Industrial Hygiene in Construction

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.

If you have a building built pre 1985 (I know this date can be different, but I’m playing it safe) before bidding a project you need to have an asbestos survey performed, called a building inspection. Honestly, they usually aren’t done before bidding. SOMETIMES, they’re performed before starting the work (not good).

How do you find a good building inspector? …Google?, Yellow pages (who does that anymore?) Abatement contractor?

Whomever you hire, make sure they have a current AHERA Building Inspector Certificate. This is a Federal program maintained by TSCA Title II EPA AHERA/ASHARA Model Accreditation Program. This is your only recourse if something goes wrong. It doesn’t matter if have have a PhD, CIH, ROH, CSP and MBA, they MUST have a current AHERA Building Inspector Certificate.

Here are some things to consider:

• Does the Building Inspector have a current certificate?
• Will they sample for asbestos?
• Which lab will they use for analysis? Their own? (not always a bad thing)
• Which areas are they unable to access in the building?
• Will they check for leaded paint?
• Will they take pictures?
• How long till you will get the results & report?
• Will they write a report?
• Are they capable of performing air monitoring? (worth asking, but not a deal-breaker)
• Will they look back at previous records / management plans?
• Cost?

Good luck in your search. As most things, a good referral from a friend is probably a great starting spot.

Many construction companies have a multi gas meter (s). Here is my word of caution: if you have one, know how to use it.

I bet if you’re reading this post, you do know how. However, do your employees?

This type of training is SO critical. Below are some common mistakes I’ve seen from construction companies using these types of equipment:

• Let someone else (a GC, or subcontractor) tell you if it’s ok to enter a confined space (or hazardous one).
  • = do you own monitoring, & use your own equipment!
• Use someone else’s multi gas meter.
  • =do NOT use someone’s meter unless you 1. know the machine and 2. are able to calibrate and see the documentation. Would you send your employees to work in an area you think there might be a deadly hazard? Treat the 4-gas meter like it is your only available tool.
• Not performing a precalibration and bump test before using the gas meter.
  • = ALWAYS perform a bump test (not just zero-out)
• Not knowing which sensors are inside the machine (and what they mean).
  • =train your employees on when/why it alarms. CO is not CO2.
• Blame the machine if it alarms
  • =the machine is alarming for a reason. You either screwed it up, or something is going on. Figure it out. I had a project where the handheld radios were interfering with the multi gas meter. It took us 2 days to figure this out. Luckily no one was so desperate to work they ignored the alarm. On another project, employees were telling me it was ok to work while the alarm was sounding off. Their response was that, “it always goes off for CO, but we aren’t worried”. Yikes! I was.
• Not knowing what the hazards are
  • =you must know what you are measuring for. If you have isocyanates inside the confined space, the multi gas meter is probably not going to give you adequate warning.- if any. Just like wearing the right type of filter cartridge on your respirator, know the hazard you are measuring.

My friend, Shelley, sent me these pictures of a city maintenance crew hanging up the Christmas decorations in town. These guys have probably been working this way for years. What will take to make them change? Administrative controls? As I’ve mentioned before, falls are the #1 killer in construction.

 

The new global harmonization system (GHS) is officially adopted by OSHA. Each state run program is rolling out their acceptance of the new changes. Where I live, we have until December 2013 to train employees in this new type of hazard communication.

Honestly, I’m NOT too EXCITED about it. But, I’m trying to have a good attitude. Below are some good things which may occur:

• Raise the level of awareness of hazardous materials & their toxicity
• Train employees (hopefully, retrain) on how to handle chemicals
• More training = less citations. (?) OSHA’s top ten citations include #3 – hazard communication. Maybe people will actually do the training?! (my guess is that there will be more citations)
• Consistent information worldwide.  All UN countries should have the same format. (this might take years)
• Proprietary information will be more visible on the SDS. In the new rules, manufacturers are required to list the % of their proprietary ingredients.
• Pictograms! They’re so cool. My favorite is the exploding person.
• Maybe this is my favorite?!: Manufacturers will have to look again at their products and classify them according to the physical & health criteria. Nowadays with more relevant information from worldwide occupational exposure limits, it might help make employers aware of the hazards.
  • This might help OSHA enforce newer exposure limits (other than the 1978 AGCIH TLVs).

How do you plan on training your employees? If you need help, contact me here.

You probably already knew this. Risk changes over time.

As we start to measure, and value, loss we immediately want to minimize it. However, it’s an unobtainable goal. “Zero losses”. Really? It’s not actually possible, you know (at least in the long term).

Look at this graph of the number of deaths in the US over the years due to silica. In 1968 we had approximately 1,000 deaths. Now, in the year 2005, we are less than 200. Yet, OSHA wants us to lower the exposure limit.  (I am personally not opposed to it – but I am open to debate about it, really)

Our world is becoming smaller. But, you already knew this, too.

To give an example, look at what happened in Bangladesh on November 24/25, 2012. Meanwhile in the US, we were watching football and eating leftover turkey.  Over 100 people died due to safety concerns that turned into a fire. This country is going through what the US experienced pre-1970. Other countries have similar problems.

I suppose living in the US is a yet another reason for thanksgiving. Yes…, But.  What can you do to make the biggest impact? I don’t have the answer, but, I am open to suggestions.