Ideally, employers should provide employees with workplaces free of safety and health hazards. However, due to the nature of a given work operation, employees may be exposed to potentially hazardous chemical and physical agents. It is not uncommon for CWA members to be exposed to such work conditions. This is particularly true for members employed in the high hazard bargaining units and occupations that the Union represents (e.g., manufacturing, telecommunications service and installation, printing, and health care jobs).
As stated in the Occupational Safety and Health Act of 1970, employers must provide workplace controls to protect employees from exposures to hazardous substances. The type(s) of control measures that may be implemented will depend on the nature of exposure, the substance, and its route of entry into the body: inhalation (breathing), absorption (skin), and ingestion (swallowing).
Before making a decision on what type of control measure(s) to implement, the circumstances surrounding the problem(s) should be thoroughly examined. For example, in the case of an air contaminant, an exposure problem may be minimized/eliminated by reducing the amount of the contaminant in the breathing zone. An analysis of the source of the toxic, the path by which the contaminant travels to the worker, and the employee's work pattern should provide the worker with information enabling her/him to select or be provided with the most protective control measure.
Control Measures
Engineering Controls- The best method of controlling potential occupational safety and health hazards is through the implementation of engineering controls. Engineering controls are design methods that prevent harmful worker exposure. Ideally, the proper time to establish engineering controls is when the workplace is being designed. However, quite often this is either not done or not possible. In these circumstances, the following control measures should be considered.
Closed Systems- Where possible, work operations that involve potentially hazardous exposures should be conducted in closed systems. Closed systems allow for materials to be brought into the workplace in sealed containers and emptied into storage tanks, thus preventing employee contact or exposure to the substance. Unfortunately, not all operations lend themselves to such an approach.
Substitution- Quite often, a less hazardous substance or process than that currently being used may be available. Where a problem exists, CWA members should advise the employer of this consideration. Useful examples of less hazardous substitutes would include mineral spirits for trichloroethylene and trichloroethane, as well as non-asbestos products to replace asbestos materials.
Changing A Process- Another control method would be altering or changing a work operation to minimize worker exposure. For example, vapor degreasing could be accomplished with the use of dip tanks with adequate ventilation controls rather than having the worker hand wash parts in open containers.
Isolation- Where possible, potentially hazardous work operations might be isolated or enclosed to reduce employee exposures. An example of this process would be utilizing acoustic panels to reduce noise. Isolation equipment may be operated by remote control from some protected location. The degree of isolation should be determined by the toxicity of the substance, the amount and duration of the contaminant exposure, and the involved work patterns.
Wet Methods- Wetting a particular substance will reduce the generation of dust. This control method is widely utilized because it is a simple, effective, and an inexpensive way to minimize potential health hazards. In order that this control method works most effectively, use of a wetting agent may be required and proper disposal procedures should be used.
Local Exhaust Ventilation- Local exhaust ventilation is a system located at the source of contaminant generation that captures the hazardous substance(s) before it/they escape into the workplace environment. Local exhaust ventilation systems are a preferred control method because they remove air contaminants rather than just dilute them. Local exhaust systems should be used when substitution, changing the process, or enclosure are not compatible with the work operation.
General Ventilation- General or dilution ventilation systems add or remove air from the workplace to keep the concentration of air contaminants below hazardous levels. General ventilation consists of the airflow through open windows or doors, fans, and roof ventilators. It should be remembered that general ventilation control only dilutes air contaminants unlike local exhaust ventilation that removes air contaminants. Therefore, general ventilation should not be used to remove great amounts of air contaminants from the workplace environment or to control major localized sources of air contamination. When using general ventilation systems, care should be taken not to re-circulate the toxic substances throughout the workplace.
Personal Protective Equipment- When it is not possible or feasible to eliminate hazardous levels of air contaminants from the workplace, it may become necessary for the employer to provide personal protective equipment so that toxic exposures may be minimized. However, personal protective equipment should only be used when it is not possible to isolate a work process, provide ventilation, or use another more protective control method. Personal protective equipment does nothing to minimize or eliminate the source of the problem, i.e., the hazard. Thus, if the personal protective equipment fails to work properly, the worker suffers immediate exposure to the toxic substance.
Personal protective devices include eye and face protection such as safety glasses, goggles, and face shields; hearing protection like ear muffs and ear plugs; protective clothing such as gloves, gauntlets, coveralls, aprons, and boots; protective creams and lotions; and respirators. Importance must be placed upon the employer furnishing the proper type of personal protective equipment for specific work operations and exposures. For example, when an employee is working with a particular solvent, she/he should be provided the proper gloves to prevent the substance from seeping through the glove and causing harmful skin contact.
