Attachment 4 HQDA EXORD 031-19 Final 031116SEP19.pdf

UNCLASSIFIED/FOUO//

SUBJECT: HQDA EXORD 031-19 ENSURING SAFE AND HEALTHY WORKPLACES

THAT GENERATE OR HAVE POTENTIAL FOR EXPOSURE TO HEAVY METALS //

(U) REFERENCES:

REF//A/ (U) AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL

HYGIENISTS (ACGIH) THRESHOLD LIMIT VALUES (TLVS) FOR CHEMICAL

SUBSTANCES AND PHYSICAL AGENTS AND BIOLOGICAL EXPOSURE INDICES

(BEIS), 2018// REF//B/ (U) ARMY REGULATION (AR) 420-1, ARMY

FACILITIES MANAGEMENT, 24 AUGUST 2012//

REF//C/ (U) AR 200-1, ENVIRONMENTAL PROTECTION AND ENHANCEMENT,

13 DECEMBER 2007//

REF//D/ (U) AR 40-5, PREVENTIVE MEDICINE, 25 MAY 2007//

REF//E/ (U) AR 11-34, THE ARMY RESPIRATORY PROTECTION PROGRAM, 25 JULY

2013//

REF//F/ (U) DEPARTMENT OF THE ARMY PAMPHLET (DA PAM) 40-503,

INDUSTRIAL HYGIENE, 02 APRIL 2013//

REF//G/ (U) DA PAM, 40-11, PREVENTIVE MEDICINE, 19 OCTOBER 2009//

REF//H/ (U) DEPARTMENT OF DEFENSE INSTRUCTION (DODI) 6055.01: DOD

SAFETY AND OCCUPATIONAL HEALTH (SOH) PROGRAM, APPENDIX TO ENCLOSURE 4

– IMPLEMENTING GUIDANCE FOR CONTROLLING SURFACE CONTAMINATION IN

OPERATIONS USING LEAD, HEXAVALENT CHROMIUM, AND CADMIUM, 14 OCTOBER

2014//

REF//I/ (U) DODI 6055.05-M, OCCUPATIONAL MEDICAL EXAMS AND

SURVEILLANCE MANUAL, 31 AUGUST, 2018//

REF//J/ (U) OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(OSHA) STANDARDS #1910.1200, HAZARD COMMUNICATION//

REF//K/ (U) OSHA STANDARDS #1910.1025, LEAD (PB)//

REF//L/ (U) OSHA STANDARDS #1910.1026, HEXAVALENT CHROMIUM (CR(VI))//

REF//M/ (U) OSHA STANDARDS #1910.1027, CADMIUM (CD)//

REF//N/ (U) OSHA STANDARDS #1910.1024, BERYLLIUM (BE)// REF//O/ (U)

OSHA STANDARDS #1910.134, RESPIRATORY PROTECTION// REF//P/ (U) OSHA

STANDARDS #1910.141, SANITATION//

REF//Q/ (U) OSHA STANDARDS #1910.339, MEDICAL QUALIFICATIONS//

REF//R/ (U) OSHA STANDARDS #1960, ELEMENTS FOR FEDERAL

EMPLOYEE OCCUPATIONAL SAFETY AND HEALTH PROGRAM

REF//S/ (U) THE ARMY PUBLIC HEALTH CENTER – HEXAVALENT

CHROMIUM,

HTTPS://PHC.AMEDD.ARMY.MIL/TOPICS/WORKPLACEHEALTH/IH/PAGES/CR6.

ASPX// REF//T/ (U) OSHA SMALL ENTITY COMPLIANCE GUIDE FOR

HEXAVALENT CHROMIUM STANDARDS, US DEPARTMENT OF LABOR, OSHA

3320-10N 2006//

AMPN// (U) THE ABOVE REFERENCES PROVIDE GUIDANCE AND ADDITIONAL

PROCEDURES NEEDED TO: (1) ADDRESS THE 2016 OSHA STANDARD ON

IDENTIFICATION AND MANAGEMENT OF PB, CD, CR(VI), AND BE EXPOSURES AND

(2) PROCEDURES NEEDED TO ADDRESS IMPLEMENTING UPDATED OCCUPATIONAL

EXPOSURE LEVELS FOR CHROMIUM AND CHROMIUM COMPOUNDS (CR/CR

COMPOUNDS)//

1. (U) SITUATION.

1.A. (U) FOR THIS EXORD ALL REFERENCE TO HEAVY METALS WILL BE LIMITED

TO LEAD (PB), CADMIUM (CD), CHROMIUM (CR)/CR COMPOUNDS, AND BERYLLIUM

(BE). PERSONNEL IS DEFINED AS ALL SERVICE MEMBERS, CIVILIANS, AND

CONTRACTORS, AS DEFINED BY CONTRACTUAL REQUIREMENTS. DUE TO THE

POTENTIALLY NEGATIVE HEALTH OUTCOMES AND READINESS IMPACTS ASSOCIATED

WITH EXPOSURES TO HEAVY METALS, COMMANDERS WILL FOLLOW ARMY POLICY AND

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) STANDARDS. IN

ORDER TO ADEQUATELY TRACK AND MONITOR OCCUPATIONAL EXPOSURES TO THESE

HEAVY METALS, THE ARMY MUST IDENTIFY ALL WORKSITES THAT PERFORM

PROCESSES THAT USE AND GENERATE THESE HEAVY METAL HAZARDS.

