Safety Policies

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 silica-grinding
  • 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*


Can we measure an exposure accurately with just one sample? (statistically, no.) Also consider: Can we measure a “worst case” scenario and be OK for the rest of the project? (again, hypothetical question)

There was a blog post, here by Mike Jayjock, which reminded me of how silly our data points (aka industrial hygiene sample results) are in the big picture of statistics.  I’m slowly reading a book titled, “Control Banding” by David Zalk who is with Lawrence Livermore National Labs. The CDC also has a section on control banding here.

Another side of this is a common practice we all perform called Risk Analysis. There is much on the subject, but essentially it’s similar to triage at an emergency room. What is the easiest, best thing you can do: given what you have available and what you are able to muster?safety triangle

Too often (myself included) we perform air monitoring for a specific situation and use that information as the gospel-truth. Well, this might be like living in the United States and never traveling. We meet a very nice person from the Ukraine. They seem very typical Eastern European and have a thick accent, but are they really like everyone in Russia? Is this person typical? Are they exactly like every other person from Russia?

This type of stereotyping is the same as taking one sample and drawing conclusions about all exposures. You might be right, BUT…you might be wrong.

There is a fun app you can download called, IH DIG by Adam Geitgey (Apple & Android).  This app illustrates the importance of using statistical tools, rather than guessing. (It’s a game)

Sorry I do not have many answers in this post, just a lot of questions.

I previously wrote about a worst-case scenario in which asbestos was not discovered till after it was disturbed.TSI asbestos

Recently I heard a story of the opposite:

A general contractor hired a company to remove various pieces of asbestos. They had obtained an asbestos building survey, which clearly stated where the  asbestos was located. A boiler with surrounding insulation was identified as non-asbestos containing (asbestos-free). The employee was using a bobcat to demolish the boiler. As he started to tear into the insulation surrounding the boiler (disturb it), he paused. He checked the building survey again, and it had clearly stated it was “asbestos free” (actually 5 samples had been taken of the insulation around the boiler). Then, he did what most other people would not do: HE REFUSED to demo the insulation. He told the General Contractor and owner he thought it was asbestos containing and wanted it tested, AGAIN.

Guess what they found? Yep. Asbestos WAS contained inside the insulation around the boiler.

There was obviously some break-down in communication with the report, inspector, and possibly the lab.  However, this employee is to be commended and, really, the safety culture at this company should be congratulated. You never know where you will find asbestos.  The employee had enough guts to speak up for his safety (and for the others).

Measuring good-safety behavior is the type of thing we should reward. In the past (and still today) many safety-people measure losses ( ie. how many injuries). This is backwards thinking. We should be rewarding good behavior and encouraging people to speak up for safety.

For example; what do you say to this guy?

scaffold ladder

There are only a few instances when you are not required to perform fit testing. The main reason not to perform fit testing is if the employees are wearing a respirator voluntary. (meaning: it’s not required)

So, how do you know if it’s required? It’s required when:

  • You have overexposures to a substance (it’s required by OSHA to wear a respirator- so make sure you know, perform air monitoring), or
  • If everyone is wearing a respirator during this task (it’s probably also required, just not formally- ie. spray finishing, or my favorite sanding drywall dust) or,
  • If your company policy requires them to be worn (management says: it’s required to wearing a respirator during this task).

So, if you choose voluntary to wear a respirator and there is NOT a policy, or law, that says you HAVE to wear one then, you don’t need fit testing. (but you do need a few other things, Appendix D, etc.)

There is only one other exception:loose fitting respirator

  • loose fitting hooded /helmet atmosphere supply respirators (when used in areas not immediately dangerous to life and health (IDLH))

Some employers choose to use these types of respirators because:

  • the employee wears a beard
  • it is convenient to use
  • offers eye/face/neck protection
  • it offers a greater protection factor
  • it’s easier to don/doff (take on/off)

These guidelines for fit testing are different than medial testing before wearing a respirator, as spoken about here.

helmet respirator

If you’ve ever won an award before, sometimes getting the award rarely equates to anything lasting (other than your increased ego). gold starHowever, in construction nowadays, safety awards are HUGE! This is especially true if you are competitive bidding (or plan to in the future). I know companies who have received jobs & project  based upon one (or several) safety awards they have won. Of course they had other things going for them, but the safety award was the tipping point.

I am talking about company safety awards, not safety awards for being safe (see my earlier post, about safety incentives).

I really don’t think it matters where you get the award.

Heck, create your own award! If you’re a GC, or a specialty contractor, why not give awards to your subcontractors or general contractors if they do an amazing safety work, or provide innovation? Print off your own certificates. Or, at the end of your project, ask your owner/GC if they will recommend and/or give you an award for the safe work you’ve performed.

Here’s an example of a construction website’s awards: Russell, James (no connections). Here’s a similar article from EHS Today.


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.

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. hex chrome cleaningIf 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.

AIHA has released (2013) a white paper for guidelines on skills & competencies in silica specific to construction. It is a great outline for training your employees.

Some interesting points:

  • Respiratory protection, and their respective assigned protection factor is mentioned. (Are you wearing the right respirator?)
  • There is no mention of air sampling. Thank you. You do not need air sampling every-time, we already know it’s hazardous.
  • They emphasize control measures for silica.

Another recent publication from IRSST in Canada explains the effectiveness of controls with regard to specific tools and where exposures are found in the industry. It has a lot of information, but if you are looking for the best method to control dust with a certain tool, it would be worthwhile to read the 108 page document.

silica- IIRST graph


The best resource for silica is You can create a plan for controlling it here. They have a database of tools & controls. Very handy. Someday soon we may see 3D printers able to make these dust controls and adapters for us at a moments notice. Until then, pre plan your task.

It’s always fun to hear about new/different situations especially when the contractor handles it properly.


During the start of a demolition on a 1989 structure, the first swing of the hammer produced a pile of vermiculite sand.




After some discussion on “what in the world is this doing inside a wall cavity“. The contractor stopped work, had an asbestos test performed and quarantined the area. The bulk sampling for asbestos came back with the report of “asbestos containing, but less than 1%“. Well, as you know (and as I have mentioned earlier) it may not be safe to treat this product like every other demolition project. In this case, the asbestos was very friable and by opening the wall cavity, it had definitely been disturbed.  The contractor quickly set up some procedures. Here they are:

  • Stop work in area. Quarantine area and place warning on doors.
  • Train employees & subcontractors onsite to hazard (asbestos).
  • Abatement contractor will remove wall & vermiculite
  • Abatement contractor will treat the material as if it is asbestos containing
  • Once the area is abated. An aggressive clearance test will be performed to assure no airborne levels of asbestos are present.

But why in the world was it in there in the first place? The best guess is it was added as a sound proofing / noise dampening for a air conditioning unit (actually a liebert unit) located on the adjacent wall. No other wall cavities contained the material.

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

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