Page 26

4

Data Utilization and Records Management

Data generated by workplace monitoring programs and activities are immediately useful as real-time, or near-real-time, indicators of exposure to chemicals of concern and as operational tools for mitigating risk and facilitating operating decisions. In addition, monitoring data collected and stored in a readily accessible form can provide a basis for a variety of other analyses. For example, cumulative monitoring data can be used to document the frequency and magnitude of chemical releases and/or exposures.

DATA REQUIREMENTS

Several CSDP documents require the establishment and maintenance of on-site databases. PMCD's Monitoring Concept Plan requires that personnel maintain documentation of all monitoring activities during operations, including daily logs of air monitoring, equipment calibration, maintenance, inspections, and agent responses, as well as sample records, standard operating procedures for air monitoring and laboratory analysis, authorizing signatures, and other documentation (U.S. Army, 1997a).

The ACAMS laboratory is required to transmit the electronic file and the results of data collection to the laboratory project officer. Routine ACAMS parameters are tracked and maintained by the disposal facility laboratory according to site-specific protocols. The same is true for DAAMS analyses.

In addition to a site-specific agent monitoring plan and related documentation, the Monitoring Concept Plan requires that the laboratory at each site develop a site-specific monitoring plan for the continuous emission monitoring system (CEMS) and specifies the documentation and data parameters this plan must address (U.S. Army, 1997a). For instance, at TOCDF, the CEMS monitoring plan addresses continuous monitoring of carbon monoxide, carbon dioxide, and oxygen in exhaust sampled from each incinerator/furnace; NOx emissions are only sampled from exhaust from the common stack (EG&G, 1994). Routine CEMS data are generated and maintained in accordance with records requirements in the PMCD Quality Assurance Program Plan (QAPP) for all of the CEMS at each facility (EG&G, 1994). Data parameters are forwarded to the laboratory project officer upon request.

The CSDP Generic Medical Support Plan states that the CSDP medical director is the custodian of medical records for CSDP workers (U.S. Army, 1998a). The records, which are considered private and confidential information, must be complete enough to provide data for use in health maintenance and treatment, epidemiological studies, and government and contractor program evaluations. Medical records must identify the patient, support the diagnosis, justify the treatment, and document follow-up care or referrals. Record keeping for employees in the nerve agent or mustard agent medical surveillance programs is described in the Army pamphlets Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to Nerve Agents GA, GB, GD and VX and Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to Mustard Agents H, HD and HT (U.S. Army 1990, 1991). Screening of medical



The National Academies | 500 Fifth St. N.W. | Washington, D.C. 20001
Copyright © National Academy of Sciences. All rights reserved.
Terms of Use and Privacy Statement



Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.

OCR for page 26
Page 26 4 Data Utilization and Records Management Data generated by workplace monitoring programs and activities are immediately useful as real-time, or near-real-time, indicators of exposure to chemicals of concern and as operational tools for mitigating risk and facilitating operating decisions. In addition, monitoring data collected and stored in a readily accessible form can provide a basis for a variety of other analyses. For example, cumulative monitoring data can be used to document the frequency and magnitude of chemical releases and/or exposures. DATA REQUIREMENTS Several CSDP documents require the establishment and maintenance of on-site databases. PMCD's Monitoring Concept Plan requires that personnel maintain documentation of all monitoring activities during operations, including daily logs of air monitoring, equipment calibration, maintenance, inspections, and agent responses, as well as sample records, standard operating procedures for air monitoring and laboratory analysis, authorizing signatures, and other documentation (U.S. Army, 1997a). The ACAMS laboratory is required to transmit the electronic file and the results of data collection to the laboratory project officer. Routine ACAMS parameters are tracked and maintained by the disposal facility laboratory according to site-specific protocols. The same is true for DAAMS analyses. In addition to a site-specific agent monitoring plan and related documentation, the Monitoring Concept Plan requires that the laboratory at each site develop a site-specific monitoring plan for the continuous emission monitoring system (CEMS) and specifies the documentation and data parameters this plan must address (U.S. Army, 1997a). For instance, at TOCDF, the CEMS monitoring plan addresses continuous monitoring of carbon monoxide, carbon dioxide, and oxygen in exhaust sampled from each incinerator/furnace; NOx emissions are only sampled from exhaust from the common stack (EG&G, 1994). Routine CEMS data are generated and maintained in accordance with records requirements in the PMCD Quality Assurance Program Plan (QAPP) for all of the CEMS at each facility (EG&G, 1994). Data parameters are forwarded to the laboratory project officer upon request. The CSDP Generic Medical Support Plan states that the CSDP medical director is the custodian of medical records for CSDP workers (U.S. Army, 1998a). The records, which are considered private and confidential information, must be complete enough to provide data for use in health maintenance and treatment, epidemiological studies, and government and contractor program evaluations. Medical records must identify the patient, support the diagnosis, justify the treatment, and document follow-up care or referrals. Record keeping for employees in the nerve agent or mustard agent medical surveillance programs is described in the Army pamphlets Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to Nerve Agents GA, GB, GD and VX and Occupational Health Guidelines for the Evaluation and Control of Occupational Exposure to Mustard Agents H, HD and HT (U.S. Army 1990, 1991). Screening of medical

