Industrial Hygiene in Construction

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 
• 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*

I was recently forwarded an article on a gentleman who won a large sum of money ($8.75 million) for an asbestos related disease. There are many people getting these types of settlements for similar exposures.

However, what is interesting, is the attorneys argued the company knew about asbestos in 1965, but the exposure occurred in the 1970’s. Keep in mind, the asbestos rules at OSHA didn’t come out until the 1970s as well. So, exposure occurred before the regulations were in effect.

So, they knew of the airborne hazard, but continued to exposure workers before there was a rule. Does this sound like any modern day issue?   –hint– silica?!

Nowadays with the public being uber-aware of “potential” airborne hazards (mold?), with information so readily available, with OSHA rules outdated (annotated Z1 tables), and others publishing health standards like ACGIH,….the lesson is: protect your employees.

I don’t think we should be arguing about the OSHA rules. Let’s use available information and science. “More Than Just A Number” (article published by AIHA, May 24, 2016).

You’ve probably heard the Federal silica proposed-rule has moved in it’s next step towards being a promulgated-rule.

And, you’ve hopefully looked at my prior post about the positives and negatives of the rule. I am usually not in favor of more rules, but as a safety person, my overall opinion is the new rule would be good.

However, there is some opposition (EHS Today Summary Article) from a few industry groups and associations, including ARTBA, NAM, and the ACC in an article to plastic manufacturers. And just recently a lawsuit was filed to stop the rule. They have some good arguments, of which, I think the best are: THERE ARE ALREADY OVEREXPOSURES at the current PEL, and silica related deaths have been in decline for decades.

The ACGIH and NIOSH have been recommending lower airborne limits for years. If you are a construction firm, hopefully you already have (engineering & administrative) controls and respiratory protection in place. If not, the best time to start was yesterday, and the next best time is tomorrow.

OSHA has recently announced the final time frame for the proposed silica rule. February 1, 2015 is their anticipated rule promulgation. However, we will see if anyone protests this new information, and if the date for final rule “sticks”.

AIHA broke the news (at least to me) and you can see their summary here. If this is the first you’ve heard about this new rule, then it’s time to do some research, and I might recommend starting here. There are quite a few new requirements, including a lower permissible exposure limit (PEL).

Question: During mixing of portland cement bags of material (or similar types), am I overexposed?

Maybe, likely. But, probably not to silica. Most manmade, off the shelf products do not contain free-silica, or respirable fraction of the dangerous parts of silica. However, there is overexposure to respirable and total dust. But, be forewarned, if the product has rocks in the material, these may contain silica and if you cut the cured product- you can release respirable silica.

So, best practice is to:

• Use a product without silica (look for the warning on the SDS/MSDS, or bag)
• Eliminate any visible dust by water control methods (misting) or use local exhaust ventilation
• Don’t be dumb; stay upwind. Or, at least do the mixing away from others
• Wear a respirator
  • N95, aka paper dust maks is ok** (but, I’ve got a strong opinion of these)
  • 1/2 face tight fitting respirator with P100 (HEPA) filter is best

**You really do not know which respirator to wear unless you have performed airborne exposure monitoring**

There is a lot of confusion over confined spaces in construction. OSHA is enforcing these rules since Aug 3, 2015, but has given a 60 day postponement (effective Oct 2, 2015). Right now you need to make “good faith efforts” to comply. For those in construction, you need to get up to speed, and even more importantly, get confident. Unfortunately, this information isn’t going to get you 100% there.

The reason confined spaces (and the rules) are so complicated is because every space is different. It’s not a minimum height guard rail, or fall arrest system. There are just too many factors, including: 

• the size (or smallness)
• the ventilation (or lack of)
• access (or lack of)
• the work activity (what you introduce)
• the hazards (before you enter, and what you introduce)
• the people inside (people are different, and work different)

To begin getting educated, here are my suggestions:

• Know the definition of (and when it’s) a confined space (hint: 3 things)
• Know the location(s) of your confined spaces (AND mark them as such)
• Train your employees and yourself
• Buy a multi-gas meter
  • And, know how to use it, bump it, and calibrate it
  • And, train others
• Know: host employer, controlling contractor, sub contractor, mobile worker. It may not be obvious.
• Know: ventilation. When you can use it,  what changes, and how much you need
• Understand “rescue”.  And, the answer is not calling 911.

When an accident happens in a confined space, there’s a high likelihood it’s a fatality.

If you have confidence in the rules, and, more importantly, in the hazards & controls, confined spaces can be safe.

If you haven’t already heard, it is worth while to mention,OSHA now has jurisdiction over confined spaces in construction (in force on August 3, 2015). Hopefully those working in construction have already realized this hazard and have taken steps to prevent injury.

