Industrial Hygiene in Construction

I’ve had some good questions come out of the silica training sessions I’ve given in the past year. Below are some of the better ones.

• How often do we need to perform competent person training?
  • There is NOT a specific answer to this question. But, OSHA considers this as a performance standard, so if employees are not performing their “competent person” duties, then you must retrain. I personally think this will vary depending on how often they are engaged in these types of activities, the size of the company and how often you discover gaps. I’ll guess and say every 1-3 years.
• How do you dispose of silica dust, after it is collected in a 99% efficient vacuum?
  • OSHA says not to reintroduce this material into the air.
  • I have explained in classes that if you learn about particulate capture technology, you’ll see that the small (less than 5 micron) size are captured by electrostatically attaching to a larger particle. So, if you are collecting these particulates in a vacuum, they should be attached as a bigger size and dumping it into a bag without making a huge dust cloud is probably adequate.
  • Keep in mind that if you are using a HEPA vacuum for other activities (lead paint, or asbestos) this will have other environmental impacts and cross-contamination (lead=TCLP, asbestos=haz waste disposal). I’d recommend having a silica-only vacuum.
• How do we make sure the dust is collected adequately?
  • The short answer is, you should perform air sampling. I have performed a very limited amount of air sampling for tasks listed in Table 1, but they have all been below the detection limits. I have heard (not seen results) of some Table 1 tasks that were above recommended protection factors of Table 1.
  • Another answer is that you should be following the manufactures’ instructions on the use of the tool and dust collection.
• How large should your silica “designated work areas” be when you set these up?
  • I don’t have a straight forward answer to this, but I usually answer it by talking about those individuals who are “engaged” in the task, or not. I also mention there are many variables like; outdoor/indoor, task being performed, wind, etc.
  • The bottom line is that if you are producing a lot of dust, you probably aren’t controlling the airborne silica, and you need to look at your controls, NOT how large or small your designated work area size.
• How do I know if my subcontractors are performing their silica tasks properly/adequately?
  • This is a tough one because most General Contractor’s (GC) rely on their subs to do the work. However, all GCs must assure their subs are doing it correctly. The short answer is: do you see a dust cloud? If so, they’re doing it wrong.
  • It would be best if all GCs review their subs silica exposure control plan and program prior to starting work. This should include the methods they will be using to control their silica tasks.
  • It would also be beneficial to do job walks to verify subs are following their plan. AND, it would be awesome to catch them doing it right, and give THAT feedback.

Unfortunately this website has taken a backseat to actual work. My apologies for not updating the information, and especially to trusted subscribers of this site.

In the coming months, I plan to publish more posts with the same type of information. Thanks for hanging on. – Alden

As a preview: Did you notice that the State of Michigan OSHA (MIOSH) has updated (lowered) their lead (Pb) blood level mandates? Sadly, it took a lot of people being overexposed to lead (remember Flint, MI?) in order to make this simple change. I hope other states follow.

What questions do you have? What would be useful?

Email your responses to: alden (@) IH construction .com

I live in a moderate climate, but we had some 102 degree weather and it reminded me of how important it is to have a heat stress program and educate our workers.

Here are some tips and suggestions for keeping this hazard under control:

• Mandatory rest/water breaks (time between work & break dependent on heat) in shade
• Monitor/measure water consumption (& urine, if extreme)
• Educate employees on symptoms and factors which might contribute (medications, were you drinking last night?= deydration)
• Always work with a partner
• Flexible work schedule (start early, leave when conditions get unbearable)
• Increase ventilation
• Consider the space (attics can be worse than conditions outside)
• Provide easy access to emergency services
• One of the coolest (pun intended) ways is a “smart” vest with a downloadable app – workers wear this safety vest and it will alert people when symptoms/conditions get bad (heart rate, temperature, etc). Developed in Australia by RMIT University in Melbourne.

Exciting news! In just a few months we will be releasing free training materials!

In summary: I applied (and obtained) a grant through OSHA to produce training materials for the four major health hazards in construction. We are titling it, “Focus 4 Health Hazards for Construction”.  (similar to the Focus 4 Susan Harwood training materials available at OSHA)

Indented audience is for younger construction workers in hazard recognition of, 1. silica, 2. noise, 3. asbestos and 4. lead (pb) in construction. A short video (1-4 minutes) for each subject gives an introduction to the hazard. And, to follow up a training power point presentation (and short summary) will also be available to further instruct people in how to control and protect themselves.

