DIVISION OF OCCUPATIONAL SAFETY AND HEALTH
POLICY AND PROCEDURES MANUAL
DIRECT READING REPORT
Issue Date: 6/30/94
Revised: 8/1/94, 7/1/95
AUTHORITY: Not applicable.
POLICY: It is the policy of the Division of Occupational Safety and Health to record data required to support a health violation document direct reading sampling performed by compliance personnel on the OSHA Form 93.
B. SPECIAL ISSUES
Compliance personnel shall use the OSHA Form 93 to document exposures measured by passive sampling devices which can be read directly. Use the Air Sampling Report, OSHA Form 91, to document samples which require lab analysis.
Since more than one direct reading instrument often will be used to document an exposure, space has been allotted for the calibration of up to three instruments. Care must be taken, however, to ensure that the pre- and post-sampling calibration data for a given instrument are all in the same block on the form.
If using media that is sensitive to more than one agent, but only one agent is determined to be present, report the exposure against that specific substance code. If several agents are present, report the exposure against a substance code for the general category of substances, for instance, general aldehydes.
When documenting leakage tests, only Items 33, 34 and 36-38 need to be completed within the pre- and post-sampling calibration data on the reverse side of the form.
Date stamps may be used for all the date entries on this form.
C. OFFICE PROCEDURES
NOTE: If more space is required, compliance personnel shall use additional OSHA Form 93s. On each additional OSHA Form 93, mark through the pre- printed Sampling Number and enter the Sampling Number from the first form used. Then complete Items 22-31, as necessary, renumbering the line numbers in Item 21. Complete Item 32 on the first form and leave this item blank on the additional forms. Use as many OSHA Form 93s as are necessary and staple the forms together before submitting them to OMDS.
D. FORM DISTRIBUTION
E. FORM COMPLETION
Complete this item only when it is necessary to change an OSHA Form 93 previously submitted to OMDS. If modifications to the Form 93 are made, compliance personnel shall mark the modifications in red ink on the Form 93, enter "M" in the MOD box, enter the date of the modification in the "DATE" box and give the modified Form to Office Support Staff for submission to OMDS.
The Reporting ID of the submitting office.
Enter the Inspection Number from the related Cal/OSHA Form 1.
A preprinted number unique to each OSHA-93. It identifies each sampling experience. This number must always be used when modifying the information on a sampling form.
Enter the name of the establishment as it appears on the Cal/OSHA Form 1.
The safety engineer or industrial hygienist who is performing the sampling must sign or initial the sampling form to verify that the method(s) prescribed by the Cal/OSHA IH Tech Manual have been followed.
Enter the SE/IH ID of the person actually performing the sampling.
Enter the month, day and year the sample(s) were collected.
Enter the name, address (including ZIP Code) and telephone number of the employee being sampled.
Enter the job title of the employee being sampled. The job title must be descriptive, concise (no more than 20 characters) and legible. If this is an area sample, enter the job title of the employee(s) who are most at risk from exposure. If one cannot be determined, enter the area of the worksite sampled.
If known, enter an appropriate occupational code that corresponds to the job title in Item 10.
Enter the type(s) and the effectiveness of any personal protective equipment (PPE) the sampled employee is using, including the manufacturer's name and model number, the approval number, if available, and the type and concentration of the contaminant against which it protects. If no PPE is in use, enter "None."
Enter an estimation of the number of employees who are suspected to be over exposed to the hazard. Include the sampled employee as well as employees potentially over-exposed on all shifts. This number represents a subjective assessment of the scope of the exposure problem at the time the samples were taken.
Enter this number only once for each hazard area by entering the appropriate number on the first OSHA Form 93 for a particular hazard area and leaving this item blank on all subsequent OSHA Form 93s for the same area.
It is essential that this number not be repeated on sample forms relating to the same hazard area. Repeated entries will result in multiple counting and will invalidate the IMIS data.
Enter the length of time that the alleged violation has existed. This number indicates how long the hazard(s) has existed, not how long the sampled employee has been exposed to the hazard. It is not necessary to enter the duration on all OSHA Form 93s for an area unless the information is different.
Describe, as concisely as possible, the general frequency of exposure in the sampling area. Convey the complete picture for all over exposed employees, not just that of the sampled employee. This may require several frequency descriptions and the number exposed at each frequency.
EXAMPLE: 2 for 8 hrs/day, 8 for 3 hrs/week or 3 for 10 hrs/week.
