By Liz Cox, MS, CSP, Sr. Supervisor –Environmental, Health & Safety, U.S. Compliance
Maintaining a safe and healthy work environment is critical in any industry, particularly in manufacturing and other industrial sectors where employees may be exposed to a variety of health hazards. Industrial hygiene plays a crucial role in identifying, evaluating, and controlling these hazards to ensure worker safety and regulatory compliance. As organizations strive to create healthier workplaces and reduce occupational illnesses, understanding the principles of industrial hygiene and its regulatory implications becomes essential.
This article will explore the fundamentals of industrial hygiene, whether industrial hygiene testing is required by the Occupational Safety and Health Administration (OSHA), the general requirements employers must follow, what is commonly tested in workplace settings, and the U.S. Compliance testing process.
What is Industrial Hygiene?
Industrial hygiene is a key component of workplace health and safety programs. It focuses on identifying and controlling environmental factors that may adversely affect the health and well-being of workers.
According to the American Industrial Hygiene Association (AIHA), industrial hygiene is:
“The science and art devoted to the anticipation, recognition, evaluation, prevention, and control of those environmental factors or stresses arising in or from the workplace that may cause sickness, impaired health and well-being, or significant discomfort among workers or among citizens of the community.”
In simpler terms, industrial hygiene boils down to identifying and managing employee exposure in the workplace.
A foundational concept in industrial hygiene is understanding how exposure occurs, and this often falls into two categories: direct exposure and process-generated exposure.
● Direct exposure occurs when an employee routinely or intentionally comes into contact with a hazardous substance as part of their job duties. Examples include a painter applying solvents or a lab technician working with reagents. In these scenarios, the worker is actively using or handling the hazardous material, and the exposure is inherent to the task.
● Process-generated exposure happens when harmful agents are released as byproducts of workplace activities, even if the worker is not directly interacting with the source. For instance, silica dust generated during concrete cutting, fumes released from welding in a nearby area, or dust produced during grinding operations may lead to unintended exposure for workers in the vicinity.
Understanding the distinction between direct and process-generated exposure is essential for accurately assessing workplace health risks and implementing targeted controls. Whether exposures are intentional or incidental, industrial hygiene principles guide employers in evaluating the risks and applying appropriate protective measures, such as ventilation systems, process changes, or personal protective equipment, to reduce or eliminate them.
Ultimately, an effective industrial hygiene program fosters safer work environments, ensures regulatory compliance, and supports the long-term health and productivity of the workforce.
Is Industrial Hygiene Testing Required by OSHA?
While OSHA does not universally require industrial hygiene testing for all workplaces, employers are legally obligated to assess and manage workplace hazards that could affect employee health. This responsibility is rooted in both the General Duty Clause and several specific OSHA standards that make exposure assessments a critical component of compliance.
OSHA’s General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act, requires employers to provide a workplace free from recognized hazards that are likely to cause death or serious physical harm. This broad requirement establishes the foundation for identifying and mitigating health risks, including those that may not be addressed by specific OSHA standards. If a workplace hazard is known, such as exposure to airborne chemicals, excessive noise, or respiratory risks, employers are expected to evaluate the risk, often through industrial hygiene testing.
Several OSHA standards go further by outlining specific circumstances when testing or exposure monitoring must occur:
● 29 CFR 1910.134(d)(1)(iii) under the Respiratory Protection Standard requires employers to “identify and evaluate the respiratory hazard(s) in the workplace,” including a reasonable estimate of employee exposure. This regulation implies that air monitoring or industrial hygiene testing is necessary to determine the type and extent of the hazard and to select appropriate respiratory protection.
● 29 CFR 1910.132(d)(1) under the Personal Protective Equipment (PPE) Standard states that “the employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment.” This assessment may involve exposure monitoring or industrial hygiene testing to accurately identify risks that require controls, such as gloves, eye protection, or protective clothing.
In addition to these standards, OSHA has set Permissible Exposure Limits (PELs) for a range of chemical substances. If there is a possibility that employee exposure may exceed a PEL, employers must evaluate those exposures. For instance, if employees are working around substances such as lead, asbestos, formaldehyde, or silica, the corresponding OSHA standards require initial and, in some cases, ongoing exposure assessments.
