Fair Q. The designated substance requirements aren’t changing, other than with regard to standardization of the medical surveillance rules, which will now be the same for all designated substances. What I meant by requiring separate policies, is accounting for the special requirements that apply when the substance you’re protecting workers from is one of the designated substances, e.g., medical surveillance, emergency response procedures for ethylene oxide, the additional elements required for coke oven emissions programs (e.g., for charging and coking), etc. Again, those requirements aren’t changing. The reason I mention separate policies, though, is that like it is now, you won’t be able to cover all of these requirements in a single Bio & Chem Agents Policy like the Model we provided–unless it was a much longer policy. Although the Model would be the foundation for such a policy, you’d have to adapt to deal with each of the designated substances to which your workers are exposed.
Hope that makes sense. This can get kinda’ confusing, I know. Thanks. Glenn
