Exposure Index

NTNU is required to keep an index of employees who are exposed to certain hazardous physical, chemical or biological strains (factors) in their work. The purpose of this is, among other things, to look after the health of employees and students. These guidelines state which hazardous factors are subject to registration, who should be registered, why we have to keep the index and how the registration is performed.

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Responsibilities and tasks #

The leader should provide information about the index to all employees and students who perform work where they can be exposed to substances subject to registration. Employees and students should familiarize themselves with the contents of these guidelines.

Registration in Eco Exposure #

NTNU has elected to use Eco Exposure as its exposure index. Eco Exposure is a separate system module in NTNU's substance index, ECO Archive. Both Eco Archive and Eco Exposure are provided by the company EcoOnline. See also Safety data sheets.

The registration process #

Log into the substance index, click 'Administration' in the menu on the left side, and click 'Exposure'. 

In order to register exposure, you must have registered your national identity number/D-number first. Click "Eco Archive" (top left of the screen) - "My Page" - "Administration" - "Settings" (Personal ID number) to register. 

Do you need help with the registration process? Please contact EcoOnline Support by phone (33 01 68 20) or the system administrators at the HSE Division.

Registration access: Employees and students who want to register an exposure (for themselves or others) have to get access to Eco Exposure. Contact your substance index contact person (in Norwegian) if you need access to the index.

NTNU's general recommendation: everyone should register personally, including students. The academic supervisor (lecturer) is responsible for informing students about the index and how to register.

Each unit can decide how to solve the registration process. Example: Selected persons can collect information and perform the registration of groups of employees/students. See instructions on how to record exposure of student groups in connection with laboratory courses. 

Guest lecturers and others visiting NTNU for a short period of time:NTNU recommends that the unit selects an employee to collect information and perform the registration for the guests.

The units must document how they inform employees and students about the index and how they perform the registration.

Important information:

  • To be able to register an exposure, it must be associated with a safety data sheet or information sheet. Safety data sheets and information sheets that are already in the database are easily retrieved.
  • Where this type of documentation is missing, information sheets can be created using Local Publisher. Contact your substance index contact person (in Norwegian) to obtain a license for Local Publisher.

Who should be registered? #

Employees and students should be registered in accordance with the requirements for the different exposure factors, as stated in the paragraphs below.

Carcinogenic and mutagenic chemicals #

According to the regulations (chapter 31), NTNU is required to keep an index of employees and students who are or might be exposed to carcinogenic or mutagenic (harmful to genes) chemicals. NTNU interprets this to mean that all employees and students who are working with such chemicals have to be registered, provided that exposure cannot be ruled out. If exposure can be ruled out, this must be documented. Employees and students who do not personally work with the chemicals should not be registered, unless there is a nonconformity where everyone in the room might be exposed.

In practice, this means that employees and students who work with chemicals labelled with at least one of the risk or hazard statements stated in table 1 should be registered.

Table 1 shows the risk and hazard statements that require registration (cf. the Regulations concerning the performance of work § 31-1 in Norwegian):

Other hazard statements (for instance H341 – Suspected to cause genetic damage or H351 – Suspected to cause cancer) do NOT require registration. You can find a detailed explanation of this in the Regulations concerning the performance of work, §31-1a.

Other work and situations that require registration:

  • Work described in the Regulations concerning of the performance of work, §31-1b.
  • Tasks where employees might come in contact with carcinogenic/mutagenic chemicals and are only protected by personal protective equipment. Example: Changing filters in ventilating ducts connected to fume cupboards where chemicals with statements listed in table 1 are used.
  • Nonconformities (spills, «blowouts», ventilation failure etc.) that cause everyone present to be exposed, also persons who are not working directly with the chemicals in question.
  • Work with other substances/factors that are labelled as carcinogenic in safety data sheets or in the Regulations concerning Action and Limit valuesappendix 1 (list of boundary values for pollution of the work atmosphere).

The index should include the employee's name, personal identification number, position, place of work, information about which hazardous substances the employee is working with, how the work is performed (including work processes and safety measures like using special ventilation, personal protective equipment etc.), in which form and concentrations the substances occur, and time and duration of the work. The index should only contain this information.

Lead #

NTNU must keep an index (chapter 31) of all employees and students who work with lead or lead compounds, unless exposure can be ruled out. If exposure can be ruled out, this must be documented.

The index should include the employee's name, personal identification number, position, place of work, how the work is performed (including work processes and safety measures like using special ventilation, personal protective equipment etc.), in which form and concentrations the lead or lead compounds occur, and time and duration of the work. The index should only contain this information.

