Industrial Hygiene in Construction

If you live in the United States, you have less than one month to train your employees on the new Hazard Communication standard (1910.1200(h) & 1926.59), which should include information about the new types of Safety Data Sheets (formerly known as MSDS) and the adaptation with the Global Harmonization System (GHS). December 1, 2013 is the enforcement start date for OSHA. Don’t make this complicated, it is straightforward. Here’s what you should do:

• Train employees in hazard communication (simply: so they know the hazards they are working with)
• Document your training (in case of an OSHA inspection)
• Show them a sample Safety Data Sheet (SDS), compared with the old MSDS
  • Explain the new standard hazard phrasing & pictograms
  • Explain how to review a SDS
  • Remind them about container labeling
• Explain that the new SDS will not be available immediately, but will roll-out over a few years (or more)

*Please note the “Beer” hazard warning on the right is not GHS compliant. 

For Help:

• Oregon OSHA (OR-OSHA has a new fact sheet on what you need to do for compliance.
• Here’s a link to a sample hazard communication plan (in Word!). More help here.
• AND, a free training guide for employers, another here. Shout-out to Siobhan & Dan at SAIF for this.
• Also, some Susan Harwood free training materials here (spanish too!).

If you haven’t heard, Federal OSHA is proposing to reduce the airborne silica permissible exposure limit (PEL) to 50 µg/m³. It is difficult to say how much lower this new rule will be, since the current standard relies on a calculated formula to obtain the exposure limit. However, to make this easier, let’s just say it’s a 50% reduction in the PEL. This limit is the same at the NIOSH Recommended Limit and above the ACGIH Threshold Value of 25 µg/m³. Before I offer my opinion, you can state yours to OSHA here, and I’d recommend you do.

Benefits:

• Increase awareness by everyone (any news is good news for silica awareness)
• Further protect employees from overexposures
• Update the health standards. The original rule was from the 1970s.
• New products for the industry will be created to control silica, like this.
• Pretask planning (JSA, JHA) will become more common
• Consultant hygienists will get more $ to: train, air monitor, etc.
• Alternatives to sampling. This is written in the proposed rule.
  • Rather than air sampling, you can choose to “over protect” and assure employees have adequate PPE
  • This is great for short duration tasks where exposure monitoring is prohibitive (see Table 1. below from OSHA’s Fact Sheet)

Weakness:

• Employers will spend additional money:
  • on controls for silica
  • on labor during the activities
  • on consultants to verify you’re below the PEL
• OSHA will cite you easier
  • (my guess) is compliance officers will cite you for failure to implement controls, rather than measuring the airborne dust and finding overexposure
  • driveby citations. Look at some of my “caught on camera” overexposures. It is easy to see why this will be easy for OSHA to cite.
• More confusion
  • remember how you felt when you started working with leaded paint? Picture that again.
  • smaller contractors might be confused with the changes
• I’ve heard: the airborne levels trying to be achieved are so low, they are at the laboratory detection limits. (this is a bit beyond me, honestly, but it has to do with chemistry & analytical methods)

Overall, I think lowering the limit will reduce employee overexposures to silica. The increase in awareness across the US will bring more attention to the danger. Contractor employers who are doing absolutely nothing to control silica will get caught, punished, and hopefully change. For good-contractors out there, this will make it easier to explain to your subcontractors who are a little behind. I can see many contractors using Table 1 as a guide to easily protect employees on short tasks with high silica exposures.

Your thoughts? I’d love to hear them. Here is a NY Times Article perspective.

Let me first say that I am still learning about this hazard and why it is so dangerous.

Polyurethane foam is used as an insulating material. More info on it’s uses here. The danger is when you spray it (think: expandable type), or apply it, or cut/remove it after it’s cured. The danger is in the off-gassing.

There are two main considerations:

• the process of applying the foam
  • spray type
  • quantity?,
  • ventilation?
• the type (manufacturer/brand/type) of foam
  • curing rate,
  • type of hazard, etc.