1.B. (U) CURRENT ARMY POLICY MANDATES THE USE OF THE ACGIH TLVS AS THE

OCCUPATIONAL EXPOSURE LEVEL (OEL) CRITERIA WHEN THE OSHA PERMISSIBLE

EXPOSURE LIMIT (PEL) IS LESS PROTECTIVE OR WHEN NO OSHA PEL EXISTS.

THE ACGIH LOWERED ITS TLV EXPOSURE GUIDELINES FOR CHROMIUM IN ITS 2018

TLV PUBLICATION AND AS PART OF THE REVIEW PROCESS. AS A RESULT OF THIS

POLICY, INDUSTRIAL HYGIENISTS MUST ENSURE THAT INDUSTRIAL HYGIENE (IH)

EXPOSURE ASSESSMENTS USE AN APPROPRIATE SAMPLING METHODOLOGY, PER

APPLICABLE OSHA STANDARD AND/OR ARMY POLICY.

1.C. (U) TRADITIONALLY, ARMY ELEMENTS HAVE CONDUCTED AIRBORNE

OCCUPATIONAL EXPOSURE MONITORING IN THE WORKPLACE FOLLOWING GENERALLY

ACCEPTED AIR SAMPLING METHODS FOR TOTAL PARTICULATE MATTER. TOTAL

PARTICULATE MATTER IS DEFINED AS TOTAL IN THIS DOCUMENT. THE 2018

ACGIH TLV UPDATE REQUIRES THAT OCCUPATIONAL EXPOSURES ARE REASSESSED

AT ALL ARMY WORKSITES THAT PERFORM PROCESSES THAT GENERATE CR/CR

COMPOUNDS USING INHALABLE SAMPLING TECHNIQUES. AS SUCH WITH ANY NEW

ARMY STANDARD, THERE IS AN ACCEPTABLE TIMEFRAME IN WHICH TO UPDATE

ARMY PROCEDURES, STANDARDS, AND METHODS TO ACHIEVE THE NEW STANDARD.

THIS TIMEFRAME WILL BE ADDRESSED IN THE APPLICABLE PHASES OF THIS

EXORD AND ANY FOLLOW-ON GUIDANCE.

2.(U) MISSION. NOT LATER THAN (NLT) 90 DAYS FROM ISSUE DATE OF THIS

EXORD THE ARMY WILL IDENTIFY ALL ARMY OWNED WORKSITES WHERE POTENTIAL

EXPOSURES TO HEAVY METALS EXIST. THIS ACCOUNTING IS REQUIRED IN ORDER

TO ENSURE COMPLETENESS OF DEFENSE OCCUPATIONAL AND ENVIRONMENTAL

HEALTH READINESS SYSTEM - INDUSTRIAL HYGIENE (DOEHRS-IH) DATA AND

COMPLIANCE WITH ARMY POLICY AND OSHA STANDARDS. AFTER IDENTIFICATION

OF WORKSITES, IMPLEMENT ACTIONS TO MITIGATE, EDUCATE, PREVENT, AND

ELIMINATE HEAVY METAL EXPOSURES IAW ARMY POLICY WITHIN 5 YEARS TO

ENSURE THE HEALTH AND SAFETY OF PERSONNEL.

3.(U) EXECUTION.

3.A. (U) COMMANDER’S INTENT. EFFECTIVELY COLLABORATE, SYNCHRONIZE, AND

COMMUNICATE EFFORTS TO IDENTIFY AFFECTED WORKSITES, COMPLY WITH ARMY

POLICY AND OSHA STANDARDS, AND DEFINE AND IMPLEMENT CONTROLS/BEST

PRACTICES TO ENSURE THE HEALTH AND SAFETY OF PERSONNEL AT ARMY

WORKSITES FROM HEAVY METALS HAZARDS.

3.A.1. (U) KEY TASKS.

3.A.1.A. (U) USING THE APPLICABLE ACGIH AND OSHA STANDARDS IDENTIFY

ALL ARMY OWNED WORKSITES WHERE POTENTIAL EXPOSURES TO HEAVY METALS

EXIST NLT 90 DAYS FROM ISSUE DATE OF THIS EXORD.

3.A.1.B. (U) DEFINE AND IMPLEMENT RECOMMENDED CONTROLS AND BEST

PRACTICES TO REDUCE POTENTIALLY HAZARDOUS WORKPLACE EXPOSURES TO HEAVY

METALS, AND SUPPORTING COMPLIANCE WITH ARMY POLICY AND OSHA STANDARDS.

3.A.1.C. (U) DEVELOP A COMPREHENSIVE HAZARD AND RISK COMMUNICATION

STRATEGY IN SUPPORT OF THE ARMY-WIDE IMPLEMENTATION OF APPLICABLE OSHA

STANDARDS AND ACGIH TLVS AS THE ARMY OELS FOR HEAVY METALS.

3.A.2. (U) END STATE. IDENTIFIED AND ASSESSED ALL ARMY WORKSITES WHERE

THERE IS POTENTIAL EXPOSURE TO HEAVY METALS; EXECUTED TASKS TO

IMPLEMENT APPLICABLE OSHA AND ACGIH STANDARDS FOR HEAVY METALS THROUGH

A COORDINATED AND SYNCHRONIZED EFFORT; AND IMPLEMENTED CONTROLS/BEST

PRACTICES TO MAINTAIN A SAFE AND HEALTHY WORK PLACE WITHIN 5 YEARS OF

CONFIRMING THE HAZARD EXISTENCE.

