Industrial Hygiene in Construction

To raise awareness for construction fall protection, OSHA is asking for construction employers to join them between June 2 – 6, 2014 for employee training on the subject.

At OSHA’s site, you can find out how to:

• conduct a safety stand-down
• get additional resources; videos, wallet cards, etc
• print a certificate
• get a company poster (even in spanish)
• share your story

And, look at my earlier posts for more additional resources.

Let’s clarify: You are a working adult. You are feeling symptoms (of some sort). And, you think it’s from something your exposed to while at work (in construction). This could include, but will not, the flu-bug. Below is a list of the most common construction illnesses.

Most Common Construction Illnesses:

1. Upper respiratory
   • could be from silica, drywall, dust, asbestos, nuisance dust, chemicals (I won’t even try to list all of them)
2. Skin (dermal, dermatitis) damage –
   • From: concrete, abrasion, chemicals
3. Eyes
   • mostly from things that get into the eye.
4. Cumulative trauma (ergonomics) or inflammation
   • repetitive motion, over a day hurts, imagine this for years
5. Burn (heat or chemicals)
   • Usually around hot work like welding, but this can occur when using certian chemicals
6. Hearing loss
   • cumulative trama to the ears when exposure is above about 85 decibels for any extended period of time.
7. Poisoning– General or systemic
   • From: poison ivy, stinging needles, dog bites, bees, etc.

This list may vary depending on many things including what type of construction you are in; GC, heavy, civil, specialty, etc.  I put this list together to get a picture of where we see illnesses. However, as previously mentioned, and, everyone knows, the FOCUS FOUR is really where most injuries occur in construction.

We have seen the most prevention of illness due to one single device:

the back support.   ha. just kidding, of course.

If you live in the United States, you have less than one month to train your employees on the new Hazard Communication standard (1910.1200(h) & 1926.59), which should include information about the new types of Safety Data Sheets (formerly known as MSDS) and the adaptation with the Global Harmonization System (GHS). December 1, 2013 is the enforcement start date for OSHA. Don’t make this complicated, it is straightforward. Here’s what you should do:

• Train employees in hazard communication (simply: so they know the hazards they are working with)
• Document your training (in case of an OSHA inspection)
• Show them a sample Safety Data Sheet (SDS), compared with the old MSDS
  • Explain the new standard hazard phrasing & pictograms
  • Explain how to review a SDS
  • Remind them about container labeling
• Explain that the new SDS will not be available immediately, but will roll-out over a few years (or more)

*Please note the “Beer” hazard warning on the right is not GHS compliant. 

For Help:

• Oregon OSHA (OR-OSHA has a new fact sheet on what you need to do for compliance.
• Here’s a link to a sample hazard communication plan (in Word!). More help here.
• AND, a free training guide for employers, another here. Shout-out to Siobhan & Dan at SAIF for this.
• Also, some Susan Harwood free training materials here (spanish too!).

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.

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)

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 camera” overexposures. 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.

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:

• 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:

• isocyanates (people can die, and get asthma), and it is a OSHA Emphasis Program, and OSHA page here
• amines
• VOCs (volatile organic chemicals)
• flame retardants (PBTs)
• Blowing agents (EPA link)

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 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 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.

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.

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.

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.

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.