What we know is that there is a hazard. AND, this hazard may not effect everyone, OR, it may not effect you until some time has gone by. But, some of the chemicals in these types of products include:

• isocyanates (people can die, and get asthma), and it is a OSHA Emphasis Program, and OSHA page here
• amines
• VOCs (volatile organic chemicals)
• flame retardants (PBTs)
• Blowing agents (EPA link)

There is a huge potential for work related asthma when using these types of products. And, even contact with the skin can trigger an allergic response/asthma attack. If you have employees working around this type of product and have ANY respiratory symptoms (or asthma), please have them checked by an occupational medicine doctor.

Control of this hazard should include:

• PPE for employees (respiratory, eye, & skin protection)
• ventilation during application
• ventilation during off-gassing & curing (can be 72 hours)
• control plan for spills, cutting & demo
• control plan for employee/occupants with asthma

The EPA has a quick reference card here (hat tip to Tom), and more detail from the EPA on how to control the hazard here. The Spray Polyurethane Foam Alliance has free training here (haven’t checked it out though), and be mindful that anyone can be an instructor (good & bad).

On one hand it makes perfect sense. If you work safely, over time, this is something that should be rewarded. Many, many companies provide a safety-incentive for no/low work place injuries.  However, there is a downside, which some people have discovered:  If you reward people for being safe, there is a possibility they won’t tell you if something isn’t safe. It’s called a reporting bias, or selective reporting.

Unfortunately this bias is exactly the opposite of what the best companies do. The best companies report every little thing (every incident). People who scrutinize the numbers can tell you for every accident that occurs, there are usually 100 little incidents which occurred prior to the accident. The reporting of incidents is the best indicator for future accidents. (aka, catch phrase: leading indicators)

A really cool example of this is Google Dengue Trends. Dengue is a mosquito-spread virus. Google looks at search words and, over time & many data points, can actually see people where the fever is spreading. An article in Science & Tech (June, 2001 Graham Smith) “Google launches Dengue Trends tool to help doctors track spread of deadly fever”

So how do you motivate people to report an unsafe act?

Here are some ideas:

• Pre task planning & post task wrap-up (downside: can be a lot of paperwork)
• Check the first-aid safety box for what’s being used
• Encouraging open communication
• Spies (not my favorite)
• Follow up on any report of near miss (by management within a certain time frame)
• Reward the reporting of incidents
• Make it easy, safe, convenient, rewarding, honorable, and validating

Or, maybe you should ask the opposite question: What would motivate someone NOT to tell you? In construction, it is common practice to provide a bonus at the end of a project based upon various factors. This most definitely includes profitability, but it can also include safety. If you didn’t hurt anyone on the project, you SHOULD be rewarded. (or, at least be given a pat on the back). Here’s a case of someone who really got it backwards: A former safety manager at the Shaw Group (formerly Stone & Webster Construction) falsified records.

AIHA has released (2013) a white paper for guidelines on skills & competencies in silica specific to construction. It is a great outline for training your employees.

Some interesting points:

• Respiratory protection, and their respective assigned protection factor is mentioned. (Are you wearing the right respirator?)
• There is no mention of air sampling. Thank you. You do not need air sampling every-time, we already know it’s hazardous.
• They emphasize control measures for silica.

Another recent publication from IRSST in Canada explains the effectiveness of controls with regard to specific tools and where exposures are found in the industry. It has a lot of information, but if you are looking for the best method to control dust with a certain tool, it would be worthwhile to read the 108 page document.

The best resource for silica is silica-safe.org. You can create a plan for controlling it here. They have a database of tools & controls. Very handy. Someday soon we may see 3D printers able to make these dust controls and adapters for us at a moments notice. Until then, pre plan your task.

