Industrial Hygiene in Construction

As the saying goes, “if I had a penny for every time someone asked me…” Well, here are my most commonly (frequently) asked questions (FAQs) for dealing with asbestos and lead on a construction job-site.  These are my answers, so consult the appropriate governing body.

LEAD

• Do I need to comply with EPA’s new lead rule? How do I?

If you are working in a public area, or specifically, with kids under the age of 6, you MUST comply. Go to EPA’s website (www.epa.gov) and take an accredited training class and get your company approved for leaded paint activities.

• How do I know if I have leaded paint on my job-site?

If the building was built before 1978, a building survey (performed by an accredited inspector) should be taken. Rumor has it that leaded paint can be found in buildings up to 1985 or later. An accredited inspector can be found by calling the Construction Contractors Board, OSHA,  or the EPA/DEQ.

• Can I use a do-it-yourself lead testing kit?

Yes, but they can sometimes be misleading. They only test the surface paint -not the other layers below. In addition, these kits cannot determine the amount of lead, or the airborne levels of lead on your jobsite.

• I do have leaded paint on my construction project. Where can I find the current regulations on how to handle this situation?

OSHA (www.osha.gov), the Environmental Protection Agency (EPA) aka: Department of Environmental Quality (DEQ), the Construction Contractors Board (CCB), and sometimes Department of Human Services (DHS). Many of their rules overlap, but they all have unique rules that are designed for their particular jurisdiction.

• We had a building survey for lead hazards performed. Our accredited inspector had the paint tested and found that it was only 0.3% total lead. It is less than 1%, do we need to comply with the regulations since it is such a small amount?

Yes. Any amount of lead found in lead paint requires that comply with OSHA’s regulations. Depending on the project, you may also need to comply with the standards of other governing bodies (see above).

ASBESTOS

• How do I know if I have asbestos on my jobsite?

Buildings built before 1980 are required by DEQ to have a survey performed before any demolition or renovation.  The survey must be performed by an Asbestos Hazard Emergency Response Act (AHERA) accredited inspector.  They will take bulk samples of the material and determine the amount of asbestos present.

• The accredited laboratory reported the asbestos had less than 1% but more than 0.001%. Does this mean it has asbestos?

Yes, it has asbestos (less than 1%), but OSHA considers it to be non-asbestos containing. However, even at 1% asbestos, you would want to control the possible exposures. Work practice procedures, training, and PPE should be used.

• There is a small quantity (less than 10 linear feet) of asbestos on my jobsite. My employees may have to touch it. What type of training do they need?

There are four classes (or types) of asbestos work. Class I is the most hazardous and Class IV is the least hazardous. To answer your question-you need to compare your situation to the definition of Class III and Class IV asbestos work. Class III work is defined as, “repair and maintenance operations, where asbestos containing material, including thermal system insulation and surfacing asbestos containing material is likely to be disturbed”.  This type of training is 16 hours in length and must be done by a EPA/DEQ certified trainer. Class IV work is defined as, “maintenance and custodial activities during which employees contact but do not disturb asbestos containing materials and activities to clean up dust, waste and debris resulting from Class I, II and III activities”. This type of training is 2 hours in length and is the minimum. The particular type of training needed will depend on your situation.

• We obtained a building survey before starting our job-site. After we started demolition we found some “questionable building materials” that did not look like they had been tested in this report. What do I do?

Stop work. Call an accredited building inspector for the material you need to test and have the material tested. Then report the results to the owner, and others on the jobsite, within 24 hours.

• Our company policy is that we do not touch asbestos or lead. Do I need to write that down as “my company policy”?

Yes. Plus you should include what your employees should do if they run across a “questionable” material and whom they should contact.

• We subcontract all asbestos and lead work. Do I need to have my employees trained in lead and asbestos awareness?

Yes.  There is still a good chance that your employees will see or have to deal with these hazards on the jobsite.

A suggestion brought to one of my postings was, “how do you control the exposures?”. The answer, …in my best legalese was, “it depends”.

There are many ways to control the exposures.  However, as an general rule there is a method of approach that is best. OSHA describes it in some of their rule-language (such as lead 1926.62, and others).  So the first step in controlling an exposure is:

1. Engineering controls

What this means is: Can we remove the hazard from the employee. The best method is elimination. Using a different product that is less harmful can sometimes be discussed. Next, can we control the substance so that it is not harmful- like using a local exhaust ventilation? Can we use water to control airborne releases? Engineering controls should always be considered first. I suggest that when you have an exposure situation, have your safety committee brain-storm these types of controls and document them. OSHA has issued citations for employers who choose NOT to consider this control.

