, for periodic surveys, annotate

whether the finding is a repeat from any previous survey and cite the source.

1. Monitoring results, in most cases, are best presented in tables to provide a

summary of the data that is easily understood.

2. Discuss workplace assessments, evaluation of controls, exposure

assessments and any monitoring; make a definite positive or negative

statement as to exposure of personnel relative to established standards or

guidelines.

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3. Each finding showing non-compliance with a standard or guideline must

include an appropriate citation of the referenced standard or guideline.

4. Best practices should be documented and shared.

(b) Recommendations. In sequential order, include at least one feasible

recommendation for improvement that corresponds to each finding showing

non-compliance with a standard or guideline. Some recommendations might be

made even if it is not a non-compliance situation (e.g., some PPE). For periodic

surveys, make any updates as needed regarding the recommendations.

1. Recommendations might include controls such as: substitution, isolation,

engineering controls, administrative controls and PPE.

2. Cite the reference or source of each recommendation.

3. A recommended PPE chart by shop and work operation/process is often

useful for the shop personnel.

4. If engineering controls are not installed or used properly, identify them for

inclusion in the surveyed command's Navy Occupational Safety and Health

Hazard Abatement Log.

5. Additionally identify those work operations/processes and hazards where

employees require enrollment in medical surveillance programs based on

OSHA regulatory requirements and/or the qualitative/quantitative exposure

assessments.

NOTE: The industrial hygienist’s role is to recommend stressor/hazard based

medical surveillance and exposure based respirator user certification

examination. It is not the role of the industrial hygienist to recommend

medical surveillance for job certifications unrelated to IH exposure

assessments since it is a command supervisor or human resources’

responsibility to provide that information. To help commands identify

medical surveillance requirements for job certifications, this section could

include a reference to the Medical Surveillance Procedures Manual and

Medical Matrix,” NMCPHC-TM OM 6260.

guideline and recommendations needing action are based on cited references.

Follow the guidance of reference 2-2 to select appropriate references. For

example, when citing the lack of respirator standard operating procedures

(SOPs), use OPNAVINST 5100.23G, paragraph 1513.a.(2). When citing references,

be specific enough to assist with improvements without limiting creative

responses to problems found in the field.

(4) EMP by Shop and SEG. Identify any required monitoring for each work

operation/process and hazard by SEG for each shop. Per reference 2-2, an EMP will

be completed for required or necessary sampling/measurements, as part of the IH

survey or using OPNAV Form 5100/14 or equivalent. This includes

sampling/measurements required by regulation, or necessary to statistically assess

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exposures, determine trends or validate professional judgement of unchanged

exposure assessments. The plan should also include monitoring necessary to

document the need for controls and the effectiveness of existing controls (e.g.,

ventilation measurements or other sampling/measurements to assess engineering

or administrative controls). Reference 2-3 requires exposures needing monitoring

and specifically routine ventilation system evaluation be included on the EMP.

Reference 2-2 requires EMPs to include what must be sampled and how often the

sampling should be performed.

f. Command-wide Summary Tables and Other Appendices. Summary Tables can be

beneficial to the customer. However, not all are required by references 2-2 or 2-3 or

other policy. If the IHPO chooses to use command-wide Summary Tables, the NMCPHC

recommends including information that enhances or complements the workplace

evaluation in an appendix, as appropriate or required. These summary tables and

appendices can include:

(1) Respiratory Protection Recommendations Summary. This command-wide summary

table is required for afloat commands per reference 2-3 and lists areas and

processes requiring respiratory protection. It should list the recommended

respiratory protection by shop or SEG, work operation/process, location (as

appropriate), and hazard. It should detail the minimum type of respirator required

for adequate protection.

(2) Eye Hazardous Areas and Processes Summary. This command-wide summary table is

required for afloat commands per reference 2-3 during the initial IH survey, and lists

eye hazardous areas and processes shop and/or location. It should list the

recommended eye protection by shop or SEG, work operation/process, location (as

appropriate) and hazard. It should detail the type of eye protection required for

adequate protection.