So, while standing in the California jet-way waiting to board my plane, I noticed this sign. It was most likely a Proposition 65 labeling warning. However, what in the world do you do with that information? How did posting that sign change any behavior? Could I have done anything different to avoid the jet fumes?

It reads, “Warning. Chemicals known to the State of California to cause cancer, birth defects and other reproductive harm are present in the jet engine exhaust fumes from jet fuel, and exhaust from equipment used to service airplanes. Sometimes these chemicals enter this jet bridge.”

In much the same way, sometimes our warning to employees is pointless. What can they do different? What is the point of telling them something if there is nothing we can do different?

The global harmonization system (GHS) is being implemented in the US by the end of 2013. By 2014 you must train your employees on the new changes to the (Material) Safety Data Sheets (SDS, now). (BTW, there are also some other things you must do).

The message I am trying to make (double irony, I know) is when you are training your employees, how do you measure the effectiveness  If they “sign in and say they were in your training”, were you effective? Here are some suggestions, which might help to measure the right thing:

• Questions. This ___ number of the audience asked ___ questions.
• Feedback. I received ____ # of suggestions for the next training.
• Changes. They are going to implement ____ changes to their workplace.
• Secondary labeling. (GHS specific, of course) While walking around the site, I noticed ____ secondary labels with the new labeling pictographs.

I admit these aren’t the-best-suggestions-ever. But, warning someone without an alternative, method to change, or way to adopt a change, is really pointless.

This type of potential exposure usually doesn’t cross my mind. Luckily, the specifications in the construction project (and the obvious towers nearby), alerted us to the hazard.

If employees are working near areas of potential high electromagnetic (EM) activity, you should do something (see below). High EM potential areas are power lines, cellular towers, TV/Radio broadcast sites, etc. We have all heard the dangers of living under high voltage power lines, and this is essentially the same concern: Non-ionizing radiation.

The FCC has a guidance document OET-65 (radio frequency) which has some recommended limits, called maximum permissible exposures (MPE). These limits vary depending on the frequency range and how close/what type of work you are doing nearby. OSHA (1910.97) has some guidance (based upon an old ANSI standard) and the ACGIH also has recommended limits. New research is ongoing due to the increased use, and the future demand, of cell phones. The clearest guidance is from IEEE (C95 radio frequency). They provide recommendations and a sample plan. But, to summarize:

• look for the source (s) of the radiation (sometimes it’s not obvious)
• take measurements (might be difficult, unless you have access to a field intensity meter) Ask the FCC?
• determine risk potential
• make a plan
  • develop controls – time & distance are easiest 
  • consider off-hours/ shut down of towers (in extreme cases)
• train
• consider:
  • cranes, large pieces of equipment that may resonate with a certain frequency
  • heat from stored energy
  • nondescript symptoms, which is usually the first sign of a problem

This is a somewhat new field (no pun). But, remember when power lines, cell towers, and tv/radio stations were installed. – The goal wasn’t to keep these away from people, it was to bring them closer. How close should we get? I’d love to hear if anyone has been dealing with this a lot in construction.

I had the opportunity to attend a construction safety award presentation and listen to various commercial construction companies (GC, and Specialty Contractors) explain why their company deserved an award. Owners, CEOs, Safety Directors, and Employees spoke about their company. Their stories were amazing. Below I have listed some of the ideas that inspired me. They may not, at first glace, appear to be amazing. However, consider when the CEO tells a story that makes him cry, or when a superintendent explains how he is part of a family,…. it makes the words ring different.

