Industrial Hygiene in Construction

When clients ask me to assist in choosing a product, I try to recommend a product with the least dangerous chemicals in it. I understand this isn’t always possible. However, I try to emphasize the worst case health scenarios and leave it up to the company to decide how to proceed. There are reasons to use a hazardous (to your health) product.

However, here are some considerations when choosing a hazardous product:

• more hazard vs less cost
• more hazard vs less time actually using product
• more hazard vs cost of PPE
• more hazard vs what the spec says
• more hazard vs different hazard
• more hazard vs terrible health effect/potential
• more hazard vs perception by others on the project (by the GC/public/subcontractors, media, neighbors)

Another issue with chemicals is the names and nomenclature. There are so many different names, common names, chemical names, and sub names of products – it gets confusing.

One solution called, ChemHat.org, offers a unique way of considering other chemicals. Plug in the CAS# (Chemical Abstract Number) or the name, and it gives you some ideas.

Another alternative in choosing the best product is to ask.

• Ask your industrial hygienist if this product is safe and/or are there concerns?
• Ask the GC if this is the only product that can be used
• Ask the architect if there are alternatives that are equally effective
• Ask the manufacturer if they have comparable products without the XXX hazard

Background: A new client recently had an OSHA health inspection (industrial hygiene). He received citations stemming from overexposures(they found levels above the PELs) to airborne particulates.

The company wondered what to do next. Here were my suggestions:

• Fix the problem. You will need to comply and assure that your employees aren’t overexposed. Even if the inspection made you upset, use your energy to make the situation right. Focus your energy on removing the hazard, not complaining about how you were treated.
  • Engineer the problem out. Remove the hazard. If not,
  • Change your policies so no one is further overexposed. If you can’t fix it by the this, or the above method, then,
  • Provide personal protective equipment to affected employees.
• Request the full inspection package. – this will include the officer’s field notes, interview questions, observations and sampling methodology.
  • look through these documents carefully
  • keep them for your records
•  Informally appeal the citations.
  • at the appeal show them you have complied/changed
  • ask for a reduction in fines (it never hurts to ask)
  • ask to group the citations together – instead of citation 1 item 1a, 1b, item 2, etc. ask to narrow it down to just one
  • bring any additional information which supports your side and/or the changes you’ve made (including training docs, programs, policies, etc.)
• Resample the areas.
  • make significant changes to these areas. Then,
  • hire an industrial hygienist to perform additional sampling in these areas
  • ask them to document the changes you have made to reduce the exposures
  • review this with your safety committee & those affected

As you might be aware, there is a loudness of noise which your ears cannot be protected against. Your body’s system of preventing the sound waves from entering your ear are just too much for it to handle. As the noise (sound pressure) hits your inner ear the bones convert the physical energy (noise) into a chemical & neurological process so you are able to hear. Ear plugs and ear muffs are not sufficient enough to protect against the amount of noise exposure.

However! Sometime in the future we might have a pill to prevent this type of hearing loss.

Researchers have found that the chemicals, D-methionine, ebselen & N-acetylcysteine, battle chemical stress on your ears.  We are still a long way from being able to take a pill to avoid hearing loss. They must go through more testing and the FDA approvals.

But, isn’t that cool!?

If you operate a ready-mix plant and have concrete trucks, you are aware of this process. Once a year (hopefully, only once) a person must climb into the drum of the ready-mix truck and chip off excess concrete. What happen during regular use, is that some concrete hardens, which usually sets-up over and around the blades. Access into the drum is by either the 3×4 hole in the side, or down the chute.

Yes, it is a confined space (def’n: 1. large enough to enter, 2. not designed for occupancy, and 3. limited entry/egress).

Here are a list of the possible hazards:

• silica dust (from chipping concrete)
• noise exposure
• hazardous atmosphere (curing concrete uses up oxygen, which we DO need BTW)
• slipping hazard (drum is round inside)
• heat stress (if you’re trying to do this activity in the summer)
• eye hazard (chipping)
• electrical hazard (if you’re using water & have an electric hammer)
• lock out / tag out (if the truck drives away, or if the barrel starts turning)

There are many resources available (see below). Some things to keep in mind; ventilation (fans, etc) to control the airborne silica dust are usually not effective (too much dust versus exhaust). Water controls are best, but you must limit the amount of water and the direction of the sprayer. I suggest looking at what others have done.

Keep in mind, if you perform this activity you will need (as a company):

• respiratory program (medical, fit test, written plan)
• confined space program (multi gas meter, written program, attendant?)
• lock out /tag out policy or procedures
• training (for each of the above, and for this specific activity)

At this point I know what my contractor-friends are thinking…I will subcontract this out!   ha. If you do, please make sure your sub is doing it right.

Resources:

Georgia Tech – good presentation & guidance

Georgia Tech/OSHA – Safe Work Practices (in Spanish too!)