3.B. (U) CONCEPT OF OPERATION. THIS OPERATION WILL BE CONDUCTED IN

FOUR (4) PHASES:

3.B.1. (U) PHASE 1 – NOTIFICATION AND IDENTIFICATION. THIS PHASE

BEGINS WITH RECEIPT OF EXORD 031-19 ENSURING SAFE AND HEALTHY ARMY

WORKPLACES THAT GENERATE OR HAVE POTENTIAL FOR EXPOSURE TO HEAVY

METALS. THIS PHASE IS COMPLETE ONCE ALL ARMY WORKSITES WITH POTENTIAL

HEAVY METAL GENERATING PROCESSES AND POTENTIAL EXPOSURES ARE UPDATED

IN TAB C TO APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION), AND PROVIDED

TO THE ARMY COMBAT READINESS CENTER (USACRC) POINT OF CONTACT (POC)

LISTED IN COMMAND AND SIGNAL, PARAGRAPH 5, NLT 90 DAYS FROM ISSUANCE

OF THIS EXORD. ANY EXTENSIONS TO THE TIMELINE MUST BE REQUESTED ON A

CASE BY CASE BASIS.

3.B.2. (U) PHASE 2 – EXECUTION OF INDUSTRIAL HYGIENE (IH) EXPOSURE

ASSESSMENTS. THIS PHASE BEGINS IN EACH COMMAND AFTER THE COMPLETION OF

PHASE 1. THE PHASE WILL END UPON COMPLETION OF IH ASSESSMENTS OF ALL

IDENTIFIED WORKSITES. THESE IH ASSESSMENTS WILL BE PRIORITIZED BY THE

LEVEL OF RISK AS DETERMINED BY A QUALIFIED IH PROFESSIONAL AND ENSURE

REQUIRED ASSESSMENT DATA IS RECORDED IN DOEHRS-IH. THIS PHASE WILL BE

COMPLETED NLT 30 APRIL 2020.

3.B.3. (U) PHASE 3 – REPORT, RECORD, DEFINE CONTROLS, AND DEVELOP

IMPACT STATEMENT. REPORT EXPOSURE DATA TO RELEVANT PERSONNEL AND

RECORD REQUIRED ASSESSMENT DATA IN DOEHRS-IH. DEFINE APPROPRIATE

CONTROLS, IN ACCORDANCE WITH (IAW) THE HEIRARCY OF CONTROLS, WITHIN

SIX (6) MONTHS OF RECEPTION OF FINALIZED IH ASSESSMENT REPORT.

DEVELOP AN IMPACT STATEMENT THAT CAPTURES COST AND OTHER IMPACTS OF

IMLPEMENTING DEFINED CONTROLS (E.G. WEARING PPE, TRAINING, MEDICAL

SURVEILLANCE, AND OTHER NEWLY INTRODUCED SAFETY HAZARDS). CONSOLIDATE

DATA AND SUBMIT THROUGH THE ACOM/ASCC/DRU TO THE POCS LISTED IN

PARAGRAPH 5B FOR ARMY LEVEL CONSOLIDATION, ANALYSIS, AND GUIDANCE FROM

SENIOR LEADERSHIP. THIS PHASE WILL END WHEN ALL IMPACT ASSESSMENTS

ARE RECEIVED (NLT FEBRUARY 2021 FOR THE LAST FACILITY ASSESSED IN

APRIL 2020).

3.B.4. (U) PHASE 4 – CONTROL AND CORRECT. THE HEAVY METALS WORKING

GROUP COMPILES ARMY IMPACT ASSESSMENTS AND DEVELOPS COURSES OF ACTIONS

(COAS) FOR SENIOR LEADER CONSIDERATION. COAS WILL INCLUDE

RECOMMENDATIONAS FOR IMPLEMENTATION THAT ARE RESOURCE INFORMED AND

INCLUDE UPDATED TIMELINES FOR FULL COMPLIANCE WITH ARMY POLICY.

PENDING SENIOR LEADER GUIDANCE, A FULL IMLPEMENTATION PLAN WILL BE

DEVELOPED TO ELIMINATE OR REDUCE WORKPLACE EXPOSURES TO HEAVY METALS.

PHASE 4 WILL BE COMPLETE WHEN IMLPEMENTATION GUIDANCE IS PUBLISHED AND

TRACKING TO COMPLETION IS IN PLACE.

3.C. (U) TASKS TO SUBORDINATE UNITS.

3.C.1. (U) COMMANDERS, ARMY COMMANDS (ACOM), ARMY SERVICE COMPONENT

COMMANDS (ASCC), AND DIRECT REPORTING UNITS (DRU).

3.C.1.A. (U) IDENTIFY ARMY OWNED, LEASED, OR SUPPORTED WORKSITES

WITHIN THEIR AREA OF OPERATION THAT PRESENT A POTENTIAL EXPOSURE TO

HEAVY METALS.

3.C.1.B. (U) REVIEW INFORMATION PROVIDED IN ANNEX E (PROTECTION) AND

ANNEX F (SUSTAINMENT) OF THIS EXORD. ENSURE DISTRIBUTION TO ALL

SUBORDINATE COMMANDS AND ARMY ORGANIZATIONS INCLUDING DOD JOINT BASES.