Here are my takeaways:

• Safety really starts at the top. It’s not a priority, it’s a core value. Check out the Injury Free Forum (IIF).
  • This is basically a club/meeting for CEOs to gather and talk about how to prevent injuries. It’s ‘almost’ an invite-only type of event. But, if you’re a CEO/President you should think about it. (helps if you live in the NE part of the US)
  • Here are some companies participating, Gilbane, Gilbane video (yep, it’s good), JMJ Associates, Baker Concrete video
• During initial employee orientation;
  • one company has each employee write a letter to their family saying (apologizing) why they are gone/dead. This really emphasizes to each individual why they need to work safe.
  • the CEO gives each new employee his business card and tell them to call him directly if they are asked to do something unsafe.
  • each new employee is assigned a mentor (the time period varies from 2 weeks to 1 month) to watch them work safely.
• Each employee has the right to stop work due to safety. If they do it: the CEO/President writes them a personal thank you note.
• Make each near miss a incident, but do NOT have a lot of paperwork, just simple documentation for future learning.
• Have a innovative idea challenge at your company for good safety ideas.
  • Put a bar code on infrequently used tools. Link to a short video which explains how to use it.
  • Zip tie PPE onto the tools upon checkout.
• Send your “Safety Incident” or “Safety Summary” to their home. Ask them to put it on their fridge. Then, run a contest. Randomly find a name & call that employee to see if they can tell you what the safety topic is. Give a prize. Repeat.
• Look at the design. A large GC mandated that every hole in their project have safety netting installed during the concrete pour. …and they did it!
• An electrical firm uses no knives. None. Think that helps cut down on injuries? (pun intended)

The goal is zero injuries. So, what happens after zero injuries? How about sending your spouse to work…and they come home healthier! It’s not far away for some companies, Health & Wellness programs are already being implemented. For whom are you working? Here’s one of my reasons:

Much research has been done in construction safety. If you are working in construction, you have probably heard the facts over and over. The majority of construction injuries are from four main hazards, hence the “focus four hazards“. Although this site is for health issues & industrial hygiene in construction, it would be ridiculous to NOT mention these other hazards.

• Falls,
• Caught-in or Caught-between,
• Struck-by &
• Electrocution.

When talking with superintendents and safety coordinators, you can usually tell very quickly  if they have these under control. Either their subcontractors already do it right, or if/when they see an error, they immediately stop and address the inefficiency.

I saw this ladder in front of my children’s school. There was no one around and, by the look of it, there might have been someone on the roof. I should have waited, or fixed the ladder and spoken to the individual. But, I didn’t. Instead, I took a picture, put it on the internet, and now I’m telling everyone why it’s wrong.

Reviewing a material safety data sheet (MSDS), or soon to be called a SDS (safety data sheet), can be a useful skill. Most times the product is straightforward and gives you what you need. However, there are somethings to watch for and areas to focus to make your reviewing skills better.

To start,  make sure you have the right SDS. Match the product with the form. If is is not exactly right, find the right one. It must list the model/product name & manufacturer.

Below are some suggestions:

• What is the date of the SDS?
  • is it the most recent?
  • when was it last updated?
• Look at section 2/3 (Hazardous components) VERY carefully.
  • google the CAS# and find the name (they sometimes hide the true-name)
  • look at the % of each component
  • what is the listed exposure limit? Is it correct? What about other recommended limits?
  • remember the hazard is only listed in this area if it is greater than 1% of the total
• Look through each section mindful of how you will be using the product.
  • for example: if you are going to be burning the product, usually the SDS will not address these types of concerns/exposures
  • what are the required PPE during “regular use”
  • what happens if you use this product in a confined area?
  • does the manufacturer recommend air monitoring? when?
• Familiarize yourself with the emergency procedures
  • what if it spills?
  • disposal?
  • what can cause exposure? inhalation? skin?
• Look at the other sections with a inquisitive eye
  • do they list other chemicals, which are NOT included in the product section? why?
  • do they mention Proposition 65?
• Finally,
  • post/make available a copy wherever it’s needed
  • make sure you know the product

It is a mixed-bag when it comes to the quality of SDS from a manufacturer. Some of them will work with you, others are a total-pain. Remember it is YOUR RIGHT to know about the products you use. If you don’t feel comfortable with the information they’ve given you, call them. OR, go find another product.