Industrial Hygiene in Construction

There are some items you need to do BEFORE you wear a respirator. If you are using it on a voluntary basis, go here.

1. obtain medical approvalfor employees to wear a respirator
   • fill out a questionaiire (just like Appendix C of OSHA)
   • they might have you perform a lung function test (spirometry)
   • you will get a yes/no answer (probably 99% are approved)
   • you might try an online medical evaluation
2. have a fit test performed
   • qualitative fit test unless you wear a full face mask, or a type better than this
   • my favorite choice is irritant smoke, but it could also be saccharine, isoamyl acetate (banana), or Bitrex (R).
3. get trained. Learn how to:
   • clean it
   • store it
   • know what your respirator can’t protect you from
   • choose the right cartridges
   • know when you have break through
   • fit check (different than a fit test -BTW)

Wondering how often you must update the above steps? Go here. There are more steps to having a respiratory program, but you must do these things before you start.

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.

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

If you operate a ready-mix plant and have concrete trucks, you are aware of this process. Once a year (hopefully, only once) a person must climb into the drum of the ready-mix truck and chip off excess concrete. What happen during regular use, is that some concrete hardens, which usually sets-up over and around the blades. Access into the drum is by either the 3×4 hole in the side, or down the chute.

Yes, it is a confined space (def’n: 1. large enough to enter, 2. not designed for occupancy, and 3. limited entry/egress).

Here are a list of the possible hazards:

• silica dust (from chipping concrete)
• noise exposure
• hazardous atmosphere (curing concrete uses up oxygen, which we DO need BTW)
• slipping hazard (drum is round inside)
• heat stress (if you’re trying to do this activity in the summer)
• eye hazard (chipping)
• electrical hazard (if you’re using water & have an electric hammer)
• lock out / tag out (if the truck drives away, or if the barrel starts turning)

There are many resources available (see below). Some things to keep in mind; ventilation (fans, etc) to control the airborne silica dust are usually not effective (too much dust versus exhaust). Water controls are best, but you must limit the amount of water and the direction of the sprayer. I suggest looking at what others have done.

Keep in mind, if you perform this activity you will need (as a company):

• respiratory program (medical, fit test, written plan)
• confined space program (multi gas meter, written program, attendant?)
• lock out /tag out policy or procedures
• training (for each of the above, and for this specific activity)

At this point I know what my contractor-friends are thinking…I will subcontract this out!   ha. If you do, please make sure your sub is doing it right.

Resources:

Georgia Tech – good presentation & guidance

Georgia Tech/OSHA – Safe Work Practices (in Spanish too!)

Teamsters H&S hazards & controls

Illinois DCEO – Consultation on ready mix cleaning

The new standard for material safety data sheets (MSDS) which incorporate the global harmonization system (GHS) rules are coming.

Federal OSHA has approved the rules, and in our state, Oregon, they have been proposed, with an adoption to take place in December 2013.

It’s time to panic!… No. Not really.

Most employers will have until December of 2013 to implement the rules. OSHA will be publishing additional (and hopefully, helpful) information on what to do. For most employers it will mean you need to do a few major things:

• Train your employees on the new rules
• Reclassify (rename) the hazards, mainly the flammable ones, which have changed the most.

If you really need help with this, or feel like you can’t wait until OSHA publishes more information, email or find me here and we can discuss.

After performing an industrial hygiene survey (air monitoring), have you considered when you should resample? Here are some considerations that might help you in determining when.

• Are there specific rules that state when you must resample? For example, the construction lead standard (1926.62) states that you must resample yearly (or actually, that you can only use relevant results for one year).
• Has the process changedsince the last time you sampled? This one is hard to determine. Lot of things can change air monitoring results, here’s a “starter list” of things that can change a process.
  • Different employee?
  • Time of year? Summer versus winter? (closed up/open and humidity)
  • Is a new tool in place?
  • Has the ventilation changed?
  • Have new controls been put in place? (administrative, systems operations)
• Has the product changed? Check the safety data sheet (aka MSDS).
• Are more (or less) employees exposed to this hazard? This might change some assumptions you have made about your risk.?

If you have air sampling performed, make sure you have a written report of your findings. Laboratory results without an explanation of how they sampled, where, # of employees, process description, PPE used, safety data sheets, etc….is worthless. You may remember is well enough, but OSHA will have a hard time believing that it is a similar exposure the next time you do the “exact same thing”.

Having this report and sharing it with the employees will fulfill (part of) the hazard communication standard requirement to employees.

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.

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.

On occasion, owners say they just want to do the minimum to be in compliance with OSHA. Most times this is due to lack of understanding.

For some rules OSHA’s standard is right on the money. Take, for instance, lead (leaded paint) exposure. They have specific rules and guidelines that, if followed, keep virtually everyone protected*. The trouble is that some of OSHA’s rules have not been updated since 1973. New research and industry practices have found these levels to be unsafe even at current standards and exposure limits (PELs).

So, how do you know if the OSHA standards are current?

The quick answer is, you don’t.

Good safety professionals and industrial hygienists study the standards, recommended guidelines, and occupational limits worldwide.  In the US, the American Conference of Governmental Industrial Hygienists (ACGIH) provides the most current best practices. However, there are other methods and standards for specific hazards. ANSI, AIHA (although getting more dated due to lack of funding), European OELs (occupational exposure limits), and others.

It is rare that an employer knowingly exposes employees to a hazard. On the other hand, ignorance isn’t acceptable either….which might be the best reason for OSHA to be in existence. I wish they would spend more money on resources, information and training.  Consult your safety professional!

*recently there is some discussion about low level lead exposure to children

If you weren’t aware, OSHA is in the process  of establishing a ‘new’ rule (could be years) for confined spaces in construction (here).

In the meantime, if you plan on entering a space that is confined, below is my “standard” answer: Get help!

What I mean by this is; obtain some assistance as early as you can. Ideally this might even be before you bid the job. I often suggest to  send a superintendent or project manager to a 1/2 day training. Do not rely on the owner, or your general contractor to “safely approve” your employees entering this space. It is your job!

Although confined spaces are simple by definition (restricted opening, large enough to be in, and not meant to be occupied) , they can get  complicated easily. The first thing to consider is what is/was in the space. Secondly, what are you bringing into it? If those two questions are answered completely, the dangers are usually identified.

When reviewing, consider: electrical, oxygen, engulfment, entrapment, access (ingress & egress), coatings, noise, slips, temperature and emergency response (this is NOT an exhaustive list).

There are many other items and steps to have a well-run confined space program. Take a class, know the space, and train your employees. There are many resources at Federal OSHA and at your state OSHA, like Washington here, or like this one from Oregon.