OCR for page 26
Page 27 records for the chemical personnel reliability program is based on Army regulation Nuclear and Chemical Weapon and Materiel Chemical Surety and procedures described in Army regulation Medical Services Medical Record Administration and Health Care Documentation (U.S. Army, 1995; 1999e). Employee exposure records are kept in compliance with OSHA Standard 29 CFR 1910.1020, Access to Employee Exposure and Medical Records. The PMCD Generic Medical Implementation Plan stresses the importance of accurate record keeping for an efficient and reliable health education and surveillance program (U.S. Army, 1999b). Each employee's health history, including confidential information, is used to track his or her health status. Therefore, records must be legible, accurate, and professional. Access to records is restricted to health care professionals, the employee and his/her designee, and appropriate certifying officials. Information in individual medical records can be released only after a signed and dated “Authorization for Release of Medical Records” has been received by the medical staff. Information concerning an employee's reliability and ability to perform work safely may be conveyed to the employee's supervisor and the certifying official without a signed written consent form. Finally, PMCD work permits must be issued for all entries into chemical agent hazard areas and areas designated “Permit Required Confined Spaces.” Work permits, which must identify the individual and the work to be performed, are reviewed by operations maintenance and safety personnel and approved by the shift manager. Special monitoring may be required, and records of entries and monitoring must be kept for 30 years beyond the last day of employment or the closure date of the facility. The extensive data collected via ACAMS and DAAMS are captured and stored in electronic form with total redundancy. However, they can only be immediately accessed at the operating site, making analyses at the programmatic level difficult. As additional sites become operational, the capability of reviewing and analyzing agent monitoring data from several or all sites at the programmatic level could be useful. Data generated by nonagent CEMS instruments are recorded both on chart recorders and electronically for transmission to the process data acquisition recording (PDAR) system for recording on magnetic disks (EG&G, 1994). Data are archived both as hard copy (e.g., instrument service logbooks, recorder charts, calibration forms) and electronically on disk. At TOCDF, hard copies are maintained by the Monitoring Branch for three months and then sent to the TOCDF Document Control Center, where they are stored until the Utah Department of Environmental Quality gives its permission for the data to be recorded on microfiche and transferred to a government archive. Electronic data are maintained on disks in the plant control room for 45 days. Disks are then transferred to the Document Control Center, where they are stored until approval is received to transfer them to a government archive (EG&G, 1994). As additional sites become operational, it may be useful for all emissions data to be accessible electronically for analysis on a program-wide level. Current management of data from worker monitoring is governed by a number of guidelines and regulations, the purpose of which is to ensure that a thorough exposure and treatment history is maintained for all CSDP employees. A review of the guidelines and requirements, and discussions with PMCD medical staff, indicated that most employee monitoring records are maintained in paper form at the employment site during active employment but are moved to archival records storage facilities when the employee leaves the site. Once records have been archived, they can only be recovered through a laborious manual search according to the employee's name. Therefore, it would be difficult to use worker monitoring data for program-level analyses or other studies. CORRELATING TIME/ACTIVITY AND CHEMICAL CONCENTRATION RECORDS One method of reconstructing worker exposure to a harmful chemical is to correlate location data from shift duty records, hazardous operations records maintained by the industrial hygiene program, and toxic area entry work records with area airborne agent or industrial hygiene workplace survey records. Indeed, correlating activity pattern data with measurements or estimates of chemical, biological, or other environmental contaminants has been identified by the NRC as an effective method of estimating the level of exposure to harmful substances sustained by deployed U.S. military personnel (NRC, 2000c). However, retrospective analyses of this type are difficult or impossible to conduct if activity and chemical monitoring records are not archived or are only available in paper files. Reconstructing the exposure history of an individual worker who was employed at two or more chemical disposal facilities, pos-

OCR for page 26
Page 28 sibly managed by different contractors using different record forms and content, could be a daunting task. Electronic records with a common format could make retrospective analyses much more feasible. EMPLOYEE HEALTH INFORMATION AND WORKPLACE MONITORING DATA Health effects studies, such as epidemiological studies, utilizing employee health records require that the records be complete, well maintained, and readily accessible, and that they contain comparable information. These requirements apply to records for all sites. Therefore, automation and centralization of the records is practically a necessity. Records from multiple CSDP sites with multiple contractors at each site may be kept in a variety of forms and according to a variety of procedures. Standardized forms and procedures for all sites would ensure that records could be used for health effects studies. Epidemiological studies on occupationally related diseases are most meaningful when employee exposure data are available for correlation with the health data. Complete, high-quality health and exposure data would help ensure the validity of the study results. STANDARDS FOR ELECTRONIC DATABASES If the Army decides to create a programwide electronic database for tracking worker monitoring, guidance provided in three National Standards published by the American Society for Testing and Materials could be applicable: E 1769-95 Standard Guide for Properties of Electronic Health Records and Record Systems E 1902-97 Standard Guide for Management of the Confidentiality and Security of Dictation, Transcription, and Transcribed Health Records E 1384-99 Standard Guide for Content and Structure of the Electronic Health Record A database based on these standards could significantly raise the quality of the program-wide database, reduce start-up problems, and facilitate CSDP's attainment of worker protection standards.