Industrial Hygiene & Occupational
Health Program
Ashland has a state-of-the-art Industrial Hygiene and Occupational Health (IH and OH) Program that establishes the requirements and responsibilities for industrial hygiene and medical surveillance programs at all Ashland facilities. This program contains all the requirements and programs that we will use, on a global basis, to manage and control employee exposures to chemical, physical, and biological hazards. These programs include the following subjects:
o Employee Exposure and Risk Assessment
o General Chemical Hazards
o Chemical Specific Hazards
o Active Pharmaceutical Ingredients
o Physical Hazards
o Biological Hazards
o Engineering Controls
o Personal Protective Equipment
o Respiratory Protection
o Medical Surveillance
Industrial Hygiene and Occupational Health are complex topics, and our facilities are also responsible for identifying and complying with all applicable regulatory requirements that apply to them at their local sites. We have Environmental, Health and Safety (EHS) subject matter experts (SMEs) that help assist these facilities as needed to comply with these local requirements, as well as those of Ashland. When Ashland’s requirements are stricter, we apply these regardless of the location’s local rules.
As part of Ashland’s Occupational Health program requirements, each facility is required to appoint a Coordinator who works with IH and OH SMEs to comply with specific standard requirements, such as exposure assessments and medical examinations. Each Facility Coordinator receives training provided by Ashland’s SME staff and outside sources to ensure that they have the technical knowledge to properly apply the requirements of Ashland’s IH and OH program.
Part of our program requires a comprehensive review of each functional area to determine effectiveness. This is done on an annual basis. It is accomplished in a number of ways, most commonly through external auditing or self-assessments.
Ashland’s IH and OH program requires that each facility have a documented process in place to evaluate workplace exposures to chemical, physical, and biological hazards. The employee exposure and risk assessment process includes, but is not limited to:
o A qualitative exposure and risk assessment that is used to determine if further evaluation is necessary
o A quantitative exposure assessment is required if the qualitative risk assessment identifies any concerns; this includes a monitoring plan and designated frequency for re-monitoring
o All analyses of samples are required to be performed by American Industrial Hygiene (AIHA) accredited laboratories; in cases where samples are taken outside the Unites States and no AIHA accredited lab is available, the local government recommended laboratories are utilized
o A process for the introduction of new chemical, biological, and physical hazards into the workplace
o A process for notifying facility employees of changes to the IH and OH programs in accordance with Ashland’s Management of Change Standard; potential changes could include introduction of new hazards in the workplace, new processes, changes in regulations, and changes in applicable occupational exposure limits (OELs)
These qualitative and quantitative exposure assessments of chemical, physical, and biological hazards are completed by qualified professionals.
One of the foundations of Ashland’s Industrial Hygiene program is the requirement that the lowest available Occupational Exposure Limit (OEL) be used for exposure assessments. These limits can be found from these various organizations:
o The local regulatory authorities
o T he American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs)
o The American Industrial Hygiene Association Workplace Environmental Exposure Level (WEEL)
o An OEL that has been developed by Ashland’s EHS department
o An OEL that has been developed and provided by the raw material’s supplier and has been approved by Ashland’s EHS QRA department
o An OEL for a surrogate substance, that has similar toxicological effects, may be used when no OEL is available for the substance being evaluated
Ashland also follows the hierarchy of controls to reduce and eliminate employee exposures to chemical, physical, and biological hazards; in the following order:
o Elimination of the hazard whenever possible
o Substituting a less hazardous substance or process when appropriate
o Implement engineering controls to reduce the hazard
o Implement administrative controls such as worker rotation
o Implement personal protective equipment
o Employee personal exposure assessment results shall be communicated in writing to impacted employees, in accordance with local regulations, and documented in facility files
Finally, Ashland communicates results of all sampling and assessments to employees, in writing. We have a defined process for sharing these results and storing records in accordance with government regulations.
And while we applaud the achievements of the sites that have already achieved zero workplace injury incidents, we continue to focus on the remaining sites to drive toward our goal of zero incidents company-wide while sustaining the performance of those that have reached zero.