3.C.1.C.(U) CROSS CHECK WORKSITES THAT PRESENT A POTENTIAL EXPOSURE TO

HEAVY METALS WITH THE DOEHRS-IH DOCUMENTED SITES PROVIDED IN TAB A AND

TAB B TO APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION). IN THE EVENT

THERE ARE ARMY OWNED, LEASED, OR SUPPORTED WORKSITES IDENTIFIED WHERE

POTENTIAL EXPOSURES TO HEAVY METALS EXIST THAT ARE NOT DOCUMENTED ON

THE DOEHRS-IH LIST PROVIDED IN TAB A AND TAB B TO APPENDIX 7 (SAFETY)

TO ANNEX E (PROTECTION), THAT COMMAND OR ORGANIZATION WILL COMPLETE

TAB C (WORKSHEET - ARMY WORKSITES WITH HEAVY METAL EXPOSURES) TO

APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION) TO IDENTIFY BUILDING

LOCATIONS THAT INVOLVE THE TOP PROCESSES, AS DEFINED IN TAB C

(WORKSHEET - ARMY WORKSITES WITH HEAVY METAL EXPOSURES) TO APPENDIX 7

(SAFETY) TO ANNEX E (PROTECTION ASSOCIATED WITH EXPOSURES TO THESE

HEAVY METALS. AS ADDITIONAL HEAVY METAL HAZARD TOP PROCESSES ARE

IDENTIFIED, CONTINUOUSLY ENSURE THAT MEASURES ARE TAKEN TO COMPLY WITH

ARMY REGULATIONS AND OSHA STANDARDS FOR HEAVY METALS (E.G,

HOUSEKEEPING AND OTHER PROTECTIVE MEASURES). THE COMPLETED WORKSHEETS

WILL BE CONSOLIDATED AT THE ACOM, ASCC, OR DRU HEADQUARTER (HQ) LEVEL

AND FORWARDED TO THE USACRC POC LISTED IN COMMAND AND SIGNAL,

PARAGRAPH 5, NLT 90 DAYS FROM THE RELEASE OF THIS EXORD. IF AN

INSTALLATION IS UNABLE TO COMPLETE BY THE NLT DATE, THE COMMAND WILL

PROVIDE CAUSE OF DELAY AND ESTIMATED COMPLETION DATE.

3.C.1.D. (U) IF A COMMAND OR ORGANIZATION DOES NOT CONDUCT OPERATIONS

INVOLVING TOP PROCESSES LISTED IN TAB C (WORKSHEET - ARMY WORKSITES

WITH HEAVY METAL EXPOSURES) TO APPENDIX 7 (SAFETY) TO ANNEX E

(PROTECTION), OR IF ALL HEAVY METALS POTENTIAL EXPOSURE SITES ARE

ANNOTATED ON THE DOEHRS-IH LIST PROVIDED IN TAB A AND TAB B TO

APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION), THEN TAB C (WORKSHEET -

ARMY WORKSITES WITH HEAVY METAL EXPOSURES) TO APPENDIX 7 (SAFETY) TO

ANNEX E (PROTECTION)) NEED NOT BE COMPLETED. HOWEVER, AN

ACKNOWLEDGEMENT WITH CONFIRMATION OF NO CHANGES TO THE DOEHRS-IH HEAVY

METALS LIST, MUST BE FORWARDED TO USACRC POC LISTED IN COMMAND AND

SIGNAL, PARAGRAPH 5 FOR FURTHER REVIEW BY THE USACRC NLT 90 DAYS AFTER

THE ISSUE DATE OF THIS EXORD.

3.C.1.E. (U) CROSS CHECK ALL IDENTIFIED ARMY OWNED, LEASED, OR

SUPPORTED WORKSITES WHERE POTENTIAL EXPOSURES TO CR/CR COMPOUNDS EXIST

WITH THE SCHEDULES PROVIDED IN TAB A (INDUSTRIAL HYGIENE INHALABLE

SAMPLING PLAN SCHEDULE) AND TAB B (INDUSTRIAL HYGIENE INHALABLE

SAMPLING PLAN SCHEDULE) TO APPENDIX 3 (ARMY HEALTH SYSTEM SUPPORT) TO

ANNEX F (SUSTAINMENT).

3.C.1.F. (U) FOR IDENTIFIED ARMY OWNED, LEASED, OR SUPPORTED WORKSITES

WHERE POTENTIAL EXPOSURES TO CR/CR COMPOUNDS EXIST, AND WHERE THESE

SITES ARE ANNOTATED IN TAB B (INDUSTRIAL HYGIENE INHALABLE SAMPLING

PLAN SCHEDULE FOR CR/CR COMPOUNDS, INSTALLATION IH PROGRAM- LED) TO

APPENDIX 3 (ARMY HEALTH SYSTEM SUPPORT) TO ANNEX F (SUSTAINMENT),

ACOM, ASCC, DRU, AND ORGANIZATIONS WILL CONTACT THEIR RESPECTIVE IH

PROGRAM MANAGER TO COORDINATE EXECUTION OF THE REQUIRED FOLLOW-ON IH

EXPOSURE ASSESSMENT IN ACCORDANCE (IAW) THE CALENDAR MONTH ANNOTATED

ON TAB B (INDUSTRIAL HYGIENE INHALABLE SAMPLING PLAN SCHEDULE FOR

CR/CR COMPOUNDS, INSTALLATION IH PROGRAM-LED) TO APPENDIX 3 (ARMY

HEALTH SYSTEM SUPPORT) TO ANNEX F (SUSTAINMENT). IN ORDER TO ENSURE

THAT ALL HEAVY METAL EXPOSURE ASSESSMENT DATA IS INPUTTED INTO DOHERS-

IH, THE USE OF MEDICAL COMMAND (MEDCOM)/ ARMY PUBLIC HEALTH CENTER

(APHC) IH SUPPORT IS RECOMMENDED FOR THE COMPLETION OF SUCH EXPOSURE

ASSESSMENTS. IF CONTRACTED IH SUPPORT IS USED, THE APHC POC IN COMMAND

AND SIGNAL, PARAGRAPH 5 WILL BE INFORMED. ANY CONTRACTED IH SUPPORT

WILL BE REQUIRED TO INCLUDE DOEHRS-IH DATA ENTRY.

