Industrial Hygiene in Construction

Yep. Polychlorobiphenyls (PCB) are found in caulking. Typically buildings before 1979 have this caulk. (EPA Facts about PCB in Caulk) The only way to know is to test. BUT, wait!

Either:

• Assume you have it and renovate with caution. Or,
• Have the air tested for PCBs in the air.

Do not have a bulk sample taken. You should ask for an exposure assessment to be performed (air monitoring) by a qualified industrial hygienist. The reason is two-fold.

1. The potential for the hazard is airborne. In most instances, people aren’t getting exposure from any other method.
2. By measuring the air, you account for any other sources of PCBs (paint, ballasts, oils, ceiling tiles).

Most of this caulk is found in outdoor uses (high grade) in older buildings up to around 1980-ish. If an airborne exposure assessment finds levels below the acceptable rules & recommendations (depends on age & location), you may continue with your project. Of course, you would take appropriate precautions, like these recommendations from the EPA. They also have a very nice flow chart. Just like a choose-your-adventure book, make sure you don’t fall into the “Abatement” box!

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).

It’s not a secret. (previous article here) Formaldehyde is in many types of composite, pressboard, and multidensity wood products. The EPA is now proposing to limit the amount of formaldehyde that can be added to these types of products.

When you build a structure, these types of products can offgass small amounts of formaldehyde. Even though the total formaldehyde is far less than 1% of the total product by weight/volume (which means it may NOT be listed on the SDS/MSDS- clue: look for the Prop 65 label). This can add up. The EPA is proposing to regulate the amount of formaldehyde a product can off-gas, and provide 3rd party certification framework for regulating it . 

Unfortunately, nowadays “GREEN” products/ or recycled goods can contain a lot of formaldehyde. (used in the process of making & adhering the different recycled materials together).

Expect some push back from industry. Even though it’s a known carcinogen, there is sure to be some push-back.

There are some things in occupational hygiene which make our job harder: politics, money, personalities, fiction (not facts), rules/laws and schedules.

However, there is one person who we can blame. Maybe not entirely, but he epitomizes the opposite of protecting people’s health. Thomas Midgley, Jr. Who? Yea, he’s new to me too. 

This guy has killed millions of people. Maybe not directly, but through his politics and lack of ethics. Here is a great article from Seth Godin on this guy. Essentially he allowed lead to be added to gasoline, AND, helped to provide CFC (chlorofluorocarbons) to products. However, he probably got what he deserved: He died from his inventions. It is easy to look at hindsight and blame him, but at the time, I wonder what he was thinking? My guess is money.

The enemy of Occupational Hygiene is probably not Thomas Midgley. It’s our ethics. If we fail to make the right choice every time, where does that lead us?

If you’re reading this, you probably don’t suffer from an ethical-failure to protect people. (Most people in safety don’t.) Rather, you should pat yourself on the back and keep doing the right thing. Good job.

There are only a few instances when you are not required to perform fit testing. The main reason not to perform fit testing is if the employees are wearing a respirator voluntary. (meaning: it’s not required)

So, how do you know if it’s required? It’s required when:

• You have overexposures to a substance (it’s required by OSHA to wear a respirator- so make sure you know, perform air monitoring), or
• If everyone is wearing a respirator during this task (it’s probably also required, just not formally- ie. spray finishing, or my favorite sanding drywall dust) or,
• If your company policy requires them to be worn (management says: it’s required to wearing a respirator during this task).

So, if you choose voluntary to wear a respirator and there is NOT a policy, or law, that says you HAVE to wear one then, you don’t need fit testing. (but you do need a few other things, Appendix D, etc.)

There is only one other exception:

• loose fitting hooded /helmet atmosphere supply respirators (when used in areas not immediately dangerous to life and health (IDLH))

Some employers choose to use these types of respirators because:

• the employee wears a beard
• it is convenient to use
• offers eye/face/neck protection
• it offers a greater protection factor
• it’s easier to don/doff (take on/off)

These guidelines for fit testing are different than medial testing before wearing a respirator, as spoken about here.

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.

It’s always fun to hear about new/different situations especially when the contractor handles it properly.

During the start of a demolition on a 1989 structure, the first swing of the hammer produced a pile of vermiculite sand.

After some discussion on “what in the world is this doing inside a wall cavity“. The contractor stopped work, had an asbestos test performed and quarantined the area. The bulk sampling for asbestos came back with the report of “asbestos containing, but less than 1%“. Well, as you know (and as I have mentioned earlier) it may not be safe to treat this product like every other demolition project. In this case, the asbestos was very friable and by opening the wall cavity, it had definitely been disturbed.  The contractor quickly set up some procedures. Here they are:

• Stop work in area. Quarantine area and place warning on doors.
• Train employees & subcontractors onsite to hazard (asbestos).
• Abatement contractor will remove wall & vermiculite
• Abatement contractor will treat the material as if it is asbestos containing
• Once the area is abated. An aggressive clearance test will be performed to assure no airborne levels of asbestos are present.

But why in the world was it in there in the first place? The best guess is it was added as a sound proofing / noise dampening for a air conditioning unit (actually a liebert unit) located on the adjacent wall. No other wall cavities contained the material.

Yes, there can be airborne silica in the concrete when you are chipping up motar & tiles from a concrete base. This week a friend told me about his neighbor. He is a self-employed tile setter. He has worked in the industry for 20+ years. They just discovered he has cancer and will have the upper portion of his lungs removed.

Go here for more information. NPR article on silica rule delay.

From what I have seen, there are not a large amount of formaldehyde exposures in construction. However, there is A LOT of formaldehyde used in construction materials. Formaldehyde can be dangerous at levels undetectable by your nose. And, the symptoms of exposure are nondescript (irritant & tingling of eyes, nose, respiratory tract).

Here are some products that may contain trace (or more) amounts of formaldehyde:

• resins in plywood, MDF, CDX, particle board/fiber board
• garage doors
• drywall
• roofing
• glues / mastics
• paint/coatings
• carpets
• insulation (spray in and batting)

I believe the reason we do not see high exposures is due to the limited duration of exposure, and the open-aired nature during the construction. Some exceptions are warehouses with large storage areas of particle board/MDF. (I have found exposures in these areas)

The OSHA exposure limit for formaldehyde is 0.75 ppm (action limit of 0.5 ppm, and short term limit of 2 ppm). However, this may not be low enough, based upon other standards (ACGIH says 0.3 ppm, NIOSH 0.1 ppm)

Another major issue with this hazard in construction is once the space is occupied.

• Once construction is done, the space may be sealed up, heated, and additional curing can occur.
• This may release more formaldehyde, and also NOT allow as much to escape (by dilution ventilation).
• Compounding this issue are the type of occupants in the building. Are there children, non-working adults, immunocompromised individuals, sick, or elderly occupying this space? The OSHA standards are NOT protective for these types of people.

I do not forsee this type of sign being posted immediately after new construction.

On the plus side, someone has discovered that plants may help reduce formaldehyde & VOC levels in homes. Horticulture Science Kwang Jim Kim, et.al

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.