Data Utilization and Records Management - Occupational Health and Workplace Monitoring at Chemical Agent Disposal Facilities - page 25

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 Medi-
cal Record Administration and Health Care Documen-
tation (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 surveil-
lance 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 certi-
fying 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 con-
cerning an employee's reliability and ability to perform
work safely may be conveyed to the employee's super-
visor and the certifying official without a signed writ-
ten consent form.
Finally, PMCD work permits must be issued for all
entries into chemical agent hazard areas and areas des-
ignated “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 im-
mediately accessed at the operating site, making analy-
ses 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, cali-

bration forms) and electronically on disk. At TOCDF,
hard copies are maintained by the Monitoring Branch
for three months and then sent to the TOCDF Docu-
ment 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 monitor-
ing is governed by a number of guidelines and regula-
tions, 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 re-
quirements, and discussions with PMCD medical staff,
indicated that most employee monitoring records are
maintained in paper form at the employment site dur-
ing 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 accord-
ing to the employee's name. Therefore, it would be dif-
ficult 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 hy-
giene workplace survey records. Indeed, correlating
activity pattern data with measurements or estimates of
chemical, biological, or other environmental contami-
nants 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 person-
nel (NRC, 2000c). However, retrospective analyses of
this type are difficult or impossible to conduct if activ-
ity and chemical monitoring records are not archived
or are only available in paper files. Reconstructing the
exposure history of an individual worker who was em-
ployed at two or more chemical disposal facilities, pos-