APPENDIX C: Exposure Assessments, Medical Consultations and Examinations

1.0 Suspected Exposures to Toxic Substances

There may be times when employees or supervisors suspect that an employee has been exposed to a hazardous chemical to a degree and in a manner that might have caused harm to the victim. If the circumstances suggest a reasonable suspicion of exposure, the victim is entitled to a medical consultation, and if so determined in the consultation, also to a medical examination at no cost nor workday lost time attributed to the victim.

1.1 Criteria for Reasonable Suspicion of Exposure

  1. It is the policy of the University of the South to promptly investigate all employee- reported incidents in which there is even a remote possibility of employee overexposure to a toxic substance.
  2. Events or circumstances which might reasonably constitute overexposure include:
    1. A hazardous chemical leaked or was spilled or was otherwise rapidly released in an uncontrolled manner.
    2. A laboratory employee had direct skin or eye contact with a hazardous chemical.
    3. A laboratory employee manifests symptoms, such as headache, rash, nausea, coughing, tearing, irritation or redness of eyes, irritation of nose or throat, dizziness, loss of motor dexterity or judgment, etc. and:
  3. Some or all of the symptoms disappear when person is taken away from the exposure area and breathes fresh air, and the symptoms reappear soon after the employee returns to work with the same hazardous chemicals.
  4. Two or more persons in the same laboratory work area have similar complaints.

1.2 Exposures

All complaints and their disposition, no matter what the ultimate disposition may be, are to be documented. If no further assessment of the event is deemed necessary, the reason for that decision must be included in the documentation. If the decision is to investigate, a formal Exposure Assessment will be initiated.

In cases of emergency, Exposure Assessments are conducted after the victim has been treated.

NOTE: It is not the purpose of an Exposure Assessment to determine that a failure on the part of the victim, or others, to follow proper procedures was the cause of an exposure. The purpose of an Exposure Assessment is to determine that there was, or was not, an exposure that might have caused harm to one or more employees and if so, to identify the hazardous chemical, or chemicals, that were involved. Other investigations might well use results and conclusions from an Exposure Assessment, along with other information, to derive recommendations that will prevent or mitigate any future overexposures; but Exposure Assessments determine facts, they do not make recommendations.

  1. Unless circumstances suggest other or additional steps, these actions constitute an Exposure Assessment:
    1. Interview the complainant and also the victim if not the same person.
    2. List the essential information about the circumstances of the complaint including:
      1. The chemical under suspicion.
      2. Other chemicals used by victim.
      3. All chemicals being used by others in the immediate area.
      4. Other chemicals stored in that area.
      5. Symptoms exhibited or claimed by the victim.
      6. How these symptoms compare to symptoms stated in the Material Safety Data Sheets for each of the above identified chemicals.
      7. Were control measures, such as personal protective equipment and hoods used properly?
      8. Where any air sampling or monitoring devices in place, and if so, are the measurements obtained from these devices consistent with other information?
  2. Monitor or sample the air in the area for suspect chemicals.
  3. Determine whether the victim's symptoms compare to the symptoms described in the MSDS or other pertinent scientific literature.
  4. Determine whether the present control measures and safety procedures are adequate.
  5. Within 15 working days of receipt of the results of any monitoring, notify employees of those results.

2.0 Medical Consultation and Examination

The details of Medical Consultations and Examinations are determined by the physician.

The purpose of a Medical Consultation is to determine whether a Medical Examination is warranted. When from the results of an Exposure Assessment, it is suspected or known that an employee was overexposed to a hazardous chemical or chemicals, the employee should obtain Medical Consultation from or under the direct supervision of a licensed physician.

When warranted, employees also should receive a Medical Examination from or under the direct supervision of a licensed physician who is experienced in treating victims of chemical overexposure. The medical professional should also be knowledgeable about which tests or procedures are appropriate to determine if there has been an overexposure; these diagnostic techniques are called "Differential Diagnoses".

These provisions apply to Medical Consultations and Examinations:

  1. The employer shall provide all employees who work with hazardous chemicals an opportunity to receive Medical Consultation and Examination when:
    1. The employee develops signs or symptoms associated with a hazardous chemicals to which the employee may have been exposed in the laboratory.
    2. Monitoring, routine or otherwise, suggests that there could have been an exposure above the Action Level, or PEL if there is no Action Level, for a chemical for which a Substance Specific Standard has been established.
    3. There is a spill, leak, or other uncontrolled release of a hazardous chemical.
  2. The physician will be provided with:
    1. The identity of the hazardous chemical or chemicals to which the employee may have been exposed.
    2. The exposure conditions.
    3. The signs and symptoms of exposure the victim is experiencing, if any.
  3. Ordinarily physicians will furnish to the employer in written form:
      2.1 Documentation

      All memos, notes and reports related to a complaint of actual or possible exposure to hazardous chemicals are to be maintained as part of the record.

      2.2 Notification

      Employees shall be notified of the results of any medical consultation or examination with regard to any medical condition that exists or might exist as a result of overexposure to a hazardous chemical.