Industrial Hygiene in Construction

Yea, I know. Strange one, huh? In my time consulting, this is actually the second time I’ve come across this.

It is more commonly know as: Mace (R) or tear gas (not pepper spray though, that is Oleoresin Capsicum). Hopefully you haven’t actually experienced it’s exposure. It is worse (so I’m told) than pepper spray. More differences compared here.  All can be quantitatively measured by your favorite occupational hygienist.

Exposure in construction can come from incidental releases (incident response) or during clean up/ demolition of structures where this was used (think: police entry into a structure).

The OSHA exposure limit is 0.3 mg/m3. (NIOSH REL is the same, ACGIH TLV 0.35 mg/m3). They are all very low, actually.  Exposure can occur by inhalation, eyes, ingestion, and skin exposure.  NIOSH Pocket Guide is here.

Personal protection is a bit interesting. NIOSH recommends a full face respirator with P100 and organic vapor cartridges be used. The interesting part is that using this type of protection would allow exposure (based upon the protection factor) up to 15 mg/m3. Which, incidentally, is also the level as immediate danger to life and health (IDLH) = 15 mg/m3.

Some guides for dealing with this substance can be found here.

Let me first say that I am still learning about this hazard and why it is so dangerous.

Polyurethane foam is used as an insulating material. More info on it’s uses here. The danger is when you spray it (think: expandable type), or apply it, or cut/remove it after it’s cured. The danger is in the off-gassing.

There are two main considerations:

• the process of applying the foam
  • spray type
  • quantity?,
  • ventilation?
• the type (manufacturer/brand/type) of foam
  • curing rate,
  • type of hazard, etc.

What we know is that there is a hazard. AND, this hazard may not effect everyone, OR, it may not effect you until some time has gone by. But, some of the chemicals in these types of products include:

• isocyanates (people can die, and get asthma), and it is a OSHA Emphasis Program, and OSHA page here
• amines
• VOCs (volatile organic chemicals)
• flame retardants (PBTs)
• Blowing agents (EPA link)

There is a huge potential for work related asthma when using these types of products. And, even contact with the skin can trigger an allergic response/asthma attack. If you have employees working around this type of product and have ANY respiratory symptoms (or asthma), please have them checked by an occupational medicine doctor.

Control of this hazard should include:

• PPE for employees (respiratory, eye, & skin protection)
• ventilation during application
• ventilation during off-gassing & curing (can be 72 hours)
• control plan for spills, cutting & demo
• control plan for employee/occupants with asthma

The EPA has a quick reference card here (hat tip to Tom), and more detail from the EPA on how to control the hazard here. The Spray Polyurethane Foam Alliance has free training here (haven’t checked it out though), and be mindful that anyone can be an instructor (good & bad).

If you’ve ever won an award before, sometimes getting the award rarely equates to anything lasting (other than your increased ego). However, in construction nowadays, safety awards are HUGE! This is especially true if you are competitive bidding (or plan to in the future). I know companies who have received jobs & project  based upon one (or several) safety awards they have won. Of course they had other things going for them, but the safety award was the tipping point.

I am talking about company safety awards, not safety awards for being safe (see my earlier post, about safety incentives).

I really don’t think it matters where you get the award.

• Could be a OSHA SHARP, OSHA VPP, a regional/local conference (here’s an example, and here),
• an association award for safety (AGC, CURT, ABC),
• an insurance award (workers comp, your general liability carrier),
• safety program award,
• trade association (HVAC, Landscape, Union) or go for
• Safety non-profit (National Safety Council), ASSE, local section, or
• LEED and sustainability award (I know, not exactly safety-related).

Heck, create your own award! If you’re a GC, or a specialty contractor, why not give awards to your subcontractors or general contractors if they do an amazing safety work, or provide innovation? Print off your own certificates. Or, at the end of your project, ask your owner/GC if they will recommend and/or give you an award for the safe work you’ve performed.

Here’s an example of a construction website’s awards: Russell, James (no connections). Here’s a similar article from EHS Today.

On one hand it makes perfect sense. If you work safely, over time, this is something that should be rewarded. Many, many companies provide a safety-incentive for no/low work place injuries.  However, there is a downside, which some people have discovered:  If you reward people for being safe, there is a possibility they won’t tell you if something isn’t safe. It’s called a reporting bias, or selective reporting.

Unfortunately this bias is exactly the opposite of what the best companies do. The best companies report every little thing (every incident). People who scrutinize the numbers can tell you for every accident that occurs, there are usually 100 little incidents which occurred prior to the accident. The reporting of incidents is the best indicator for future accidents. (aka, catch phrase: leading indicators)

A really cool example of this is Google Dengue Trends. Dengue is a mosquito-spread virus. Google looks at search words and, over time & many data points, can actually see people where the fever is spreading. An article in Science & Tech (June, 2001 Graham Smith) “Google launches Dengue Trends tool to help doctors track spread of deadly fever”

So how do you motivate people to report an unsafe act?

