Hazard Communication

Honestly, I did not think lead exposure to adults (and even kids in small amounts) was an issue. Mainly because:

  • OSHA has good (protective) rules on lead in construction (updated in 1993) and they mimic the ACGIH TLVs.
  • We all have lead in our blood. (…and I seem to be doing fine)
  • We are doing better as a society. For example: no more* leaded gasoline.

But, one technical session last year at a conference changed my mind. We have a long ways to go.

The point: low levels of lead may have significant health consequences. And, if you have lead (Pb) in your body–it is from a source.

If I haven’t convinced you, the CDC is also considering ANOTHER reduction in childhood blood lead levels. In 2012 they reduced the advisory blood lead levels (in children) to 5 ug/dl. Later this month (Jan 17, 2017) they are meeting to consider reducing this level to 3.5 ug/dl! Whether of not they reduce it, the fact they are considering it should further our attention.

And, if you think this just applies to industries with heavy lead, think again. It has A LOT to do with construction.

“Construction Program researchers and the New Jersey Department of Health and Senior Services (DHSS) conducted a surveillance study in 1993 and 1994 involving the voluntary participation of 46 construction workers’ families. BLL (blood lead level) testing of young children indicated that the workers’ children, particularly those under age six, were at greater risk of having elevated BLLs (≥ 10 µg/dL) than children in the general population”

We (you) must pinpoint the source of your lead exposure. And, it may not be obvious. Since lead exposure can occur from airborne levels and by ingestion, the sources of lead exposure can vary widely.

For example, in Flint, Michigan they changed water sources to a more natural one. But, *spoiler alert*, the water had more salt – which was corrosive – which leached higher levels of lead from the pipes. Other sources can include: kids toys, jewelry, fishing weights, battery recycling, glass manufacturing, etc. (the picture of the above light pole looks like galvanized metal, but actually contained 45% leaded paint!)

What to do…

  • Train and make people aware of the issue (free video that we produced! 1:31)
  • Blame someone. Just kidding. Find the source of your lead exposure.
  • Before starting a project, know where the lead paint is, and the activities you plan on performing.
  • Get your blood tested for lead levels
  • Wear the proper PPE and ESPECIALLY have good hygiene
  • Perform air monitoring (and probably wipe sampling) to verify lead is not escaping from project.

At this point, the OSHA silica rules are forthcoming, what should you be doing to prepare?

  • Read the OSHA Small Entity Guide. Initially it is daunting – 103 pages, but much of it is specific to tasks from Table 1 and the full rules are within it, as well. Plus, they have pictures!
  • Identify tasks which could have silica exposures silica-grinding
  • Train employees, identify your “competent person(s)” – my suggestion is: Superintendents/Project Managers
    • Warn those on your projects: NO VISIBLE DUST on any tasks (cutting, finishing, dry sweeping, etc.)
  • Document activities with airborne silica exposures below 25 ug/m3
  • Identify possible solutions for overexposures
    • Verify airborne levels with personal air sampling
  • Start a process to log the number of days with (any) exposure – >30 is inclusion into medical
  • Find a medical provider that can have medical screen performed & with a B reader

*Thanks Andrew for the photos*


I was recently forwarded an article on a gentleman who won a large sum of money ($8.75 million) for an asbestos related disease. There are many people getting these types of settlements for similar exposures.

However, what is interesting, is the attorneys argued the company knew about asbestos in 1965, but the exposure occurred in the 1970’s. Keep in mind, the asbestos rules at OSHA didn’t come out until the 1970s as well. So, exposure occurred before the regulations were in effect.

So, they knew of the airborne hazard, but continued to exposure workers before there was a rule. Does this sound like any modern day issue?   –hint– silica?!

Nowadays with the public being uber-aware of “potential” airborne hazards (mold?), with information so readily available, with OSHA rules outdated (annotated Z1 tables), and others publishing health standards like ACGIH,….the lesson is: protect your employees.

I don’t think we should be arguing about the OSHA rules. Let’s use available information and science. “More Than Just A Number” (article published by AIHA, May 24, 2016).

asbestos snow

Exciting news! In just a few months we will be releasing free training materials!

In summary: I applied (and obtained) a grant through OSHA to produce training materials for the four major health hazards in construction. We are titling it, “Focus 4 Health Hazards for Construction”.  (similar to the Focus 4 Susan Harwood training materials available at OSHA)

Indented audience is for younger construction workers in hazard recognition of, 1. silica, 2. noise, 3. asbestos and 4. lead (pb) in construction. A short video (1-4 minutes) for each subject gives an introduction to the hazard. And, to follow up a training power point presentation (and short summary) will also be available to further instruct people in how to control and protect themselves.

