Industrial Hygiene in Construction

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 controlling 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 don’t hate all N95 respirators (paper dust masks rated by NIOSH), but they are used wrong very often in construction. And, if you agree, and need another reason to hate them,… guess what??

Now there are FAKE ones! Yes, people have actually copied the crappy dust masks and made even crappier ones.

The fake ones are easy to tell…if you can read the misspelling of NIOSH.  (NIOSH notice here)

The latest push from NIOSH is ridiculous, in a bad way. It’s titled, “Recognizing N95 Day” on September 5. I’ve written about these types of respirators before.

Let’s start with:

• NIOSH estimates 20 million workers exposed to airborne health risks
• N95 (s) are the most commonly used respirator
• NIOSH certifies all respirators. And, OSHA requires all respirators to be certified by NIOSH
• All certified respirators must have an “assigned protection factor”, which is a level of protection they are able to achieve
• N95 respirators are certified to provide a protection factor of “up to” 5 times the exposure limit

For the record, I am not disputing how NIOSH certifies respirators, or if these respirators can achieve a protection factor of 5 (5x the exposure limit). I will also add that in the healthcare setting (hospitals) these might have a useful role.

Here’s the problem:

• If you need a respirator, you would NOT choose a N95. They are terrible fitting.
  • To put it another way: if you had to work in an environment which had a dangerous airborne hazard, would you CHOOSE this respirator?
  • Or another way: “There is a chance this N95 respirator might protect you, wear this just in case”. (?)
• If you have fit tested these types, you know they are hard to fit, and at best, mediocre in their protection. At times it is hard to fit test a tight fitting 1/2 face respirator on someone who is clean shaven.
• N95 respirators are handed out (like candy) at construction sites for any task which “may be hazardous”.
• Let’s be honest:
  • these are “comfort” masks. AKA:  peace of mind, not for protection.
  • these are cheap. That is why most employers buy them.
• And, let’s mention:
  • exposure levels can vary (have you measured the worst case scenario?)
  • change out schedule? Do your workers wear the same respirators every day? Do they change them when they start getting hard to breathe?
  • facial hair (no one who is on a jobsite has this, right?)
  • there are knock-off N95 respirators which actually aren’t certified (they’re fake)

In this instance I wish NIOSH would spend money on training people to use the correct type of respirator. Or, how to adequately measure the hazards found at various sites.

As a quick review. If you need to wear a respirator, here are the proper steps.

Construction workers falling is the number 1 cause of death in this industry (residential & commercial).

NIOSH has published a prevention through design (PtD) document for those who design parapets to prevent falls. This document is new. But the principle of it has been around since Moses’ time: “When you build a new house, make a parapet around your roof so that you may not bring the guilt of bloodshed on your house if someone falls from the roof.” Deuteronony 22:8. 

Another good resource: Stop Construction Falls .com. They even have an interesting map which shows where they occur.

The CPWR obtained a NIOSH grant and has some free videos here.

Spring is when the work picks up, be safe out there.

It’s sad to say, but many construction companies have not yet started a formal hearing conservation program. Their solution is to purchase the best earplugs, for the lowest cost, and give them away like candy.

As I’ve mentioned before: Sometimes OSHA’s rules are protective (meaning: you will be safe) and other times they are really not on par with the health research. Hearing loss and OSHA’s method of measuring noise are NOT protective to employee health (your hearing). For the best method of measuring noise, look to the recommended guidelines of the ACGIH. In order to get the exact parameters, you must purchase their Guide to Occupational Exposure Values (TLVs) booklet. It hasn’t changed (at least for noise) for a few years, but it is still the most up to date on health for your hearing. Here’s a summary of some differences:

• Exchange rate (how noise doubles and is averaged over time)
  • OSHA uses 5, ACGIH uses 3 >>which means noise doubles every 5, or 3 dB increase
  • this makes a BIG difference in your accumulated average noise level (TWA).
• Exposure Limit, or Criterion Level
  • OSHA says 90 dBA, ACGIH says 85 dBA
  • Doesn’t seem too different (-5), but remember noise is logarithmic and it’s measured different by OSHA & the ACGIH

NIOSH also has some guidelines, which are very similar to the ACGIH.

There are some strong benefits to having a hearing conservation program. Here are some examples and suggestions for bettering your own program.

• You can be recognized
• Win an award. 
• Have less (or even better: none) hearing loss claims
• What about just hearing soft noises? kids? hunting? sports? the TV?

If you have worked in construction for any period of time, you know how loud it can be, and how much exposure is out there. Don’t assume working in this industry that hearing loss will to happen to you. Do something about it. Here’s a presentation from CDC/NIOSH a few years back on how to start.

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.