(3) Eye Wash and Deluge Shower Areas Summary. This command-wide summary table

is required for afloat commands per reference 2-3 during the initial and PIHS and

lists areas where emergency eyewashes and deluge showers are present or

recommended by shop and/or location. It should detail the type of eyewash or

shower, whether it is required for that location, any referenced standard, a brief

description of any corrective action required and any other comments.

(4) Noise Hazardous Processes and Areas Summary. This command-wide summary table

is recommended, and lists the areas and equipment designated as noise hazardous.

It should list the recommended hearing protection and signage by shop (and SEG as

appropriate) and/or location, noise source, and work operation/process and/or

equipment. It should detail the range of sound pressure levels measured, the type of

hearing protection required for adequate protection, and the required labeling

(single or double hearing protection required) as noise hazardous.

(5) Medical Surveillance Recommendations Summary. This command-wide summary

table is recommended and lists medical surveillance recommendations by shop or

SEG, work operation/process, and hazard, based upon OSHA regulatory

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requirements, and/or the qualitative/quantitative exposure assessments. The

summary is particularly useful for presentation to designated medical surveillance

program managers. It should detail the recommended medical surveillance program,

and estimated number of personnel. A recommended format for listing medical

surveillance recommendations is provided in Appendix 2-E.

NOTE: The industrial hygienist’s role is to recommend stressor/hazard based medical

surveillance and exposure based respirator user certification examination. It is not

the role of the industrial hygienist to recommend medical surveillance for job

certifications unrelated to IH exposure assessments since it is a command supervisor

or human resources’ responsibility to provide that information. To help commands

identify medical surveillance requirements for job certifications, this section could

include a reference to the Medical Surveillance Procedures Manual and Medical

Matrix,” NMCPHC-TM OM 6260.

(6) EMP. This command-wide summary table or the OPNAV 5100/14 form (or

equivalent) is recommended, and lists what must be sampled, and how often the

sampling should be performed. Additionally, any other clarifying comments or

details should be included. It should be grouped by shop or SEG, work

operation/process, location (as appropriate) and hazard for the needed monitoring.

EMPs should cover all required or necessary sampling/measurements.

(7) Reproductive/Developmental Hazard Summary. This command-wide summary table

is recommended, and lists the particular identified and annotated reproductive or

developmental hazards by shop or SEG, and work operation/process.

(8) Carcinogen Summary. This command-wide summary table is recommended, and lists

the particular identified and annotated carcinogens by shop or SEG, and work

operation/process.

(9) Ototoxin Summary. This command-wide summary table is recommended, and lists

the particular identified and annotated ototoxins by shop or SEG, and work

operation/process.

(10) Hazardous Material Storage Locations Summary. This command-wide summary

table lists the shops and/or locations where the hazardous material is stored,

detailing the type of hazardous material.

(11) Ventilation Measurements Summary. This command-wide summary table lists the

existing industrial ventilation systems (i.e., for contaminant control, but also

including flammable and hazardous materials storerooms and laundry, scullery and

galley exhaust systems) by shop (and SEG as appropriate) and/or location, and work

operation/process. It should detail system location; hazard controlled; system type,

system measurements; any referenced standard, guideline, or design criteria for

that system; whether the system meets the standard, guideline or design criteria; a

brief description of any corrective action needed; and any other comments.

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Technical Manual NMCPHC-TM6290.91-2 4 JUN 2021

Appendix 2-A, Page 10

(12) Repeat Technical Findings Summary. For periodic surveys, if there are multiple

repeat findings, it might be useful to include a command-wide summary table

listing the findings by shop or SEG, work operation/process, location and hazard.

(13) Monitoring Results Documentation. Supporting documentation for all

sampling/measurement results used to make the workplace evaluations during that

IH survey can be included as an appendix to the survey report. For example, include

copies of field data sheets used to record the results of direct reading instruments

such as sound levels, ventilation, radio frequency and illumination. Also include

copies of laboratory reports for personal and general area air samples, and bulk and

wipe samples.

