| A.
Management Program and Responsibilities |
|
Section Score
|
Comment
|
|
|
|
|
| |
Type |
|
Corrective Action or
Comment |
|
1.
Is shop management providing commitment,
leadership, and involvement for the shop's overall
metal
removal fluid (MRF) management program?
|
C |
Y N
|
|
2.
Has
overall responsibility for MRF management been
assigned to an individual? |
C |
Y N
|
Responsible Person:
|
3.
Is
there a written program specifying procedures for
MRF use and management
that includes the elements
of fluid selection, fluid testing, material
management,
training, record keeping, delivery system management,
and ventilation system management? (There is a
one-year grace period from
the first assessment.) |
C |
Y
N |
|
4.
Does
the written program include goals for the
successful management of metal
removal fluids? |
C |
Y
N |
|
5.
Does
the written program specify responsibilities for
the employer, the fluid
manager, the maintenance or
facilities manager, and the employees?
(There may be a
grace period; see #3 above.) |
C |
Y N |
|
6.
Is
the MRF management program evaluated
periodically as part of a continuous
improvement or
quality program? |
C |
Y
N |
**
|
| |
B.
Employee Participation |
** |
Section Score
|
**Comment |
| |
|
|
|
| |
Type |
|
Corrective Action or
Comment
|
1.
Have
employees participated in the design and
implementation of the fluid
management program?
(Skip this question of the program is just being
started.) |
C |
Y
N |
|
2.
Do
employees participate in the investigation of
hazards or complaints? |
C |
Y
N |
|
3.
Are
employees required to wear appropriate eye
protection for their job
functions (e.g., safety glasses,
goggles, face shield)? |
C |
Y
N |
|
4.
Is
other personal protective equipment specified as
appropriate to specific
job functions (e.g., gloves,
safety shoes, protective clothing,
respirators)? |
I |
Y
N NA |
|
| |
| C.
Fluid Selection, Testing, and Management |
|
Section
Score |
Comment |
For the "I" (important) questions
in this section only:
Yes:____ No: ____ NA: ____
% = Yes/(14-NA)*100 ____
|
|
|
|
| |
Type |
|
Corrective Action or
Comment |
1.
Does
the written metal removal fluid management
program include procedures for
selecting, sampling,
testing, and evaluating the fluids? |
C |
Y
N |
|
2.
Does
the written program include guidelines for use
and safe handling
instructions for anti-microbial
(biocide) additives for water-miscible MRFs? |
C |
Y
N NA |
|
3.
Are
water-miscible MRF systems routinely monitored
for MRF concentration,
pH,
microbial levels, tramp oil,
and suspended particulate matter as
appropriate? |
C |
Y
N NA |
|
4.
Are
the collected data on fluid condition reviewed on a
regular basis? |
C |
Y
N |
|
5.
When
indicated by the collected data, are corrective
actions taken in a timely
manner? |
C |
Y
N |
|
6.
Has
a metal removal fluid supplier been selected that
can provide the products
and support needed for a
cost-effective and responsible MRF management
program? |
I |
Y
N |
|
7.
Are
MSDSs reviewed to understand the acute and
chronic toxicity potential of MRFs? |
I |
Y
N |
|
8.
Are
MRFs selected to minimize components that may
be irritating or
objectionable (such as some
alkanolamines, some short-chain fatty acids,
or volatile
petroleum products)? |
I |
Y
N |
|
9.
Has
the compatibility of the MRFs with machine
lubricants, seals, metals, and
process cleaners been
included in the selection process? |
I |
Y
N |
|
10.
Are
fluid system additions controlled by the MRF
Coordinator/Manager, recorded
on a log sheet, and
performed "off-shift," when the plant
population is
reduced? |
I |
Y
N NA |
|
11.
Are
mechanisms in place to minimize tramp oil
contamination of the MRF, i.e.,
record keeping,
maintenance systems? |
I |
Y
N NA |
|
| 12.
Are
MRF fluid system cleanouts routinely scheduled? |
I |
Y
N NA |
|
13.
Do
system clean-outs follow a standard operating
procedure for draining,
cleaning, and recharging
(DCR) that is contained in the written management
program? |
I |
Y
N NA |
|
14.
Are
systems thoroughly cleaned (e.g., power washing
and rinsing) before being
recharged with fresh fluid? |
I |
Y
N NA |
|
15.
Has
the effect of the MRFs on the waste treatment
system been evaluated? |
I |
Y
N NA |
|
16.
Are
all wastes generated by the use of the MRFs
disposed of in a proper
manner? |
I |
Y
N NA |
|
| |
| D.