Yea, I know. Strange one, huh? In my time consulting, this is actually the second time I’ve come across this.

It is more commonly know as: Mace (R) or tear gas (not pepper spray though, that is Oleoresin Capsicum). Hopefully you haven’t actually experienced it’s exposure. It is worse (so I’m told) than pepper spray. More differences compared here.  All can be quantitatively measured by your favorite occupational hygienist.

Exposure in construction can come from incidental releases (incident response) or during clean up/ demolition of structures where this was used (think: police entry into a structure).

The OSHA exposure limit is 0.3 mg/m3. (NIOSH REL is the same, ACGIH TLV 0.35 mg/m3). They are all very low, actually.  Exposure can occur by inhalation, eyes, ingestion, and skin exposure.  NIOSH Pocket Guide is here.

Personal protection is a bit interesting. NIOSH recommends a full face respirator with P100 and organic vapor cartridges be used. The interesting part is that using this type of protection would allow exposure (based upon the protection factor) up to 15 mg/m3. Which, incidentally, is also the level as immediate danger to life and health (IDLH) = 15 mg/m3.

Some guides for dealing with this substance can be found here.

Yep. Polychlorobiphenyls (PCB) are found in caulking. Typically buildings before 1979 have this caulk. (EPA Facts about PCB in Caulk) The only way to know is to test. BUT, wait!

Either:

• Assume you have it and renovate with caution. Or,
• Have the air tested for PCBs in the air.

Do not have a bulk sample taken. You should ask for an exposure assessment to be performed (air monitoring) by a qualified industrial hygienist. The reason is two-fold.

1. The potential for the hazard is airborne. In most instances, people aren’t getting exposure from any other method.
2. By measuring the air, you account for any other sources of PCBs (paint, ballasts, oils, ceiling tiles).

Most of this caulk is found in outdoor uses (high grade) in older buildings up to around 1980-ish. If an airborne exposure assessment finds levels below the acceptable rules & recommendations (depends on age & location), you may continue with your project. Of course, you would take appropriate precautions, like these recommendations from the EPA. They also have a very nice flow chart. Just like a choose-your-adventure book, make sure you don’t fall into the “Abatement” box!

Chromium in it’s elevated valence state, called Chromium 6, or hexavalent chromium is a known carcinogen and sensitizer. From a toxicological point of view, it has a really interesting exposure to disease path.

I’ve mentioned it before, but recently NIOSH reduced their suggested limit from 1.0 µg/m³ to 0.2 µg/m³ (80% reduction for you math wiz’es).  They base this on eye & skin irritation, respiratory damage & lung cancer. Yikes.

OSHA has listed their exposure limits, along with other’s recommended limits here.

The take-away from this reduction is the serious nature of Chromium 6. If you are dealing with this hazard, you should take more than just a little precaution. Even if your prior air monitoring data is below the Action & Exposure Limit, continue  to document and verify your employees are well below the regulatory & recommended limits. As you know, hexavalent chromium is a skin hazard and can be absorbed easily into your body. I would also suggest performing wipe samples (area & skin) & decontamination in areas where there is work activity with hexavalent chromium.

For most construction companies, investigate these areas:

• welding (any stainless steel?) See this earllier post, also here.
  • And, OSHA has a new Fact sheet on welding & hexavalent chromium here.
  • Washington’s OSHA (L&I) has a great page on the hazards during welding here, including training videos. (so cool!)
• hardfacing on equipment. See earlier post.
• Bridge painting – (or painting with chromates) OSHA’s new safety bulletin is here.
• Electroplating – OSHA’s safety bulletin is here.
• Anytime you heat, or work with chromate painted surfaces.
• Portland cement when working with it wet and on your skin. NIOSH has some information here. hint: Try adding ferrous sulfate to lower the Cr6.

And, if you don’t work in construction, but live in Garfield, NJ, you might have to pull your toenails out to prove you aren’t exposed to hexavalent chromium.

NIOSH has just recommended a new exposure limit (REL) for hexavalent chromium. The new limit is 0.2 ug/m3 as an 8-hour TWA. If you remember, the OSHA PEL is 2.5 ug/m3 (8-hour TWA). SO, if you’re good at math, you can see this is A LOT lower.

The reasoning for this level is they have found a lung cancer risk (get this) EVEN AT 0.2 ug/m3. They recommend bringing airborne levels below this limit for lung exposures.

As I’ve described before, exposures are not limited to just inhalation. Dermal contact is a big concern.

If you have any hexavalent chromium at your facility, or stainless steel (welding, welding2, hardfacing, etc.) you need to do more than just air sampling. You need a comprehensive program including wipe samples, medical monitoring, etc. This may not be a specific OSHA rule for your facility.  However, these exposures are something you must manage.