In summary, while not every workplace is automatically required to conduct industrial hygiene testing, employers must perform hazard assessments and exposure evaluations when there is a potential for harmful exposure. Failure to do so may result in noncompliance with OSHA’s General Duty Clause and other specific standards, leading to citations or increased liability.
What Are the General Requirements?
Industrial hygiene programs must be proactive, ongoing, and adaptable to workplace conditions. OSHA’s standards and best practices provide a structured framework for evaluating and controlling employee exposure to hazardous agents. While specific requirements may vary depending on the hazard, there are several core elements employers should consider when establishing or maintaining an industrial hygiene program.
Hazard Assessment
Under 29 CFR 1910.132(d)(1), employers must assess the workplace for potential hazards that may require the use of personal protective equipment (PPE). This hazard assessment serves as a foundation for determining the need for industrial hygiene testing and informs decisions about control measures. The assessment should include a review of all processes, materials, and tasks that could present chemical, physical, or biological hazards.
Baseline Testing
Baseline exposure testing is recommended when a facility is first evaluating potential hazards or introducing new processes or materials. It provides an initial data set that helps determine whether employees are exposed to hazardous substances at or above OSHA’s Permissible Exposure Limits (PELs). This information supports the proper selection of engineering controls, PPE, and monitoring strategies. Without baseline data, it is challenging to assess the effectiveness of future corrective actions.
Periodic Testing
If initial or baseline testing identifies exposures near or above regulated limits, periodic or routine monitoring may be required. The frequency of this testing depends on the substance involved, the level of exposure, and applicable OSHA standards. For example, OSHA’s lead standard requires monitoring every six months if exposures exceed the action level. Even when exposures are below the PEL, periodic re-evaluation is a best practice to ensure conditions have not changed and to verify continued compliance.
Facility or Process Changes
Industrial hygiene testing must be re-evaluated anytime there is a modification in facility layout, ventilation systems, equipment, raw materials, or production processes. These changes can introduce new hazards or increase the potential for employee exposure. For instance, increasing the speed of a production line, switching to a different solvent, or moving operations closer to other departments may all warrant new exposure monitoring.
Contaminant-Specific Testing
Certain OSHA standards require targeted testing for specific substances, such as respirable crystalline silica, formaldehyde, hexavalent chromium, and benzene. These standards define when and how testing should be performed, often including thresholds for initial testing, periodic monitoring, and actions triggered by results. Employers are responsible for identifying which substances are present in their workplace and ensuring compliance with substance-specific regulations.
Control Measures
When exposure levels exceed or approach permissible limits, employers must implement appropriate control strategies. These may include engineering controls (such as local exhaust ventilation), administrative controls (such as rotating workers), or PPE (such as respirators or gloves). The hierarchy of controls prioritizes eliminating or substituting the hazard before relying on PPE. When PPE is necessary, here’s how to select the appropriate respiratory protection for your facility.
Recordkeeping
Employers must maintain documentation of exposure assessments, testing results, control measures, and employee training. These records may be required for OSHA inspections and serve as critical evidence in case of future health claims or enforcement actions.
Medical Surveillance
For certain hazardous substances like lead and noise, OSHA standards mandate that employers offer medical surveillance programs when exposure levels meet specific criteria. These programs help detect early signs of occupational illnesses and ensure that employees are physically able to perform their jobs safely.
What is Commonly Tested in Industrial Hygiene?
Industrial hygiene testing focuses on identifying and measuring workplace exposures to a variety of chemical, physical, and biological agents. The goal is to determine whether these exposures exceed regulatory limits or internal safety thresholds, and to evaluate the effectiveness of control measures.
While the specific substances tested will vary depending on the nature of the work and materials used, there are several common agents and stressors frequently monitored in industrial settings:
Total Particulate
Dust from cutting, grinding, sanding, or handling dry materials can contribute to poor air quality and respiratory irritation. Total particulate testing measures the overall concentration of airborne dust in the breathing zone, helping determine whether ventilation or housekeeping practices are adequate. This is often a starting point in evaluating general air quality.
Respirable Crystalline Silica
Silica dust is generated during operations such as cutting, grinding, or drilling materials like concrete, brick, or stone. Respirable crystalline silica particles are small enough to reach deep into the lungs, posing serious health risks, including silicosis and lung cancer. OSHA’s standard for silica requires exposure assessment when such activities are conducted.