Enter, when necessary, the temperature, altitude and other weather conditions existing during the sampling period which may affect the sample data.
If a photo(s) was taken, circle "Y."
Identify any known or suspected substances or conditions (for example, magnetic fields) present during sampling which might affect the sampling results. If no interferences are present, draw a slash through this item.
Enter a detailed description of the work environment of the sampled employee including all pertinent information about the work being performed, such as the operation, the equipment associated with the hazard (including identifying numbers), and the work location(s). Include information such as the employee's activities during non sampling periods when it might affect the exposure, general observations of work practices and environment, unusual events which compliance personnel observe. Be sure to include observations on the following when they affect exposure or the issuance of a citation:
Begin your description here and continue on the back or on additional pages, such as the OSHA Form 94. Always precede the continuation with the appropriate item number and indicate to which sampling form it relates, e.g.,
"Jones-item 16" for the job description of employee Jones who is the subject of the test, or
"p. 4-16" for Item 16 on field page number 4, or
"26120-16" for the continuation of Sampling Number 26120).
Cont'd. When the case file has been organized and the pages numbered, enter the case file page number(s) in the "Cont'd" box to indicate where any continuation page for this job description can be found. This is not necessary if the continuation page directly follows the sample form.
DIRECT READING DATA
Enter the substance for which the sample is being taken.
Enter the time(s) the instrument is turned on or turned off, or the time of each reading.
Enter the reading of the instrument or detector tube.
Enter the specific location at which each reading was taken. Note the employee's activity at that moment and any other observations, such as the employee's proximity to the hazard. Include here or on continuation pages, an explanation of your sampling strategy or the standard method used. In that explanation, be sure to reference the substance or agent to which the strategy or method relates.
If more than one instrument is used for the same substance, the instrument relating to each reading must be identified. Figure XXV-1 shows samples for carbon monoxide taken with both detector tubes and an ecolyzer.
After sampling has been conducted and analyzed, complete the Exposure Summary (Items 21-32) whether or not a citation will be issued. If the samples documented on an OSHA-93 do not meet the criteria for submission to OMDS (reference paragraph B of this chapter), write "VOID" or some other sign across the exposure summary box, signifying that these forms will not be sent to OMDS.
Enter a sequential number used to identify a particular exposure in the computer record. Each unique exposure must be assigned a line number and this number must be used in referring to individual records for modifications or retrieval.
Enter the appropriate hazardous substance code. See Attachment E, P&P C-170 & 170A.
Enter a code from among those listed below to indicate what kind of sample was taken.
Enter a code from the following list to indicate the kind of exposure being reported.
F=Not Detected (N/D) or Not Found (N/F)
L=Short Term Exposure Limit
T=Full Shift TWA
Not Detected or Not Valid. If none of the above codes apply because no substance could be detected, enter "F" in this item. If the sample was considered invalid for some reason, for instance, it was contaminated at the site, enter "V" in this item. If either "F" or "V" is entered in this item, leave Items 25 through 29 blank.
More than One Type of Exposure for the Same Substance. If a TWA, ceiling and/or peak are calculated for the same substance code, each value must be entered on a unique line.
More than One of the Same Exposure Type for the Same Substance. If more than one ceiling, peak or other exposure type is calculated for the same substance code, enter only the "highest" exposure for each type measured.
Enter the exposure determined by sampling. TWAs shall be based on the full shift and must be entered regardless of whether an overexposure exists.
Enter the appropriate code from the following list to indicate the unit of measure in which the exposure level and the PEL are expressed for the substance identified in Item 22.
P=Parts per million
M=Milligrams per cubic meter
U=Milliwatts per square centimeter
G=Million particles per cubic foot
C=Picocuries per liter (radon)
NOTE: If the Exposure Level or PEL is expressed in micrograms, it must be converted to milligrams before submittal to OMDS.
Enter the appropriate PEL or other standard against which the exposure is being evaluated. The PEL entered here must correspond to the type of exposure reported in Item 24. If the exposure is evaluated in relation to an Action Level, enter the Action Level here. (Be sure to use the appropriate substance code in Item 22.) If the PEL must be adjusted because of a novel work schedule or other unusual circumstance, enter the adjusted PEL. If there is no level against which to evaluate the exposure, enter zero (0) in "PEL" and leave "Severity" Item 29, blank.
Mark if the PEL was adjusted; if not, leave blank.
