industrial hygienist

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*


There have been lots of new information available, so this post will just share new information on a few different subjects:

  • Silica rule:
    • At this point, it doesn’t appear that the silica rule will be legally blocked. So, now is the time to prepare for all of the coming changes. However, the new administration may have some influence.
    • Federal OSHA has (finally) published their Small Entity Guide (103 pages!) but, no doubt, this will be useful for many.
  • NIOSH Noise Control Contest
    • I encouraged people to submit their ideas…and then, I missed the deadline to submit.
    • However, the results are in.  And at least one of them seems like a decent one (I have my opinion, but will let you decide which one is your favorite)
    • Check their main page, Hear and Now, for a summary
  • I AM IH
    • Another contest!
    • AIHA is asking for a short documentary highlighting the people behind the industrial hygiene profession. Are you interesting? ’cause most IH’s arent… (ha)
  • Free Safety Videos- Health in Construction
    • This project has taken a massive amount of my time, and it is still not completed yet . However, below are the links to the videos for those of you looking for a sneak peek.  Please feel free to share…more materials,  website upgrades, and ‘giant fan fare’ will be forthcoming.
      • Silica Awareness Video: Hierarchy of controls
      • Noise: Life from a construction worker’s experience with noise
      • Asbestos: What to do when you encounter suspect asbestos
      • Lead: A humorous look at why we shouldn’t be exposed to lead


For 100% selfish reasons, I debated about sharing this link.

Do you have an awesome idea for noise controls that uses technology?  NIOSH would like to hear about it. They make no promises, other than they will keep it a secret. But, this may be an opportunity to make your idea come to fruition.

I think the key to this “noise challenge“is to combine new technology for use in education, limiting exposure, or noise metercontrolling exposures. Personally, I think construction has a lot of room for improvement. Unfortunately there is no money to the winner, but I think this may be a good thing, so as it promotes and attracts the people who want to do it for the right reasons. Here are some of my inferior ideas:

  • make a low cost audiometric exam workers could do pre/post work to measure temporary hearing loss
  • ask Google and Apple to install the sound level meter app in everyone’s phone. Then based on Big Data create “noise maps” so people will know how loud it is wherever they are going
  • crease a device which produces acoustical waves which can be calibrated and set for stationary equipment. Once calibrated, it produces acoustical waves in the opposite direction – thereby cancelling the noise. (yea, I know, far fetched)

A new idea, SmartSite, which may spark some interest is a wireless health & safety monitoring system for construction sites similar to the residential “Nest” systems. They have a monitoring system set up on a tripod with a laser particle counter and noise level meter. The information is able to measured in real-time.

So working people, be challenged! Submit your idea by September 30, 2016. Email me if you do, and I will accept your challenge, and throw mine in the hat with you.

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

You’ve probably heard of this issue in the news, originally from the CBS News 60-minutes Show, March 1, 2015.

Formaldehyde is NOT good to have indoors, especially with kids (or those with upper respiratory issues). I believe there are a lots of homes and facilities with issues (which are not reported).

There are is some good information out there if you are worried you may have this flooring in your home or business. In summary, here are some notable points:

  • you should really ignore the people pushing this issue (remember they shorted the stock before the news story)
  • formaldehyde is used in a lot of product during manufacturing
  • go to Lumber Liquidators and get your free test kit
  • if you find high levels of formaldehyde, do something.
  • But, the solution may not be to tear out your floors.
  • Remember, formaldehyde can come from many sources.

Here’s a good article on the subject from Galson Labs. If you have concerns, hire a qualified industrial hygienist.


I was asked to summarize my thoughts on the OSHA proposed silica rule (which is currently pending). I’ve done it before, but since it was for the ASSE’s Industrial Hygiene Practice Specialty, it seemed fitting to post it on this site as well.

Wondering what is happening with the OSHA crystalline silica rule? In aviation terms it’s called a holding pattern. This airplane may-or may not-land. And, it is anyone’s guess.

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, for rounding purposes, let’s just say it’s a 50% reduction in the PEL. This limit is the same at the NIOSH Recommended Limit but still above the ACGIH (2006) Threshold Limit Value of 25 µg/m³.

Over the last year my views on this rule haven’t changed much: It’s a mixed-bag. There are still overexposures to silica. However, will the new rule change behavior?

To show some of the contrast, let me explain. Overexposures to airborne crystalline silica are still occurring. However, silica deaths have continued to decrease over the recent past (without the new rule). But, will the small employers comply? Or just wait to be cited? There is rarely a perfect solution for all situations. I’d like to provide a perspective balance to both sides of the rule.

The obvious benefit to lowering the silica exposure limit will be to protect overexposures to silica. I believe the rule will accomplish this in a number of ways. Any new rule will generate increased awareness for the subject of silica. The new rule will drive OSHA compliance by both lowering the PEL and by compliance with their additional controls. This will drive changes and modification to industries. Innovation will be spurned for controls and the need to comply.  In turn, this will create more discussions on the topic, the solutions, and overall awareness.