Total Welding Fume
Welding processes produce fumes composed of a mixture of metal oxides and other potential constituents. Testing for total welding fume helps determine the concentration of these airborne contaminants, especially in poorly ventilated areas. The results can guide decisions around local exhaust ventilation and respiratory protection. For industries like metal fabrication, where exposure to welding fumes and metal dust is frequent, tailored testing strategies are essential. Learn more about common industrial hygiene testing needs specific to metal fabrication.
Hexavalent Chromium
Hexavalent chromium is a known carcinogen found in stainless steel welding fumes, anti-corrosion coatings, and certain pigments. When stainless steel is welded or ground, hexavalent chromium may be released into the air. OSHA has specific standards for hexavalent chromium, requiring monitoring when there is potential for exposure.
Carbon Monoxide (CO)
Carbon monoxide is a colorless, odorless gas that can be produced by propane-powered forklifts and other combustion equipment used indoors. Elevated CO levels can cause headaches, dizziness, or even fatal poisoning. Monitoring CO concentrations is essential in enclosed or poorly ventilated areas where propane-powered equipment is in use. Here’s what you need to know about hidden CO exposures.
Volatile Organic Compounds (VOCs)
VOCs are a broad class of chemicals found in solvents, paints, adhesives, and degreasers. Common VOCs include toluene, xylene, and acetone. Exposure to VOCs can cause respiratory irritation, neurological effects, and long-term organ damage. Air sampling helps determine whether concentrations exceed occupational exposure limits.
Noise
Occupational noise exposure is a leading cause of hearing loss in the workplace. Noise levels are measured using sound level meters or dosimeters to assess employee exposure across a work shift. Explore practical strategies for noise reduction in manufacturing settings. OSHA requires a hearing conservation program when noise exposures exceed an 8-hour time-weighted average of 85 decibels. Learn how to implement an effective hearing conservation strategy.
Formaldehyde
Formaldehyde is used in manufacturing resins, textiles, and other industrial applications. It can be released as a vapor during processing or from treated materials. Formaldehyde is a known irritant and potential carcinogen. OSHA mandates air monitoring when formaldehyde is used in quantities that may result in exposure above the action level.
These are just a few of the most commonly monitored hazards in industrial hygiene programs. Each facility should evaluate its specific operations, materials, and employee tasks to determine what testing is necessary.
U.S. Compliance Testing Process
At U.S. Compliance, our industrial hygiene testing services are designed to help facilities safeguard employee health and proactively manage potential workplace hazards. Our process is structured, efficient, and tailored to each client’s unique operations. Here is an overview of what you can expect when partnering with us for industrial hygiene testing:
- Consultation Call
We begin with a discovery call to understand your facility’s tasks, processes, potential exposure concerns, and any recent changes that may have introduced new hazards. - Safety Data Sheet (SDS) Review
Our team requests and reviews your Safety Data Sheets (SDSs) for chemicals and materials related to your concerns. This helps us select the appropriate sampling methods and equipment. - Schedule Testing
We will send our testing recommendations and coordinate with your team to schedule the test at a time that minimizes disruption to operations. We consider shift schedules, production cycles, and task-specific activities to ensure accurate sampling during representative work conditions. - Complete Testing
The equipment is shipped to your facility and either coordinated with our Compliance as a Service (CaaS) site visit or accompanied by a scheduled video call with our team to review the equipment, setup, and process. Once the testing is complete, the equipment is returned to the lab for third-party analysis. - Provide Results and Recommendations
Following testing, we interpret the lab’s results into a report letter. The report presents information in a clear and easily digestible format.
Throughout the entire process, U.S. Compliance provides expert guidance and clear communication to help your facility improve workplace safety and protect your workforce.
Conclusion
Industrial hygiene is a vital part of protecting worker health and maintaining regulatory compliance. Although OSHA may not require routine testing for every facility, the presence of hazardous materials or physical agents often necessitates industrial hygiene assessments. By identifying and controlling exposures to hazards, employers not only meet regulatory requirements but also foster a safer, more productive workplace.
Reach out to your U.S. Compliance Representative for industrial hygiene consultation, testing, and evaluation services.
