W911SA-22-Q-3082 - Attachment 3 - HQDA_EXORD_031-19.pdf

UNCLAS F O U O

HQDA EXORD 031-19 ENSURING SAFE AND HEALTHY WORKPLACES THAT GENERATE OR HAVE POTENTIAL FOR EXPOSURE TO HEAVY METALS HQDA EXORD 031-19 Annex E (Protection) (final).docx HQDA EXORD 031-19 App 7 (Safety) to Annex E (final).docx HQDA EXORD 031-19 Tab A (Known DOEHRS-IH Heavy Metal Workplaces) to App 7 to Annex E (final).xlsx HQDA EXORD 031-19 Tab B (Known DOEHRS-IH Beryllium Workplaces) to App 7 to Annex E (final).xlsx HQDA EXORD 031-19 Tab C (Phase 2 Worksheet - Army Worksites with Heavy Metal Exposures) to App 7 to Annex E (final).xlsx HQDA EXORD 031-19 Tab D (Example Housekeeping Plan Best Practices Template to App 7 to Annex E (final).docx HQDA EXORD 031-19 Annex F (Sustainment) (final).docx HQDA EXORD 031-19 App 3 (Army Health System Support) to Annex F (final).docx HQDA EXORD 031-19 Tab A (Industrial Hygiene Inhalable Sampling Plan Schedule) to App 3 to Annex F (final).docx HQDA EXORD 031-19 Tab B (Industrial Hygiene Inhalable Sampling Plan Schedule) to App 3 to Annex F (final).docx

Originator: DA WASHINGTON DC

DTG: 062222Z Sep 19 Precedence: P DAC: General

To: ARLINGTON NATIONAL CEMETERY ARLINGTON VA, ARNG NGB COMOPS ARLINGTON VA, ARNG NGB J3 JOC WASHINGTON DC, ARNGRC ARLINGTON VA, ARNGRC WATCH ARLINGTON VA, CDR 5 ARMY NORTH AOC FT SAM HOUSTON TX, CDR ARMY FUTURES COMMAND AUSTIN TX, CDR ATEC ABERDEEN PROVING GROUND MD, CDR FORSCOM DCS G3 CENTRAL TASKING DIV FT BRAGG NC, CDR FORSCOM DCS G3 CURRENT OPS FT BRAGG NC, CDR FORSCOM DCS G3 WATCH OFFICER FT BRAGG NC, CDR MDW J3 FT MCNAIR DC, CDR MDW JFHQ-NCR FT MCNAIR DC, CDR NETCOM 9THSC FT HUACHUCA AZ, CDR TRADOC CG FT EUSTIS VA, CDR TRADOC DCS G-3-5-7 OPNS CTR FT EUSTIS VA, CDR USAR NORTH FT SAM HOUSTON TX, CDR USARCENT SHAW AFB SC, CDR USAREUR WIESBADEN GE, CDR USASOC COMMAND CENTER FT BRAGG NC, CDR USASOC FT BRAGG NC, CDR USASOC MESSAGE CENTER FT BRAGG NC, CDR1STIO FT BELVOIR VA, CDR3RD ARMY USARCENT WATCH OFFICER SHAW AFB SC, CDRAMC REDSTONE ARSENAL AL, CDRFORSCOM FT BRAGG NC, CDRHRC G3 DCSOPS FT KNOX KY, CDRINSCOM FT BELVOIR VA, CDRINSCOMIOC FT BELVOIR VA, CDRMDW WASHINGTON DC, CDRUSACE WASHINGTON DC, CDRUSACIDC FT BELVOIR VA, CDRUSACYBER FT BELVOIR VA, CDRUSACYBER G3 FT BELVOIR VA, CDRUSACYBER G33 FT BELVOIR VA, CDRUSAEIGHT G3 CUROPS SEOUL KOR, CDRUSAEIGHT SEOUL KOR, CDRUSAFRICA VICENZA IT, CDRUSAMEDCOM FT SAM HOUSTON TX, CDRUSARC G33 READ FT BRAGG NC, CDRUSARCYBER WATCH OFFICER FT BELVOIR VA, CDRUSARPAC CG FT SHAFTER HI, CDRUSARPAC FT SHAFTER HI, COMDT USAWC CARLISLE BARRACKS PA, HQ IMCOM FT SAM HOUSTON TX, HQ INSCOM IOC FT BELVOIR VA, HQ SDDC CMD GROUP SCOTT AFB IL, HQ SDDC OPS MSG CNTR SCOTT AFB IL, HQ USARSO FT SAM HOUSTON TX, HQ USARSO G3 FT SAM HOUSTON TX, HQDA ARMY STAFF WASHINGTON DC, HQDA CSA WASHINGTON DC, HQDA EXEC OFFICE WASHINGTON DC, HQDA IMCOM OPS DIV WASHINGTON DC, HQDA SEC ARMY WASHINGTON DC, HQDA SECRETARIAT WASHINGTON DC, HQDA SURG GEN WASHINGTON DC, MEDCOM HQ EOC FT SAM HOUSTON TX, NETCOM G3 CURRENT OPS FT HUACHUCA AZ, NGB WASHINGTON DC, SMDC ARSTRAT CG ARLINGTON VA, SMDC ARSTRAT G3 ARLINGTON VA, SUPERINTENDENT USMA WEST POINT NY, SURGEON GEN FALLS CHURCH VA, USAR AROC FT BRAGG NC, USAR CMD GRP FT BRAGG NC, USAR DCS G33 OPERATIONS FT BRAGG NC, USARCENT G3 FWD, USARPAC COMMAND CENTER FT SHAFTER HI, HQDA VDAS WASHINGTON DC, HQDA ASA IE WASHINGTON DC

CC: HQDA AOC DAMO ODO OPS AND CONT PLANS WASHINGTON DC, HQDA AOC G3 DAMO CAT OPSWATCH WASHINGTON DC, HQDA AOC G3

DAMO OD DIR OPS READ AND MOB WASHINGTON DC

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 WITH THIS ACCOUNTING

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,

AND AFTER IDENTIFICATION OF WORKSITES, IMPLEMENT ACTIONS TO MITIGATE,

EDUCATE, PREVENT, AND ELIMINATE HEAVY METAL EXPOSURES IAW ARMY POLICY

WITHIN FIVE (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 FIVE (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 ISSUANCE OF THIS EXORD. 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 HIERARCHY OF CONTROLS, WITHIN

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

DEVELOP AN IMPACT STATEMENT THAT CAPTURES COST AND OTHER IMPACTS OF

IMPLEMENTING 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 5.B. 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

RECOMMENDATIONS FOR IMPLEMENTATION THAT ARE RESOURCE INFORMED AND

INCLUDE UPDATED TIMELINES FOR FULL COMPLIANCE WITH ARMY POLICY.

PENDING SENIOR LEADER GUIDANCE, A FULL IMPLEMENTATION PLAN WILL BE

DEVELOPED TO ELIMINATE OR REDUCE WORKPLACE EXPOSURES TO HEAVY METALS.

PHASE 4 WILL BE COMPLETE WHEN IMPLEMENTATION 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.

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 TO

ANNEX E.

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

E.

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

APPENDIX 7 TO ANNEX E.

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

APPENDIX 7 TO ANNEX E.

- 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 TO ANNEX F.

- TAB B (INDUSTRIAL HYGIENE INHALABLE SAMPLING PLAN SCHEDULE FOR

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

F.

BT

#4696