Industrial Hygiene in Construction

1. To better understand the levels of exposure(s).

•  avoid possible exposures to employees, document the non-exposure, show how safely you can perform the work

2. To save $.

• Avoid OSHA fines, worker compensation claims, avoid lawsuits, reduce liability

3. To go “Green”.

• reduce airborne emissions, remove harmful chemicals from the environment & employees, recycle & reuse emissions

4. To increase employee morale.

• investigate employee concerns, change environmental conditions to avoid exposures, increase employee involvement, reduce disgruntlement

5. Increase efficiency.

• doing the job right-the first time, less overhead, better prepared for the project and future projects

This blog-post is directed to employees….the drywall framers, hangers, tapers, fireproofers & plasteres who sand and finish mud & drywall.

Question: What type of respirator do you wear when you sand?

…answer? Anything I can find.

This question misleading… and is similar to the one where the attorney asks in divorce court, “Do you beat your wife only when you’re drunk, or all the time?”

But, reiterate.  Do you ever NOT wear a respirator when sanding?  Answer: No. We always wear a respirator. It’s dusty.

So if I may ask a leading question (as a bad attorney): What type of respirator would you wear if you were worried about OVERexposure?

Answer: a tight fitting 1/2 face (or full face, for eye protection & fogging control) negative pressure respirator with HEPA cartridges.

I think I’ve made my point. Why would you choose a paper dust mask? The fit is mediocre, they are disposable, you cannot fit test them (very well). Who cares if it’s a N95 or P100. You can feel the dust escaping around your nose. Below are some “average” pictures of people sanding. What will you do?   more info here

Occasionally I hear of certain (construction) trades having to touch asbestos. Usually it is an electrician, sheetmetal worker, carpenter, or plumber.

How it usually happens is that they have a small remodel/install/repair. They must cut through the asbestos to install the item (duct work, electrical, plumbing). Be careful. If you look at OSHA’s definition you may not be able to perform this type of work without specific training. In some cases, 16 hours of asbestos-specific training!

If you work with any type of asbestos (or, are even near it) you must have Class IV (4) training. This is a 2-hour training which is defined as, “…contact, but DO NOT disturb asbestos…”. As a contractor, you want to make sure you fall under this type of training. The alternative is,

Class III (3) training. This type of training where employees are, “likely to disturb” asbestos.  If you think you disturbed asbestos in your activities, you REALLY should prevent it. Here are some suggestions for making sure you never disturb asbestos.

• Always, always get (in writing) a building survey for asbestos (and leaded paint) before performing work
• Train your employees in how to recognize asbestos, etc. (Class IV training as a minimum. See my earlier post)
• Establish procedures for how you will prevent contact with asbestos

If you must touch (and possibly disturb it) asbestos then also,

• Have specific procedures for how you prevent exposure
• Have PPE (including respirators)
• Obtain air monitoring data while you are performing your activities – document that you DO NOT disturb the asbestos
• Dispose of the material properly

Asbestos is one of those hazards you can’t ignore. If you are not doing the correct procedures, it will bite you (a claim, a citation, a lawsuit, horrible PR, or someone getting ill!).

Who has jurisdiction over lead based paint? Are the EPA’s lead rules all I need to follow? Or, do I follow OSHA?

Well, the short answer (for those in construction) is YES. Usually OSHA, but maybe both EPA and OSHA (*and others, HUD, etc).

OSHA’s focus (as I’m sure you know) is to protect employees. If you are removing leaded on your own home, OSHA has no jurisdiction. However, if you have employees and are working with lead based paint, you must follow OSHA.

The EPA is focused on the environment (of course). They have implemented (April 22, 2008) a rule called the Renovation, Repair & Painting Rule. This rule applies when you are working on any facility which effects kids under the age of 6. If you are contractor looking to work on a project (s) with this demographic, you need to be certified by the EPA. Here is a good starting spot.

It is interesting (maybe just to me) but the EPA has very little enforcement, compared to OSHA. Yet, most people are very aware of the EPA rule. In contrast, I find contractors working with leaded paint who don’t know that they are under OSHA’s rules. I suppose the EPA has done a great job of marketing.

Another interesting comparison is that the EPA and OSHA rules are actually very similar. There are differences, but in general, if you are following the OSHA rules correctly, you are most likely very close to complying with the EPA. (one difference: the EPA requires certification)

As continued from my earlier post, and, a little more to the point…What do you ACTUALLY do when you think you have mold?

Test the air! Perform air monitoring for as many different things as you possibly can. Just kidding. Actually, DON”T do this. (caveat: if you plan legal action-then you might do this)

If there is visible mold/fungus. The first step is to find the water.  In order for mold to grow it must have moisture and a place to grow. There are many places to look including; the roof, windows, seams, ANY penetrations into the building envelope, from below (seeping up), water lines, A/C units, condensation, etc. You absolutely cannot fix the damage or test the air until you stop all sources of water.

Second step, assess the damage. The general rule of thumb is if the damage has altered the substrate (ie, the wood is damaged) then you need to replace it. If it is only on the surface, it may be possible to just clean, dry and seal it. If it is more than 10 square feet of damage, consider hiring a qualified specialist.

Thirdly, repair & replace any concerned areas.

Fourthly, dry it thoroughly, then seal it. Look into methods to increase the ventilation into this area.

Fifthly, inspect and finish. A good visual inspection is far better than air monitoring. If you can still see mold growing, you’re not done.

Finally, clean the ducting & surrounding areas. Please choose a qualified inspector. For some reason this industry attracts lots of bogus contractors.

Air sampling vary rarely gives you any information that will assist you in these steps. Some other good information about indoor air quality and mold from California can be found here.