Chapter 10 Evaluating the Industrial Hygiene Program
10.4 Developing the Assessment Plan and Lines of Inquiry
Once the critical attributes of the assessment have been identified, then an assess- ment plan and associated lines of inquiry are developed. The development of an assessment plan can be tailored to be either simple or quite formal and lengthy, and the extent to which the assessment plan is developed is dependent on the purpose of the assessment and the needs of the company. If the assessment is to be used
within the industrial hygiene program group to evaluate the performance of a par- ticular function, then it can be as simple as a checklist. If it will be used to support ongoing legal litigation or provide feedback to corporate on areas to improve across a company, then more elaborate criteria documents may be warranted. An example of a simple assessment plan is shown in Figure 10.2. A typical assessment plan should include the following:
• Assessment topic
• Person performing the assessment
• Assessment time frame
• Assessment methods
• Lines of inquiry to be used when conducting the assessment (which could consist of a ready-made checklist)
• Assessment results
Company X Assessment plan Assessment topic:
Person performing assessment:
Assessment timeframe:
Assessment methods:
Assessment lines-of-inquiry:
Implementation of the asbestos program
Susan B. Anthony
July 21, 2017August 6, 2017 Walk-through of the area.
Review of program documentation.
Interviewing two workers.
1. Does the company maintain a list and location of asbestos contaminated material? Select several work locations to confirm that all required signs and postings are visible.
2. Have workers been provided initial and continuing training as required?
3. Are workers provided the appropriate PPE commensurate with program requirements?
4. Are the results of sampling work evolutions below regulatory and company requirements?
5. Is a written program in place, which is compliant with regulatory requirements, and requires all appropriate monitoring?
6. Are appropriate respirators used when required?
7. Are employees who perform work with asbestos in a medical surveillance program?
8. Do workers feel they are protected?
9. What opportunities exist for improving program and field implementation?
10. Does the company have an effective asbestos program?
FIGURE 10.2 Assessment plan template.
If the assessment is being informally conducted, then a written plan is not neces- sary; however, depending on how the information from the assessment will be used, it is always recommended to document the assessment methods and results in some manner for future reference, whether it be in a logbook or an informal database. The information can be used for communicating to management or workers that a work process has been evaluated and determined to either be adequate or need improve- ment. As part of the assessment plan, the method of assessment will need to be defined. Assessment methods include the following:
• Reviewing program or process documentation
• Interviewing workers and management
• Observing work in the field
As an assessor, you will decide the best method for performing the assessment based on the topic and needs of the assessment. One or more assessment methods are generally used in any type of assessment. The assessment methods are used to implement the lines of inquiry.
The lines of inquiry are typically written in the assessment plan as a question, but could be in the form of a statement, and can be used with any assessment method (e.g., whether you are interviewing a worker in the field or reviewing documentation that is used to validate safety and health information communicated to the workforce).
Lines of inquiry can originate from program and process procedures, and form the fundamental basis for performing the assessment. The reason for why the assessment is being performed will drive how the lines of inquiry are written. If the assessment is being conducted to determine whether the program or process is compliant with regu- latory or contractual requirements, then the lines of inquiry will be developed from the requirements in the form of a question or a statement. For example, 29 CFR 1910.95(c) requires employers to administer a continuing, effective hearing conservation program whenever employee noise exposures equal or exceed an 8-hour time-weighted average (TWA) sound level of 85 dB on the A scale or, equivalently, a dose of 50%. A line of inquiry that can be used to evaluate this requirement may consist of, “Does the com- pany require an employee to be in a hearing conservation program if the employee noise exposures equal or exceed an 8-hour time-weighted average (TWA) sound level of 85 dB on the A scale or, equivalently, a dose of 50%?” The method used to evaluate this line of inquiry could include review of exposure monitoring results to determine which employees would qualify to be in a hearing conservation program, and then evaluate whether the employees have been enrolled in such a program. The number of lines of inquiry developed will vary depending on whether the scope of the assessment is large or small. There is no defined number of lines of inquiry needed; however, the number of lines of inquiry should be sufficient to draw conclusions of the assessment that support whether the program or process is adequate or improvement is needed.
Additional factors to consider when developing lines of inquiry include
• What information is being sought when reviewing documentation?
• What are the work practices that the workers will be following when per- forming the task to be observed?
• How will the information from the assessment be used, and are there other considerations, such as legal or personnel requirements, that should be incorporated into the lines of inquiry?
• How can one communicate the questions in such a manner that both the people being assessed and the personnel who will use the information understand?