Airborne Monitoring Programs: Ensuring Compliance with OSHA Permissible Exposure Limits
Industrial and manufacturing environments involve processes that may generate airborne particulates or vapors depending on the specific operation. To ensure workplace conditions remain within established safety thresholds, employers routinely implement personal exposure monitoring programs as part of their workplace health and safety practices. These monitoring programs help determine compliance with standards established by the U.S. Occupational Safety and Health Administration (OSHA). To evaluate worker risk, OSHA established Permissible Exposure Limits (PELs) or regulatory limits that define the maximum allowable concentration of hazardous substances in workplace air during a specified time period, typically an eight-hour time-weighted average (TWA). These science-based limits provide a regulatory framework for evaluating exposures and implementing appropriate controls to protect worker health.
In recent years, several OSHA enforcement actions and major lawsuits have highlighted the consequences of failing to monitor and control workplace hazards. Most of these cases had both legal and financial implications for employers. To emphasize my point above, below are two industry examples that illustrate why comprehensive airborne monitoring programs are an important component of workplace health and safety management:
In 2023, a battery manufacturing facility in Georgia was cited for exposing employees to unsafe levels of lead and U.S. Department of Labor investigators determined that employees were exposed to airborne lead levels with exposures as high as 471 micrograms per cubic meter of air, far exceeding OSHA’s PEL of 50 micrograms per cubic meter averaged over an eight-hour work shift. Because of a lack of due diligence, the Georgia based company faced more than $160,000 in penalties stemming from multiple violations related to lead exposure and inadequate controls.
In 2024, a jury in Los Angeles awarded $52.4 million in damages to a countertop fabricator after he developed “accelerated silicosis” from exposure to crystalline silica while cutting stone slabs. The jury found that his employer along with several artificial stone manufacturers were liable for failing to warn about the hazards associated with silica dust.
The California silicosis case was considered a landmark verdict because it highlighted the severe health risks associated with silica exposure while also holding manufacturers culpable for not protecting workers from foreseeable hazards. These examples reinforce the importance of conducting thorough exposure assessments and maintaining effective monitoring programs. Aligning workplace practices with science-based exposure management practices and regulatory requirements helps protect worker health while reducing the risk of regulatory citations, financial liability, and reputational damage.
There are countless examples that support the need for personal exposure monitoring and exposure monitoring programs but what does industry need to do in order to protect their employees while protecting themselves from liability? Well, below is a quick list of action items that every manufacturer should be following:
1. Demonstrate Your Regulatory Compliance
OSHA requires that employers ensure employee exposures are below applicable PELs. Personal sampling provides the documented legal evidence necessary to demonstrate your compliance.
2. Identify High-Risk Employee Based Tasks
Airborne exposures can often vary significantly depending on the type of job being performed. For example, welding can generate substantially higher contaminant levels (fumes) than other surrounding operations. Personal monitoring helps identify which tasks and processes create the greatest exposure risks, allowing organizations to prioritize reduction efforts and engineering controls.
3. Evaluate Your Engineering Controls
OSHA emphasizes the hierarchy of controls, which prioritizes the following engineering solutions:
- Local exhaust ventilation
- Process enclosure
- Substitution of hazardous materials
- Automation of dusty processes
Exposure monitoring allows industrial hygienists to determine whether these controls effectively reduce airborne contaminants below regulatory limits.
4. Protecting Worker Health
Long-term exposures can cause irreversible damage and diseases that may not appear until years after exposures occur. Regular monitoring helps organizations detect exposure exceedances early and implement corrective measures before workers develop serious health effects.
Conclusion
Personal exposure monitoring is a critical component of occupational health and safety programs in industrial and manufacturing environments and companies that invest in exposure assessment programs not only protect worker health but also reduce regulatory and legal risks.
Ultimately, exposure monitoring is not simply a compliance requirement, it is an essential tool for building safer, more resilient manufacturing operations!
About the Author
Scott L. Dombrowski is a Senior Associate with Patriot Engineering PC With 26+ years working as an industrial hygienist. He works closely with organizations in industrial and manufacturing environments to provide environmental testing and compliance support, including industrial hygiene services, personal air monitoring and regulatory compliance assessments. He may be reached at sdombrowski@patrioteng.com.
Patriot Engineering PC is an MMA Industry Member and has been an MMA member company since January 2026. Visit online: www.patrioteng.com.