The new rule will get closer to the ACGIH TLV and update the health standards. The original rule was from the 1970s. And, OSHA is on the prowl for ways to update their current PELs.

Health and safety consultants will have an occasion for additional revenue in training, air monitoring, recommending controls, and other opportunities.

The new rule allows for alternatives to sampling. Rather than air sampling, you can choose to “over protect” and assure employees are controlling silica exposures.  This is a great solution for short duration tasks where exposure monitoring is prohibitive (see Table 1 from OSHA’s Fact Sheet). They emphasize control measures for silica.

There are very few new products and control measures for mitigating silica exposure in industry. Technology has somewhat sidestepped innovating products for dust capture and control for concrete work. Hopefully new products will be created to control silica. If nothing else, maybe we will see frequent job safety analysis (JSA, JHA) as a common practice to control exposures.


However, there are notable weaknesses to the proposed rule. The obvious downside is employers are expected to spend money. This will be an additional cost to doing business. Money will be spent on citations, controls for silica, labor during the activities, and for consultants to verify exposures are below the PEL.

This new rule will also allow OSHA to issue citations easier.  There are many items in the new rule which are beyond merely lowering the exposure limit. I imagine compliance officers will cite for failure to implement controls, or other technical aspects, rather than measuring the airborne dust and finding overexposure. Look for more drive-by citations.

And, there will be more confusion. Remember explaining to people how to calculate the current PEL? Well, in the short term, it won’t get easier. Although the PEL will be a fixed amount, there will be other things to explain. And, remember all the OSHA rules for leaded paint? The new rule is similar in how it allows you to provide adequate PPE and controls for “interim” work without measuring airborne levels.  Imagine you are a smaller contractor employer. This will be confusing and a lot of background work in order to use a jackhammer for one small project.

And, analytically, the airborne levels attempting to be achieved are so low, they are at the laboratory detection limits. With laboratory I currently use, to reach the detectable minimum PEL you will need to sample for at least 80 minutes (200 Liters). There is some newer sampling equipment which makes these levels easier to achieve. But, guess what? That will cost more money.  In addition, contained in the rule are mention of specific medical evaluations and facilities for those with continued overexposures. There are not enough medical facilities to support the number of people who need them.


Overall, I believe the new silica rules will help reduce overexposures to silica. The increase in awareness across the US will bring more attention to the danger. Employers who are doing absolutely nothing to control silica will get caught, punished, and hopefully change their ways. For employers already in compliance, there will be a small, but manageable, learning curve. I also see many contractors using interim controls (Table 1) as a guide to easily protect employees on short tasks with high silica exposures.

To stay ahead of the curve, the 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. Another great resource for awareness and silica control measures is As a reminder, pre-task planning is still one of the best methods for health and safety.

 Here’s my sampling outfit.

my silica bag


I love hearing about other IH/EHS/Safety -people and their careers. They are inspiring and there are some really COOL jobs in this profession. I’d like to introduce you to Michael Grasso. He’s been on some very interesting projects, is very personable, and has some insight into the future of construction safety. OLYMPUS DIGITAL CAMERA

How did you get started in IH/Safety?

I got started in IH/Safety in high school as a student athletic trainer. In college I was a health science major, the athletic training program was only opened to physical education majors. My professor for School and Community Safety encouraged me pursuit a career in safety. At this time OSHA was fairly new. The professor took me along with him when he did safety inspections on the campus. While going to the University I attended classes at the local community college in Safety and one in Industrial Hygiene. The text book was the first addition of the NIOSH white book. During the summers I worked for a public utility company as a laborer. The Safety Director bought me a copy of the “Accident Prevention Manual for Business & Industry” (NSC). My grandfather related the story of miners dying in the tunnel in West Virginia from the dust. Years, latter while reading the Washington Post, I found out it was Gauley Bridge, West Virginia.

What is your background?

I have a Bachelor’s of Science Degree in Health Science and minored in biology and psychology. I did my student internship in the corporate safety office of an electric and gas Utility Corporation and an internship with the county health department in the environmental health division. Upon graduating from college worked as a laborer for a pipeline company. The majority of my career has been in a construction related field. Starting off as a Safety and Health technician advancing by changing jobs to Safety and Health Manager and finally to a Corporate Safety Director position for a design-build firm. At this firm I was instrumental in building the organizations safety and health program and culture from ground zero. In a short period of time the company won the AGC Contractor of the year award, had one VPP site, several SHARP projects and won numerous safety awards including the Golden Hardhat award from the USACE.

What do you do in your current position?

Currently I am an EHS professional for a large engineering firm. I work on various wet-infrastructure projects for clients in the northeast; assist the client with developing EHS procedures in accordance with ISO 14001 and ANSI/AIHA Z10 protocols and severe as temporary EHS manager on projects. Internal client’s consultant with me on unique health and safety issues they run into as related to construction and environmental remediation projects.