2. Administrative controls

These types of controls are a bit harder to describe. Suppose your worker must go into a high noise area multiple times during their shift – the answer might be limiting their time in this area. And possibly allowing other employees to “share” this exposure during their shift.  Another example would be having a protocol that minimizes airborne exposure by a method of work that is enforced by management.

3. Personal Protective Equipment (PPE)

This should be used as a last-resort. Most times it’s not. The reason it is NOT used is usually because of convenience.  However, there are many ways this control can fail including, improper use, breakthrough, permeation, penetration, degradation, and failure.

As a guy, I must admit… these tools are really cool. They’re loud, look like a space-age pistol, and have loaded bullets.  They use a .22 or .27 round casing  to drive the nail through the wood (or steel) stud (or bracket) and into the concrete.  It is really fast and …essentially a gun.

Powder actuated tools (sometimes confused with power, but it’s not) are typically used as  a quick method to anchor into concrete. There are a few types of these tools (Hilti, Simpson, Ramset) and there are specific safety precautions and controls that must be in place during use. However, I will focus on the newer hazard that was brought to my attention:  airborne lead exposure during their use.

I have seen these in use for many years, and at one point it was brought to my attention that lead was listed in the MSDS in section 2 Hazardous Ingredients (lead styphnate) and some of the manufactures caution the extended use of the tool. I actually dismissed the concern for airborne releases.   Well, I was corrected.

A study done by Liberty Mutual’s Mark Wiggins, CIH, CSP, ARM found that when as few as 50 to 90 loads are used per shift, the OSHA Action Limit can be exceeded.  It depends upon the type of load, where work is being done (location), and the type of work (overhead, etc).  He also suggests that the airborne exposure can be estimated based upon the number of rounds.

There are many alternatives to minimizing this exposure including: using battery-operated, or pneumatic anchoring tools, loads without lead, decreasing the frequency of use, and finally- respirators. A half-face, tight fitting negative pressure respirator is suggested to be adequate.

Leave me a comment if you would like the more information about this study.

This post will be an attempt to describe the hazard of the heavy metal, hexavalent chromium.  The subject is confusing. It’s a technical subject, and I will try to make it simple to understand.  If you have questions you can contact Julia Roberts,  from the movie Erin Brockovich.  (This was the one of the contaminants in the water in that movie/documentary)

Chromium is a metal found as chromium-3 (it’s valence) – and…if you remember from chemistry, the valence is the number of positive charged ions.  The point: when chromium is heated, it “becomes” chromium-6, or hexavalent chromium.  Hexavalent chromium will eventually go back to chromium-3. I believe the half-life is about 17 days (it takes 17 days for half of the material to convert back from cr6 to cr3).  Here’s the confusing part:  Chromium-6 isn’t harmful, but it is VERY able to be absorbed by your body (skin & membranes).  Chromium-3 is harmful, but isn’t able to be absorbed by your skin.

So, here’s what happens:

1. you have a material (or a product, ie. stainless steel, or look at your MSDS) with chromium-3 in it.
2. you heat it up
3. it turns into chromium-6 (hexavalent chromium)
4. it absorbs into your body (breathe, drink, touch)
5. it goes back to chromium-3
6. you develop symptoms/disease

Symptoms might include:   irritation or damage to nose/throat/lung, chrome ulcers (gross, huh?), lung cancer (if breathed), eye damage, allergic response (including dermatitis).

In construction we typically see exposures in these activities:

• Welding
• Stainless steel metal-work
• Painting- (as a pigment) or an anti-corrosion agent
• Hardfacing – applying weld-beads to the sides of loader buckets (see picture)

The risk of high exposure varies due to many factors including, type of work, ventilation, amount of chromium in the product, etc.

The CDC has some good information here.

Controls:  As usual, it depends. However, as a general rule you should try and eliminate the hazard (use non-chrome materials, or add ventilation). If it is still of concern, use administrative controls (limit the time, make sure employees are following protocols). And, finally, personal protective equipment to control exposures. Proper respirators (with HEPA cartridges) and don’t forget skin protection (gloves, tyvek, etc.).