(14) SOPs for Specific Programs. "Boiler plate" SOPs can be included to assist the SOH

manager in organizing and operating the occupational health programs, (e.g., any

particular SOPs for lead control, asbestos abatement, etc.).

(15) Glossary. A glossary of terms common to IH can be included. Technical terms used

in the report are listed with a plain English definition.

(16) Customer Satisfaction Survey. A customer satisfaction survey can be included.

However, inclusion with the survey report alone is not often effective in eliciting

responses. Specifically asking for response in the Executive Summary and also in

communications with the serviced command or shops might improve response

rate.

6. Command IH Survey Report Index

If the IH survey reports for a command are provided in multiple documents (e.g., by

directorate, department, division, etc.) during the applicable reporting period, then a

command IH survey report index needs to be prepared. This index references all of the

previously provided IH survey reports and includes a list of all the shops surveyed in

each individual report. The shop list should include the shop name, priority (per

Appendix 2-D), and walk-through survey date.

Industrial Hygiene Field Operations Manual

Technical Manual NMCPHC-TM6290.91-2 4 JUN 2021

Appendix 2-B, Page 1

Appendix 2-B – Survey Report Element Requirements for Initial/Periodic

Industrial Hygiene Survey Reports and Shop Specific Supplements to a

Periodic Industrial Hygiene Survey Report

Report Element

Initial/Periodic Industrial

Hygiene Survey Report

Elements

Shop Specific

Supplement to Periodic

Industrial Hygiene

Survey Report Elements

Cover Letter

Required

Table of Contents

Required only when MORE

than 4 shops are included

Required only when

MORE than 4 shops are

included

Executive Summary

Required

Overall Program Findings and

Recommendations as part of

the Executive Summary

Required, for respiratory

protection program for ashore

commands

Recommended, as needed for

others

Required, as applicable

for those shops

surveyed, for

respiratory protection

program for ashore

commands

Recommended, as

applicable for those

shops surveyed, for

others

Worksite Evaluations, Exposure

Assessments, Findings and

Recommendations and

References, and Exposure

Monitoring Plan

Required

Required, but only for

those shops surveyed

Respirator Protection Summary

Required for afloat commands

Recommended for others

Required, if applicable

for those shops

surveyed, for afloat

commands

Recommended, if

applicable for those

shops surveyed, for

others

Industrial Hygiene Field Operations Manual

Technical Manual NMCPHC-TM6290.91-2 4 JUN 2021

Appendix 2-B, Page 2

Report Element

Initial/Periodic Industrial

Hygiene Survey Report

Elements

Shop Specific

Supplement to Periodic

Industrial Hygiene

Survey Report Elements

Eye Hazardous Areas and

Processes Summary

Required for afloat commands

initial survey

Recommended for others

Optional

Eye Wash and Deluge Shower

Summary

Required for afloat commands

initial and periodic survey

Recommended for others

Required, if applicable

for those shops

surveyed, for afloat

commands

Recommended, if

applicable for those

shops surveyed, for

others

Noise Hazardous Processes and

Areas Summary

Recommended

Medical Surveillance

Recommendations Summary

Recommended

Recommended, if

applicable for those

shops surveyed

Exposure Monitoring Plan

Summary

Recommended

Recommended, if

applicable for those

shops surveyed

Reproductive/Developmental

Hazard Summary

Recommended

Recommended, if

applicable for those

shops surveyed

Carcinogen Summary

Recommended

Recommended, if

applicable for those

shops surveyed

Ototoxin Summary

Recommended

Recommended, if

applicable for those

shops surveyed

Other Command-Wide

Summary Tables and

Appendices

Optional

Industrial Hygiene Field Operations Manual

Technical Manual NMCPHC-TM6290.91-2 4 JUN 2021

Appendix 2-C, Page 1

Appendix 2-C – Periodic Industrial Hygiene Survey Report Frequency

Command

Hazard