Biological factors #

In accordance with regulations (chapter 31), NTNU must keep an index of employees and students who are or have been exposed to biological factors in infection risk groups 3 or 4. NTNU interprets this to mean that all employees and students who are working with biological factors in these infection risk groups have to be registered, provided that exposure cannot be ruled out. If exposure can be ruled out, this must be documented. Employees and students who do not personally work with these biological factors should not be registered, unless there is a nonconformity where everyone in the room might be exposed.

Other work and situations that require registration:

  • Tasks where employees could come into contact with biological factors in infection risk groups 3 or 4 while only wearing personal protective equipment for protection. Example: Changing filters in ventilation ducts connected to fume cupboards where biological factors in infection risk groups 3 or 4 have been used.
  • Nonconformities (spills, «blowouts», ventilation failure etc.) that cause everyone present to be exposed, also persons who are not working directly with the biological factors in question.

See the Regulations concerning Action and Limit values, appendix 2, for a list of biological factors in infection risk groups 3 and 4.

According to the regulation, the index should contain information about the type of work performed and, if possible, the biological factor the employees have worked with. The index should also contain information about exposure in connection with accidents. By using Eco Exposure, the employee's name, personal identification number, position, place of work, how the work is performed (including work processes and safety measures like using special ventilation, personal protective equipment etc.) and time and duration of the work will also be recorded.

Dust containing asbestos fibres #

NTNU must keep an index (chapter 31) of all employees and students who need to undergo a medical examination due to exposure or possible exposure to asbestos fibres while working for NTNU (in accordance with the Regulations concerning the performance of work § 4-13).

NTNU does not have any employees or students who work with asbestos on a daily basis (for instance, all asbestos removal work is performed by external companies). Nonconformities can cause exposure and require registration. If NTNU employees or students come in contact with asbestos, this will most likely be incidental and with amounts that are not large enough for it to be considered as exposure. The need for registration can be assessed in connection with targeted medical examinations. See the Regulations concerning of the performance of work § 31-2 (in Norwegian) for information on which information should be recorded in these cases.

Hazardous substances in rock work #

NTNU must keep an index (chapter 31) of employees and students who are exposed to hazardous substances during rock work. NTNU employees do not perform rock work as defined in the Regulations concerning the performance of work §1-4, pt. 7. However, some employees perform laboratory work with types of rock that can cause exposure to hazardous substances with properties that require registration (e.g. quartz, asbestos, ionising radiation). Nonconformities can cause exposure and require registration. In order to determine whether registration is necessary, employees and students need up-to-date knowledge on which substances they handle and which types of exposure this can cause.

The index should contain information about the employee's name, age, position, place of work and type of work, as well as the type, degree and duration of exposure. By using Eco Exposure, how the work is performed (including work processes and safety measures like using special ventilation, personal protective equipment etc.) and time and duration of the work will also be recorded.

Ionising radiation #

NTNU must keep an index (chapter 31) of employees and students who work with ionising radiation, unless exposure can be ruled out. If exposure can be ruled out, this must be documented. This implies the following: 

  • When working with controllable ionising radioactive sources (i.e. sources that can be switched on/off or put in a closed position) under circumstances where it can be documented that exposure beyond normal background levels is ruled out, it is not mandatory to keep an index of the employees and students involved.
  • When working with open radioactive sources, an index including all employees and students involved must be kept.

Employees who do not work with ionising radiation, but who might be exposed beyond normal background levels, must be included in the index.

The index should contain the employee's name, address, personal identification number, current work, time of employment and individually measured radiation doses. By using Eco Exposure, how the work is performed (including work processes and safety measures like using special ventilation, personal protective equipment etc.) and time and duration of the work will also be recorded.

Type of exposure and regulations #

In accordance with the Regulations concerning the performance of work, chapter 31, NTNU must keep an index of employees who are exposed to the following factors:

  • Carcinogenic chemicals
  • Mutagenic chemicals (chemicals that are harmful to genes)
  • Lead and lead compounds
  • Hazardous substances in rock work
  • Ionising radiation
  • Biological factors in infection risk groups 3 or 4
  • Dust containing asbestos fibres

The registration requirements are different depending on the factor in question, and are detailed under Who should be registered?

Work performed as practical training of students, for the purpose of education or research, is subject to the provisions of the Working Environment Act when the work takes place in conditions that might cause danger to life and health, cf. the Regulation of the application of the Working Environment Act related to persons who are not employees, § 1 (in Norwegian).

This applies, for instance, when the education includes the use of substances that might cause danger to life and health. In these cases, the students' rights and obligations in terms of systematic HSE work are the same as for employees, and the students should also be registered.

NTNU is subject to the duty of substitution as stated in the Working Environment Act, §4-5 second paragraph, and should actively seek to substitute hazardous chemicals and biological materials when possible. This includes NTNU avoiding the use of substances/materials that require registration.

