Monitoring of High-Risk Employees

Employees remain at risk throughout clean-up. Therefore, employers must monitor high-risk employees after the clean-up phase of a hazardous waste operation begins. 29 CFR 1910.120 gives examples of clean-up operations; some of the examples include moving or disturbing soil, surface water, or containers.

Employers may use a "representative sampling approach," which identifies high-risk employees who are most likely to have the highest exposure limits (and then using the results of their testing as a representation of the possible exposure levels of co-workers who complete the same tasks). 29 CFR 1910.120 does not provide specifics as to how often employers should test employees or by what means. However, the code states that employers should test employees by "using personal sampling" that is completed "frequently enough to characterize employee exposures." Employers should use their knowledge and research of the hazards, common sense, and the help of OSHA (if necessary) to determine how often to test high-risk employees.

If any high-risk employee tests above the permissible or published exposure levels, then monitoring should be performed again to determine other high-risk employees who are also above those limits.

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