Enter the severity of exposure, for example, Full Shift TWA divided by PEL, calculated to two (2) significant figures. This value must be recorded even if it is less than 1.
Mark as many of the following box(es) as apply regarding citation issuance.
No Citation. No citation was issued as a result of this sample.
FTA (Failure to Abate). An additional penalty was assessed for the employer's failure to abate a previous violation.
Over Exposure. A citation was issued for over-exposure to the hazardous substance identified in Item 22.
Engineering. A citation was issued for lack of or faulty engineering and/or administrative controls.
PPE (Personal Protective Equipment). A citation was issued for lack of, or faulty, personal protective equipment.
Training. A citation was issued for lack of adequate training.
Medical. A citation was issued for lack of medical surveillance.
Other. A citation was issued for other reasons.
If substances, due to their similar physiological effects, are considered additive, and if a citation results from the additive effects, enter the line numbers from Item 21 (i.e., 1, 2, 3, etc.) of the substances identified in Item 22 that are additive.
On the same line, under "Severity" Item 29, enter the equivalent exposure for the mixture, as referenced in 29 CFR 1910.1000(d)(2)(i). This value is equivalent to the sum of the severity ratios for each substance contributing to the additive effect. Then mark an "X" in the appropriate box(es) under "Citation Information," Item 30.
Enter the total number of line entries made in the Exposure Summary section. This total includes both the total number of entries made in Item 22, and Item 31, if completed. If multiple pages are used, enter on the FIRST page the total number of lines entered on all related pages of the OSHA Form 93, then leave this item blank on all the subsequent pages.
NOTE: This item must also be completed if the Exposure Summary is being modified.
Case File Page
When the case file is organized, the sampling forms and their continuation sheets should be placed immediately behind the Worksheet, OSHA Form 1B, to which they relate. All sample forms which do not support a violation should be placed together at the back of the case file. After the case file has been organized, all of the pages should be numbered sequentially according to current office filing procedures.
PRE-SAMPLING CALIBRATION (See the back of the OSHA-93)
If compliance personnel use the Cal/OSHA Form 1E, all pertinent information must be transferred to the OSHA Form 93.
Enter the type of direct reading instrument being calibrated, its manufacturer's name and model number, and its serial number.
If the instrument is calibrated in the office, enter "OFFICE." If calibrated elsewhere, enter the address of the location at which the calibration is performed. If more than one instrument is used for a given exposure documentation and they are calibrated at the same location, enter the location for the first instrument and enter "SAME" in Item 34 for the additional instruments. Include temperature and barometric pressure, when necessary.
If all the instruments are calibrated at the same location, the address should be noted on the first form used and a slash drawn through this item on subsequent forms.
Describe completely the calibration source used.
EXAMPLE: For the Ecolyzer: Eco-Span Gas, 51 ppm For the G.C.A.: 1.23 mg/M2 GCA disc
Enter the results of the pre-sampling calibration.
EXAMPLE: For the Ecolyzer: 52 ppm
For the G.C.A.: 10 rdgs averaged: 1.22
For Leakage test: ok
The person performing the pre-sampling calibration must certify that standard calibration procedures have been followed by initialing the form in this space.
Enter the date and time of the pre-sampling calibration.
POST-SAMPLING CALIBRATION (See the back of the OSHA-93)
Be sure that each instrument's post-sampling calibration record is in the block to the right of its pre-sampling calibration record. If compliance personnel use the Cal/OSHA Form 1E, all pertinent information must be transferred to the OSHA Form 93.
Describe completely the calibration source used. (See the examples for Item 35.) If the same calibration source was used for the pre-sampling calibration, draw a slash through this item.
If the instrument is calibrated in the office, enter "OFFICE." If calibrated elsewhere, enter the address of the location at which the calibration is performed. If more than one instrument is used for a given exposure documentation and they are calibrated at the same location, enter the location for the first instrument and enter "SAME" in Item 39 for the additional instruments. Include temperature and barometric pressure, when necessary. Reference the IHTM for guidance.
NOTE: If all the instruments are calibrated at the same location, the address should be noted on the first form used and a slash drawn through this item on subsequent forms. If the pre- and post-sampling calibrations were both done at the same location, draw a slash through this item, but enter the temperature and barometric pressure, if needed, on the first form used.
Enter the results of the post-sampling calibration. See the examples for Item 36.
The person performing the post-sampling calibration must certify that standard calibration procedures have been followed by initialing the form in this space.
Enter the date and time of the post-sampling calibration.