Industrial Hygiene in Construction

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 
• 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*

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 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).

Question: During mixing of portland cement bags of material (or similar types), am I overexposed?

Maybe, likely. But, probably not to silica. Most manmade, off the shelf products do not contain free-silica, or respirable fraction of the dangerous parts of silica. However, there is overexposure to respirable and total dust. But, be forewarned, if the product has rocks in the material, these may contain silica and if you cut the cured product- you can release respirable silica.

So, best practice is to:

• Use a product without silica (look for the warning on the SDS/MSDS, or bag)
• Eliminate any visible dust by water control methods (misting) or use local exhaust ventilation
• Don’t be dumb; stay upwind. Or, at least do the mixing away from others
• Wear a respirator
  • N95, aka paper dust maks is ok** (but, I’ve got a strong opinion of these)
  • 1/2 face tight fitting respirator with P100 (HEPA) filter is best

**You really do not know which respirator to wear unless you have performed airborne exposure monitoring**

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:

Silica:

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.

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.

Noise has some interesting health effects. Most people assume the worst that can happen is you will lose part of your hearing. However, a recent (March, 2014) study in Injury Prevention by Girard, et.al, concluded that those employees exposed to loud noise (above 100dBA) were admitted to hospitals more frequently, and at risk for other injuries.

Some other known health effects include (from Medscape & WHO):

• fatigue
• impaired concentration
• behavioral changes
• irritation
• impaired academic performance
• interrupted sleep (during sleep times)
• changes in endocrine & autonomic nervous systems
• increase in heart rate, blood pressure, vasoconstriction
• sexual impotence
• neurosis
• hysteria

Noise is a simple subject, but there are many factors which influence noise exposure to individuals. Some include:

• The individual: age, prior exposure
• The noise: loudness (dB), type of noise (Hz), distance from noise
• Time: exposure vs. non-exposure time per day

More information on how to control this hazard in construction can be found here.

And, as a bonus, the Journal of the Acoustical Society of America has published a review of the top Smartphone Sound Measurement Apps..  The winner (most accurate) was SPLnFFT, at only $3.99. A close runner up was SoundMeter by Faber. Another summary review is here, and here.

This has to be one of the coolest types of cutting. Raw obliteration of metal.

As you know, hexavalent chromium (Cr6) is generated when the metal, chromium, is heated. Cutting this metal with a plasma torch is an easy way to heat it up quickly.  We performed air monitoring on one employee performing plasma cutting on #304 stainless. Luckily the employee was wearing a 1/2 face tight fitting respirator (and skin protection due to the body readily absorbing Cr6) and we found exposures at 36% of the exposure limits (they were within the acceptable limits). This employee was able to stand away from the cutting due to the machine he was using. He did not do this task all day and no engineering controls (ventilation) was used. 

****Caveat: Please do your own air sampling. Conditions and environment may not be similar to your environment, and they can change rapidly. One sampling event rarely indicates all conditions. We’re talking about people’s health!****Keep in mind welding safety! 

And a close up of the cutting machine without the motor & tracks:

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!).

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.