REPRODUCTIVE & DEVELOPMENTAL HEALTH PROTECTION PROGRAM

1.0 INTRODUCTION

2.0 BACKGROUND ON REPRODUCTIVE HAZARDS

2.1 Exposure Limits
2.1.1 Occupational Safety and Health Administration
2.1.2 California Department of Health Services (DHS)

3.0 RESPONSIBILITIES

3.1 EH&S
3.2 Supervisor/PI
3.3 Employee
3.4 Occupational Health Physician
3.5 Human Resources

4.0 METHODS OF EXPOSURE CONTROL

5.0 COMMUNICATION/TRAINING/EDUCATION

5.1 Confidential Conferences
5.2 Safety Trainings

6.0 DECLARATION OF PREGNANCY

6.1 Sequence of Events

7.0 ANTI-DISCRIMINATION POLICY

1.0 INTRODUCTION

As a complex research and medical university, employees and students at Stanford University may work with agents known or suspected of being capable of posing a hazard to human reproduction.

"It is the policy of Stanford University to maintain a safe and healthy work environment. Managers and supervisors are responsible for the establishment and maintenance of good health and safety practices."1

The objective of the Reproductive & Developmental Health Protection Program is to:

• protect the reproductive health of all employees, students, and visitors from occupational exposures to substances (chemical, biological, radiological or physical) known or suspected of being capable of posing a hazard to human reproduction;
• identify potential reproductive and developmental hazards and implement appropriate exposure control measures.

2.0 BACKGROUND ON REPRODUCTIVE & DEVELOPMENTAL HAZARDS

2.1 General

Reproductive Toxicity - Adverse effects on the health of the reproductive organs, endocrine system, or gametes (egg or sperm) from exposure to an exogenous agent. May result in effects such as menstrual dysfunction, impaired fertility, feminization/masculinization, or inability to maintain a pregnancy.

Developmental Toxicity - Adverse effects on the developing organism that may occur anytime from conception to sexual maturity. Effects may include spontaneous abortion, structural or functional defects, low birth weight, or effects that may appear later in life.

The underlying issue with reproductive and developmental toxicity is that short-term exposures during a critical period can result in long-term health effects. Thus it is very important to recognize potential risks and intervene early.

2.2 Exposure Limits

A developing fetus may also be adversely affected by exposures lower than those generally considered safe for adults. For this reason Stanford University's goal is to keep exposures as low as reasonably achievable to minimize the potential for reproductive or developmental hazards. Stanford complies with all established regulatory exposure limits.

2.2.1 California Occupational Safety and Health Administration (Cal/OSHA)

• Although the Occupational Safety and Health Administration (OSHA) has established occupational exposure limits for numerous hazardous materials, there are no general standards governing reproductive hazards.
• Cal/ OSHA has issued a limited number of standards (e.g., Lead, Dibromochlorpropane, and Ethylene Oxide) that acknowledge and provide partial protection from reproductive risks to these specific chemicals.

2.2.2 California Department of Health Services (DHS)

• The DHS has an occupational radiation dose limit for the whole body of 5 rem per year (for adult workers).
• The limit for the embryo/fetus of a declared pregnant worker during the entire gestation period is 0.5 rem. Further, the National Council on Radiation Protection and Measurements (NCRP) recommends a monthly equivalent dose limit of 0.05 rem to the embryo/fetus once the pregnancy is known.

3.0 RESPONSIBILITIES

3.1 Department of Environmental Health and Safety

3.1.1 Occupational Health & Safety Program

• Develop, implement and administer Stanford University's Reproductive & Developmental Health Protection Program.
• Evaluate areas where potential chemical, biological, or physical reproductive hazards exist and determine extent of potential exposures.
• Recommend proper procedures to reduce workplace exposures to reproductive hazards (i.e., engineering controls, use of PPE, job rotation, etc.).
• Provide Tier II training on chemical, physical and biological reproductive hazards in the work area, including proper use of personal protective equipment, safety devices, etc. and other methods of decreasing exposure.
• Provide information regarding reproductive hazards in the workplace.
• Provide specific radiation safety training, including information on declaration of pregnancy for radiological issues.
• For declared pregnancies, implement measures to achieve the lower exposure limit (0.5 rem to embryo/fetus during entire gestation period) and conduct dose monitoring.
• Manage written declaration of pregnancies for workers exposed to radiological hazards.
• See Radiation Safety Manual 1997 p. I.25 for more information.

3.2 Supervisors

Supervisors have the primary responsibility for implementation of the Reproductive & Developmental Health Protection Program in their work area. This involves:

• Maintaining an inventory of chemical, biological, and radiological agents used in the work area.
• Being familiar with the hazards associated with these agents - including reproductive or developmental hazards.
• Providing operation-specific training (Tier III) to employees and students.
• Coordinating with EH&S regarding physician's workplace restrictions.
• Control exposures to potential hazards to acceptable levels through
  • process or equipment engineering design
  • administrative procedures
  • use of personal protective equipment

3.3 Employees and Students

The employees and students are responsible for:

• Complying with all university policies and Cal/OSHA requirements and regulations to assure a safe and healthful working environment.
• Utilizing protective clothing and equipment provided to decrease exposure to hazards in the work area.
• Reporting to supervisor unsafe or hazardous working conditions.
• Completing the Reproductive and Developmental Health Hazard Questionnaire and providing to EH&S.
• Consulting with their personal physician regarding reproductive and developmental health issues.
• Submitting any physician certifications regarding work restrictions or limitations to their supervisor.