Why the need for an exposure index? #

The exposure index has several purposes:

  • It provides an overview of the employees' use of hazardous factors. On the basis of this information, the unit can initiate measures to prevent exposure.
  • It creates a foundation for offering health care to employees and students.
  • It provides documentation of exposure that can cause occupational injury or illness.
  • It helps NTNU fulfil its duty as employer to survey and follow up the working environment.

Access to the exposure index #

Employees and students who are registered in an exposure index should be made aware of this and have access to their own registered information.
Information that is not of a personal nature should be made available to the employees.

The index should also be available to the health and safety staff, the safety deputy, members of the Working Environment Committee, other persons who are responsible for health and safety in the workplace, and the Norwegian Labour Inspection Authority (the Regulations concerning the performance of work §31-6).

At NTNU, the availability requirements are solved as follows:

  • Employees and students get access to their own information, regardless of whether they register personally.
  • The occupational physician and the corporate nurse at Occupational Health Services have access to all information in the exposure index.
  • The system administrators at the HSE Division (central substance index contact persons, two employees) have access to all the information in the exposure index.
  • The senior safety representative (HVO) has access to all the information in the index. Other safety deputies can get relevant information upon request to the HSE Section.
  • Members of the Working Environment Committee and the Norwegian Labour Inspection Authority can get relevant information upon request to the HSE Section.
  • "Others with special responsibility for the work environment", for example the employer or the HSE coordinator, can get relevant information upon request to the HSE Section.

How long should the information be stored? #

There are different requirements in terms of how long the information about each employee/student should be stored:

Exposure to biological factors:

  • The index must be kept for at least 10 years following conclusion of the exposure. In the following instances, the index must be kept for up to 40 years following the last known exposure that can lead to infection:
    • exposure to biological factors that are known to induce persistent or hidden infections,
    • exposure to biological factors that, based on current knowledge, cannot be detected before the illness breaks out years later,
    • exposure to biological factors that have a particularly long incubation period before the illness breaks out,
    • exposure to biological factors that cause an illness that might reappear after a long period of time in spite of treatment, or exposure to biological factors that can cause serious sequelae in the long term.

Exposure to carcinogenic chemicals, mutagenic chemicals, lead and lead compounds, hazardous substances in rock work, dust containing asbestos fibres, ionising radiation:

  • At least 60 years after conclusion of the exposure.

If the activities that require an exposure index are discontinued, the index should be transferred to the Norwegian Labour Inspection Authority.

FAQ #

Is everyone who works with carcinogenic/mutagenic chemicals, lead or lead compounds, ionising radiation or biological factors in infection risk groups 3 or 4 required to register, regardless of their type of work, duration of work and working conditions?

According to NTNU's interpretation of the regulations, everyone who works with the factors above should be registered. In some cases, the correct course of action could be to avoid registration – provided that it can be documented with certainty that the employee/student does not come in contact with the factors in question (for instance if the work is performed in a closed system). The HSE Division can assist with interpretation of the regulations in these situations.

The safety data sheet label of an undiluted chemical indicates that it requires registration, but I work with diluting the chemical in its pure form. Do I have to register?

Labels and other information in safety data sheets of pure chemicals do not necessarily apply to diluted versions of the same chemicals. If diluted versions are produced, these must be accompanied by information sheets (or possibly safety data sheets) with labels that determine whether you should register or not. See instructions on when to make information sheets and how to label diluted substances.

I work with a substance that is labelled with a red warning triangle in the substance index. Do I have to register?

Not necessarily, only if the substances you are handling are labelled with one or more of the hazard statements listed in table 1. A red warning triangle in itself is not a direct indication that the substance requires registration.

I use a personal dosimeter in relation to work with ionising radiation sources. The results from the personal dosimeter must be reported to and recorded by The Norwegian Radiation Protection Authority, cf. the Radiation Protection Regulation §33. Should I also register my work with ionising radiation sources in Eco Exposure?

Yes, you should.

 When I’m about to add a chemical to my exposure registration, I thought I could only choose between the chemicals labeled with hazard codes H340, H350 or H350i. However, I can also choose chemicals labeled with H341 and H351. Is there a reason why it’s like this? I though we only had to register exposure for the chemicals labeled with H340, H350 and H350i?

 It’s correct that the chemicals labeled with hazard code H341 and H351 show up, in addition to H340/H350/H350i. Like you mentioned, its only the chemicals labeled with the hazard code H340/H350/H350i we are required to register in the exposure index. But as we have chosen to label the chemicals marked with H341/H351 with a red warning triangle, these chemicals will also show in the exposure register. We want everyone to be aware that even though these chemicals are “only” marked as “suspected of causing genetic defects/suspected of causing cancer”, it does indicate that they are in fact chemicals that may cause adverse health effects. Also, it is not unthinkable that these chemicals will be upgraded to H340/H350/H350i.