Here are some ideas:

• Pre task planning & post task wrap-up (downside: can be a lot of paperwork)
• Check the first-aid safety box for what’s being used
• Encouraging open communication
• Spies (not my favorite)
• Follow up on any report of near miss (by management within a certain time frame)
• Reward the reporting of incidents
• Make it easy, safe, convenient, rewarding, honorable, and validating

Or, maybe you should ask the opposite question: What would motivate someone NOT to tell you? In construction, it is common practice to provide a bonus at the end of a project based upon various factors. This most definitely includes profitability, but it can also include safety. If you didn’t hurt anyone on the project, you SHOULD be rewarded. (or, at least be given a pat on the back). Here’s a case of someone who really got it backwards: A former safety manager at the Shaw Group (formerly Stone & Webster Construction) falsified records.

Chromium in it’s elevated valence state, called Chromium 6, or hexavalent chromium is a known carcinogen and sensitizer. From a toxicological point of view, it has a really interesting exposure to disease path.

I’ve mentioned it before, but recently NIOSH reduced their suggested limit from 1.0 µg/m³ to 0.2 µg/m³ (80% reduction for you math wiz’es).  They base this on eye & skin irritation, respiratory damage & lung cancer. Yikes.

OSHA has listed their exposure limits, along with other’s recommended limits here.

The take-away from this reduction is the serious nature of Chromium 6. If you are dealing with this hazard, you should take more than just a little precaution. Even if your prior air monitoring data is below the Action & Exposure Limit, continue  to document and verify your employees are well below the regulatory & recommended limits. As you know, hexavalent chromium is a skin hazard and can be absorbed easily into your body. I would also suggest performing wipe samples (area & skin) & decontamination in areas where there is work activity with hexavalent chromium.

For most construction companies, investigate these areas:

• welding (any stainless steel?) See this earllier post, also here.
  • And, OSHA has a new Fact sheet on welding & hexavalent chromium here.
  • Washington’s OSHA (L&I) has a great page on the hazards during welding here, including training videos. (so cool!)
• hardfacing on equipment. See earlier post.
• Bridge painting – (or painting with chromates) OSHA’s new safety bulletin is here.
• Electroplating – OSHA’s safety bulletin is here.
• Anytime you heat, or work with chromate painted surfaces.
• Portland cement when working with it wet and on your skin. NIOSH has some information here. hint: Try adding ferrous sulfate to lower the Cr6.

And, if you don’t work in construction, but live in Garfield, NJ, you might have to pull your toenails out to prove you aren’t exposed to hexavalent chromium.

Much 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.

Since you are reading this, you probably know the answer. Everyone. But, who is everyone? It should include your CEO/Company President/COO (or similar). If not, I guarantee you aren’t working as safely as possible.

The reason:  The person doing the work usually isn’t involved in the bidding & planning of the project.  It’s not always the President’s fault that the proper safety equipment wasn’t bought, or there are no available tie off points on the roof. (But, it might be their fault if they are willing to press forward without making changes.)

Here is one way to deal with these issues. Train the CEO (President/COO/Project Manager/Estimator) beforehand. Here’s how:

• Make the training for them. 
  • Don’t talk about safety harnesses, or the three different types of asbestos.
  • Go over big items (where are your claims? what are similar claims for your industry?)
• Emphasize the proper methods to control any hazard:
  • #1 engineering controls
  • #2 administrative controls
  • #3 PPE (in that order!)
• Get them to contact you during the bidding process (not after you’ve won it). Talk about what might be dangerous work & plan for it.
• Share a success story. Ask a superintendent to explain how they controlled a possible exposure.
  • Did they make the architect install in a tie-off point?
  • Did they ask the owner to change adhesive products to a less hazardous one?
  • Did they use an abatement contractor who performed the work well?
• Keep it simple & short. You don’t need a lot of time, but you do need them all on the same page.

When everyone in the company has the same interest in safety, it isn’t hard to explain.

There is a lot of confusion about N95 paper dust masks. And, it is confusing. The reason is because NIOSH has rated this type of equipment as a respirator. Prior to this, it was called a “comfort mask”. This name sounded better than calling it, “a worthless false sense of protection”. It is now called a, “dust mask”, or a “filtering face-piece”.

Here is what is required by OSHA if you wear this type of respirator (N95, or similar):

• Employees must read and sign Appendix D (of the OSHA respirator standard)
• Employees must clean, inspect, and store their dust mask

That’s it.

UNLESS you are wearing this because:

• Your employer requires it
• You have overexposures
• or, nobody “wouldn’t wear it”. (meaning: it’s an industry practice, and when when we do this XXX task, everyone wears this type of respirator– this is the same as your employer requiring it)

If  any of the above statements are true, then you have more to do. Here are links for more information:

Voluntary Use of respirators

Getting ready to wear a respirator

Professionally I do not recommend these type of respirators. Email me if you’d like to know why.

My friend, Shelley, sent me these pictures of a city maintenance crew hanging up the Christmas decorations in town. These guys have probably been working this way for years. What will take to make them change? Administrative controls? As I’ve mentioned before, falls are the #1 killer in construction.

 

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