Industrial Hygiene in Construction

Did you know that there are two ways to get industrial hygiene sampling for free? I know, there’s always a catch, but below are my favorites.

1. OSHA

Obviously if you have an inspection and they perform air monitoring, you can use this information. Hang onto it! Get the field notes from the inspector so that, if necessary, you can reproduce these results. There is also (in some states with state-run plans) a separate division who can provide consultative air monitoring and/or assessments. I strongly urge employers to use this method. While your company is under consultation, they are under obligation to NOT allow an inspection (there are caveats).

2. Insurance carrier
   Your company’s insurance carrier can many times provide industrial hygiene services. This might come from your worker’s compensation carrier, your general liability carrier, and sometimes even your agent. If you have a legitimate concern and are able to wait to meet their schedule, this is a very attractive option.
3. The General Contractor
   If your GC has hired an IH consulting firm for a similar type process that you are performing, see if they will also take a sample on one of your employees.
4. Your Sub Contractor
   If you’ve hired a subcontractor to provide abatement for asbestos, or lead, request that they also perform a test on one of your employees. Sometimes even a sub-level tier will provide this as a courtesy.

I think the key to each of these is being nice. If you are a jerk, or attempt to strong-arm your GC or sub into this, it will never happen. In the safety world, most people want to help- that is why they got into this business in the first place.

Industrial hygienists are usually defined by the job functions they provide. Many of these activities overlap with safety, environmental, toxicology, compliance, scientific, mathematics, physics, medical, and sometimes legal.

The AIHA’s definition is (and I summarize):

• to recognize, evaluate and control environmental factors, elements, and stresses in the workplace which might affect the health of workers

Primarily the job functions include:

• investigating & examining workplace hazards
• training & educating employees on health risks in the workplace
• reviewing MSDS
• performing air monitoring to assess employee exposures
• making recommendations to control workplace hazards
• recommending personal protective equipment
• providing insight/counselling for an employer, or for employees on hazard risks

I don’t have a good “elevator pitch” when describing my work. It’s just too complicated. I usually start out with, “I sort of work with employers and employees in regards to safety & OSHA”. It’s a horrible intro and I wish I could get away from it. Unfortunately, most people know and understand OSHA. We need to do a better job of, 1.explaining what we do and, 2. educating people that there are more effective ways to protect employees than OSHA compliance.

I’ve also heard the jokes. IH = industrial hyenas. 

OSHA states that:

• Medical exam – must be completed prior to wearing a respirator. The individual must be examined again if there are significant changes to their medical/respiratory system.
• Fit Testing– this must be performed yearly (either qualitative or quantitative fit test, depending on the respirator) and be performed for each type of respirator worn (not for each filter used)
• Fit Checks- these are performed every time an individual puts on a respirator. Cover the inlets and breathe in (mask should collapse). Cover the exhale valve and breathe out (mask should expand)

Individual cards for employees are not required. Sometimes, when filing the medical exam, the physician/medical reviewer, will not require the individual to come into the office. As a best practice, I would have every employee fill out the paperwork and see someone in the medical office. Employees have every reason to want to pass this “exam” and they may leave out things on the written exam that are easily discovered (or may be obvious) when someone sees them in person.

…..: Red paint.

The point for the day is to remember that your sense of smell can be very good, or very misinformed depending on what you’re smelling (and who you are).

Sulfur (sulfur dioxide) can be smelled when it’s as low as 0.009 parts per million (ppm). The exposure limits are at 5 ppm. There are many chemicals that work just the opposite.

Before you make an assumption, figure out what you are smelling.

This question, at times, can really make a difference with how you proceed. Where you get your information, and, more importantly, who provides the information is essential. Not only for compliance, but also for how your employees are protected.

Unfortunately, the answer is often complicated.

To address this question, the answer is YES. They all might overlap depending on what you are doing, and in what situation. I will attempt to briefly summarize when each specific rule or standard might apply.

• OSHA – if you have employees and they work for you – you must comply. Sometimes each state (Washington, California, Oregon all have their own) may have a specific rule that enforces a bit differently, but Federal OSHA is the minimum rule.
• MSHA – if you are operating in a mine (surface or underground) they have jurisdiction. Your shop may (or may not) be in their umbrella.
• ACGIH – If they are referenced, it is usually a good practice to follow their rules. Look specifically at the date of the information. ACGIH updates their information yearly and is protective of the employee. Follow these rules if at all possible.
• AIHA – Another good recommended source of information (like ACGIH). However, they just announce they will not be updating (due to funding) their WEELs and BEELs.
• State rules – Occasionally, or more likely, depending on the specific issue, states will make specific rules. The Department of Human Services or similar will provide protective rules for the public. This may be an issue if your are working on a public project, or where small children, HUD, or other specific situations arise.
• Local rules – Similar to the state rules, sometimes a city will make rules to protect it’s citizens. Being active in the local community is the easiest way to find these rules. Searching through the local city or county rules is a chore, but may reveal some obscure rules.

Finally, at more importantly, why are we looking at rules?

I would suggest focusing on employee health, employee concerns, best practices, and available data to best help our employees. They perform their jobs for a long duration in the day. They usually have the answer, or the best suggestion for fixing it…if we would listen.

There are many distinct, separate, and important issues when entering a confined space. The point I would like to make is, as a manager of “safety” , Do you allow your employees to enter a confined space?

Most employers do (with consent, acquiesce ). Below are some questions to consider.

• Do employees know what a confined space is? (see OSHA definition)
• Do they know if it is a permit required space?
• Have they been trained? (this is a separate question)
• Do you control the space? What about the space around it? (what about the space where the air/water comes from?)
• Would you allow any employee to enter?
• Who would you NOT allow? (subcontractors? safety personnel? inspectors?)
• What paperwork/training would you want to see if you did allow these people to enter?

The management of confined spaces is by far the most critical piece. The space could be as innocent as a treehouse, or as dangerous as sewer hole immediately dangerous to life and health.