Air Quality – Industrial-Type Environments

Purpose

The City of Toronto is committed to achieving and maintaining acceptable air quality in all workplaces that are occupied by City employees, in accordance with legislative requirements and generally-accepted industry standards. From the perspective of exposure to chemical and biological substances, the City is committed to ensuring that employees are not exposed to these substances at concentrations that may cause adverse health effects.

Application

This policy applies at all work locations in which City employees engage in industrial-type work. All City divisions and staff will implement the provisions of this policy, as appropriate to the work operations performed and chemical and biological substances used or generated.

This policy does not apply to work locations or those areas of work locations that are addressed by the Indoor Air Quality Policy.

Definitions

Industrial-type work

Work in which chemical or biological substances are used or generated as a result of work operations. This includes work performed within shops (e.g. wood-working shops, welding shops, vehicle maintenance shops, laboratories, plants, garages), underground or outdoors, if the nature of work performed may result in employee exposure to substances regulated under the Regulation respecting Control of Exposure to Biological or Chemical Agents or Designated Substances Regulation, made under the Occupational Health and Safety Act.

Qualified person

A person who is qualified, by training and experience, to perform the work.

OEL

Occupational exposure limits (including TWAs, STELs and Cs)

TWA

The time-weighted average limit (TWA) is the average of the airborne concentrations of a biological or chemical agent determined from air samples of the airborne concentrations to which a worker is exposed in a work day or a work week. If the Regulation respecting Control of Exposure to Biological or Chemical Agents or Designated Substance Regulation sets out a time-weighted average limit (TWA) for the agent, exposure shall not exceed that value.

STEL

The short-term exposure limit (STEL) is the maximum airborne concentration of a biological or chemical agent to which a worker is exposed in any fifteen-minute period determined from a single sample or a time-weighted average of sequential samples taken during such period

CEV

The ceiling limit (C) is the maximum airborne concentration of a biological or chemical agent to which a worker is exposed at any time.

Preventive measure/control

Engineering controls (e.g. local ventilation), work practice controls, administrative controls, hygiene facilities and personal protective equipment (where appropriate)

Guiding Principles

This policy supplements the City’s Workplace Hazardous Materials Information System policy.

Chemical and biological hazards are assessed to determine whether employees, under routine, non-routine or emergency conditions, may be exposed to concentrations of chemical or biological substances that approach or exceed occupational exposure limits (OELs) and consequently may result in short- or long-term adverse health effects. Occupational health and safety staff, as needed, as well as joint health and safety committees or health and safety representatives will be consulted when assessing hazards.

Occupational hygiene assessments, where appropriate or needed, will be conducted to evaluate whether employee exposures to chemical or biological substance(s) may place their health at risk.

Occupational hygiene assessments are needed if:

an understanding of baseline exposure is needed
chemical or biological hazard assessments indicate there is potential for employee overexposure
employees express concerns regarding exposure
they are recommended by joint health and safety committees or health and safety representatives,
illnesses/diseases attributed to exposure are reported
The effectiveness of controls require verification
Verification of legislative compliance is needed

When concentrations of chemical or biological substances in City work locations are determined, through occupational hygiene monitoring, to exceed 50% of the appropriate OEL (TWA, STEL or C), recommendations to lower employee exposure will be made and implemented, wherever practicable.

Preventive measures/controls to ensure that employee exposure to chemical and biological substances is below established OELs will be introduced.

If introduction of a control requires completion of a pre-start health and safety review (see Appendix A), the review will be conducted and documented in accordance with legislated requirements.

Engineering controls (e.g. local exhaust system or general ventilation system) will be maintained according to manufacturer’s instructions or accepted industry standards [e.g. Canadian Standards Association (CSA), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), American National Standards Institute (ANSI)]. Regular inspections of these controls will be conducted by qualified persons. Questions with respect to these controls (e.g. Are the controls working? Are they being maintained?) should be included in the workplace inspection checklist of the joint health and safety committee or health and safety representative representing workers who are impacted by these controls.

When selecting controls, engineering and administrative controls will be given priority over the provision and use of personal protective equipment. Personal protective equipment may be provided and used when engineering or other controls:

are not in existence or are not obtainable;
are not reasonable or not practical to adopt, install or provide because of the duration or frequency of the exposures or because of the nature of the process, operation or work;
are rendered ineffective because of a temporary breakdown of such controls; or
are ineffective to prevent, control or limit exposure because of an emergency.

If personal protective equipment is required or requested by an employee to minimize employee exposure to chemical or biological substances, employees will be trained in its use, storage, maintenance, fit and limitations. Fit testing is required whenever the employer provides a respirator to an employee, to be used on either a mandatory or voluntary basis.

