Industrial Hygiene in Construction

If you really have an indoor air quality and mold/fungus issue, it usually stems from moisture. I’ve talked about it before, here. The simplest answer is to find the water. Control the moisture and you inevitable will control the future indoor air quality concerns. Once you have found (and controlled) the water, then it is time to repair the damage and lingering water (which can’t evaporate).

The issue is: where does moisture come from? Well, it ‘can’ come from almost any direction:

• from above (rain, roof vents, skylights)
• from below (moisture in flooring, concrete)
• walls (penetrations into the exterior, or windows and flashing)
• out of thin air (relative humidity)

The EPA has written a new document titled, “Moisture Control Guidance for Building, Design, Construction and Maintenance“. As a contractor, how do you know when the clean up is too much to handle? I’ve written a bit more about it here.

The best time to clean up a moisture issue was yesterday, but the second best time to clean it up is today. Don’t let it sit, it usually doesn’t get any better.

Yep. Polychlorobiphenyls (PCB) are found in caulking. Typically buildings before 1979 have this caulk. (EPA Facts about PCB in Caulk) The only way to know is to test. BUT, wait!

Either:

• Assume you have it and renovate with caution. Or,
• Have the air tested for PCBs in the air.

Do not have a bulk sample taken. You should ask for an exposure assessment to be performed (air monitoring) by a qualified industrial hygienist. The reason is two-fold.

1. The potential for the hazard is airborne. In most instances, people aren’t getting exposure from any other method.
2. By measuring the air, you account for any other sources of PCBs (paint, ballasts, oils, ceiling tiles).

Most of this caulk is found in outdoor uses (high grade) in older buildings up to around 1980-ish. If an airborne exposure assessment finds levels below the acceptable rules & recommendations (depends on age & location), you may continue with your project. Of course, you would take appropriate precautions, like these recommendations from the EPA. They also have a very nice flow chart. Just like a choose-your-adventure book, make sure you don’t fall into the “Abatement” box!

Let me first say that I am still learning about this hazard and why it is so dangerous.

Polyurethane foam is used as an insulating material. More info on it’s uses here. The danger is when you spray it (think: expandable type), or apply it, or cut/remove it after it’s cured. The danger is in the off-gassing.

There are two main considerations:

• the process of applying the foam
  • spray type
  • quantity?,
  • ventilation?
• the type (manufacturer/brand/type) of foam
  • curing rate,
  • type of hazard, etc.

What we know is that there is a hazard. AND, this hazard may not effect everyone, OR, it may not effect you until some time has gone by. But, some of the chemicals in these types of products include:

• isocyanates (people can die, and get asthma), and it is a OSHA Emphasis Program, and OSHA page here
• amines
• VOCs (volatile organic chemicals)
• flame retardants (PBTs)
• Blowing agents (EPA link)

There is a huge potential for work related asthma when using these types of products. And, even contact with the skin can trigger an allergic response/asthma attack. If you have employees working around this type of product and have ANY respiratory symptoms (or asthma), please have them checked by an occupational medicine doctor.

Control of this hazard should include:

• PPE for employees (respiratory, eye, & skin protection)
• ventilation during application
• ventilation during off-gassing & curing (can be 72 hours)
• control plan for spills, cutting & demo
• control plan for employee/occupants with asthma

The EPA has a quick reference card here (hat tip to Tom), and more detail from the EPA on how to control the hazard here. The Spray Polyurethane Foam Alliance has free training here (haven’t checked it out though), and be mindful that anyone can be an instructor (good & bad).

You may have seen a product label which states that, “this product is known to cause cancer”…if used in California. (ha)

Proposition 65 is essentially a labeling rule. in 1986, California made a rule mandating anyone selling to California to label the product… if it had a serious health risk. This rule was above and beyond the OSHA reporting limit of 1%, like on a MSDS (henceforth called SDS, BTW).

The rule is actually good. It makes manufacturers tell you if there is anything hazardous in their product, or if they used anything hazardous when they made the product. (Side: If you haven’t heard, some manufacturers like to hide their ingredients, some say for proprietary reasons. Here’s an example)

More information about the rules is here. There is controversy over it’s usefulness (see here), but in this day in age, I believe you should be made aware of the information.

What usually happens is you find a SDS with no information about the product. Then, as you investigate, you find a “Proposition 65 warning”, indicating something about the product which, “may cause cancer”. So you ask, why does this happen? (more FAQ here) Well, the manufacturer used, or contains, something in their product that is hazardous. It can be a nice trail leading to chemicals which to sample for, or investigate.

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 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.

As I have said in an earlier post, some OSHA, EPA, and MSHA rules are a good fit. They blend well with health research, scientific technology, good practices, and a low-cost-of-compliance for employers. Other rules are just bad. They are  totally out of date, not protective enough, or just not feasible/practical. Here’s my plug for a good safety manager/industrial hygienist – A good one will know which rules/guidelines to follow.

The New York Times (July 19, 2012, Cara Buckley) recently wrote an article on the US noise standards which are not protective enough for employees. In construction we also have three additional problems.

1. hearing loss is expected (or at least assumed in certain fields – carpenters, sheetmetal, ironworkers, etc.) and,
2. work shifts are usually over 8-hours. Noise exposure is usually calculated on an 8-hour time weighted average. During the busy months, an 8-hour work day is rare. It’s at least 10, maybe 12-14 hours. This doesn’t allow your ears to “rest” between shifts. For more information on extended work shifts go here.
3. extracurricular activities contribute to overall hearing loss – my point is that most construction workers don’t sit at home at the end of their shift. Almost everyone I know in construction is involved in one of these activities: hunting, shooting, motorcycles, water sports, yard work, cars, wood working/cutting, concerts, music, etc. Each of these activities contribute to their overall hearing loss, and again, doesn’t allow your ears to “rest”.

…which reminds me that I need to keep a set of ear plugs in my motorcycle jacket.

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)

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.