3.4 Occupational Health Physician

The occupational physician is responsible for:

• When contacted by EH&S, evaluating the potential reproductive and developmental hazards to the employee/student by:
  • reviewing the employee's Reproductive & Developmental Health Hazard Questionnaire;
  • reviewing reports or evaluations conducted by EH&S of the employee's work area and operations.
• Determining necessary workplace restrictions or modifications in consultation with the employee and the employee's physician.

3.5 Human Resources

The employee's human resources office is responsible for:

• Assisting the supervisor to review workplace limitations and/or modifications indicated by the occupational physician, personal physician, and/or EH&S.

4.0 METHODS OF CONTROL

The most desirable method of managing risk to pregnancy and reproductive health of employees/students is to control exposure from chemical, biological, and physical agents to acceptable levels for all workers through a combination of:

• Substitution of a less hazardous agent;
• Installation of effective engineering controls, such as enclosure and local exhaust ventilation;
• Use of safer work practices;
• Appropriate use of personal protective equipment.

Administrative controls include:

• Postponing procedures/operations that may pose developmental risk until after the pregnancy.
• Using job rotation to reduce exposures.
• Transferring the employee to a job which does not involve exposure to reproductive or developmental hazards.

5.0 COMMUNICATION/TRAINING/EDUCATION

5.1 Confidential Conferences

Individuals may receive safety information about reproductive or developmental hazards posed by potential chemical/radiological/biological/physical exposures anytime from EH&S without declaring actual, suspected, or planned pregnancy. Safety information includes:

• Copy of this program and its attachments
• Answers about the individual's general workplace hazards
• Information on work practices to reduce exposures

It is acknowledged that some individual's may choose to maintain their pregnancy status as personally confidential for a time. However, the involvement of the supervisors is an essential part of the University's safety management program. Every employee is urged to involve their supervisor in all work-related discussions.

5.2 Safety Trainings

• The University promotes early recognition of potential reproductive hazards so that employees/students can seek appropriate assistance. To that end, information about this Program is promulgated to individuals during chemical, radiological, and biological safety trainings provided by EH&S to schools and departments.
• Supervisors provide Tier III training (i.e., operation-specific processes).

6.0 DECLARATION OF PREGNANCY

If an individual wishes the University to be involved in helping protect her embryo/fetus, and for radiation workers (keeping exposures to the fetus below the 0.5 rem limit), she must declare her actual, suspected, or intended pregnancy to her supervisor and EH&S.

6.1 Sequence of Events

1. Employee informs EH&S and supervisor that she is pregnant, suspects she is pregnant, or intending a pregnancy. Also completes and submits to the EH&S Health Physics Program a written Declaration of Pregnancy(2) if she wishes the 0.5 rem limit to apply. Individuals may contact EH&S for a confidential consultation prior to declaration if they so wish.
2. Employee completes the Reproductive And Developmental Health Hazard Questionnaire. EH&S conducts an evaluation and health risk assessment of work area based on questionnaire results and operations performed in work area.
3. EH&S provides a copy of evaluation, including recommended methods to control exposures, to supervisor and employee.
4. Employee takes EH&S evaluation results to her personal physician for discussion. EH&S may also involve Stanford University's occupational health care provider. As needed the occupational physician will consult with the employee's personal physician regarding possible work restrictions.
5. After consulting with EH&S and the personal physician, the occupational health physician will recommend any restrictions or limitations on employee/student's work activities if needed.
6. Employee provides physician's written limitations to supervisor. Supervisor responsible for contacting EH&S regarding any work restrictions they receive.
7. Supervisor forwards any work restrictions to the local human resources officer.
8. EH&S provides Tier II training if not already obtained by employee. Supervisor is responsible for Tier III training (i.e., operation-specific processes).
9. Supervisor complies with recommendations given by physician and EH&S to protect employee and embryo/fetus. EH&S, supervisor, and/or employee may seek assistance from Stanford University's Human Resources for assistance in implementing recommendations.

7.0 ANTI-DISCRIMINATION POLICY

• The University does not discriminate by sex, race, disability, age, or any other protected characteristic in the hiring, assignment or promotion of employees because of actual or perceived differences in susceptibility to reproductive effects caused by toxic substances.
• However, the transfer of a particular employee or employees may be necessary in some cases in order to remove an employee or employees from exposure to toxic substances at levels above those allowed by applicable regulations. Such transfers will only be considered where materials substitution, additional engineering controls, and safe work practices are technologically unfeasible or ineffective in reducing exposures to levels prescribed by applicable regulations.
• If employee or employees must be removed from exposure, the group of employees affected will be defined as narrowly as possible, taking into account the risks of the particular substance, while providing for the greatest possible element of employee choice consistent with adequate protection of their reproductive health and health of their offspring.
• No employee removed from exposure will suffer any loss of earnings.

1 Stanford University Administrative Guide Memo 25.5

2 Radiation Safety Manual, 1997 - p. IV.34

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