3.C.1.G. (U) FOR IDENTIFIED ARMY OWNED, LEASED, OR SUPPORTED WORKSITES

WHERE POTENTIAL EXPOSURES TO CR/CR COMPOUNDS EXIST AND WHERE THESE

SITES ARE ANNOTATED IN TAB A (INDUSTRIAL HYGIENE INHALABLE SAMPLING

PLAN SCHEDULE FOR CR/CR COMPOUNDS, APHC-LED) TO APPENDIX 3 (ARMY

HEALTH SYSTEM SUPPORT) TO ANNEX F (SUSTAINMENT), ACOM, ASCC, DRU, AND

ORGANIZATIONS WILL CONTACT THE APHC POC LISTED IN COMMAND AND SIGNAL,

PARAGRAPH 5 TO COORDINATE EXECUTION OF THE REQUIRED FOLLOW-ON IH

EXPOSURE ASSESSMENT IAW THE CALENDAR MONTH ANNOTATED ON TAB A

(INDUSTRIAL HYGIENE INHALABLE SAMPLING PLAN SCHEDULE FOR CR/CR

COMPOUNDS, APHC-LED) TO APPENDIX 3 (ARMY HEALTH SYSTEM SUPPORT) TO

ANNEX F (SUSTAINMENT). APHC-LED INHALABLE SAMPLING FOR CR/CR COMPOUNDS

WILL NOT BE CONTRACTED OUT.

3.C.1.H. (U) UPON RECEIPT OF EXPOSURE ASSESSMENT RESULTS FROM

SUPPORTING IH PROGRAM OFFICE, NOTIFY ALL PERSONNEL OF THEIR INDIVIDUAL

INDUSTRIAL HYGIENE EXPOSURE ASSESSMENT RESULTS. IF AN INDUSTRIAL

HYGIENE EXPOSURE ASSESSMENT RESULT INDICATES THAT AN EXPOSURE TO HEAVY

METAL(S) EXCEED(S) THE APPLICABLE OSHA PEL(S) OR ACGIH TLV(S)), ALL

AFFECTED PERSONNEL MUST BE NOTIFIED. AFFECTED PERSONNEL ARE DEFINED AS

ALL PERSONNEL CONSIDERED TO BE POTENTIALLY EXPOSED ABOVE THE

APPLICABLE PEL(S) OR ACGIH TLV(S)). INCLUDE THOSE PERSONNEL WHO ARE

NOT ACTUALLY SUBJECT TO PERSONAL MONITORING, BUT WHO ARE REPRESENTED

BY A WORKER EXPOSED. NOTIFICATION MAY OCCUR IN WRITING OR POSTED IN AN

APPROPRIATE LOCATION ACCESSIBLE TO ALL AFFECTED PERSONNEL (E.G.,

BULLETIN BOARD ACCESSIBLE TO ALL AFFECTED PERSONNEL). WRITTEN

NOTIFICATION MUST DESCRIBE RECOMMENDED CORRECTIVE ACTION(S) (E.G., USE

OF ENGINEERING CONTROLS, ALTERATIONS TO WORK PRACTICES, AND USE OF

RESPIRATOR PROTECTION). OSHA GENERAL INDUSTRY STANDARD REQUIRES WORKER

NOTIFICATION WITHIN 15 WORKING DAYS FROM WHEN EXPOSURE ASSESSMENT IS

COMPLETE OSHA CONSTRUCTION AND SHIPYARD STANDARDS REQUIRES WORKER

NOTIFICATION AS SOON AS POSSIBLE, BUT NOT MORE THAN FIVE (5) WORKING

DAYS OF WHEN EXPOSURE ASSESSMENT IS COMPLETE.

3.C.1.I. (U) ENSURE COMPLIANCE WITH THE OSHA GENERAL INDUSTRY

REQUIREMENTS FOR REGULATED AREAS. THE PURPOSE OF THE REGULATED AREA IS

TO ENSURE THAT PERSONNEL ARE AWARE OF THE POTENTIAL OF EXPOSURES AT

LEVELS ABOVE THE OSHA PELS AND/OR ACGIH TLVS, AND TO LIMIT EXPOSURE.

PERSONNEL IN OR AROUND REGULATED AREAS MAY RECEIVE EXPOSURE FROM

HAZARDOUS CONTAMINATION THAT SETTLES ON, OR MIGRATES TO, SURROUNDING

SURFACES. OSHA HAS PLACED SIGNIFICANT EMPHASIS ON THE REQUIREMENTS FOR

REGULATED AREAS TO CONTROL SECONDARY INGESTION AND INHALATION HAZARDS

FROM SURFACE CONTAMINATION.