On a personal level…it has been exhausting, and I’ve learned a lot!  From obtaining the grant, to hiring a videographer, filming, securing filming sites, and quarterly reports…. exhausting.  But, I’m confident you (and others) will enjoy it. Subscribe (via email) to keep updated. You can also follow me on instagram: “adventuresInIH”. (link coming)

You’ve probably heard the Federal silica proposed-rule has moved in it’s next step towards being a promulgated-rule.

And, you’ve hopefully looked at my prior post about the positives and negatives of the rule. I am usually not in favor of more rules, but as a safety person, my overall opinion is the new rule would be good.

However, there is some opposition (EHS Today Summary Article) from a few industry groups and associations, including ARTBA, NAM, and the ACC in an article to plastic manufacturers. And just recently a lawsuit was filed to stop the rule. They have some good arguments, of which, I think the best are: THERE ARE ALREADY OVEREXPOSURES at the current PEL, and silica related deaths have been in decline for decades.

The ACGIH and NIOSH have been recommending lower airborne limits for years. If you are a construction firm, hopefully you already have (engineering & administrative) controls and respiratory protection in place. If not, the best time to start was yesterday, and the next best time is tomorrow.

There are pieces of equipment used in construction which are VERY difficult to control their noise generation; open cabs of equipment, drilling machines, impact drivers/drills, and some mechanical devices are the first to come to mind.

Modifying equipment to control the noise is better than handing out ear plugs. But, before you modify the equipment, does your company have a “Buy Quiet” program? NIOSH & CPWR released some info graphics which can help start you down this road to considering noise levels when purchasing new equipment.

Before modifying equipment to control noise consider:

• Does the manufacturer have a “factory approved” modification already available?
• Are there any liability considerations if you make this change?
• Have you discussed the modifications with:
  • The manufacturer? Engineers?
  • Operator?
  • Mechanics?
  • Scope of work?
• How much noise reduction are you hoping to achieve?
  • remember noise is logarithmic, so a reduction of  1 dB is achieving a lot…
  • but not much practical difference in regards to operations
• Measure noise before and after, both static and dynamic

“Do I need a bloodborne pathogens (BBP) program for my construction company?”

Of course, the answer depends, . But, OSHA does have a letter of interpretation.

The basics are: do your employees have DAILY exposure (anticipated exposure) to blood, or blood containing substances? Further defined as; “today we are going to pick up these bloody needles. Or, “this afternoon we are going into this live sewer, which is coming from the treatment plant”.

Here is OSHA Bloodborne construction letter of interp, but interpret the letter of interpretation yourself. 🙂

“…while the bloodborne pathogens standard does not apply to construction work, as defined in 29 CFR 1910.12(b), it does apply to employees performing maintenance activities who experience occupational exposure to blood or other potentially infectious materials. OSHA expects the construction employer performing maintenance activities to take the following precautions as required by the following referenced standards: Section 29 CFR 1926.21(b)(2) requires that the employer instruct each employee in the recognition and avoidance of unsafe condition…”

In summary, most construction firms do NOT need a full blown bloodborne pathogen program. However, you should still train your employees on the hazards they might incur. This might include the hazards of bloodborne pathogens. There may be a time and project where they wished they had the training.

You’ve probably heard of this issue in the news, originally from the CBS News 60-minutes Show, March 1, 2015.

Formaldehyde is NOT good to have indoors, especially with kids (or those with upper respiratory issues). I believe there are a lots of homes and facilities with issues (which are not reported).

There are is some good information out there if you are worried you may have this flooring in your home or business. In summary, here are some notable points:

• you should really ignore the people pushing this issue (remember they shorted the stock before the news story)
• formaldehyde is used in a lot of product during manufacturing
• go to Lumber Liquidators and get your free test kit
• if you find high levels of formaldehyde, do something.
• But, the solution may not be to tear out your floors.
• Remember, formaldehyde can come from many sources.

Here’s a good article on the subject from Galson Labs. If you have concerns, hire a qualified industrial hygienist.

I was asked to summarize my thoughts on the OSHA proposed silica rule (which is currently pending). I’ve done it before, but since it was for the ASSE’s Industrial Hygiene Practice Specialty, it seemed fitting to post it on this site as well.

