Elements of an Exposure Control Plan

What is an Exposure Control Plan (ECP) and its Purpose?

An Exposure Control Plan (ECP) is a crucial component of an organization's chemical or health and safety management system. It serves as a guideline, outlining measures to prevent worker exposures. Depending on your location, regulatory authorities may mandate the creation of one or more exposure control plans tailored to your organization and worksite. These documents detail potential exposure hazards that workers may encounter during routine and non-routine tasks, along with the corresponding protective measures.

What Information Should Be Included in an Exposure Control Plan?

There are many common elements for a successful exposure control plan. Specific elements referenced in legislation include: 

  • Statement of purpose 
  • Responsibilities of the owner, prime, employer, designated resources (i.e. H&S Manager), supervisors, and workers 
  • Health hazards and risk categories for each product in your worksite 
  • Written work procedures and practices 
  • Required engineering controls, administrative safety controls, and measures 
  • Exact personal protective equipment (PPE) requirements 
  • Hygiene facilities and decontamination procedures 
  • Education and training 
  • Annual review process 
  • Implementation processes (recommended and often requested by regulators)

The elements above are common to many successful exposure control plans. Exposure control plans must be customized to incorporate your workplace hazards and risks, operating procedures, worksite tasks, JSAs, organization standards (i.e. Benzene, H2S, Decontamination), and Industrial Hygiene monitoring results.

Exposure Control Plan Sections in Detail

What should you consider when developing your exposure control plan? The following 14 sections should be considered when authoring an exposure control plan:

Section 1 - Purpose and Responsibilities

This section needs to provide an overview of the purpose of the exposure control plan and responsibilities by authority groups and individuals. Responsibilities range from requirements to make your ECP implementation successful to completing an annual review. This is common for all exposure control plans. It should align with your company health and safety management systems and/or programs.

Exposure Control Plan Recommendations for Owners/Prime Contractors/Employers

  1. Ensure the exposure control plan is practical and can be used and implemented to protect workers. 
  2. Ensure less toxic chemical substitutes are selected when possible. 
  3. Ensure controls required to implement an exposure control plan are readily available. 
  4. Ensure that operations and the exposure control plan at a minimum meet or exceeds the regulatory requirements. 
  5. Provide SDSs to the operations for products introduced with time to assess chemical hazards at the site. 
  6. Consider your contractors and how controls around chemical hazards will be communicated. 
  7. Plan and schedule for evaluation and review of the exposure control plan. Especially when new chemical hazards are introduced.

Recommendations for Managers/Supervisors

  1. Ensure the exposure control plan is being used and implemented as per your operations and regulatory requirements. 
  2. Ensure the exposure control plan and supporting materials are available. 
  3. Ensure materials are readily available to fully implement and maintain this exposure control plan are readily available. For example: Tools, equipment, PPE and training 
  4. Provide adequate instruction to workers on the hazards of exposure to chemicals during operations, maintenance and transport. 
  5. Ensure selection and implementation of the appropriate control measures.

Recommendations for Workers

  1. Understand and adhere to the exposure controls when using chemicals in the workplace. 
  2. Understand all aspects of the exposure control plan prior to commencing work activities. 
  3. Understand and use the assigned protective equipment in an effective and safe manner including how to don and don off personal protective equipment, proper fit, and proper functionality. 
  4. Follow established work procedures. Report any unsafe conditions, unsafe acts, incidents of chemical exposure, or possible signs or symptoms of chemical exposure as outlined in the safety data sheet (https://www.chemscape.com/resources/sds-essentials)(SDS). 
  5. Provide adequate instruction to workers on the hazards of exposure to chemicals during operations, maintenance and transport. 
  6. Ensure selection and implementation of the appropriate control measures.

Recommendations for Workers

  1. Understand and adhere to the exposure controls when using chemicals in the workplace. 
  2. Understand all aspects of the exposure control plan prior to commencing work activities. 
  3. Understand and use the assigned protective equipment in an effective and safe manner including how to don and don off personal protective equipment, proper fit, and proper functionality. 
  4. Follow established work procedures. Report any unsafe conditions, unsafe acts, incidents of chemical exposure, or possible signs or symptoms of chemical exposure as outlined in the safety data sheet (SDS).