3.C.1.J. (U) EMPHASIZE THE IMPORTANCE OF A RIGOROUS HOUSEKEEPING

PROGRAM TO PREVENT ACCUMULATION OF HAZARDOUS DUST. ENSURE THAT

HOUSEKEEPING PROGRAMS/PLANS ARE REVIEWED AND APPROVED BY THE

RESPONSIBLE IH OR IH PROGRAM MANAGER, SAFETY PROGRAM MANAGERS AND

INSTALLATION ENVIRONMENTAL PROGRAM OFFICES (TO ENSURE THAT HAZARDOUS

WASTE IS PROPERLY COLLECTED, STORED, AND DISPOSED OF). A HOUSEKEEPING

BEST PRACTICES TEMPLATE IS PROVIDED IN TAB D (EXAMPLE HOUSEKEEPING

PLAN BEST PRACTICES TEMPLATE) TO APPENDIX 7 (SAFETY) TO ANNEX E

(PROTECTION).

3.C.1.K. (U) EMPHASIZE THAT ARMY WORKPLACES ARE NOT REQUIRED TO

COLLECT SURFACE DUST WIPE SAMPLES TO VERIFY CLEANING EFFECTIVENESS.

THE OSHA HYGIENE PROVISION REGARDING SURFACES BEING MAINTAINED AS FREE

AS PRACTICABLE OF HAZARDOUS DUST ACCUMULATION IS PERFORMANCE-ORIENTED.

TO DATE, THERE IS NO MAXIMUM ALLOWABLE SURFACE CONTAMINATION CRITERIA

FOR PB, CD, CR/CR COMPOUNDS, OR BE ACCUMULATION ON SURFACES. PLEASE

CONTACT APHC POC LISTED IN COMMAND AND SIGNAL, PARAGRAPH 5, FOR MORE

INFORMATION REGARDING THE LIMITED CIRCUMSTANCES WHEN SURFACE DUST WIPE

SAMPLING MAY BE HELPFUL.

3.C.2. (U) COMMANDER, U.S. ARMY COMBAT READINESS CENTER (USACRC).

3.C.2.A. (U) COMPLETE FINAL REVIEW OF TAB C(WORKSHEET - ARMY WORKSITES

WITH HEAVY METAL EXPOSURES) TO APPENDIX 7 (SAFETY) TO ANNEX E

(PROTECTION) AND SUBMIT RESULTS TO THE APHC POC LISTED IN COMMAND AND

SIGNAL, PARAGRAPH 5, NLT 90 DAYS AFTER THE ISSUE DATE OF THIS EXORD.

3.C.2.B. (U) DEVELOP A COMPREHENSIVE HAZARD COMMUNICATION STRATEGY

THAT ENSURES COMPLIANCE WITH 29 CFR 1910.1200 - HAZARD COMMUNICATION.

ENSURE HAZARD COMMUNICATION PRODUCTS AND GUIDANCE ARE SOCIALIZED WITH

APHC RISK COMMUNICATION POC LISTED IN COMMAND AND SIGNAL, PARAGRAPH 5,

NLT 90 DAYS AFTER THE ISSUE DATE OF THIS EXORD.

3.C.3. (U) COMMANDER, ARMY PUBLIC HEALTH CENTER (APHC).

3.C.3.A. (U) USING TAB C (WORKSHEET - ARMY WORKSITES WITH HEAVY METAL

EXPOSURES) TO APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION), DEVELOP A

LIST OF CR/CR COMPOUND-SPECIFIC GENERATING SITES AND INTEGRATE SITES

INTO THE APPROPRIATE PLAN PROVIDED IN TAB A AND B (INDUSTRIAL HYGIENE

INHALABLE SAMPLING PLAN SCHEDULE FOR CR/CR COMPOUNDS) TO APPENDIX 3

(ARMY HEALTH SYSTEM SUPPORT) TO ANNEX F (SUSTAINMENT). PROVIDE THIS

LIST AND UPDATED TAB A AND TAB B (INDUSTRIAL HYGIENE INHALABLE

SAMPLING PLAN SCHEDULE) TO APPENDIX 3 (ARMY HEALTH SYSTEM SUPPORT) TO

ANNEX F (SUSTAINMENT) TO THE RESPONSIBLE IH PROGRAM MANAGER TO

COORDINATE EXECUTION OF THE REQUIRED FOLLOW-ON IH EXPOSURE

ASSESSMENTS.

3.C.3.B. (U) PROVIDE TAB C (WORKSHEET - ARMY WORKSITES WITH HEAVY

METAL EXPOSURES) TO APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION) TO

THE RESPONSIBLE IH PROGRAM MANAGER AND SAFETY MANAGER TO

FACILITATE EXECUTION OF THE REQUIRED FOLLOW-ON IH EXPOSURE

ASSESSMENTS FOR WORKSITES WHERE POTENTIAL EXPOSURES TO HEAVY

METALS EXIST AND HAVE NOT BEEN PREVIOUSLY DOCUMENTED IN DOEHRS-IH.

3.C.3.C. (U) DEVELOP AND DISTRIBUTE IH-SPECIFIC GUIDANCE/REQUIREMENTS

FOR THE EXECUTION OF SAMPLING IAW THE PLAN PROVIDED IN ANNEX F -

APPENDIX 3 – TAB A AND TAB B.

3.C.4. (U) COMMANDERS, U.S. ARMY MEDICAL COMMAND (MEDCOM)

3.C.4.A. (U) ENSURE REQUIRED IH EXPOSURE ASSESSMENTS ARE CONDUCTED,

RECORDED, AND REPORTED IAW ARMY POLICY.