More and more, employers have begun emphasizing the use of respirators rather than implementing adequate engineering controls. Respirators should not be viewed as a substitute for engineering controls. Rather, when used, they should be seen as offering only short-term or emergency protection. An approved respirator should be appropriate for the particular hazard or work environment in which the respirator is to be utilized (e.g., dust masks should not be used to protect against chemical exposures). In addition, the type of air contaminant, its expected maximum concentration, the possibility of oxygen deficiency, the life of the respirator, and available escape routes should be determined before the work is initiated. Before supplying employees with respirators, employers should give them complete physical examinations to determine workers' adaptability to respirators and provide them thorough respirator protection training programs.
Personal Hygiene- Employers should make hand-washing facilities readily available to employees working with or near toxic substances. It is important that workers be able to wash promptly in case of accidental splashes of toxic substances. Also, where called for, convenient access to emergency showers should be provided. Eating and storage or drinking of foods and liquids should be forbidden where toxic substances are used.
Regulated areas, where biological hazards or proven or suspected cancer-causing agents are used or handled, should be properly marked to inform workers of the potential hazards and the regular and emergency procedures required. Employers should also provide workers who enter such areas with a place to change protective clothing and equipment.
Medical Controls- Medical controls should be an extremely important part of an employer's safety and health or medical program. Such controls would include a physical examination for all workers, consisting of a thorough medical and work history including exposures to toxic and hazardous substances. Audiometric tests should be a part of the physical examination. Results from these exams provide baseline data that, with the results of periodic exams, allow for the detection of the harmful effects of particular work operations and the evaluation of their severity. Medical records must be maintained by the employer and made available to requesting employees.
In addition to periodic medical examinations, workplace exposure monitoring tests should be conducted on a periodic, regular basis. Instrumentation that continuously monitors the work environment for airborne contaminants and triggers an alarm when concentrations exceed safe levels should be obtained and used. Use of information from both physical examinations and workplace exposure monitoring can be an effective method of discovering potential occupational safety and health hazards.
Administrative Controls- An employer might decide to use administrative controls to minimize occupational exposure to toxic substances. One type of administrative control would be a reduction of work periods for jobs that involve exposure to toxics. For example, by transferring an employee who has worked four hours at an operation involving exposure to hazardous substances/agents to work at a less hazardous task for four hours, the worker's toxic exposure is minimized. Administrative controls should not be viewed as long-term substitutes for engineering controls, and other more effective methods of minimizing exposures to hazardous substances.
Maintenance- All employers should make sure that adequate maintenance schedules are established and adhered to. Poor maintenance of workplace equipment usually causes poor operation of machinery and, in turn, increased workplace accidents and illnesses. A regular maintenance schedule should include periodic shutdowns of all equipment. In addition, employees performing maintenance should be provided with the necessary personal protective equipment.
Good Housekeeping- It makes sense for companies to establish and maintain good housekeeping practices. Proper good housekeeping procedures include a thorough cleaning of the workplace, as well as adequate washing, toilet, eating, and waste disposal facilities. Employers should ensure that toxic substance spills are cleaned immediately. Work practices should also be in effect for the safe disposal of toxic chemicals and other hazardous substances.
Training- All employers representing CWA members should have effective training programs that deal with employees' working conditions. Part of this training should include information on the types of occupational hazards, adequate coverage of personal protective equipment, a medical surveillance program, and emergency situations. Where companies have not formulated such a training program, CWA-represented workers should encourage them to do so.
What Can You Do?
All CWA members should make sure that their employer is maintaining a safe and healthful workplace. The key to making the workplace safe for all CWA members is strong, active local safety and health committees. The committee can identify dangerous conditions at the workplace and discuss them with management. If the employer refuses to cooperate, the committee can request an OSHA inspection. The committee should always coordinate its activities through the local officers, the CWA Representatives, and negotiated safety and health committees.
In addition, CWA members may obtain information and assistance by contacting the:
CWA Occupational Safety and Health Department
501 Third Street, NW
Washington, D.C. 20001-2797
Webpage: www.cwasafetyandhealth.org
Phone: (202) 434-1160.
Developed in 1980 and revised in 1991, 1994, 1996, 2000, 2002, 2004, 2007, and 2009.
