Industrial Hygiene in Construction

I previously wrote about a worst-case scenario in which asbestos was not discovered till after it was disturbed.

Recently I heard a story of the opposite:

A general contractor hired a company to remove various pieces of asbestos. They had obtained an asbestos building survey, which clearly stated where the  asbestos was located. A boiler with surrounding insulation was identified as non-asbestos containing (asbestos-free). The employee was using a bobcat to demolish the boiler. As he started to tear into the insulation surrounding the boiler (disturb it), he paused. He checked the building survey again, and it had clearly stated it was “asbestos free” (actually 5 samples had been taken of the insulation around the boiler). Then, he did what most other people would not do: HE REFUSED to demo the insulation. He told the General Contractor and owner he thought it was asbestos containing and wanted it tested, AGAIN.

Guess what they found? Yep. Asbestos WAS contained inside the insulation around the boiler.

There was obviously some break-down in communication with the report, inspector, and possibly the lab.  However, this employee is to be commended and, really, the safety culture at this company should be congratulated. You never know where you will find asbestos.  The employee had enough guts to speak up for his safety (and for the others).

Measuring good-safety behavior is the type of thing we should reward. In the past (and still today) many safety-people measure losses ( ie. how many injuries). This is backwards thinking. We should be rewarding good behavior and encouraging people to speak up for safety.

For example; what do you say to this guy?

Hypothetically (and allegedly):

• You receive a project as a subcontractor.
• You are verbally told no asbestos or lead onsite. Only that’s not true.
• There is asbestos, and you, and multiple other subs, have disturbed it.
• The prime contractor says, “oops”. Has the materials tested, and then blames the owner for not letting them know.
• OSHA is called and citations are issued to the owner and GC for not testing and telling people.
• A year goes by and now both the owner and GC are being sued by 5 employees for $10,000,000 (yep $10 million, that’s the max BTW).
  • As a footnote: this incidentally is not a worker compensation case (yet) since they are not suing their employer (they are suing the GC and owner)

Even if the employees don’t win $10m, are you prepared for: the headache, loss of client-relationship, trust breaking? Here’s a similar hypothetical article about such a situation.

On the flip side, here are some positive things you can do:

• get a written copy of the building survey (lead & asbestos) ALWAYS. (you might also ask for cadmium, radon, other possible hazardous substances)
• Train your employees about asbestos prior to having to deal with it.
• Give employees the power to “stop work” if they are suspicious of possible asbestos containing material (PACM).
• When handing out a building survey to your subs, get their acknowledgment (in writing, of course)
• Fight your OSHA citations. Go to your informal conference. Present your evidence and, at the very least, beg for forgiveness.

Industrial hygiene (aka occupational hygiene) focuses on occupational-related diseases due to many reasons.

Have you considered, at your home, maybe even as you sleep, you might be exposed to something hazardous? Below are seven possible hazards in your home (related to IH):

1. Radon. It comes from the ground and they say it causes cancer* (*some people question this toxicological data). You must perform a test to know if you have hazardous levels.
2. Formaldehyde. If you have a newer house you have 2 things going against you: 1. your house is tightly built (no air leaks and limited fresh air) and 2. more particle board (recycled wood) was used in construction. Also, many furniture contains multidensity fiber wood (MDF) which off gas formaldehyde. Again test for it to know if you have dangerous levels.
3. Lead. Is your house built prior to 1978? It probably has leaded paint. Any remodeling might distrupt it and you can expose your kids to lead.
4. Isocyantes. (HDI, TDI, MDI, and others) Can cause asthma & respiratory issues. If your house was insulated with spray foam (polyurethane type) it needs to off-gas for awhile before you move right in.
5. Asbestos. Causes cancer when airborne. If your house was built prior to 1980, you might have asbestos in your pipe insulation, popcorn ceiling, etc. Be sure and have it checked prior to remodeling.
6. Mold. Respiratory diseases.
7. Cleaning products. The symptoms can vary depending on the type of chemicals in the product. Use the recommended gloves, eye protection and respirator, if necessary, while cleaning with chemicals.

Do not be overly concerned about any one thing. Simply test and make any necessary adjustments. However, do keep in mind that most health recommendations for substances relate to normal working adults who go home to a non-hazardous place. There can be issues if you are either: not considered in the general population of healthy workers and, you go home to a place that isn’t free of additional hazards.

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.

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.

When training people who work around asbestos I usually discuss the word “disturbance” for a LONG time. The reason is simple. If you avoid “disturbing” it, you avoid most of the health issues.

As most people are aware, asbestos is found in many types of materials. Floor tiles, popcorn ceilings, wall panels, etc.

Disturbance relates to the specific activities you perform AND the type of material the asbestos is in.