Exposure Control Plan Considerations for Contractors

  1. Contractors should also be included in the exposure control plan and acknowledge that they understand the requirements of the ECP prior to commencing work activities. 
  2. Contractors should understand signs or symptoms of illness from exposure to chemicals as outlined in the SDS and know who they can report to in the event of any exposure. 
  3. The use, handling and storage of chemicals on the jobsite must be clarified between owners, prime contractors, contractors, subcontractors, and suppliers. 

Section 2 - Hazard Identification and Assessment

This section of the exposure control plan describes the hazards and associated risks. An exposure control plan addresses the worksite hazards; everything from your chemical inventory, processes, maintenance activities, as well as physical hazards that may pose an exposure risk.

You should also think about certain categories of chemicals. The manufactured product category also includes those products considered as ‘production’. In the oil and gas industry (), these could be products that from wellbores and/or plants that are potentially hazardous.

Examples include:

  • Crude oils 
  • Sour crude 
  • Natural gas 
  • Condensate 
  • Produced water 
  • Benzene 
  • CO2 
  • Methane

Process Additives

Process additives are chemical products added to a process to perform a function within that process to obtain a desired result.  

Examples include:

  • Acids 
  • Catalysts 
  • water treatment additives 
  • H2S scavengers

Shop Supplies

Shop Supplies is another category of chemicals that are used for operating or maintenance activities or other tasks/ uses on site. Examples include welding rods, blasting sands, and cleaners. 

When examining your process additives and shop supplies see if anything can be substituted. This is a good application of the hierarchy of controls.

Accurate Chemical Inventory

An accurate chemical inventory and having up-to-date safety data sheets is the foundation for hazard assessment. The ability to control the hazards and resulting risk is dependent on the accuracy of the chemical inventory. Other sources of information include produced wellbore fluids, sampling and lab analysis. Risks cannot be managed unless all chemical hazards are known.

Consider Non-Routine Situations

Finally, it is important to remember non-routine situations in your chemical hazard identification and assessment like breaking of containment either intentionally to take samples or for routine maintenance or unintentional breaks of containment (e.g. spills, fire and emergency situations).

Section 3 – Health Hazards from Chemical Exposure

At this point you need to ask yourself - do you have a strong understanding of the health hazards of your chemicals? Do you understand the potential routes of entry (breathing, skin absorption, skin contact and swallowing) for chemical exposure and potential harm? 

Chemicals can cause many different types of harm, ranging from mild skin irritation to cancer. The effects of hazardous chemicals may be seen immediately after contact (e.g. chemical burn) or many years after the exposure (e.g. lung cancer following exposure to asbestos). Some effects appear following a single short exposure (e.g. infrequent use of a chemical) or longer- term exposures (e.g. daily use of a chemical in the workplace). 

Different chemicals affect the body in different ways. Chemicals that are sensitizers, reproductive hazards, and carcinogens have extreme hazards and risks and have special precautions.

Risk of Exposure Consideration Factors

There are several factors that must be taken into consideration for assessing the risk of chemical exposure including: 

Risk of chemical exposure factors – Chemscape

Inhalation hazards should be of greatest concern and require unique controls to manage their risk. Skin absorption the next area of concern followed by ingestion of chemicals. 

Section 4 – Risk Assessment

Risks cannot be managed unless workplace hazards are identified. A complete hazard inventory is necessary. Evaluating hazards and risk can be done using various methods. One viable method to assess all your chemicals is control banding. Control banding objectively divides the hazards into predetermined categories then uses standard measures of quantity and dustiness or volatility to generate a repeatable risk assessment and predict a control method. The International Labour Organizations (ILO) Chemical Control Toolkit has a control banding process that is used around the world as a basis for chemical hazard management. Outputs are in the following control approaches: natural ventilation, local exhaust ventilation, containment and seek expert advice.

What are the risks of the workplace?

Assess the workplace environment and know the risks. Several factors should be considered including the quantity, time, and relative dustiness.

What are the Exposure Limits?

A solid understanding of what exposure limits are, needs to be part of the risk assessment. 

Based on the preceding information, risk of exposure is calculated then engineering controls are recommended. The best controls should be used to eliminate or reduce the hazard. This can include:

  1. Engineering controls 
  2. Administrative controls 
  3. Personal protective equipment

Health and injury effects from chemical exposure vary depending on the chemical constituents of the products used. Potential health and injury effects from overexposure/exposure to chemicals are outlined in each SDS. The hazard identification assessment and risk assessment of each workplace will determine what chemical and ingredients are harmful to health, may cause injury, and potentially impact the environment.

