Industrial Hygiene in Construction

If you have a building built pre 1985 (I know this date can be different, but I’m playing it safe) before bidding a project you need to have an asbestos survey performed, called a building inspection. Honestly, they usually aren’t done before bidding. SOMETIMES, they’re performed before starting the work (not good).

How do you find a good building inspector? …Google?, Yellow pages (who does that anymore?) Abatement contractor?

Whomever you hire, make sure they have a current AHERA Building Inspector Certificate. This is a Federal program maintained by TSCA Title II EPA AHERA/ASHARA Model Accreditation Program. This is your only recourse if something goes wrong. It doesn’t matter if have have a PhD, CIH, ROH, CSP and MBA, they MUST have a current AHERA Building Inspector Certificate.

Here are some things to consider:

• Does the Building Inspector have a current certificate?
• Will they sample for asbestos?
• Which lab will they use for analysis? Their own? (not always a bad thing)
• Which areas are they unable to access in the building?
• Will they check for leaded paint?
• Will they take pictures?
• How long till you will get the results & report?
• Will they write a report?
• Are they capable of performing air monitoring? (worth asking, but not a deal-breaker)
• Will they look back at previous records / management plans?
• Cost?

Good luck in your search. As most things, a good referral from a friend is probably a great starting spot.

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?

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.

Controlling most of these types of exposures is really simple. If you know the job- and you know it will generate airborne silica = Pre Task Plan!

I wish Superintendents would enforce their project managers, or project engineers, to make a pre-task plan for every concrete/silica producing task. Then, (please don’t stop yet), review the plan once the project starts!

Below are two examples with different outcomes:

1. Cutting concrete block.

The pretask plan called for a garden hose with attachment(s) to wet the cutting area. Everything was perfect until the water was shut off. But, they improvised and found an electric water pump with bucket and recycled the water. It was a great outcome. What if the power went out? They could have used a Hudson sprayer.

2. Grinding plaster off a brick wall.

They built an enclosure and containment. They had a negative air machine with HEPA filters. They had a vacuum with HEPA filters, tyvek, 1/2 face respirator, eye protection, etc. But, as they worked the vacuum couldn’t keep up with the amount of dust generated by the 7 inch Bosch grinder. It was really dusty. They worked like this for days. No one onsite saw them because they were in containment. Unfortunately  the project is almost over and it could have been better. A simple shroud to the grinder, like this one (no endorcement) might have controlled the dust & silica. Sure, it might have been troublesome to find the exact one, and get a vacuum attachment, and have the extra weight, and ….

So, let’s talk to people about silica, talk about solutions, and then check to see if they’re effective.

You probably already knew this. Risk changes over time.

As we start to measure, and value, loss we immediately want to minimize it. However, it’s an unobtainable goal. “Zero losses”. Really? It’s not actually possible, you know (at least in the long term).

Look at this graph of the number of deaths in the US over the years due to silica. In 1968 we had approximately 1,000 deaths. Now, in the year 2005, we are less than 200. Yet, OSHA wants us to lower the exposure limit.  (I am personally not opposed to it – but I am open to debate about it, really)

Our world is becoming smaller. But, you already knew this, too.

To give an example, look at what happened in Bangladesh on November 24/25, 2012. Meanwhile in the US, we were watching football and eating leftover turkey.  Over 100 people died due to safety concerns that turned into a fire. This country is going through what the US experienced pre-1970. Other countries have similar problems.

I suppose living in the US is a yet another reason for thanksgiving. Yes…, But.  What can you do to make the biggest impact? I don’t have the answer, but, I am open to suggestions.

You must follow both. (I’ve mentioned this before)

OSHA’s rules are very detailed and apply to any amount of lead in paint (even less than 0.5%) if you are disturbing it. The only time OSHA rules do not apply is:

• if you are working as a sole-proprietor (no employees), or
• if you are in some other country.

EPA’s rules are just a start. They apply to any residential facility where there are kids under the age of 6. OSHA’s rules are much more comprehensive and protective. (in some instances, overkill)

To EPA’s credit, they have done a great job of marketing and letting contractors know they insist on compliance. OSHA, on the other hand, only inspects 2% of businesses/year and does virtually no marketing. The chances of OSHA showing up on any given jobsite, is nearly 0%.

OSHA’s rules are very complete and comprehensive. You WILL need air monitoring, blood monitoring, PPE, change areas, water/sanitation, and training. The worst thing you can do is NOT follow the OSHA rules, find overexposures, and then try to “make up” for it. From my experience this scenario is a bad place to be, and happens all the time.

