Risk


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.

 

OSHA helps

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)

OSHA lead table 1

 

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 cameraoverexposures. 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.

Industrial hygiene (aka occupational hygiene) focuses on occupational-related diseases due to many reasons.home fireplace

Have you considered, at your home, maybe even as you sleep, you might be exposed to something hazardous? Below are seven possible hazards in your home (related to IH):

  1. Radon. It comes from the ground and they say it causes cancer* (*some people question this toxicological data). You must perform a test to know if you have hazardous levels.
  2. Formaldehyde. If you have a newer house you have 2 things going against you: 1. your house is tightly built (no air leaks and limited fresh air) and 2. more particle board (recycled wood) was used in construction. Also, many furniture contains multidensity fiber wood (MDF) which off gas formaldehyde. Again test for it to know if you have dangerous levels.
  3. Lead. Is your house built prior to 1978? It probably has leaded paint. Any remodeling might distrupt it and you can expose your kids to lead.
  4. Isocyantes. (HDI, TDI, MDI, and others) Can cause asthma & respiratory issues. If your house was insulated with spray foam (polyurethane type) it needs to off-gas for awhile before you move right in.
  5. Asbestos. Causes cancer when airborne. If your house was built prior to 1980, you might have asbestos in your pipe insulation, popcorn ceiling, etc. Be sure and have it checked prior to remodeling.
  6. Mold. Respiratory diseases.
  7. Cleaning products. The symptoms can vary depending on the type of chemicals in the product. Use the recommended gloves, eye protection and respirator, if necessary, while cleaning with chemicals.

Do not be overly concerned about any one thing. Simply test and make any necessary adjustments. However, do keep in mind that most health recommendations for substances relate to normal working adults who go home to a non-hazardous place. There can be issues if you are either: not considered in the general population of healthy workers and, you go home to a place that isn’t free of additional hazards.

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!

EPA PCB Caulk flow chart

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:spray foam

  • 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:

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).

There are some things in occupational hygiene which make our job harder: politics, money, personalities, fiction (not facts), rules/laws and schedules.

However, there is one person who we can blame. Maybe not entirely, but he epitomizes the opposite of protecting people’s health. Thomas Midgley, Jr. Who? Yea, he’s new to me too. Thomas Midgley

This guy has killed millions of people. Maybe not directly, but through his politics and lack of ethics. Here is a great article from Seth Godin on this guy. Essentially he allowed lead to be added to gasoline, AND, helped to provide CFC (chlorofluorocarbons) to products. However, he probably got what he deserved: He died from his inventions. It is easy to look at hindsight and blame him, but at the time, I wonder what he was thinking? My guess is money.

The enemy of Occupational Hygiene is probably not Thomas Midgley. It’s our ethics. If we fail to make the right choice every time, where does that lead us?

If you’re reading this, you probably don’t suffer from an ethical-failure to protect people. (Most people in safety don’t.) Rather, you should pat yourself on the back and keep doing the right thing. Good job.

 

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.

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:

live work

focusfourMuch 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.

ladder

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:SDS

  • 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.

I’m easily impressed with welding and welders. Welding looks so simple, yet hard, dangerous and permanent.

When interviewing your welder, here are some questions to ask:weld1

  • What type of welding are you doing?
  • What type of metal do you weld on? (mild steel, stainless, galvanized)
  • Is there any coating on the metal?
  • What type of flux is used?
  • Where do you weld?, and then, “Where else?”
  • Is there any ventilation in the area you weld?
  • Are there any flammables in the area?
  • Do you wear any PPE when welding? (ear plugs, respirator, leather)
  • When do you use fall protection?
  • Do you have & use welding shields?

What makes welding so difficult is the number of variables involved. The welding variables can change by the minute. Educate your employees on these dangers.

After the above questions, if the employee is agreeable, I ask some additional questions. These are the ones that provoke the best stories:

  • What is the strangest things you’ve welded?
  • Have you ever welding in a really small (confined) area?
  • Have you ever welded with exotic metals? fluxes?
  • What’s the worst thing you’ve welded on?
  • Have you ever gotten sick from welding?

There are many, many more questions to be asked depending on the answers. The authority on this subject, Michael Harris, has written an excellent book on this subject, “Welding Health and Safety“(ISBN 978-1-931504-28-7). It is available from AIHA. It is VERY detailed, and money well spent if you do welding. I have taken his short course (all day) and I learned more than I ever thought possible, and I still can’t even weld!

weld2

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