Here are some of my thoughts:

• **although there are many factors, and we should not compare hazards** OSHA estimates an “injury saving” of 780 serious injuries, and 5 lives spared with the confined space rule.  Compare this with the estimated injury saving from the proposed silica: prevent 1,600 cases of silicosis and save 700 lives.  (and, I do realize these cost employers different amounts of $)
• Oregon OSHA – confined spaces already has a (new) construction confined space standard, which is very much different. It will be interesting to see if this; meets/exceeds/or needs to be changed, to comply with the federal rule.
• Since this rule was dropped without much warning, we will wait to see if anyone calls “foul”. Other than political reasons, it is hard to imagine a reason why construction should be exempt from these rules.
• There are some differences in the construction rule and the general industry:
  • Multi-employer work sites are covered
  • Continuous monitoring – when possible engulfment
  • Upstream early warning- when possible
  • Suspension (not cancellation) of a permit

NIOSH (and with the help from some other groups) released a document this last week titled, “Best Practice Engineering Control Guidelines to Control Worker Exposure to Respirable Crystalline Silica during Asphalt Pavement Milling”. 

The issue: These machines are used to remove asphalt roads. They have a drum with teeth on them that essentially chew up the road and asphalt. A lot of respirable silica is generated (based upon the amount of silica in the rocks). The drums get really hot so water is used to cool it.  However, it does not control the respirable silica dust.  I’ve written (or, maybe complained) about the issue here, in 2010. And, I was informed, some good people were working on it.

The solution: The quick summary is: add more water and ventilation. Not rocket science, right? However, after reading this document, it might be. There’s a lot of information and specifics on what worked, and what didn’t. It was almost too much detail, but I suppose if you have a $200k+ machine, it is worth the time to figure it out. Below are some details:

• Case studies – adding water and increasing the pressure flow decreased airborne dust
• Tracer gas studies for ventilation effectiveness
• Checklists and flow rate controls
• Diagrams for where to direct water

Another benefit was the documentation of other’s work. There are numerous references  (5 pages!) to scientific articles. I did not notice any cost to implement the recommended changes, and I am curious to know what adding the ventilation system might run. Overall the document is good.

Finally, if you hold-on and continue reading to Appendix C, let me know what that all-means.  🙂

You’ve probably heard of this issue in the news, originally from the CBS News 60-minutes Show, March 1, 2015.

Formaldehyde is NOT good to have indoors, especially with kids (or those with upper respiratory issues). I believe there are a lots of homes and facilities with issues (which are not reported).

There are is some good information out there if you are worried you may have this flooring in your home or business. In summary, here are some notable points:

• you should really ignore the people pushing this issue (remember they shorted the stock before the news story)
• formaldehyde is used in a lot of product during manufacturing
• go to Lumber Liquidators and get your free test kit
• if you find high levels of formaldehyde, do something.
• But, the solution may not be to tear out your floors.
• Remember, formaldehyde can come from many sources.

Here’s a good article on the subject from Galson Labs. If you have concerns, hire a qualified industrial hygienist.

Here’s my top 5 gifts for Christmas in the (my) occupational hygiene world of construction:

1. A new carbon monoxide monitor.
   • Not just a “normal” $40 model. A Nest Protect Fire & Carbon Monoxide monitor, which is in the $100 range. This thing is sweet. Talks to you, sends you a text message. Here’s a review from Cool Tools. Or, just buy it here.
2. High flow air pump, Gast model.
   • I have some other flow rate pumps up to 5 liters per minute (LPM), but this one is great for flow rates 10-up to 28 LPM (depending on the model). Good for high volume area type samples and vacuum wipe sampling. You must have 110 power available, but once calibrated, it’s a done-deal. They can be bought for under $250. Grab a rotometer too, if you don’t have one.
3. Wireless response system to use during training.
   • Attendees have a wireless response keypad and the trainer can ask a multiple choice question. It allows the audience to reply. The results then show up on the screen. Great for anonymous responses, or a general overview from your audience. There are several vendors, here’s an example, and the leader in the industry is Turning Point. I think these are in the $500-$1,000 range.
4. A bulk asbestos example kit.
   • A bunch of “typical” building materials which are asbestos containing. In sealed glass jars, of course. I don’t know where you’d buy this sort of thing. I wish I would have kept all of my samples over the years.
5. A dedicated short term silica sampling kit.
   • SKC has a new sampler which can sample at a higher flow rate  of 8 LPM, compared with the usual 2.5, or 1.8 LPM. (which, if you think through the math; allows you to achieve a detection limit with a lower sample volume, and a shorter time duration) Unfortunately, you must purchase a new SKC Leland pump/charger, PPI sampler, calibration junk. Total cost is probably in the $2,000 range.