Some workers were performing MIG (gas metal arc) welding and subarc welding. This is a daily task and their employer requested that we measure the air – as a general assessment tool. In other words, employee’s weren’t concerned, and no one was complaining, but they wanted to explore further into this aspect of their employee’s health and wellness.

We performed air monitoring and analyzed as a welding fume profile which is a number of commonly found welding metals including:

• Antimony
• Beryllium
• Cadmium
• Chromium
• Cobalt
• Copper
• Iron Oxide
• Lead
• Manganese
• Molybdenum
• Nickle
• Vanadium
• Zinc Oxide

Along with the welding fumes, we ran a sample for hexavalent chromium using OSHA Method ID215.

Nowhere in the MSDS (material safety data sheet) did it list “chromium” in the material make-up. However, knowing that it could be a trace metal it might be an issue. MIG welding (in general) isn’t typically of high concern for this hazard. And, as it turns out, the results were found to be below their respective limits.

Employees were not welding the entire day.  At least half of the time was spent fitting, moving, tacking, remeasuring, and gathering materials. Noise was a big issue as well. Most of the day it was quiet, but when the steel would drop, or an “adjustment” to the metal was needed…it was usually followed by a hammer-bang.  Honestly, without the ear plugs, it scared me.

I was requested to perform training for a management team (VPs, Estimators, Superintendents, PMs, PEs) on health topics. The request was specific: asbestos, lead, silica and mold/ IAQ (indoor air quality). I was given an hour, which is hardly enough time. However, the audience took well to it.  I was impressed with the questions and discussion that followed the training. Here are some highlights from that training that the management team adopted as policy. Most of these can be considered tips for good management of IH programs.

ASBESTOS:

• Before the project begins we will have (in writing) an asbestos survey
• As a contractor you typically sub the abatement work
• Employees need awareness training at some level (usually class IV)
• Any asbestos found is to be sampled (by an inspector) and NOT to be touched

LEAD:

• Before the project begins we will have (in writing) a lead survey of the building
• As a contractor we must manage lead on the project (no abatement usually)
• Any lead found on the jobsite WILL BE controlled
• Employees need awareness training – site specific
• Lead ACTIVITY (s)  must be characterized and assessed for possible exposures – and further steps

SILICA:

• There is/will be silica on our jobsite
• We WILL take steps to control the silica exposure when it occurs
• Employees will be trained as to the dangers of silica

MOLD/ IAQ:

• We will manage any mold/fungus found onsite
• We will have a plan for how we handle the situation as we arises
• We will be sensitive to any health or mold/fungus concerns

I commonly hear the phrase, “I smell something” when initially assessing a work place. Although the nose can be a great tool, you would not want to rely on this method for determining if you’re employees are safe.

The American Industrial Hygiene Association (AIHA) produces a reference book titled, “Odor Thresholds for Chemicals with Established Occupational Health Standards”.  Of the 680 compounds with recommended limits, this book lists approximately 182 chemicals. So, although, we can’t smell everything, it might be good to know which chemicals we can smell and at what level.

Odor has four dimensions:

1. Detectability. Each individual can detect different levels, but let’s leave that out. For the most part there is a minimum level that it is detectable; it is considered saturated at this level and you can tell what it is.
2. Intensity. This is it’s strength. A good cook can tell when their pot roast is done by the intensity of the odor.
3. Character. What does it smell like? We all associate smells with something such as, a wet dog, a fish, or a blooming flower.
4. Foulness (Hedonic tone). This is your perceived smell. Rotten eggs are usually not a pleasant odor. However, the moldy smell from a locker room might be considered bad, but the mold odor from cheese might be more pleasant.

The best situation is to have an odor threshold well below any establish limits for the chemical you are using. An example of this is acetone (2-propanone). Acetone is found in many cleaners and paints and is detectable to the nose at around 62-100 parts per million (ppm) or 0.01%. The permissible exposure limit for acetone is 1000 ppm (or 1%).  This would be a chemical with good warning properties.

Unfortunately your nose isn’t always as good at detecting harmful levels. For example, benzene (found in gasoline and other chemicals) has an odor around 60-90 ppm (0.009%), while the exposure limit for benzene is only 10 ppm (0.001%). This means that if you can smell it, you have already exceeded the acceptable limits.

