Q:     How do I determine if industrial hygiene (IH) sampling and monitoring programs are required?

There are three primary considerations when determining whether IH sampling and monitoring may be required:

First, depending on the materials handled, methods in which they are managed, or the hazards present at the facility, IH sampling and monitoring may be required by regulation.  For example, noise levels in the workplace are often regulated, so where there is a risk of elevated noise levels, noise testing may be required.  Also, when materials are managed or processed in a way that may cause them to become airborne, there may be regulated exposure limits to protect the health and safety of workers, which could also mean that IH monitoring is required.

Where any IH monitoring is required by regulation, the R2 Facility’s legal compliance plan must clearly identify the sampling and monitoring activities required and all conditions under which they must be conducted.  If unsure of the regulatory requirements regarding IH sampling and monitoring, then further regulatory assessment is required.

Second, as indicated in Appendix E (4)(b) & (c), if food or drink are permitted in materials recovery areas or if workers take home their work clothes or shoes, then IH monitoring is required to demonstrate that there is no increased risk of exposure to hazards as a result of those practices.

Lastly, the hazards identification and assessment, required in Appendix E (1), must also be used to determine if further IH sampling and monitoring is necessary.  Risks of exposure to contaminants will vary from facility to facility based on a variety of factors including the types of materials processed, quantities of the materials processed, and the methods of processing performed.  As a result, the R2 Facility will need to determine if any IH monitoring is required based on the specific hazards identified and the associated risks posed by each.  IH monitoring may include noise level monitoring, air sampling, surface sampling, and even medical surveillance for workers.

When determining what is required for your operations, remember that IH monitoring can be an effective means to identify potential contaminants, establish baseline exposure levels, demonstrate compliance with any regulated exposure limits, and test the effectiveness of EHS controls in reducing or eliminating the risk of exposure to key hazards.

Q:    Does the hazards identification and assessment need to be conducted by a third-party?

No, Appendix E (1) and (2) do not require the use of an independent third-party, but it’s important to remember that the individual that conducts that assessment must be trained in risk assessment and analysis techniques.  They must also be knowledgeable of the occupational and environmental hazards associated with materials recovery activities of the R2 Facility.

Q:     What are some of the activities that should be involved in the hazards identification and assessment?

If you are unsure of what to include in this process, it is often a good idea to engage a professional that is familiar with environmental, health and safety hazards and risk assessment techniques.

Generally, the hazard identification process starts with a review and assessment of the facility’s overall processes and procedures.  This enables the risk assessor to gain a general understanding of the operations and identify the key processes or activities that require further detailed assessment.

Sometimes these key processes can be readily identifiable by the task or activity performed, such as LCD panel dismantling, or battery removal, and the associated hazards can be identified and assessed accordingly.  Other times, the assessment may require a more detailed analysis of specific jobs or positions, such as a shredder operator, or forklift operators, in order to identify the specific activities and hazards associated with each role.

Once identified, each of these key processes must then be examined in detail, including reviewing any process related documentation and even interviewing workers in an attempt to identify all potential hazard related to the process.

Through these detailed assessments, an inventory of hazards is developed, and each is then assessed to determine the potential level of risk that it poses.  Based on the level of risk associated with each hazard, a determination must be made on the types and levels of EHS controls that may be required to effectively manage each hazard.  Then, further periodic assessments must be conducted to re-evaluate the risk and assess the ongoing effectiveness of the EHS controls.

 Q:   Does IH monitoring need to be conducted by a third-party?

Appendix E (4)(b), (c), (i), and (k) do not require the use of an independent contractor to perform IH sampling and evaluation, however, it is important to note that specialized knowledge and skills are required not only to perform these activities but also to properly interpret any testing or sampling results.  Performing IH monitoring without the proper detailed analysis of the results by a trained individual can result in misinterpretation, potentially leading to unidentified or unmitigated hazards as well as regulatory compliance issues.

In addition, IH sampling can often require the use of very specialized monitoring equipment and the costs to purchase, calibrate and maintain this equipment may be prohibitive for only periodic testing activities.  As a result, R2 Facilities may find it both cost- and time-efficient to use outside professionals for IH monitoring.

The further benefit of using a contracted IH professional is that their independent assessment and recommendations, including any written reports, can be valuable tools to include as part of the written hazards assessment as required in Appendix E (3), and also help to demonstrate conformance during EHSMS audits as well as compliance with regulatory requirements.

Q:    What are some of the key steps in the IH monitoring process?

To ensure monitoring results are both accurate and representative of typical operations, all IH monitoring must be conducted in a planned and structured manner.  This means that specialized training and knowledge of the hazards and monitoring processes are required.