 To register an exposure I have to select a workplace. Is it possible to select a building as a workplace, and under comments describe in which room the work/exposure took place? This might be useful when the location is a bit unclear because of all the sub-locations with fridges and freezers. 

 It is possible to select a building as a workplace, and then describe the accurate location in the comments. The downside to this would be that all the chemicals in all the other locations in the building will also be present on the list over chemicals you can choose to register in the exposure index. Most likely there will also be multiple safety sheets for the same chemical. Because of this it might be harder to find the right safety sheet for the different exposures. 

A possible workaround to this could be to choose a sub-location placed a bit closer to the accurate location in the tree of locations as your workplace, instead of the whole building, and then describe the accurate workplace in the comment-field. This will reduce the number of safety sheets of chemicals that can be added to the exposure index.

 I work with ionizing radiation sources surrounded by a shield containing lead. Do I register exposure for both ionizing radiation sources and lead?

 Regulations concerning the performance of work, chapter 31-1, say that employees/students working with lead or lead compounds have to register exposure unless exposure is ruled out. When handling radiation shields with lead compounds, consider:

1. Can the usage of the shielding be considered as “work with lead or lead compounds”?

2. Can it be documented that there have not been any exposure to lead or lead compounds?

Regulations concerning the performance or work, chapter 31-1, also say that the usage of personal protective equipment shall not count when assessing whether the employees should be registered in the exposure index, even though when the correct usage of PPE would give satisfactory protection.

 To register an exposure in Eco Exposure there has to be a safety sheet or information sheet for the specific substance in the substance index. Does this apply for ionizing radiation sources as well?

 Yes, it does. If you have received a safety data sheet from the supplier of the ionizing radiation source, it has to be added to the substance index. If the radiation source does not come with its own SDS, you have to make an information sheet. NTNUs central radiation protection coordinator have considered making “general information sheets” for radiation sources, but concluded that it it best if the information sheets are made by the specific unit and for the specific radiation source.

 Isn’t there a regulation that says that the location of radiation sources must kept from public access? If I put a safety data sheet in the substance index, won’t this be open for public access?

 The Norwegian law of publicity (Offentleglova) §24, section three says that the location of radiation sources must be kept from public access because access can facilitate criminality, expose individuals to danger or facilitate environmental crime. According to a lawyer in the staff of the Director of organization, NTNUs substance index is not considered as open to public access, as long as only students and employees have access to this system. However, it is recommended that locations where safety data sheets of radiation sources are present have discrete names. If necessary, employees who are administrators of the substance index, can limit the visibility of the safety data sheets even further.

 Someone who’s not an NTNU employee does some work in NTNUs labs, and is working with substances subjected to registration in the exposure index. Should the person be registered in NTNUs exposure index?

 According to the regulations concerning the performance of work, 31-1, 1-3, it is the employers responsibility that the regulations are followed. If the person isn’t employed in NTNUs service, the person will not be affected by NTNUs exposure index. The working environment act 2-2, duties of the employer towards persons other than own employees, is about a sound working environment, not about an exposure index.

 Will it make it harder to get a life insurance when you are in the exposure index?

 There is no reason to assume that being in the exposure index will make it difficult to get a life insurance. The insurance companies cannot access the exposure index if you don’t grant them access. You have to grant them access to your health information from third parties, in this case your employer. The insurance company usually ask for permission to collect information from your GP. The patient health condition will be documented, as a main rule, in the form of processed information, such as a doctors certificate from the doctor treating you. The insurance law § 8-1 state clearly that the consent have to be limited to the information needed for each step in the insurance case. When it comes to the exposure index, it shall not contain more information than those motioned in the regulation, especially not personal information, such as medical information.

 I only find safety data sheets in English when I try to register  in the exposure index. How do I find safety data sheets in Norwegian? 

 Unfortunately only safety data sheets in Norwegian will appear when you follow the steps to register an exposure. To find safety data sheets in Norwegian, do the following: 

Follow the steps to register an exposure until you come to the window shown below. Click "Local search" in the menu to the left:Registrere

When you have clicked "Local search", a search window will appear in the bottom part of the screen. The picture below shows what will appear if you use "Advanced search" (you can also use "Search). Refine the serch as you want (Chemical name, CAS number, location, etc.):

Select "Norwegian" in the "Language" box. and click "Search". A new window will appear in the bottom part of the screen and you can select the correct safety data sheet by clicking on the green button to the right:

Søkeresultat 

Help #

NTNU regulations #

Legislation #

Contact #

Approval/signature #

Approved by the Director of HSE – 14 December 2015 – HMSR65E

In order to register exposure, you must have registered your birth number / D number first. To register the birth number / D number; Click "Eco Archive" (top left of the screen) - "My Page" - "Administration" - "Settings".

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