If the asbestos containing material (ACM) is non-friable, then in theory, it takes more effort to disturb the asbestos. If the material is friable, well, you need to be REALLY careful. – and in some cases, breathing can disturb it. For example, an electrician who uncovers an ancient acoustical ceiling panel and finds damaged asbestos pipe insulation laying on top of it…is probably already in trouble. He has essentially disturbed friable asbestos by merely moving the panel.

In contrast, a remodeling company installing a floating laminate hardwood over asbestos 9×9 inch tiles (without damaging them) is [probably*] NOT causing airborne releases of asbestos.

Most of the OSHA/EPA asbestos rules hinge on the matrix of the material and the activity you are performing on it. The reason is this is what makes the asbestos fiber airborne.

*the OSHA rules are very specific as to work activity, please do your due diligence.

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.

Assume your general contractor reports that he has found a material (floor tile, popcorn ceiling, etc) with less than 1%. He wants you to remove it with the rest of the demolition because, as you know, “…if it’s less than 1%, it’s NOT considered asbestos containing!”.

Are you ok to remove it?

Yes, and no. There is more to consider. The “1% rule” (as it’s called) as it is called states that they only regulate asbestos containing materials if they contain more than 1% of asbestos. Here are a few other considerations:

1. OSHA definition. Don’t get stuck on the definition. If you have employees, you must still follow parts of the OSHA rules. At a minimum, you must train your employees, work practices, clean-up and disposal requirments. More details on training here.
2. How were the samples taken? If one bulk sample shows less than 1% asbestos, you still might have a problem. According to the EPA/AHERA sampling rules, some types of materials must have up to 7 samples taken. This rule is in place because, back in the day, asbestos was added to joint compound (or anything similar) and it could really vary in amount according to where you take the sample. In addition, OSHA does not allow for composite sampling (combining the layers).
3. Do you know that 0.99% asbestos is still bad for you? Asbestos is a carcinogen. The greater the exposure, the greater the risk of disease. Any exposure could be the one to cause the disease. If the material is friable and you are disturbing it, I would NOT recommend performing that activity. Hire an abatement contractor.
4. Finally.Let’s assume it’s non-friable, you are not going to disturb it (when removing it) and it’s less than 1%. What will you do if your neighbor next door decides to call OSHA/EPA? Do you have a written plan and procedure? Have your employees been trained on the hazard? How to remove it? How to dispose of it? …Sometimes bad publicity will get you in worse trouble than any monetary fine.

 

I love the show, “Dirty Jobs” with Mike Rowe. I find it fascinating what people are willing to do for work. Many of the jobs on the show have a true element of danger. Either a pinch point, an animal bite/kick, struck-by, heat/cold extreme, confined space, etc.

Did you ever consider what makes something hazardous?

My “deep thought for today” (thanks Jack Handy) is that education and training can make a job less hazardous. If you know how to do it right, and you know the risk, it doesn’t seem as dangerous anymore. The risk is there, but you know how to handle it, so the “hazard” seems to fade. This week I’ve given two separate asbestos classes to two different employers. At the beginning the employees were genuinely concerned about the hazards. By the end, they looked a lot more comfortable about upcoming project.

Is it any surprise that the HazCom standard is the most OSHA cited rule year over year?

So, keep up the training! Educate the employees on the dangers.

Occasionally (actually, far too often), I hear from a subcontractor who was told by the General Contractor (or owner) there is no asbestos onsite. Then, after they have been working for a month they find out it actually IS asbestos, and they were disturbing it. What do you do?

The first thing to do is stop work. Do not try to clean it up. Call an abatement contractor. They will identify the asbestos onsite, clean it up, and provide an airborne clearance test.

Next, you will need to provide awareness training (or better, let the abatement company provide it). Ideally this will occur on the day you start back working. Train everyone onsite about asbestos.

Finally, you (as the safety manager), need to identify and characterize the exposure to the employees. It should probably be a formal letter written to the owner, general contractor and employees.

Here are some tips on writing the letter:

• include employee names, work hours, type of work, PPE worn, and locations they were working
• describe the asbestos. Amount found, locations, type, estimated amount disturbed.
• describe remedy process and steps taken. Names of GC, owner, abatement company, airborne levels found. Who was trained afterwards.
• describe how things will change in the future. Here’s a tip:  any building before 1985 WILL have a building survey performed for asbestos….in writing.

Really, one exposure to asbestos is probably* not enough to contract a disease (asbestosis, or mesothelioma). It will take 15-30 years for symptoms to appear. But, it might be worth the “goodwill” to send affected employees into a occupational health doctor for a check up. The physician will reassure the employee and may provide some comfort.

*asbestos is a carcinogen. Greater exposure = greater chance of cancer. no amount is safe.