Whether performed internally or by a contracted IH consultant, the IH monitoring process usually follows the same general steps.  Starting with a review of the most recent hazard assessment, the IH specialist will also examine the results of any previous IH tests, tour the operations and possibly conduct employee interviews as well.  The purpose of these steps is to better understand the specifics of the operations to help identify any potential risks or exposures related to the activities, particularly where there may have been any changes in the hazards or level of risk.

From there, the IH specialist will determine the specific areas and hazards to sample and monitor.  Standard IH measurement tools can include ambient air and noise monitors, body-worn air and noise monitors, light-level measurement devices, and wipe tests of various surfaces throughout the facility.

Following the monitoring and sampling activities, the IH specialist will analyze the test results, particularly looking for any trends or changes in the types of hazards or levels of risk, to determine where any further tracking, testing or EHS controls may be required.

Q:    Does Appendix E require my facility to build employee lunchrooms and changing rooms?

No, since the risk of exposure to contaminants will vary from facility to facility, based in part on the materials handled and operations performed, but also the EHS control measures in place, the types and levels of EHS controls used will also vary by facility.  As such, the standard does not require specific controls such as lunchrooms or change rooms for all R2 Facilities.  Instead, the standard requires each facility to identify the EHS hazards applicable to its operations, determine the level of risk of exposure to those hazards, and implement effective EHS control measures to manage any potential exposures.

One of the main considerations of the R2v3 requirements is the safety of workers in R2 certified facilities.  But, it is also recognized that the application of the R2 requirements by the diverse types of R2 facilities of all sizes across the globe, could include a wide array of EHS controls as best suits each individual facility.

Of course, it is important to remember that if either lunchrooms or changing rooms, or any conditions related to either, are a requirement of local regulations, then those legal requirements must be addressed regardless of the R2 requirements or hazards assessment results.

Q:    What is “No Detectable Risk”?

No detectable risk is a determination that is made by a trained and competent individual that is based on the results of the hazards identification and assessment process, and supported by regular IH testing, that indicates there is no risk of exposure to a hazard or any exposure is within permissible or other established exposure limits.

While the results of IH testing must be used to support the no detectable risk determination, there is no single test or result to make that determination.  Also, testing results do not need to indicate zero presence of a hazard, but rather that it is below an established or actionable threshold.  Exposure limits may be defined in regulation or established guidelines from a recognized organization such as the American Conference of Governmental Industrial Hygienists (ACGIH) or the National Institute for Occupational Safety and Health (NIOSH).

Determination of no detectable risk does not rely solely on IH testing however, as EHS controls are generally required to mitigate any exposure risks and those controls must be maintained on an ongoing basis and assessed for continuing effectiveness through the hazards identification and assessment process.

Under Appendix E (4)(b) & (c) certain activities are prohibited unless the R2 Facility can demonstrate no detectable risk of exposure to the associated hazards.  If it is determined through hazard assessment and IH testing that even after EHS controls have been implemented that the risk of exposure has not been sufficiently mitigated to an acceptable level, the associated activities must be prohibited.

Q:    What are the benefits of continued IH evaluations?

Once baseline IH measurements have been collected, periodic future measurements can help identify any changes in the hazards or the level of risk and also help to determine whether ongoing operations, including any risk mitigation actions, are effective. The effects of any new operations undertaken by the facility could also be measured by comparing current IH testing with the results of past tests.

Q:    How do I know what hazardous substances or components may be present in my facility?

If you are unsure of what hazardous substances may be present, or the electronic components that may contain these items, it is a good idea to engage a professional that is familiar with the environmental, health and safety hazards associated with electronics processing operations, and if necessary, can conduct some sampling to test for and establish baseline measurements of the presence of any hazardous substances.

For more general information, the National Institute for Occupational Safety and Health (NIOSH) has completed numerous Health Hazard Evaluations for electronics recycling facilities that can provide some helpful background on the key hazards and exposures related to various processing activities.  These reports also provide a number of recommended controls for managing the hazards, which should be considered wherever the hazards are present.

The NIOSH reports specifically identify the following hazardous substances as a source for potential worker and take-home exposures, as well as the key electronic components they are typically found in:

When processing any of  the above electronic components through dismantling for the purpose of material recovery, there is potential for a release of a hazardous constituent that must be further assessed to determine the risk of exposure.

For more information on the NIOSH Health Hazard Evaluation Program and to get copies of the completed reports, visit:  https://www2a.cdc.gov/hhe/search.asp.