3.C.4.B. (U) ENSURE IH EXPOSURE ASSESSMENT DATA ARE REPORTED TO

RELEVANT PERSONNEL (E.G. COMMANDERS/SUPERVISORS, OCCUPATIONAL HEALTH

MANAGERS, SAFETY OFFICE, ENVIRONMENTAL COORDINATOR, ETC.) TO SUPPORT

MEDICAL SURVEILLANCE AND HAZARDOUS EXPOSURE CONTROL EFFORTS. ALL

EXPOSURE ASSESSMENT DATA WILL BE RECORDED IN THE DOEHRS-IH PER ARMY

POLICY REQUIREMENTS, INCLUDING REQUIRING ANY CONTRACTED IH SUPPORT TO

RECORD EXPOSURE ASSESSMENT DATA IN DOEHRS-IH.

3.C.4.C. (U) FOLLOWING COMPLETION OF IH EXPOSURE ASSESSMENTS, ENSURE

THE ASSIGNED RISK ASSESSMENT CODE AND DERIVED RECOMMENDED CORRECTIVE

ACTION ARE PROVIDED TO THE APPROPRIATE COMMAND OR ORGANIZATION SAFETY

OFFICE TO BE INCLUDED IN THE INSTALLATION HAZARD ABATEMENT PLAN OR

EQUIVALENT. RECOMMENDED CONTROLS WILL ALIGN WITH THE HIERARCHY OF

CONTROLS AND OSHA STANDARD.

3.C.4.D. (U) DEVELOP A RISK COMMUNICATION STRATEGY IN SUPPORT OF THE

ARMY-WIDE IMPLEMENTATION OF THE 2018 ACGIH TLVS FOR CR/CR COMPOUNDS.

THE RISK COMMUNICATION STRATEGY WILL TARGET: (1) PERSONNEL WHO OPERATE

IN SITES THAT GENERATE CR/CR COMPOUNDS; (2) INDUSTRIAL HYGIENISTS WHO

CONDUCT EXPOSURE SAMPLING; (3) COMMANDERS OF INSTALLATIONS AND

FACILITIES THAT GENERATE CR/CR COMPOUNDS AND (4) OCCUPATIONAL MEDICINE

PROVIDERS WHO EVALUATE POTENTIALLY EXPOSED PERSONNEL. ENSURE RISK

COMMUNICATION PRODUCTS AND GUIDANCE ARE SOCIALIZED WITH THE USACRC.

RISK COMMUNICATION MATERIAL WILL BE POSTED ON THE APHC WEBSITE AT:

HTTPS://PHC.AMEDD.ARMY.MIL/TOPICS/WORKPLACEHEALTH/IH/PAGES/CR6.ASPX

3.C.4.E. (U) ENSURE COMPLIANCE WITH IH-SPECIFIC GUIDANCE/REQUIREMENTS

FOR THE EXECUTION OF SAMPLING IAW THE PLAN PROVIDED IN ANNEX F -

APPENDIX 3 – TAB A AND TAB B.

3.C.4.F. (U) NOTIFY BOTH THE AFFECTED WORKER(S) SUPERVISOR AND THE

RESPONSIBLE OCCUPATIONAL HEALTH (OH) CLINIC OR PROVIDER WHEN PERSONNEL

ARE RECOMMENDED FOR EXPOSURE-BASED MEDICAL SURVEILLANCE. NOTIFICATION

WILL INCLUDE PROVIDING BOTH THE AFFECTED WORKER(S) SUPERVISOR AND OH

CLINIC OR PROVIDER WITH A BY-NAME LIST OF PERSONNEL RECOMMENDED FOR

MEDICAL SURVEILLANCE. IN ADDITION, THE INSTALLATION/FACILITY SAFETY

OFFICE WILL BE NOTIFIED OF THESE ACTIONS TO ENSURE APPROPRIATE CONTROL

EFFORTS ARE MADE TO REDUCE HAZARDOUS OCCUPATIONAL EXPOSURES.

3.C.4.G. (U) ENSURE THAT PERSONNEL WHO ARE, OR MAY BE OCCUPATIONALLY

EXPOSED TO HEAVY METALS ARE ENROLLED IN APPROPRIATE MEDICAL

SURVEILLANCE PROGRAMS IN COMPLIANCE WITH OSHA STANDARDS AND ARMY

POLICY.

3.C.4.H. (U) ENSURE THAT HEALTHCARE PROVIDERS PERFORMING MEDICAL

SURVEILLANCE FOR POTENTIAL OCCUPATIONAL EXPOSURES TO HEAVY METALS

COMPLY WITH OSHA STANDARDS AND ARMY POLICY.

3.C.4.I. (U) PROVIDE SUPPORT TO COMMANDS AND ORGANIZATIONS REGARDING

THE ESTABLISHMENT OF REGULATED AREAS FOR AREAS THAT EXCEED OSHA PELS

AND/OR ACGIH TLVS IAW ARMY POLICY. SUPPORT MAY INCLUDE RECOMMENDATIONS

FOR: (1) BOUNDARIES OF REGULATED AREAS BASED ON EXPOSURE

DETERMINATIONS AND REASONABLE JUDGEMENT; (2) EFFECTIVE METHODS FOR

DEMARCATION; AND (3) ACCESS LIMITATIONS.