When renovations or changes in work operations may result in change of facility usage (in whole or in part) from non-industrial to industrial-type usage, the Division whose work requires the use of chemical or biological substances or results in the generation of a chemical or biological substance(s) will ensure that the space is properly equipped to prevent overexposure of those employees within and adjacent to the space.

When work operations are changed such that increased amounts of chemical or biological substances are used or generated, hazards are re-assessed and preventive measures/controls are amended, as needed.

When work operations require the use of chemical substances, efforts will be made to purchase and use the least hazardous substance operationally feasible. Prior to use of any new chemical, a hazard assessment will be undertaken.

When equipment is being purchased or replaced, efforts will be made to ensure that such equipment minimizes the potential for employee exposure to chemical or biological agents.

Where continuous monitoring devices are installed to protect employees from overexposure to chemical substances, these devices should be appropriate to the chemical substance(s) of concern and any alarm set points for these devices should be set at concentrations that will prevent employees from being overexposed. Auditory and/or visual alarms, as appropriate to work operations, should be used. Calibration should be conducted at the frequency recommended by the manufacturer or accepted industry standards.

Changes to OELs will be monitored on an ongoing basis and communicated to City representatives (management, joint health and safety committees or health and safety representatives, Occupational Health and Safety Co-ordinating Committee).

Responsibilities

The City’s senior management team will ensure that:

Responsibility for air quality management in City facilities is clearly defined.
Employees are not overexposed to chemical or biological agents in buildings or outdoor work locations occupied by City staff.

Senior management of divisions will:

ensure that chemical and biological hazards within their area of responsibility are being assessed to prevent employees from being overexposed,
establish the expectation that when chemical substances are being purchased, the least hazardous chemical substance that is operationally feasibly will be selected,
budget for and implement appropriate controls/preventive measures to ensure that employees are not exposed to chemical and biological substances at concentrations exceeding OELs,
provide the necessary resources to maintain these controls/preventive measures,
ensure that pre-start health and safety reviews are conducted, if new control measures to be introduced require their completion,
wherever practicable, implement recommendations to reduce employee exposure to chemical and biological substances when measured exposures exceed 50% of OELs,
when space usage is being changed from non-industrial to industrial-type, ensure space is appropriate to the type of work to be performed, to the agents to be used or generated, and is properly equipped to prevent employees inside and adjacent to the space from being overexposed to chemical and biological substances, and
ensure that staff within the division are aware of this policy’s content and expectations regarding its implementation.

Supervisory staff will:

assess chemical and biological hazards to determine if there is potential for employee overexposure to chemical or biological substances, consulting with joint health and safety committees or health and safety representatives and health and safety staff,
request occupational hygiene assessments if there is potential for employees to be overexposed to chemical or biological substances (see Appendix B),
address health and safety concerns regarding chemical or biological substances that are raised by their employees,
communicate status of actions taken to address employee concerns to employees and to the joint health and safety committee or health and safety representative representing employees, if actions to address the concerns will occur over an extended time period (i.e. if actions to address the concerns are not immediate and within the supervisor’s direct control),
when purchasing chemical substances, seek the least hazardous substances that are operationally feasible,
when ordering new equipment or replacing existing equipment, ensure that such equipment minimizes the potential for employee exposure to chemical or biological agents,
when there are changes in work operations or patterns of chemical usage that may potentially increase employee exposure to chemical or biological substances, re-assess the hazard to determine whether any additional preventive measures/controls are needed,
implement those recommended preventive measures/controls to reduce employee exposure that are within the supervisor’s control,
seek implementation of recommended preventive measures/controls by other levels of management, if the scope of work or cost requires the support or approval of those levels of management,
ensure that engineering controls installed to minimize employee exposure to chemical and biological substances are maintained according to manufacturer’s instructions and/or accepted industry standards, and
if personal protective equipment is required to minimize employee exposure to chemical or biological substances, ensure that employees are trained in its use, storage, maintenance, fit and limitations and, if a respirator is to be used, receive fit testing as per the City’s Respiratory Protection Policy.

Occupational Health, Safety and Workers’ Compensation Unit’s occupational hygiene staff will:

monitor changes to occupational exposure limits and communicate those changes that may impact City employees and workplaces to appropriate City staff (divisional management, operational health and safety staff, Occupational Health and Safety Co-ordinating Committee members and bargaining unit health and safety representatives),
consult and provide advice regarding preventive measures/controls to reduce employee exposure to chemical or biological substances when new processes, equipment or work operations are being introduced,
upon request (see Appendix B), conduct occupational hygiene assessments to determine levels of employee exposure to chemical substances,
copy results of these assessments to supervisory staff, the appropriate joint health and safety committee or health and safety representative and operational health and safety staff,
make recommendations to reduce employee exposure, if exposures exceeding 50% of the appropriate OEL are measured, and
assist in the development of safe work procedures and training programs to facilitate compliance with this policy.

