The Catholic University of America

Responsibilities of the Industrial Hygienist

Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act

The University may not possess a biological agent or toxin, or delivery system of a type or quantity not reasonably justified by prophylactic, bona fide research or other peaceful purpose. “Biological agent” means a microorganism, virus, infectious substance, or biological product that may be engineered, or any naturally occurring, or a bio-engineered component of same capable of causing death, disease or biological malfunction in a living organism, or deterioration of food, water, equipment, supplies or material, or deleterious environmental alteration.  “Toxin” means the toxic material of living matter or infectious substances, or a recombinant molecule including any poisonous substance or biological product that may be engineered as a result of biotechnology produced by a living organism, or derivative of such a substance.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for conducting inspections and implementing processes and procedures ensure compliance with PATRIOT Act.

Clean Air Act

DC implements the Environmental Protection Agency (EPA) Title V air quality standards and emissions limits.  Per DC regulations, a stationary source (a building, structure, facility or installation) that emits or may emit any air pollutant regulated by the EPA must get a permit. Regulated pollutants include asbestos, lead compounds, chlorine, formaldehyde, hydrochloric acid, radionuclides, and mercury. If the University's stationary sources emit 25 tons or more of air pollutants per year, then written records of the nature and amount of emissions must be kept.  If the University has stationary sources emitting more than 100 tons per year, per Title VI the University must have monitoring devices.  Emissions of particulates from fuel burning equipment cannot exceed the DC limit, and performance testing for compliance is mandatory.

The Mandatory Reporting of Greenhouse Gases Rule, implemented pursuant to the EPA’s Clean Air Act powers, rule requires that the University submit an annual report on its greenhouse gas emissions.  Gases covered include: carbon dioxide (CO2) (a pollutant per the EPA); methane (CH4); nitrous oxide (N2O); hydro fluorocarbons (HFC); per fluorocarbons (PFC); sulfur hexafluoride (SF6); and other fluorinated gases and hydro fluorinated ethers.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for required monitoring, testing, and reporting under the Act and the Rule.

OSHA - Asbestos in Construction Standard

(Applies to construction only.)  No employee may be exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic cm of air as an 8 hour time-weighted average.  The University must monitor subject areas and potentially affected employees must be notified of results within 5 days. The University must use these safety procedures:

Demarcation and specific signage

Critical barriers for isolation

Hazard communication to potentially affected employees

Restricted access

Training for employees working with asbestos containing material (ACM) or who are likely to be exposed beyond permissible limits

Supervision of work by a competent person

Use of respirators

Engineering controls such as isolation processes, vacuum cleaners with HEPA filters, prompt clean-up procedures including wet clean-up, and use of leak tight containers

Decontamination procedures for entry and exit

The requirements above also apply to contractors.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing and overseeing required monitoring and safety procedures per OSHA.

OSHA - Asbestos in General Industry Standard   

(Applies to occupational exposure other than construction.) The University must ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight hour time-weighted average.  The University must perform initial monitoring where employees are or may reasonably be expected to be exposed at or above the exposure limit, and must promptly notify such employees of the results within 15 working days.  Required, repeated monitoring depends on the initial results.  Safety and compliance procedures required: 

Demarcation of regulated areas

Warning signage

Access by authorized personnel only

Provision of respirators and a respirator program

Training for employees exposed to exposure limits

Engineering controls and work practices such as wet method clean-up and exhaust ventilation

A written program to reduce exposure limits

Hazard communication to potentially affected employees 

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing and overseeing required monitoring, safety and compliance procedures per OSHA.

OSHA - Lead in Construction Standard and DC Lead-based Paint Abatement Act of 1996                                               

(Applies to exposure to lead during construction only). The University must conduct lead exposure assessments for construction jobs (alternation, repair, demolition, painting, decorating) with possible exposure to lead to determine if exposure threshold met (i.e. > 50 micrograms concentration per cubic meter of air averaged over an 8 hours).  If the threshold is met, the University must notify affected employees, institute engineering and work practice controls to reduce exposure to permissible levels, and conduct repeat monitoring.  Also applies to contractors. 