Teamsters H&S hazards & controls

Illinois DCEO – Consultation on ready mix cleaning

While doing airborne silica sampling I noticed this industrious employee using not one, but TWO hands free mobile devices. This guy can multitask!

I think flip phones might be making a comeback.

After performing an industrial hygiene survey (air monitoring), have you considered when you should resample? Here are some considerations that might help you in determining when.

• Are there specific rules that state when you must resample? For example, the construction lead standard (1926.62) states that you must resample yearly (or actually, that you can only use relevant results for one year).
• Has the process changedsince the last time you sampled? This one is hard to determine. Lot of things can change air monitoring results, here’s a “starter list” of things that can change a process.
  • Different employee?
  • Time of year? Summer versus winter? (closed up/open and humidity)
  • Is a new tool in place?
  • Has the ventilation changed?
  • Have new controls been put in place? (administrative, systems operations)
• Has the product changed? Check the safety data sheet (aka MSDS).
• Are more (or less) employees exposed to this hazard? This might change some assumptions you have made about your risk.?

If you have air sampling performed, make sure you have a written report of your findings. Laboratory results without an explanation of how they sampled, where, # of employees, process description, PPE used, safety data sheets, etc….is worthless. You may remember is well enough, but OSHA will have a hard time believing that it is a similar exposure the next time you do the “exact same thing”.

Having this report and sharing it with the employees will fulfill (part of) the hazard communication standard requirement to employees.

Are you measuring for zero accidents? Is this even possible? I agree it is a worthy goal. But, if you are presenting this to management, can you actually achieve it?

There is plenty of discussion around this issue. Maybe a better goal is something harder to measure, but more successful/beneficial in the long term. What about measuring one of these? (or a combination)

• response time from complaint to resolution (from employees)
• number of requests for safety related issues
• satisfaction of safety by workers (rate 1-10)
• safety committee interest & interaction
• decrease in airborne exposure levels year over year
• keeping track of engineering/administrative controls put in place per year

My 2 cents.

There is much confusion over the requirements and best practices of employees using respirators voluntarily.

Let me first clarify. You must do air monitoring (or have other verifiable information) that employees are not REQUIRED to wear respirators (if they are overexposed to something, you must protect them). Also, they cannot voluntarily wear a respirators if there is a known hazard above the exposure limit (the employee cannot opt-out of wearing a respirator and be overexposed).

Some points about voluntary use:

• Assuming the above statement (s) is true, firstly, you do not have to allow them to wear respirators. I am sure this is arguable from a human resources/PR/legal stance. However, if you have documented no overexposure and have not provided a respirator, they should not need to wear one.
• Next, the employees need to be educated and you need to prove it. Having them sign Appendix D of the OSHA respiratory rule is a minimum. Training them would be better.
• What respirator are they wearing? A paper dust mask (N95, P100, or similar) is a respirator. If they are wearing anything other than this type of mask they need a medical evaluation (Appendix C of respiratory standard).
• If they are wearing a 1/2 face tight fitting negative pressure respirators (or more protective ones) the company needs to have a written respiratory program.
• Fit testing is not required to be performed
• Maintenance, inspection, storage, and training should always be done. Can you verify that the employee does this?

I personally do not recommend the paper dust masks (N95, or similar) for this simple reason. Why would you wear this type of respirator if you could have a 1/2 face, tight fitting one with the correct cartridge? The cost difference is negligible, the protection is better, and you can be assured of a better fit. If you’re going to do it, do it right.

For employees (carpenter, laborer, iron worker, plumber, electrician) using powder actuated tools, please take caution! There are possible airborne lead exposures during powder actuated tool use.

The best safety practice is to eliminate the hazard. In this case there are two easy alternatives;

1. using lead-free loads, or
2. using a pneumatic type nailer (like this one made by Pneutek, Hilti makes a CO2 type as well)

However, if you are an employee, I realize there are times that you are not given a choice. If this is the case, please consider:

• asking for the MSDS for the primer loads (look for lead styphnate, or similar)
• lead exposure can occur by inhalation and by ingestion (wash!)
• wash & be diligent around eating & what you “take home” to your family
• lead exposure to children is serious (they absorb lead better & it causes more detrimental health effects)
• respirators might be required when using these tools (so wear one!)
• working overhead (nailing into ceiling) might have higher airborne levels than other positions
• bringing up these concerns with your safety professional onsite
• performing air monitoring to determine airborne levels (although for the price of an industrial hygiene consultant, you could own a CO2 actuated tool)
• reading more about it from my earlier post here.
  

Background: We arrived at the welding /fabrication shop where they were working on stainless steel. We were the first to arrive and found this next to the project.

I found 3 things that were blatant “no-no’s”. Want to guess? (see my answers below) You might find more.

1. respirator sitting out -not put away in box (actually sitting next to it!)
2. grinder without a guard
3. eating/drinking in the work area (gum, drinking cup)