On a personal level…it has been exhausting, and I’ve learned a lot!  From obtaining the grant, to hiring a videographer, filming, securing filming sites, and quarterly reports…. exhausting.  But, I’m confident you (and others) will enjoy it. Subscribe (via email) to keep updated. You can also follow me on instagram: “adventuresInIH”. (link coming)

grant filming

I have given many safety training presentations (as you have, I’m sure). If you are lucky, the owner/president of the company will have a few words to say to the group.  I am sometimes amazed at what they say (or don’t say). Below are my tips and suggestions.

What to say:

  • Thank the employees for working and the contribution they make
  • We take your health & safety VERY seriously
  • Look out for your own safety, AND the safety of others
  • Thank your company safety director/coordinator/consultant
    • Support them and listen to them
    • Do what they ask you to do and pass it along to others
  • We want our employees to:
    • Go home to your friends & family
    • Enjoy your life – injury free. Now, and in the future.

What NOT to say:

  • We spend a lot of  money on safety
    • “Bob got his hand cut, and it cost us $1,200”
    • “We had to pay $1,200 in OSHA citations”
  • Don’t be stupid”  (thereby implying that accidents are generated from stupid people)
  • Our insurance costs are high because you are getting hurt.
  • I will give you ____ if you don’t get hurt (thereby encouraging under-reporting of injuries)


It’s probably not a new disease, but there are more cases being discovered for type of cancer called, peritoneal mesothelioma. This cancer is found in the stomach, and is cause from eating asbestos (probably not on purpose, but through the body’s normal ability to capture particulates). They are calling this cancer the “third wave”, in addition to asbestosis and mesothelioma (in lungs).

The Center for Public Integrity released a video and article on a dramatic case, Kris Penny, on Dec 17, 2015. NPR picked it up and posted it here. Hopefully more people will be aware of this type of cancer and it can be better reported/diagnosed.

In a related article, from Newser, they suppose this type of cancer is from home exposures, rather than occupational. This information was based upon Australia’s Asbestos Safety & Eradication Agency‘s 2015 report.  They claim:

  • 40.64% (568) of people had exposures from non-occupational exposures (they are self reporting for the Australian registry).
  • 20% (280) of all registration of exposure were women.
  • 62.6% (876) of reported exposures were under the age of 49
  • The “third wave” of asbestos exposures will be from DIYs


asbestos reports

Unfortunately new exposures are still occuring, especially in developing countries. There is an effort to stop asbestos use in these countries, and you can join one group, Global Alliance Against Asbestos.

There is a lot of confusion over confined spaces in construction. OSHA is enforcing these rules since Aug 3, 2015, but has given a 60 day postponement (effective Oct 2, 2015). Right now you need to make “good faith efforts” to comply. For those in construction, you need to get up to speed, and even more importantly, get confident. Unfortunately, this information isn’t going to get you 100% there.

The reason confined spaces (and the rules) are so complicated is because every space is different. It’s not a minimum height guard rail, or fall arrest system. There are just too many factors, including: death by honey

  • the size (or smallness)
  • the ventilation (or lack of)
  • access (or lack of)
  • the work activity (what you introduce)
  • the hazards (before you enter, and what you introduce)
  • the people inside (people are different, and work different)

To begin getting educated, here are my suggestions:

  • Know the definition of (and when it’s) a confined space (hint: 3 things)
  • Know the location(s) of your confined spaces (AND mark them as such)
  • Train your employees and yourself
  • Buy a multi-gas meter
    • And, know how to use it, bump it, and calibrate it
    • And, train others
  • Know: host employer, controlling contractor, sub contractor, mobile worker. It may not be obvious.
  • Know: ventilation. When you can use it,  what changes, and how much you need
  • Understand “rescue”.  And, the answer is not calling 911.

When an accident happens in a confined space, there’s a high likelihood it’s a fatality.

If you have confidence in the rules, and, more importantly, in the hazards & controls, confined spaces can be safe.

Sorry for the delay in writing. I have had some personal and professional projects taking a lot of my spare time. I have been preparing to present at a couple local conferences on Industrial Hygiene in Construction. It is a good exercise for me to ponder what I should say to these audiences. Here are some takeaways:


My latest guess (subject to change, by even tomorrow) is the Federal OSHA rule for silica will be enacted.