People who work in industrial hygiene try NOT to admit fault. There are reasons;  legal implications, credibility, and of course, pride. Since this blog is about being transparent, I will confess I made a huge mistake. My mistake wasn’t disastrous, but it could have been.

Background:

Employees were using a hudson sprayer (pump style) to apply a liquid waterproofing material. Air monitoring was performed and found to be 50% of the OELs. However, given the environmental conditions, and different areas they would need to access, I recommended they wear 1/2 face respirators. The hazard was isopropyl alcohol and a 1/2 face respirator with organic vapor cartridges was sufficient, with goggles & protective clothing.

However. It wasn’t isopropyl alcohol….it was methyl alcohol (methanol). And, there is a HUGE difference. Organic vapor cartridges (filters) provide NO protection to methanol. I should have recommended supplied air respirators.

I feel terrible, and I apologized.

“Success does not consist in never making mistakes but in never making the same one a second time” – George Bernard Shaw

The answer is Yes.

If you are working with lead (in any amount) and you are performing any of the “trigger tasks” in construction = you must follow OSHA rules. Trigger tasks are demolition, removal, encapsulation, new construction, installation, cleanup, abrasive blasting, welding, cutting, torch burning, transporting, storing, heat gun work, sanding, scraping, spray painting, burning, welding, etc. What about the EPA rules (RRP)? Look here.

The only exceptions to not measuring employees blood lead are:

I’ll admit it. My elevator pitch is not the best. I have a hard time trying to briefly describe what I do as an industrial hygienist. I usually answer the question with a recent example of a interesting project.

What would you hire an industrial hygienist for? Well, this article describes exactly when you would hire one. I bet the haz mat crew has at least one hygienist investigating this concern.

AIHA has published video on what IHs do and our job function (s). They did a much better job than I could have done, but, the video is NOT as exciting as real-life.

Background: A new client recently had an OSHA health inspection (industrial hygiene). He received citations stemming from overexposures(they found levels above the PELs) to airborne particulates.

The company wondered what to do next. Here were my suggestions:

• Fix the problem. You will need to comply and assure that your employees aren’t overexposed. Even if the inspection made you upset, use your energy to make the situation right. Focus your energy on removing the hazard, not complaining about how you were treated.
  • Engineer the problem out. Remove the hazard. If not,
  • Change your policies so no one is further overexposed. If you can’t fix it by the this, or the above method, then,
  • Provide personal protective equipment to affected employees.
• Request the full inspection package. – this will include the officer’s field notes, interview questions, observations and sampling methodology.
  • look through these documents carefully
  • keep them for your records
•  Informally appeal the citations.
  • at the appeal show them you have complied/changed
  • ask for a reduction in fines (it never hurts to ask)
  • ask to group the citations together – instead of citation 1 item 1a, 1b, item 2, etc. ask to narrow it down to just one
  • bring any additional information which supports your side and/or the changes you’ve made (including training docs, programs, policies, etc.)
• Resample the areas.
  • make significant changes to these areas. Then,
  • hire an industrial hygienist to perform additional sampling in these areas
  • ask them to document the changes you have made to reduce the exposures
  • review this with your safety committee & those affected

You already knew it. There is a lot to do in industrial hygiene. At times this occupation feels like a safety middleman trying to keep people out of trouble. Occasionally I’m rewarded with really helping someone. In the United States, there is still a lot of occupational hygiene issues and concerns. Overseas, particularly in developing countries, there is even more.

It is hard to obtain accurate exposure data, or illness rates, from these underdeveloped countries. (How does a village of 1,000 people in Kenya report that they’ve had lead exposure to battery recycling?) How these exposures are brought to light is by either a massive death (# of people, quickly) or, someone with a camera able to actually photograph the pollution. As we know, what it looks like doesn’t necessarily correlate with hazardous levels of exposure. But, in some cases, it’s pretty obvious.

I ran across this photo story on pollution (The Guardian, UK). They estimate 125 million people are exposed to industrial pollutants (generic term, I know). This makes occupational related exposures a health risk as big as TB and Malaria! The article is based upon a report from the Blacksmith Institute which included this map of the worst pollution with associated disease.

How does this apply to construction? The worst offenders are lead (Pb) (and other metals), and asbestos.

What can you do? Here’s their recommendation, from the report (p50):

Developing countries need the support of the international community
to design and implement clean up efforts, improve pollution control technologies, and provide educational
trainings to industry workers and the surrounding community

Another NPR article about lead poisoning can be found here.