Industrial Hygiene in Construction

Only the enforcement of the new silica rule has been delayed until September 23, 2107.  The Federal OSHA silica rule is still being implemented and will take effect on June 23, 2017.

OSHA says in their memorandum they are delaying the enforcement because they hope to develop additional guidance materials and train their compliance officers.

I suspect that many individual state plan OSHA (like Cal-OSHA, etc) may also delay like Federal OSHA, whether or not they announce it.

The new silica rule for construction is a lot of work, retooling, and training. If you haven’t started, there’s no time to lose. I would suggest you start by:

• Examine the tasks you perform which may have dust exposure (grinding, concrete cutting, milling, etc.)
• Refer to the Federal OSHA Small Entity Guide and see if you are properly tooled (have the correct equipment to control exposure)
• If the tasks aren’t listed in Table I – then you have more work to do (look at alternative control methods)
• Train your employees. Both in general awareness & for the competent person. Consider making your own company training video (like this one). Don’t worry, it doesn’t have to be awesome Hollywood cinematography…but having a training which is specific to your company, tools, and activities is best.

There is a lot more to the rule, but the above steps are the best place to start.

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)

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.

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.
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.

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.

Since you are reading this, you probably know the answer. Everyone. But, who is everyone? It should include your CEO/Company President/COO (or similar). If not, I guarantee you aren’t working as safely as possible.

The reason:  The person doing the work usually isn’t involved in the bidding & planning of the project.  It’s not always the President’s fault that the proper safety equipment wasn’t bought, or there are no available tie off points on the roof. (But, it might be their fault if they are willing to press forward without making changes.)

Here is one way to deal with these issues. Train the CEO (President/COO/Project Manager/Estimator) beforehand. Here’s how:

• Make the training for them. 
  • Don’t talk about safety harnesses, or the three different types of asbestos.
  • Go over big items (where are your claims? what are similar claims for your industry?)
• Emphasize the proper methods to control any hazard:
  • #1 engineering controls
  • #2 administrative controls
  • #3 PPE (in that order!)
• Get them to contact you during the bidding process (not after you’ve won it). Talk about what might be dangerous work & plan for it.
• Share a success story. Ask a superintendent to explain how they controlled a possible exposure.
  • Did they make the architect install in a tie-off point?
  • Did they ask the owner to change adhesive products to a less hazardous one?
  • Did they use an abatement contractor who performed the work well?
• Keep it simple & short. You don’t need a lot of time, but you do need them all on the same page.

When everyone in the company has the same interest in safety, it isn’t hard to explain.

The Oregon GOSH (Govener’s Occupational Safety & Health) Conference is coming March 4-7, 2013. This is a great opportunity to get some information, education, and networking.

My suggestion is to attend the Tuesday and Wednesday sessions and cram-in as much as you are able. My break-out course is hidden well in the schedule, and will be easy to miss due to the other great sessions going at the same time. But, this is why I put a lot of my information on this website!

Hope to see you there.

I’ll admit it. My elevator pitch is not the best. I have a hard time trying to briefly describe what I do as an industrial hygienist. I usually answer the question with a recent example of a interesting project.

What would you hire an industrial hygienist for? Well, this article describes exactly when you would hire one. I bet the haz mat crew has at least one hygienist investigating this concern.

AIHA has published video on what IHs do and our job function (s). They did a much better job than I could have done, but, the video is NOT as exciting as real-life.

As common as it sounds, falls in construction are still the #1 killer.

Go to www.osha.gov/stopfalls

This site has good information, reminders, training, and resources.

I recently gave a safety presentation to a large group of pile bucks (for those who don’t know, these are highly trained workers who drive pilings into the ground, among other things). All of my preplanning for the presentation was for nothing.

The projector didn’t work (I did have a backup, but not enough time to get it ready). And, as I was being introduced, they requested I also cover an entirely new topic that I hadn’t prepared for… I was scared.

The presentation actually went well. I wasn’t tied to my notes or slides…I had a lot of interaction with the crowd and they asked questions and commented on specific issues they deal with on projects. I didn’t look at my computer, prompter, or behind me. I took less time to cover the same points. I looked at everyone in the crowd and was able to engage them and change my presentation(slightly) based upon their reactions, comments, and interests.

Afterwards, I realized they learned. Maybe not as many “facts”, or points on the subject, but they sure remembered the main objectives:  Be safe. Use caution. Think ahead.

I am going to attempt more presentation just like this.

I have seen presentations given like this, but I never have the guts, or confidence, to do it that way. In fact, thinking back, I had read a blog (Seth Godin) of these exact things to do. I hit almost all of them….by accident.