Information and Training |
** |
Section Score |
Comment
|
For
the "I" (important) questions in this section only:
Yes: _____ No:
_____ NA: _____
% = Yes/(6 - NA)*100
______ |
|
|
|
| |
Type |
|
Corrective
Action or Comment |
1.
Does
the shop have a hazard communication program
to educate workers about
hazards in their workplace? |
C |
Y
N |
|
2.
Are
employees provided with information that allows
them to recognize and
understand the potential
hazards of MRFs and associated chemicals? |
C |
Y
N |
|
3.
Are
employees trained on procedures for the safe use
of MRFs and applicable
additives used on their job? |
C |
Y
N |
|
4.
Does
the written metal removal fluid management
program specify the training
needs of workers in this
environment? |
I |
Y
N |
|
5.
Does
the training section of the metal removal fluid
management program include
procedures to evaluate the
effectiveness of the training? |
I |
Y
N |
|
6.
Does
the training section of the metal removal fluid
management program include
provisions for refresher
training as appropriate? |
G |
Y
N |
|
7.
Have
employees been instructed on how to obtain the
MSDSs for the materials
they work with? |
I |
Y
N |
|
8.
Are
employees trained on physical safety concerns of
working in metal removal
operations? |
I |
Y
N |
|
9.
Are
employees instructed on how to use the metal
removal fluids according to
the MSDS and other
company-specific instructions? |
I |
Y
N |
|
10.
Is
there a process to ensure that metal removal fluid
containers, including
transfer containers, are labeled
properly? |
I |
Y
N NA |
|
| |
| E.
Investigation of Hazards and Complaints |
|
Section Score |
Comment |
For
the "I" (important) questions in this section only:
Yes: _____ No:
_____ NA: _____
% = Yes/(7 - NA)*100
______ |
|
|
|
| |
Type |
|
Corrective Action or
Comment |
1.
Does
the shop have a program for investigation of
hazards related to MRFs? |
C |
Y
N |
|
2.
Does
the shop have a program to implement and
monitor corrective actions when
needed? |
C |
Y
N |
|
3.
Does
the shop have a written program for investigation
and review of health and
safety complaints? |
C |
Y
N |
|
4.
Does
the shop have a program for preventative,
scheduled, or progressive
maintenance of machines,
MRF filtration systems, ventilation systems,
other support
facilities? |
C |
Y
N |
|
5.
Is
exposure assessment conducted on a periodic basis to
identify workers or
work areas with potentially high
aerosol exposures? |
I |
Y
N |
|
6.
Where
indicated, are quantitative measurements made
of the worker exposures to
ensure employee exposures
to ambient MRF aerosol do not exceed 1.0 mg/m3? |
I |
Y
N NA |
|
7.
Is
exposure assessment used to aid in the investigation
of worker respiratory
complaints? |
I |
Y
N NA |
|
8.
Where
employee exposures exceed 1.0 mg/m3, are
equipment repairs or
other corrective actions initiated to
reduce exposures? |
I |
Y
N NA |
|
9.
Is
new machinery specified and tested to ensure MRF
aerosol emissions are as
low as practicable in order to
further reduce workplace MRF aerosol
concentrations? |
I |
Y
N NA |
|
10.
Are
employees discouraged from smoking and eating
in the workplace? |
G |
Y
N NA |
|
11.
Are
metal removal fluids and additives for tank-side
additions stored
according to specifications? |
I |
Y
N NA |
|
| |
F. Medical
Monitoring, Management, and
Surveillance |
|
Section
Score |
Comment |
For
the "I" (important) questions in this section only:
Yes: _____ No:
_____ NA: _____
% = Yes/(3 - NA)*100
______ |
|
|
|
| |
Type |
|
Corrective Action or
Comment |
1.
Does
the shop have a medical program or set of
procedures to address health
concerns in the
workplace? |
C |
Y
N |
|
2.
Do
employees have an effective way to report health
complaints, such as
respiratory irritation or dermatitis
that my be occupational in origin? |
C |
Y
N |
|
3.
Do
employees utilize the shop medical program when
appropriate? |
I |
Y
N NA |
|
4.
Does
the shop medical program include preassignment
evaluation by a licensed
health care provider? |
I |
Y
N NA |
|
5.
Does
the shop provide for referral to a specialist for
necessary follow-up care
or a second opinion when
appropriate? |
I |
Y
N NA |
|
6.
Does
the shop medical program include periodic
medical examinations to support
occupational health
goals? |
G |
Y
N NA |
|
Contact Chris Roman, 