3.D. (U) COORDINATING INSTRUCTIONS.

https://phc.amedd.army.mil/TOPICS/WORKPLACEHEALTH/IH/PAGES/CR6.ASPX

3.D.1. (U) THROUGHOUT THE PHASES COMMANDS WILL REVIEW AND ASSESS THEIR

SOPS FOR COMPLIANCE WITH ARMY POLICY AND IMMEDIATELY IMPLEMENT

RECOMMENDED HOUSE KEEPING PROCEDURES WITHIN THEIR CURRENT

CAPABILITIES.

3.D.2. (U) COMMANDS AND ORGANIZATIONS THAT RECEIVE A CITATION FROM

OSHA FOR A HEAVY METAL EXPOSURE VIOLATION OR OSHA CITATION FOR

INADEQUATE HOUSEKEEPING WILL FORWARD CITATION DOCUMENTATION TO THE

LEGAL COUNSEL AND TO THE USACRC OSHA EVENTS EMAIL ADDRESS:

USARMY.RUCKER.HQDA-SECARMY.MBX.SAFE-OSHA@MAIL.MIL.

3.D.3. (U) USACRC WILL MAINTAIN RECORDS OF OSHA CITATIONS AND/OR

VIOLATIONS AND WILL FORWARD ASSOCIATED DOCUMENTS TO THE MEDCOM AND

ASSISTANT SECRETARY OF THE ARMY INSTALLATIONS, ENERGY AND ENVIRONMENT

(ASA (IE&E)) POCS LISTED IN COMMAND AND SIGNAL, PARAGRAPH 5.

3.D.4. (U) DIRECT LIAISON IS AUTHORIZED (DIRLAUTH) AT ALL LEVELS TO

ACCOMPLISH EXORD TASKS, KEEPING CHAINS OF COMMAND INFORMED.

4. (U) SUSTAINMENT. NOT USED.

5. (U) COMMAND AND SIGNAL.

5.A. (U) COMMAND. NOT USED.

5.B. (U) SIGNAL.

5.B.1. (U) USACRC POC: MR. GREGORY SCHNEIDER, COMM: 703-697-1267,

EMAIL: GREGORY.S.SCHNEIDER.CIV@MAIL.MIL.

5.B.2. (U) OFFICE OF THE SURGEON GENERAL (OTSG)/MEDCOM, DCS-PH, PUBLIC

HEALTH DIRECTORATE, INDUSTRIAL HYGIENE POC: MAJ PATRICIA PASSMAN,

COMM: 703-681-8382, EMAIL: PATRICIA.H.PASSMAN.MIL@MAIL.MIL.

5.B.3. (U) APHC INDUSTRIAL HYGIENE POC: MRS. SUSAN HOLT, COMM: 410-

417-2835, EMAIL: SUSAN.G.HOLT.CIV@MAIL.MIL.

5.B.4. (U) APHC RISK COMMUNICATION PROJECT MANAGER POC: MS. ANDREA

CLARK, COMM: 410-436-7709, EMAIL: ANDREA.K.CLARK.CIV@MAIL.MIL.

5.B.5. (U) USACRC HAZARD COMMUNICATION PROJECT MANAGER POC: MR. WESLEY

HEDMAN, COMM: 334-255-0235, EMAIL: WESLEY.E.HEDMAN.CIV@MAIL.MIL.

5.B.6.(U) ASA (IE&E) DIRECTOR FOR SAFETY AND OCCUPATIONAL HEALTH POC:

MS. MARJORIE MCDONALD, COMM: 703-697-3123, EMAIL:

MARJORIE.J.MCDONALD.CIV@MAIL.MIL.

6. (U) THE EXPIRATION DATE OF THIS MESSAGE IS 31 DECEMBER 2022, UNLESS

FORMALLY RESCINDED OR SUPERSEDED.

ATTACHMENTS:

ANNEX E (PROTECTION).

APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION).

TAB A (KNOWN DOEHRS IH HEAVY METAL WORKPLACES) TO APPENDIX 7

(SAFETY) TO ANNEX E (PROTECTION).

TAB B (KNOWN DOEHRS-IH BERYLLIUM WORKPLACES) TO APPENDIX 7 (SAFETY) TO

ANNEX E (PROTECTION).

TAB C (WORKSHEET - ARMY WORKSITES WITH HEAVY METAL EXPOSURES) TO

APPENDIX 7 (SAFETY) TO ANNEX E (PROTECTION).

TAB D (EXAMPLE HOUSEKEEPING PLAN BEST PRACTICES TEMPLATE) TO APPENDIX

7 (SAFETY) TO ANNEX E (PROTECTION). ANNEX F (SUSTAINMENT).

APPENDIX 3 (ARMY HEALTH SYSTEM SUPPORT) TO ANNEX F (SUSTAINMENT). TAB

A (INDUSTRIAL HYGIENE INHALABLE SAMPLING PLAN SCHEDULE FOR CR/CR

COMPOUNDS, APHC-LED) TO APPENDIX 3 (ARMY HEALTH SYSTEM SUPPORT) TO

ANNEX F (SUSTAINMENT).

TAB B (INDUSTRIAL HYGIENE INHALABLE SAMPLING PLAN SCHEDULE FOR CR/CR

COMPOUNDS, INSTALLATION IH PROGRAM-LED) TO APPENDIX 3 (ARMY HEALTH

SYSTEM SUPPORT) TO ANNEX F (SUSTAINMENT).