Section 5 – Exposure Limits

Exposure limits outline the acceptable standards for a worker's exposure to hazardous chemical substances. Exposure limits are established by competent international authorities. They are adopted and enforced by local regulatory authorities. Occupational Exposure Limits (OELs) restrict the amount and length of time a worker is exposed to airborne concentrations of hazardous biological or chemical agents. There can be significant jurisdictional differences between countries and even provinces/states. 

There are roughly 800 OELs but there are many more chemicals in use without OELS. In Canada, there are roughly 25,000 chemicals registered on the Canadian Domestic Substance List. In the USA, there are roughly 80,000 chemicals registered on the US EPA TSCA Inventory. Control banding is a practical option for chemicals without established safe limits (OELs).

Section 6 - Controls

At this point in the exposure control plan, organizations need to record the controls they have in place for the chemical hazards they have identified. They should understand how to incorporate the hierarchy of control to guide recommendations on the most effective means of harm reduction. The hierarchy of control is often the cornerstone within regulations, policy statements, health and safety and chemical management systems. Having a knowledge of each level and in what circumstances they should be used is important to effective chemical management. These controls need to be incorporated into work processes and operating standards.

Section 7 – Hygiene Facilities and Decontamination

In this section the requirements for decontamination and hygiene facilities are based on the chemicals you are working with. Having proper facilities onsite and procedures for decontamination need to be outlined. Does your organization have a decontamination standard?

Section 8 – Industrial Hygiene Monitoring

Industrial Hygiene Monitoring Plans (IHMP) may be required to quantify exposures to hazardous substances. This needs to be done by competent Industrial Hygiene professionals and the results incorporated into/ added to the ECP.

Section 9 - Designated Substances

Designated substances and highly hazardous chemicals on your site must be identified and managed in this section. Highly hazardous chemicals are defined in different jurisdictions some with very specific controls and others with the need to substitute a product of lower hazard.

Section 10 – Health Monitoring

Health monitoring is required for certain designated substances. This may include biological monitoring, such as lung function testing, chest x-rays or analysis of bodily fluids.

Section 11 – Education and Training

For an exposure control plan to be successful a plan for education and training needs to be developed. Think of everyone who needs to be trained including leaders, front line workers, and support workers. Training should include the range from the review of the specific exposure control plan to the chemicals being managed under the exposure control plan (i.e. Benzene, H2S) to the selection, safe use and maintenance of your PPE and respiratory protective equipment (RPE).

Section 12 – Exposure Control Plan Focus

Depending on the chemical hazards of your operations a focus on specific hazards and risks unique to your operations may need to be developed. Focus tabs help organizations clearly communicate the hazards, risks, controls and measures that must be implemented. This may include details on specific hazards, specific controls, site specific decontamination facilities and training needs for the hazards of concern.

Section 13 – Implementation

Implementation plan needs to be included to describe how supervisors and workers are to be trained, how the exposure control plan will be integrated into planning, communication, and day-to-day operations. A key in the implementation plan is worker engagement; therefore, the tools and guidance documents must be direct, specific and understandable. Consider using graphics to help communicate the message.

Section 14 - Annual Review

An annual review of your exposure control plan must be completed. Consider the inputs from safety committees, workers, incident /event investigations, site exposure control plan audits, and area/personal monitor(s) data. Complete your chemical inventory and approval review as part of the annual review.

Develop an ECP with Chemscape Safety Technologies

Chemscape helps organizations develop Exposure Control Plans using Chemical Hazard Assessment and Management Program (CHAMP) and in-house Industrial Hygiene Services. Chemscape’s CHAMP system automates an Exposure Control Plans based on your chemical inventory. It also supports successful implementation with tools and training aids for worker education and awareness. Our unique tools including inventory management, SmartChart® Hazard Communication, workplace labels, mobile app and safety training videos; work together to deliver a complete chemical handling program. Chemscape’s Exposure Control Plans have been approved by regulators and CHAMP produces an Exposure Control Plan that not only satisfies your compliance needs but builds a foundation for best-in-class chemical management. Speak to our occupational health experts to learn more about how CHAMP can be the foundation for your chemical management and exposure control plans. 

Elevate the level of occupational health standards for your company.