Industrial Hygiene in Construction

The new global harmonization system (GHS) is officially adopted by OSHA. Each state run program is rolling out their acceptance of the new changes. Where I live, we have until December 2013 to train employees in this new type of hazard communication.

Honestly, I’m NOT too EXCITED about it. But, I’m trying to have a good attitude. Below are some good things which may occur:

• Raise the level of awareness of hazardous materials & their toxicity
• Train employees (hopefully, retrain) on how to handle chemicals
• More training = less citations. (?) OSHA’s top ten citations include #3 – hazard communication. Maybe people will actually do the training?! (my guess is that there will be more citations)
• Consistent information worldwide.  All UN countries should have the same format. (this might take years)
• Proprietary information will be more visible on the SDS. In the new rules, manufacturers are required to list the % of their proprietary ingredients.
• Pictograms! They’re so cool. My favorite is the exploding person.
• Maybe this is my favorite?!: Manufacturers will have to look again at their products and classify them according to the physical & health criteria. Nowadays with more relevant information from worldwide occupational exposure limits, it might help make employers aware of the hazards.
  • This might help OSHA enforce newer exposure limits (other than the 1978 AGCIH TLVs).

How do you plan on training your employees? If you need help, contact me here.

Looking back at my lead in construction posts, I realized I did an inadequate job of summarizing why construction activities are dangerous when working with lead.

If you work in construction, here’s are the quick points as to why you should be concerned about lead.

• There has been A LOT of lead added to paint over the years. (it can vary 0.01% to upwards of 20%, and there’s no way to tell by looking)
• The activities we do in construction disturb this paint (some worse than others)
• You can be exposed to paint by inhaling it (if it is airborne), and if you happen to get it on your hands and you eat it (by transfer).
• The real concern is kids. (your kids, the kids who might be there after you’re gone, AND, the kids unborn (lead exposure can go from mom to baby)

The solution is simple (and, of course, more complicated as you dig in):

• test the paint to see if there’s lead in it
• if you disturb it, follow the rules (OSHA, EPA, HUD, City, etc.)
• train your employees (and measure the lead in their blood)
• prevent the dust from going everywhere (containment)
• measure the air to see if you are really screwing it up, or doing a good job.
• finally clean up. (the area, you, your hands, the perimeter) and dispose properly

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.

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

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

When measuring by air sampling for a job task, or an employee’s personal exposure, how many samples should you take?

Sometimes it is easier to place one filter cassette (or media) on the employee for the duration of their day.  At the end of the shift, you collect your equipment, mail it to the lab, and they spit out a 8-hour time weighted average (8-hour TWA). This is simple and easy to understand.

However, if you have the time and resources, it is usually beneficial to obtain multiple samples throughout the day. Taking multiple samples allow you to:

• obtain peaks, lows, and anomalies.
• look at: set up & clean up activities (separate from daily tasks)
• measure multiple employees doing the same task (to better capture the job task)
• calculate your own time weighted average
• capture short term exposure levels (STELs), or excursion limits *
• choose appropriate PPE for short duration tasks
• determine if employees are “falsifying” the data (skewing the data high or low)
• reduce filter overloading (in some cases)

There are some reasons NOT to obtain multiple samples:

• collection limit constraints (sometimes the method of sampling does not allow for this type of multiple sampling)
• it can be costly
• it is very time consuming (and nearly impossible, if you have multiple pumps on multiple employees throughout the site)
• difficulty interpreting the data (the math, the inferences, etc)

If you are hiring an industrial hygienist to perform air monitoring, ask about multiple samples. It might be slightly more expensive, but the information and data might be worth the cost.

*ACGIH recommends that if the compound does not have a STEL, all airborne levels should not exceed 3x the 8-hour TWA as an excursion limit.

Yes. If you are in construction, I recommend it. Here’s why:

First, the rules. OSHA does NOT have a specific construction standard for hearing conservation. Why does this matter? Well, the current OSHA rules state that if you have 1 day (that’s only one day) of average noise level above an average of 85 decibels A-weighted (dBA), called the Action Limit, you are required to start a program. Obviously noise levels vary on construction jobsites. I’d guess that most projects have at least one day of levels above 85dBA’s.

And, these particular OSHA rules are terrible. Well, they are terrible if you care about your hearing. (see my earlier post). The rules are simply not protective enough. If you are exposed to noise for 8-hours a day at 90 dBA (the OSHA average exposure limit) you WILL have hearing loss (this is without hearing protection). Does that seem like a very protective rule?  I’ve heard talk about them changing it, but…I doubt it will ever happen.

Second, let’s consider cost vs. reward. To start a hearing conservation program you must measure your employees hearing , called audiometric testing (and do a few other things). It costs approximately $20/employee to do this per year. Compare this with the average claim (of hearing loss) cost of around $20,000. So, if you have 20 employees, and it costs you $400/year…it takes about 50 years to pay yourself back for NOT starting a program. ($20,000/400= 50 years)

Third, consider your employees. Having their hearing checked may seem like a hassle and a worthless exercise, but, some will appreciate it. I’ve found that employees like to know how they are hearing. It’s good if your employer cares how well you hear. It’s also a yearly reminder in hazard awareness to noise.

Because in construction, we know there’s noise!

If you’re dead-set on NOT having a program, you’ll need documented noise dosimetry for each employee, job task, and possible overexposure above 85 dBAs. It is possible  for a construction company to avoid having a program, but you have the burden to prove there isn’t noise. Call your favorite industrial hygienist for help.

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.

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

…..: Red paint.

The point for the day is to remember that your sense of smell can be very good, or very misinformed depending on what you’re smelling (and who you are).

Sulfur (sulfur dioxide) can be smelled when it’s as low as 0.009 parts per million (ppm). The exposure limits are at 5 ppm. There are many chemicals that work just the opposite.

Before you make an assumption, figure out what you are smelling.