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing and overseeing required assessments, notification, controls and monitoring per OSHA.

OSHA - Lead in General Industry Standard

(Applies to occupational exposure to lead by employees in non-construction setting.) The University must ensure no employee is exposed to > 50 micrograms lead concentration per cubic meter of air averaged over an 8 hours.  Where there is potential exposure the University must make a determination as to whether employees are so exposed, and if so must notify the employee, institute corrective action via engineering and work practice controls, and repeat monitoring activities. 

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing and overseeing required determinations, notifications, controls and monitoring per OSHA.

OSHA - Bloodborne Pathogen Standard    

The University must maintain a written exposure control plan and provide appropriate instruction on precautions to all workers who might become exposed to blood or other potentially infectious materials. The regulation applies to any facility where occupational exposure, such as through first aid administration, can be reasonably anticipated.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing the bloodborne pathogen exposure control provisions in compliance with OSHA.

OSHA - Personal Protective Equipment (PPE)

PPE is required to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing exposures to acceptable levels.  The University must assess the workplace to determine if hazards capable of causing injury or impairment through absorption, inhalation or physical contact are present or likely to be present that necessitate use of PPE. If so, the University must train each employee who is required to use PPE regarding when and what PPE is necessary, how it is to be used or worn, and its limitations.  Each employee must demonstrate an understanding of the training.  PPE must be provided, used, and maintained in a sanitary and reliable condition.  The University must pay for PPE, except footwear.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing the PPE provisions in compliance with OSHA.

OSHA - Respiratory Protection Standard

The University must provide respirators when necessary to protect the health of the employee from occupational diseases caused by breathing air contaminated with harmful dusts, fumes, gases, vapors, etc.  The University must develop and implement a written respiratory protection program administered by a suitably trained program administrator.  The Program must provide procedures for the following:

Medical evaluations

Fit testing

Proper use of respirators

Maintenance schedules

Training of employees regarding respiratory hazards and proper use of respirators

Regular program evaluations

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for implementing the respiratory protection provisions in compliance with OSHA.

OSHA - Powered Industrial Trucks

The University must ensure that prior to operation of an industrial truck (fork trucks, tractors, platform lift trucks, motorized hand trucks) each operator is competent to operate the truck safely as demonstrated by successful completion of training and evaluation.  The University must certify that each operator has been trained and evaluated regarding use.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for training, evaluation and certification of operators in compliance with OSHA.

OSHA - Fall Protection

(Applies to construction only).  The University must determine if walking or working surfaces have strength and structural integrity to support employees safely.  The University must provide fall protection systems (guardrails, safety nets, fall arrest systems) where employees work 6 feet or more above edges, holes, ramps, walkways, openings or dangerous equipment, or are engaged in overhand bricklaying, roofing or precast concrete erection 6 feet or more above lower levels. If this is infeasible or creates a greater hazard an alternate fall plan must be developed.  If employees are exposed to falling objects the University must have each employee wear a hard hat and must implement toe boards, screens, or guardrail systems, erect a canopy structure, or barricade the area.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for maintaining the University’s fall protection provisions in compliance with OSHA.

OSHA - Aerial Lifts

The University must ensure that employees operating personnel-carrying devices (baskets or buckets) that is a component of an aerial device used to position workers has undergone operator training to ensure the devices are used properly.

The Industrial Hygienist, working in conjunction with the Director of EH&S, is responsible for maintaining the University’s aerial lift protection provisions in compliance with OSHA.

Related Policies

Annual Security and Fire Safety Report

Contractor Safety Guide

Environmental Health and Safety Manual

Environmental Health and Safety (website)

Laboratory Security Policy

Project Manager Safety Guide