“Why”, you say? …well:

  • Current administration would love to push it through
  • Yes. It’s still an issue in the construction world. Have you driven by a construction site lately?
  • Federal OSHA is also talking about updating the PELs…and this one (silica) is an easy one
  • When?  No idea.

Falls in Construction:

This one is huge. In a bad way. If you look at what kills the most in construction, it’s falls (inclusive of scaffolding, ladders, fall protection, etc.) They cost a lot too. Not just in the number of people killed, but the claims & recovery cost are high. And, near misses in construction are VERY common. For example, just two weeks ago: An 18 year old roofer apprentice was working on a roof.  He stepped onto a piece of drywall and would have fallen to a concrete slab 25 feet below. Luckily someone had moved a piece of equipment directly under where he fell. He only fell four feet and had no injuries.

Hierarchy of Controls:

Is anyone working with these anymore? Just kidding, sort of. But, we can do a better job in construction of:

  1. Engineering Controls first. Can we eliminate this hazard? Has anyone asked to substitute this product for a safer one?
  2. Administrative Controls second. There are ways and methods which we do things in construction. These are usually passed down from journeyman to apprentice. Overall, this is awesome. For example, we need to rethink why we place the rebar on the ground? Can we use saw horses? Better material handling would save a lot of injuries.
  3. PPE third. And as a last resort.

Personal Protective Equipment:

Oh boy. There is a lot of room for improvement here. The wrong equipment, worn incorrectly, not used enough, and damaged. I don’t have the answer for this, except we should create and encourage the best safety culture possible.  I think this helps construction to take pride in their work, and their (and their friend’s) safety.

Confession: I missed the assessment of this hazard the first time.

Awhile back I performed air sampling during aluminum welding. The welders were cordial and let me crawl over their welding equipment, poke around old boxes of wire and metal stock. I did not think there were any “real” hazards. We did find some airborne levels of various metals. From the picture can you tell who did the most welding?

welding mce

After I had performed the sampling and the report was sent, I was asked if I had checked for ozone (O3)? I admitted I hadn’t and asked if it was an issue? Well, apparently it is (or rather, might be).

I went back to the shop, begged for another chance, and performed ozone sampling. It wasn’t difficult, but eating crow was the hardest part.

More information on the subject can be found at: NIOSHUK- HSE. Ozone is formed when the UV radiation hits oxygen. The ACGIH TLV is variable (see table below)ozone acgih, and the OSHA PEL is 0.1 ppm.

Health: Ozone, O3, can cause lots of different respiratory illnesses. These can include a decrease in lung function, aggravation of asthma, throat irritation/cough, chest pain, shortness of breath, inflammation of lungs, and a higher susceptibility to respiratory illnesses. ACGIH classifies it as an A4, or not a suspected carcinogen.

Luckily the results were found to be non-detectable (“IH talk” for none-found). Which only means I didn’t find it, not that it is not there. I sampled for a long time (530 minutes) because they were working 10 hour shifts. But, they only welded for a total of approximately 1.5 hours during that time.

If welders are in a confined area, or a small space with limited ventilation, the results might be significantly different.


Instead of explaining how to calculate safe levels of chemical mixtures, this will be a reminder.

The American Conference of Governmental Industrial Hygienists (ACGIH) in their Threshold Limit Values (2014), has an excellent explanation of how to calculate a safe level of exposure. However, in summary, if separate chemicals have the same health effects (effect the body in the same way), they may do three things:

  1. Additivity – the sum of their exposure & health effect is A+B. More on this below.
  2. Synergy – the sum of their exposure is MORE than A+B. This is bad, and hard to calculate.
    • Similar in principle to smoking and asbestos. If you smoke and have asbestos exposure, you are worse than just the additive.
  3. Antagonism – the mixed chemicals cancel each other out. It usually never works this way.
    • But, as a terrible example, it would be like acid rain dissolving styrofoam. (I don’t think that’s true, BTW)

Back to Additive (Additivity):additive

If two chemicals (or more) in a mixture have similar health effects (central nervous system, or effect the kidneys, for example), then, until you know otherwise, you should assume they have additive effects. Have your favorite Industrial Hygienist use your air monitoring data to calculate the additive effects using the ACGIH Additive Mixture Formula.

This is useful for combining both full shift air monitoring data, short term, and ceiling exposures. Extreme caution should be used if the chemicals are carcinogenic (as low as reasonably achievable (ALARA) is best here), or if they are complex mixtures (diesel exhaust).

It’s a bit confusing, but worthy of reminding ourselves of chemical mixtures.

Next Page »