Tells us your favorite project?

My favorite project is working in Antarctica for two seasons as the resident industrial hygienist. I enjoyed the beauty of Antarctica, peacefulness, history, applying my experience and the people. You can always leave Antarctica but it can never leave you.Michael Grasso

What do you enjoy most about your career?

Knowing that you touched someone’s life, and made differences is the most satisfying aspect of my career.

What has been the most fun?

The most fun was doing the 30-hour construction awareness training for high school students who are in the building trades program. The students loved the lab as they got to wear the PPE and play with the monitoring equipment.

Anytime that was particularly difficult?

Emotionally the most difficult time for me was when a subcontractor’s hand was amputated in a concrete pump. When I went to his home with the OSHA investigator it was hard, as he was the bread winner of the family. His mother was proud that he graduated from high school, spoke good English and had a good job. This was the first serious accident that I experienced in my career.

Any hobbies/interest which makes you unique to the profession?

I collect old safety and health books. I have a collection going back to the 30’s. I have the Heinrich’s books which are difficult to read. It is interesting to compare what was going on in the 30’s and early 40’s and how OSHA incorporated them into their standard. Since college I have been a volunteer firefighter. What we learn in the fire service has applications I have used in safety and industrial hygiene. Presently, I am the fire company’s safety officer.

What books would you recommend reading?Christ In Concrete”, By Pietro di Donato.The Hawk’s Nest Incident: America`s Worst Industrial Disaster”, By Martin Cherniack M.D .

Words you have for those interested in construction?

It is important to know the fundamentals of construction management and the type of contract you will be working under.
Safety and health at the dirt level is where things get done and where you have the most direct influence. Saying, “Good morning Bill (or Judy)”,  or having coffee with the Project Manager goes much farther than a meeting policy statement or an EHS procedure. It shows you care. Treat others as you want to be treated goes a long away on construction projects. It is important that you can speak or understand Spanish or Portuguese. Even if you do not speak a foreign language, a smile, or a tip of the hard hat goes along way.

From an IH point what have you seen in construction that makes a difference?

Over the years heavy equipment has gotten much quitter thanks to fully enclosed cabs and engine noise reduction. Ergonomics for heavy equipment operators has come a far way in the last 10 years. It appears that many medium and large size contractors have gotten the silica message without government intervention. You see more and more workers using respiratory protection and having a hose trained on the dust generating operation. Contractors are more aware of what’s a confined space: doing monitoring, ventilation and training. Compact loaders and excavators are doing jobs once done manually. Robotic or remote operated is being used in high hazard areas. Prevention through design is slowly catching on to eliminate safety hazards. As far as health hazards go, owners, and engineers continue to specify materials potentially hazard to the health and safety of the end user, when other products are out on the market.
The number one item that is making a big difference in the construction industry is the internet. From a smartphone a trades person can find out all types of information on substances they are working or about a safety hazards.

What I see in the future for IH?

I see the future of IH playing a large role in nanotechnology. The health implications of manufacturing and using nanomaterials are not yet clearly understood. Nanotechnology may be a Pandora box.

Thank you Michael! If you have specific questions, you can reach Michael at (michaelgrasso 78 (@) hotmail .com, with no spaces).


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.

Here’s my top 5 gifts for Christmas in the (my) occupational hygiene world of construction:

  1. A new carbon monoxide monitor.
    • Not just a “normal” $40 model. A Nest Protect Fire & Carbon Monoxide monitor, which is in the $100 range. This thing is sweet. Talks to you, sends you a text message. Here’s a review from Cool Tools. Or, just buy it here.
  2. High flow air pump, Gast model.
    • I have some other flow rate pumps up to 5 liters per minute (LPM), but this one is great for flow rates 10-up to 28 LPM (depending on the model). Good for high volume area type samples and vacuum wipe sampling. You must have 110 power available, but once calibrated, it’s a done-deal. They can be bought for under $250. Grab a rotometer too, if you don’t have one.gast pump
  3. Wireless response system to use during training.
    • Attendees have a wireless response keypad and the trainer can ask a multiple choice question. It allows the audience to reply. The results then show up on the screen. Great for anonymous responses, or a general overview from your audience. There are several vendors, here’s an example, and the leader in the industry is Turning Point. I think these are in the $500-$1,000 range.
  4. A bulk asbestos example kit.
    • A bunch of “typical” building materials which are asbestos containing. In sealed glass jars, of course. I don’t know where you’d buy this sort of thing. I wish I would have kept all of my samples over the years.
  5. A dedicated short term silica sampling kit.
    • SKC has a new sampler which can sample at a higher flow rate  of 8 LPM, compared with the usual 2.5, or 1.8 LPM. (which, if you think through the math; allows you to achieve a detection limit with a lower sample volume, and a shorter time duration) Unfortunately, you must purchase a new SKC Leland pump/charger, PPI sampler, calibration junk. Total cost is probably in the $2,000 range.


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