Safety Programs


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.

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 silica-safe.org. 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.

This type of potential exposure usually doesn’t cross my mind. Luckily, the specifications in the construction project (and the obvious towers nearby), alerted us to the hazard.

If employees are working near areas of potential high electromagnetic (EM) activity, you should do something (see below). High EM potential areas are power lines, cellular towers, TV/Radio broadcast sites, etc. We have all heard the dangers of living under high voltage power lines, and this is essentially the same concern: Non-ionizing radiation.

The FCC has a guidance document OET-65 (radio frequency) which has some recommended limits, called maximum permissible exposures (MPE). These limits vary depending on the frequency range and how close/what type of work you are doing nearby. OSHA (1910.97) has some guidance (based upon an old ANSI standard) and the ACGIH also has recommended limits. New research is ongoing due to the increased use, and the future demand, of cell phones. The clearest guidance is from IEEE (C95 radio frequency). They provide recommendations and a sample plan. But, to summarize:

  • look for the source (s) of the radiation (sometimes it’s not obvious)
  • take measurements (might be difficult, unless you have access to a field intensity meter) Ask the FCC?
  • determine risk potential
  • make a plan
    • develop controls – time & distance are easiest radio tower
    • consider off-hours/ shut down of towers (in extreme cases)
  • train
  • consider:
    • cranes, large pieces of equipment that may resonate with a certain frequency
    • heat from stored energy
    • nondescript symptoms, which is usually the first sign of a problem

This is a somewhat new field (no pun). But, remember when power lines, cell towers, and tv/radio stations were installed. – The goal wasn’t to keep these away from people, it was to bring them closer. How close should we get? I’d love to hear if anyone has been dealing with this a lot in construction.

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

There is a lot of confusion about N95 paper dust masks. And, it is confusing. The reason is because NIOSH has rated this type of equipment as a respirator. Prior to this, it was called a “comfort mask”. This name sounded better than calling it, “a worthless false sense of protection”. It is now called a, “dust mask”, or a “filtering face-piece”.

Here is what is required by OSHA if you wear this type of respirator (N95, or similar):n95

  • Employees must read and sign Appendix D (of the OSHA respirator standard)
  • Employees must clean, inspect, and store their dust mask

That’s it.

UNLESS you are wearing this because:

  • Your employer requires it
  • You have overexposures
  • or, nobody “wouldn’t wear it”. (meaning: it’s an industry practice, and when when we do this XXX task, everyone wears this type of respirator– this is the same as your employer requiring it)

If  any of the above statements are true, then you have more to do. Here are links for more information:

Voluntary Use of respirators

Fit testing

Getting ready to wear a respirator

Professionally I do not recommend these type of respirators. Email me if you’d like to know why.

Before you can wear a respirator here’s what has to happen:

If you’re an employer and your employees wear a respirator, they are required to have a medical approval (Appendix C of OSHA respiratory standard). more details here.

The employee fills out the confidential questionnaire and then submits it to the medical provider of the employer’s choice. 95% (I made that # up) of the time, based upon the questionnaire ONLY, they give an approval to wear a respirator.

Occasionally, some employees are requested to come into the medical office to have a spirometry test performed, which tests for lung function. (a video of how it is done, cool accent included) This tests provides more information for the physician/nurse to determine if wearing a respirator will be too difficult for an employee to wear.

The cost for either test is usually pretty close to the same price… spirometry test, or not.

Here’s my suggestion:  Have every employee perform a spirometry test before wearing a respirator. This helps to guarantee they are capable of wearing a respirator. Maybe they forgot to list a risk factor, maybe they have a hidden serious lung problem, or, maybe they lied on the questionnaire so they can wear a respirator and keep their job.?

It is also beneficial for pre-employment screening, claims defense, and for a baseline in health. The specific results are usually NOT view-able by the employer, but they can be subpoenaed.

 

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?multi meter

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.

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