Wondering what is happening with the OSHA crystalline silica rule? In aviation terms it’s called a holding pattern. This airplane may-or may not-land. And, it is anyone’s guess.

If you haven’t heard, Federal OSHA is proposing to reduce the airborne silica permissible exposure limit (PEL) to 50 µg/m³. It is difficult to say how much lower this new rule will be, since the current standard relies on a calculated formula to obtain the exposure limit. However, for rounding purposes, let’s just say it’s a 50% reduction in the PEL. This limit is the same at the NIOSH Recommended Limit but still above the ACGIH (2006) Threshold Limit Value of 25 µg/m³.

Over the last year my views on this rule haven’t changed much: It’s a mixed-bag. There are still overexposures to silica. However, will the new rule change behavior?

To show some of the contrast, let me explain. Overexposures to airborne crystalline silica are still occurring. However, silica deaths have continued to decrease over the recent past (without the new rule). But, will the small employers comply? Or just wait to be cited? There is rarely a perfect solution for all situations. I’d like to provide a perspective balance to both sides of the rule.

Benefits:
The obvious benefit to lowering the silica exposure limit will be to protect overexposures to silica. I believe the rule will accomplish this in a number of ways. Any new rule will generate increased awareness for the subject of silica. The new rule will drive OSHA compliance by both lowering the PEL and by compliance with their additional controls. This will drive changes and modification to industries. Innovation will be spurned for controls and the need to comply.  In turn, this will create more discussions on the topic, the solutions, and overall awareness.

The new rule will get closer to the ACGIH TLV and update the health standards. The original rule was from the 1970s. And, OSHA is on the prowl for ways to update their current PELs.

Health and safety consultants will have an occasion for additional revenue in training, air monitoring, recommending controls, and other opportunities.

The new rule allows for alternatives to sampling. Rather than air sampling, you can choose to “over protect” and assure employees are controlling silica exposures.  This is a great solution for short duration tasks where exposure monitoring is prohibitive (see Table 1 from OSHA’s Fact Sheet). They emphasize control measures for silica.

There are very few new products and control measures for mitigating silica exposure in industry. Technology has somewhat sidestepped innovating products for dust capture and control for concrete work. Hopefully new products will be created to control silica. If nothing else, maybe we will see frequent job safety analysis (JSA, JHA) as a common practice to control exposures.

Weakness:

However, there are notable weaknesses to the proposed rule. The obvious downside is employers are expected to spend money. This will be an additional cost to doing business. Money will be spent on citations, controls for silica, labor during the activities, and for consultants to verify exposures are below the PEL.

This new rule will also allow OSHA to issue citations easier.  There are many items in the new rule which are beyond merely lowering the exposure limit. I imagine compliance officers will cite for failure to implement controls, or other technical aspects, rather than measuring the airborne dust and finding overexposure. Look for more drive-by citations.

And, there will be more confusion. Remember explaining to people how to calculate the current PEL? Well, in the short term, it won’t get easier. Although the PEL will be a fixed amount, there will be other things to explain. And, remember all the OSHA rules for leaded paint? The new rule is similar in how it allows you to provide adequate PPE and controls for “interim” work without measuring airborne levels.  Imagine you are a smaller contractor employer. This will be confusing and a lot of background work in order to use a jackhammer for one small project.

And, analytically, the airborne levels attempting to be achieved are so low, they are at the laboratory detection limits. With laboratory I currently use, to reach the detectable minimum PEL you will need to sample for at least 80 minutes (200 Liters). There is some newer sampling equipment which makes these levels easier to achieve. But, guess what? That will cost more money.  In addition, contained in the rule are mention of specific medical evaluations and facilities for those with continued overexposures. There are not enough medical facilities to support the number of people who need them.

Summary:

Overall, I believe the new silica rules will help reduce overexposures to silica. The increase in awareness across the US will bring more attention to the danger. Employers who are doing absolutely nothing to control silica will get caught, punished, and hopefully change their ways. For employers already in compliance, there will be a small, but manageable, learning curve. I also see many contractors using interim controls (Table 1) as a guide to easily protect employees on short tasks with high silica exposures.

To stay ahead of the curve, the AIHA has released (2013) a white paper for guidelines on skills & competencies in silica specific to construction. It is a great outline for training your employees. Another great resource for awareness and silica control measures is silica-safe.org. As a reminder, pre-task planning is still one of the best methods for health and safety.

 Here’s my sampling outfit.