Safety Policies


focusfourMuch research has been done in construction safety. If you are working in construction, you have probably heard the facts over and over. The majority of construction injuries are from four main hazards, hence the “focus four hazards“. Although this site is for health issues & industrial hygiene in construction, it would be ridiculous to NOT mention these other hazards.

  • Falls,
  • Caught-in or Caught-between,
  • Struck-by &
  • Electrocution.

When talking with superintendents and safety coordinators, you can usually tell very quickly  if they have these under control. Either their subcontractors already do it right, or if/when they see an error, they immediately stop and address the inefficiency.

I saw this ladder in front of my children’s school. There was no one around and, by the look of it, there might have been someone on the roof. I should have waited, or fixed the ladder and spoken to the individual. But, I didn’t. Instead, I took a picture, put it on the internet, and now I’m telling everyone why it’s wrong.

ladder

Before you can wear a respirator here’s what has to happen:

If you’re an employer and your employees wear a respirator, they are required to have a medical approval (Appendix C of OSHA respiratory standard). more details here.

The employee fills out the confidential questionnaire and then submits it to the medical provider of the employer’s choice. 95% (I made that # up) of the time, based upon the questionnaire ONLY, they give an approval to wear a respirator.

Occasionally, some employees are requested to come into the medical office to have a spirometry test performed, which tests for lung function. (a video of how it is done, cool accent included) This tests provides more information for the physician/nurse to determine if wearing a respirator will be too difficult for an employee to wear.

The cost for either test is usually pretty close to the same price… spirometry test, or not.

Here’s my suggestion:  Have every employee perform a spirometry test before wearing a respirator. This helps to guarantee they are capable of wearing a respirator. Maybe they forgot to list a risk factor, maybe they have a hidden serious lung problem, or, maybe they lied on the questionnaire so they can wear a respirator and keep their job.?

It is also beneficial for pre-employment screening, claims defense, and for a baseline in health. The specific results are usually NOT view-able by the employer, but they can be subpoenaed.

 

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?multi meter

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:wet saw

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 ….

 

dustless shroud

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

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
  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.

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

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.

 

 

 

As common as it sounds, falls in construction are still the #1 killer.

Go to www.osha.gov/stopfalls

This site has good information, reminders, training, and resources.

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