Occupational Health & Safety Consultants will:

when informed of changes to OELs, provide this information to joint health and safety committees and/or health and safety representatives,
provide consultation services and advice, as needed, to management, joint health and safety committees and occupational health and safety representatives to assist in hazard assessments and addressing employee concerns regarding exposure to chemical and biological substances,
consult and provide advice regarding preventive measures/controls to reduce employee exposure to chemical or biological substances when new processes, equipment or work operations are being introduced,
request occupational hygiene assessments, as needed, to evaluate employee exposure to chemical or biological substances, and
assist in the development of safe work procedures and training programs to facilitate compliance with this policy.

Joint Health and Safety Committees/ Health and Safety Representatives will:

assist supervisory staff in assessing chemical and biological hazards,
include the status of controls to minimize employee exposure to chemical substances in their workplace inspection checklists,
bring deficiencies, if any, to the attention of supervisors,
consider employee health concerns related to exposure to chemical and biological substances and make recommendations to address these concerns, as appropriate,
participate in occupational hygiene testing by being present at the initiation of testing, being copied on results and making any needed follow up recommendations, and
assist in the dissemination of information regarding chemical and biological hazards in the workplaces they represent.

Workers will:

advise their supervisors of any occupational health concerns arising from the use or generation of chemical and biological substances,
advise their supervisors of any defects in preventive measures/controls that have been implemented to minimize employee exposure to chemical and biological substances,
follow safe work procedures identified as necessary to minimize exposure to chemical and biological substances,
use/wear personal protective equipment identified as needed to minimize their exposure to chemical and biological substances, and
not take any actions that adversely impact control measures to minimize employee exposure.

The Occupational Health and Safety Co-ordinating Committee will:

monitor the implementation and effectiveness of this policy,
review and recommend amendments to the policy, as necessary.

Authority

The Occupational Health and Safety Act (R.S.O. 1990)

Designated Substances Regulation (O.Reg 490/09)

Regulations for Industrial Establishments (O.Reg 851), Sections 7 and 8, Pre-start Health and Safety Reviews

Regulation Respecting Control of Exposure to Biological and Chemical Agents (O.Reg. 833)

Workplace Hazardous Materials Information System (WHMIS) Regulation (Regulation 860)

Corporate Occupational Health and Safety Policy

Pre-Start Health and Safety Reviews

Their role in ensuring acceptable air quality in industrial-type settings

In the context of a City occupational health and safety policy regarding air quality in industrial type settings, a pre-start health and safety review may be required under the Regulations for Industrial Establishments in determining the adequacy of ventilation systems. Such a review may also be beneficial for work operations that are addressed by other sector regulations. A review will be necessary if a new apparatus, structure or protective element is to be constructed, added or installed or an existing apparatus, structure or protective element is to be modified in a process that uses or produces a substance that may result in the exposure of a worker in excess of occupational exposure limits. These limits are set out in the Designated Substances Regulation and the Regulation respecting Control of Exposure to Biological or Chemical Agents.

The Regulations for Industrial Establishments (Section 7) requires that “knowledgeable” persons conduct pre-start health and safety reviews. The Ministry of Labour has identified that pre-start health and safety reviews to confirm the adequacy of ventilation systems, so as to ensure the atmosphere will not endanger the health and safety of workers, should be conducted by persons who, in the opinion of the employer or owner, possesses special expert or professional knowledge or qualifications appropriate to assess the potential or actual hazard. The Ministry of Labour will recognize professional engineers and/or persons with credentials such as Certified Industrial Hygienist (CIH) or Registered Occupational Hygienist (ROH) as knowledgeable persons for the purpose of this type of pre-start health and safety review.

Reports of pre-start health and safety reviews must be signed by the reviewer(s) and dated. The reports of pre-start health and safety reviews must be provided to joint health and safety committees or health and safety representatives before the new or newly-modified apparatus, structure or protective element is operated or the process is used. These reports must also be kept readily accessible in the workplace together with any supporting documentation.

Appendix B

Occupational Hygiene Testing Request form

Endorsed by

Occupational Health & Safety Co-ordinating Committee (OHSCC), September 19, 2006

Reviewed and Revised by OHSCC

February 28, 2012

April 26, 2016

February 8, 2017

Approved by

City Manager, January 24, 2007

Date Approved

January 24, 2007

Reviewed by OHSCC