Policy
The University of Chicago shall minimize employee exposure to hazardous chemicals, hazardous environments, and indoor air contaminants in accordance with all relevant standards and recommended exposure limits.
Authority and Responsibility
Environmental Health and Safety is responsible for:
- Investigating complaints;
- Conducting an interview with building occupants;
- Walking through the affected area;
- Reviewing all available and relvant Safety Data Sheets (SDS);
- Determining employee’s exposure to any substance regulated by a standard which requires monitoring. For those hazardous chemicals and/or substances where no relevant standard exists or recommended limit has been established, the exposure shall be evaluated and limited to the lowest reasonably achievable limit;
- Enforcing more stringent guidelines when children are present;
- Monitoring for contaminants when deemed necessary;
- Recommending corrective action and control measures;
- Coordinating corrective actions with appropriate representatives;
- Stopping any process where an exposure is determined to be immediately dangerous to the health and safety of an employee or other individual(s) in the affected area; and
- Obtaining outside contractors, coordinating sampling scheme, managing work, and disseminating reports for any additional monitoring requested.
Please note that Environmental Health and Safety is only responsible for Industrial Hygiene Surveys outside of teaching and research laboratories. For lab activities please contact the Office of Research Safety (ORS) or your Laboratory Safety Specialist (LSS) for identifying hazards, exposure potential, and coordinating exposure monitoring.
Departments are responsible for:
- Providing access to necessary locations and employees during investigations;
- Providing requested documentation and information to representatives of Environmental Health and Safety upon request; and
- Implementing a corrective action plan.
Facilities Operations and Physical Plant are responsible for:
- Providing requested information to representatives of Environmental Health and Safety upon request; and
- Correcting deficiencies identified by Environmental Health and Safety.
Indoor Air Quality
Investigation
Phase I
Environmental Health and Safety shall conduct a preliminary assessment of the area including an interview with building occupants who have the complaint. A walk through inspection of the area shall be conducted. During the walk through, Environmental Health and Safety shall identify building ventilation systems and possible sources of contamination. Monitoring for carbon dioxide, carbon monoxide, temperature, and relative humidity may be conducted. If the immediate cause or source cannot be determined, a Phase II assessment shall be required.
Phase II
Environmental Health and Safety may conduct monitoring for the following indoor air quality parameters: carbon dioxide, carbon monoxide, nitrogen dioxide, sulfur dioxide, formaldehyde, low class hydrocarbons, high class hydrocarbons, ozone, hydrogen sulfide, temperature, and relative humidity. If there is reason to believe that a particular contaminant is suspected, sampling for that contaminant may be conducted.
If a definitive cause for the symptoms is yet to be determined and the results from the aforementioned contaminates are below permissible exposure limits, additional monitoring for volatile organic compounds (VOC’s), respirable dust, and/or total dust may be conducted when warranted.
Chemical Exposure Determination
Initial Monitoring
Initial exposure monitoring shall be conducted for employees and areas in which it is determined that exposures may be in excess of established limits or upon notification by an employee that a potential overexposure exists for a specific chemical.
Periodic Monitoring
If the employee’s initial exposure determination has exceeded the action level or permissible exposure level, monitoring requirements of the measured contaminant shall be implemented in accordance with the appropriate standard.
Termination of Monitoring
Monitoring shall be terminated by Environmental Health and Safety in accordance with the relevant standard or in the absence of a standard when the lowest reasonably achievable exposure level has been obtained.
Microbial Contamination
If complaints and/or symptoms are consistent with that of exposure to microbial material, Environmental Health and Safety shall conduct a walkthrough of the area to determine sources of moisture in the building and any visible microbial growth. If microbial growth is present, the source of the moisture shall be determined and corrected and any remediation efforts will be coordinated by Environmental Health and Safety. Because regulatory agencies have not determined acceptable/unacceptable levels of exposure and physical reaction can vary from individual to individual based on sensitivity to microbial substances, Environmental Health and Safety will not perform monitoring for microbial contaminants.
Noise Surveys
To request an evaluation of the noise levels in your area, contact Environmental Health and Safety at 773.702.9999.
Water Testing
Environmental Health and Safety shall conduct drinking water testing for general indicators such as copper, lead, turbidity, total coliform, and pH if it is believed that the water source is not acceptable for drinking quality. Results will be compared to the maximum contaminant levels for each contaminant.
To request an evaluation of potable drinking water in your area, please contact Environmental Health and Safety at 773.702.9999.
Electromagnetic Surveys
To request an evaluation of electromagnetic fields in your area, contact Environmental Health and Safety at 773.702.9999.
Employee Notification
The employee requesting sampling and the department director or supervisor shall receive a copy of the monitoring report within ten working days after the results of the monitoring have been received by Environmental Health and Safety.
The report shall include the following information:
- Executive summary;
- Scope of work;
- Constituent data;
- Sampling and analytical methods;
- Results and discussion; and
- Conclusions and recommendations
Recordkeeping
Employee monitoring results shall be maintained by Environmental Health and Safety for the duration of employment and for a period of 30 years from the date of termination. The employee or designee may request copies of monitoring results at any time during employment at the University of Chicago by contacting Environmental Health and Safety. If the employee is no longer employed by the University of Chicago, this request shall be in writing to Environmental Health and Safety.
Corrective Action
Employees and/or areas found to be in excess of established exposure limits shall be evaluated to determine what corrective actions shall be implemented. To ensure compliance and achieve the safety and health of employees, administrative, and/or engineering controls shall be implemented whenever feasible.
Administrative controls are changes in work procedures such as written safety policies, rules, supervision, and training with the goal of reducing the duration, frequency, and severity of exposure to hazardous chemicals or situations. Engineering controls eliminate or reduce exposure to a chemical or physical hazard through the use or substitution of engineered machinery or equipment such as a fume hood ventilation system.
When such controls are not feasible to ensure the safety and health of employees and achieve compliance, protective equipment, or other protective measures recommended by Environmental Health and Safety shall be used to keep the exposures to the affected employee(s) within the established exposure limits.
Medical Consultations
Where exposure monitoring reveals an exposure level routinely above the action level or permissible exposure level for an Occupational Safety and Health Administration (OSHA) regulated substance with exposure monitoring requirements, medical surveillance shall be established for the affected employee(s) as prescribed by the particular standard.
Guidance Documents
Industrial Hygiene Surveys Policy Guidance Document
Reviewed: January 2024