Determining if industrial hygiene (IH) monitoring is required

Q.  Is Industrial Hygiene testing and monitoring required for all R2 facilities?

No, IH monitoring is not specifically required for all R2 Facilities. There are however, several areas in appendix E where IH monitoring may be required for facilities performing materials recovery, where certain conditions exist.  In addition, R2 Facilities may also choose, or be required through regulatory requirements, to implement certain IH monitoring activities as part of their EHS risk assessment and evaluation processes.

Under Core Requirement 3, all R2 Facilities are required to:

• • Identify, analyze and control their environmental impact and health and safety risks; and
  • Evaluate the risk of exposure to hazardous substances.

The potential hazards and risk of exposure to hazardous substances depend on a variety of factors including the types of equipment or materials handled, the operations performed, and the EHS control measures in place.  As a result, the potential hazards can vary significantly from facility to facility.  For example, an organization that tests and repairs mobile devices, may never receive CRTs or mercury containing devices and therefore may not have any exposure to the hazards associated with those items.  Whereas, a facility that receives and processes display devices will have increased risk of exposure to hazardous substances.  And, depending on the types of displays processed, the hazardous substances will differ – e.g. risk of exposure to lead when processing CRTs, and risk of exposure to mercury when processing LCDs.  Due to these many variables and the unique aspects of each organization’s operations, the risk identification and analysis must be specific to the operations of each R2 Facility.

There are a wide variety of tools and techniques that R2 Facilities can use to identify EHS risks and evaluate expose to hazardous substances.  These activities may be included as part of a regular risk assessment process but can also be included as part of a management of change process that assesses risks related to any changes in the facility or operations, such as the implementation of new processes or processing equipment; or when new or different types of electronic equipment, components, or materials are managed.

And, depending on the hazards identified, even where not required in the R2 Standard or regulatory requirements, IH monitoring may be a useful tool for assessing and quantifying the level of risk associated with specific hazards as well as evaluating the effectiveness of EHS controls in managing them.

ADDED 1/7/2022      Q:  Does certifying to Appendix E automatically mean that the facility must conduct IH testing?

No, whether IH testing and monitoring is required or not is determined through the R2 Facility’s hazards identification and assessment, required under E (1).   (See previous question for more details)