As a complex research/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.” The objective of the Reproductive Health Protection Program is to:
- Protect the reproductive health of male and female employees and students 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 hazards and implement appropriate control measures.
2.0 BACKGROUND ON REPRODUCTIVE & DEVELOPMENTAL HAZARDS
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 such as cancer.
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.
A developing fetus may also be adversely affected by exposures lower than those considered safe for adults. Thus, exposures must be kept as low as reasonably achievable to minimize reproductive health hazards.
More detailed information regarding reproductive hazards is presented in the external links section.
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.
2.2 U.S NUCLEAR REGULATORY AGENCY
The U.S. Nuclear Regulatory Agency established an occupational radiation dose limit for the whole body of 5 rem per year (for adult workers).
A lower limit exists for the embryo/fetus – 0.5 rem for the embryo/fetus during the entire gestation period. 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.
3.1 DEPARTMENT OF ENVIRONMENTAL HEALTH AND SAFETY
3.1.1 OCCUPATIONAL HEALTH & SAFETY PROGRAM
Develop, implement and administer Stanford University’s Reproductive & Developmental Hazards Program.
Compile a list of known or suspected reproductive & developmental toxins.
Manage written declaration of pregnancies for workers exposed to chemical, biological, or physical hazards.
Evaluate areas where potential chemical, biological (in conjunction with Biosafety Officer), or physical reproductive hazards exist and determine extent of potential exposures.
Recommend proper procedures to reduce workplace exposures to reproductive hazards (e.g., 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, and other methods of decreasing exposure.
Provide information regarding reproductive hazards in the workplace.
3.1.2 HEALTH PHYSICS
Provide Tier II radiation protection training, including information on declaration of pregnancy for radiological risks.
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.
Evaluate options if dose to embryo/fetus would exceed 0.5 rem during entire gestation period.
Manage written declaration of pregnancies for workers exposed to radiological hazards.
Supervisors have the primary responsibility for implementation of the Reproductive & Developmental Hazards Program in their work area. This involves:
- Providing inventory of chemicals, biological agents, etc. used in the work area.
- Providing Tier III training (i.e., operation-specific processes) to employees/students.
- Controlling exposures to potential hazards to acceptable levels through:
- process or equipment engineering designs
- work practices arraignments (e.g., decreased exposure times, restriction from specific exposures, etc.)
- use of personal protective equipment
- Ensuring compliance with Physician’s instructions regarding workplace restrictions.
The employee/student is responsible to:
- Notify EH&S if they become pregnant (they may also contact EH&S if they are planning to become pregnant for consultative information).
- Complete the reproductive health hazard questionnaire and email the completed questionnaire to EH&S Occupational Health & Safety Program via secure email (add “Secure:” to the subject line of the email) to the recipient specified in the reproductive health hazard questionnaire.
- Obtain from physician, restrictions or limitation on exposure to hazards in the workplace.
- Submit to supervisor physician restriction and limitations.
- Comply with all campus and Cal/OSHA requirements/regulations to assure a safe and healthful working environment.
- Utilize protective clothing and equipment provided to decrease exposure to hazards in the work area.
- Report to supervisor or EH&S unsafe or hazardous working conditions.
3.4 OCCUPATIONAL HEALTH PHYSICIAN
The occupational physician is responsible for:
- When contacted by EH&S, evaluating the potential reproductive hazards of the pregnant employee/student by:
- reviewing the employee’s Reproductive Health Questionnaire;
- reviewing reports or evaluations conducted by EH&S of the employee’s work area and operations.
- In conjunction with the employee/student’s personal physician, advising the employee on any limitations or modifications to her work.
3.5 PERSONAL HEALTH PHYSICIAN
The employee/student’s personal health physician is responsible for:
- Determining whether a worker has any special medical conditions that make him/her unusually susceptible to any workplace reproductive hazards.
- Working with the Occupational Health Physician and EH&S to develop workplace limitations and/or modifications to the pregnant employee, based on potential or actual chemical, biological, radiological or physical exposures.
3.6 HUMAN RESOURCES
The employee’s human resources office is responsible for:
- Assisting the supervisor to follow-through on workplace limitations and/or modifications indicated by the occupational 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, radiological, 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, with retention of salary, protection of seniority and benefits, and the right to return to his/her original, or substantially similar, job.
5.1 CONFIDENTIAL CONFERENCES
Employees/students 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:
- a copy of this program and its attachments
- answers about the employee/student’s general workplace hazards
- information on work practices to reduce exposures
- It is acknowledged that some employees 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. Every potentially pregnant employee is urged to involve their supervisor in all work-related situations.
5.2 SAFETY TRAININGS
The University promotes early recognition of potential reproductive hazards so that employees/students can seek assistance for management and controls. To that end, information about this Program is promulgated to employees/students 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
When an employee/student wishes the University to be involved in protecting 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 in writing.
The University’s responsibility to protect the embryo/fetus begins only when the employee/student provides written notice of her actual, suspected, or intended pregnancy to EH&S.
6.1 SEQUENCE OF EVENTS
- Employee informs her PI/Supervisor and EH&S that she is pregnant, suspects she is pregnant, or intending a pregnancy.
- Employee completes the reproductive health hazard questionnaire. The questionnaire can be found online in the Stanford Reproductive and Developmental Health Protection Program website: https://ehs.stanford.edu/forms-tools/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.
- EH&S provides a copy of evaluation, including recommended methods to control exposures, to supervisor and employee.
- Employee takes EH&S evaluation results to her personal physician for discussion. Stanford University Occupational Health Center may also be involved in the review of certain cases. As needed, the occupational physician will consult with the employee’s personal physician regarding any work restrictions.
- 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.
- Employee provides written limitations to supervisor prepared by physician, if any.
- Supervisor forwards any physician limitations to the local human resources officer.
- EH&S provides Tier II training if not already obtained by employee. Supervisor is responsible for Tier III training (i.e., operation-specific processes).
- 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 will not discriminate by sex, race or age in the hiring or promotion of employees because of alleged differences in susceptibility to reproductive effects caused by toxic substances.
No employee removed from exposure will suffer any loss of earnings.
While the transfer of certain male or female employees may be necessary in some cases, it will only be considered where substitution, additional engineering controls and safer work practices are technologically infeasible or ineffective in reducing exposure to desired levels.
If employees must be removed from exposure, then 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