Another popular chemical without good warning properties is diisocyanates. These are commonly found in paint systems at auto body repair facilities. These types of chemicals diphenylmethan-diisocyanane (MDI),  Hexamethylene diisocyanate (HDI) and toluene diisocyanate (TDI) have virtually no smell, their exposure limits are very low (around 0.005 ppm), and, to make matters worse, they are hazardous to your health.

So, my advice for those seeking to know more: explore the material safety data sheets (MSDS) that you use. Look in Section 2 under Hazardous Materials. Know these chemicals. Do you know the employee’s exposure levels while it is in use? Do you know their respective exposure limits? Are you wearing a respirator? Do you know the odor threshold?

Whom enforces the rules?

Based upon my previous post, and my reference to  MSHA (Mine Safety & Health Administration),  I realized I should back up a bit and explain why MSHA matters. The differences of who is regulating the site is subtle, confusing, and terribly important. Given the right cirumstances, all 3 could be at one location with a different boundary-line. And there are others too…

• MSHA– Mine Safety & Health Administration.   It is clear that if you are working in a shaft mine, they are the ones who regulate you. However, the not-clear part is if you own a rock crusher and occasionally decide to crush some rock. MSHA jurisdiction if you sell the rock. If you crush it onsite, and leave it for your own use, then it might be OSHA. In Oregon, most of the MSHA activity is through metal/non-metal surface mines.

• Federal OSHA – Occupational Safety & Heath Administration. Governs anyone who is an employee (who has employees)  So what do they do? They enforce, help, govern, provide assistance for employees. In some states, Federal OSHA doesn’t control your state because many states have their own state-run OSHA which does these tasks. Some states without a state-run OSHA are: Idaho, Colorado, Texas.  Federal OSHA classifies the ares into regions. (Idaho is region 10) I’m not an attorney, but I’ve heard that if you are an owner (or in some cases there can be multiple owners) and are not paid hourly, and don’t have any employees, OSHA does NOT have jurisdiction.

• State OSHA – (aka Oregon-OSHA, L&I (Labor & Industries -Washington), CAL/OSHA (California), Arizona (Industrial Commission of Arizona) These states (and others) have their own state-run OSHA program. The states are required to adopt the Federal OSHA regulations so they can be “at least as effective as” Federal OSHA. Some states have more-stringent rules. This is fine as long as it is as-protective-as the Federal rules.  An interesting fact is that in Oregon there are tribal Indian lands. Even though we have a state-run program, Federal OSHA has jurisdiction if you are working on that land. Another example of this is railroads.

• Others – Now, there may be other rules and regulations depending on where you are working and what substances you are handling. There is the Department of Transportation (DOT). City rules, Housing and Urban Development (HUD).

• Other-Others – To make it more-confusing, these are just the “rules”. There are many, and I would argue, better, resources for the most-protective guidance in employee health & safety. Some of these examples are: American Conference of Governmental Industrial Hygienists (ACGIH), American National Standards Institute (ANSI), and National Institute of Occupational Safety & Heath (NIOSH), among others.

My opinion is the rules should be secondary to this:  Are your employees safe? If we are protecting them, the rules are only a start.

Industrial hygiene at a surface-mine rock crushing operation is primarily 2 major hazards: 1. airborne silica dust and 2. noise. (there are many more safety hazards but I will focus on IH)

Silica– this can vary due to:   the amount of silica in the rock, weather conditions, type of equipment, if water is used, and where the miners work around the crusher. If it’s a dry-day the groundmen’s silica exposure is right at the limits. Operators in enclosed booths, and loader operators are usually within the limits, unless their cab doors are open. And, as a caveat, to all of this information: you HAVE to do your own monitoring. There are just too many variables.

Noise– with only a few exceptions, noise levels (dosimetry)  are usually well above the MSHA Action limit of 85 dBA. Therefore most rock crushing operations need to have a hearing conservation program. – which for most companies is just measuring their employees hearing (audiogram) every year.  I always recommend that these companies have an active program. Rock crushers are LOUD.

MSHA inspectors, in our state, usually come out to each of the surface rock crushing sites 2x/year. I think it is great they get as many “safety” visits as they do, however, I’ve heard many complaints about the inspectors. Most complaints  stemming from silly citations that aren’t a safety issue, just a rule interpretation. But, to defend them, they have a hard job. They have to fly/drive all over the place, deal with miners, irritated owners, and make sure someone doesn’t get killed after they leave.

Mines (not just underground) can hurt people….but most people have seen that show on the news.