Industrial Hygiene in Construction

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.

Many times an IH is called upon to determine the cause of a person’s ailing symptoms. For example, an employee might complain of congestion, irritability, bloody nose, etc. Someone has decided it might be from their exposure at work.

The practice of industrial hygiene is difficult to apply to an individual. What I mean is, this field of study was developed due to serious health concerns over a population of people at work. This is essentially how science works, you take a population, study it, find the differences, then make conclusions.

Trouble occurs when you try this backwards. If the same person (as example above) complains of congestion, irritability, bloody nose- can we assume they must have exposure to lead dust? Not usually. We must obtain other clues.

What industrial hygienists try to do in these instances is rule-out the possible over-exposures. Sometimes we can measure for chemical exposures to see if it might be of concern. But even then, it’s not fool proof. Below are a few issues which make it complicated.

• exposure at work? job? extracurricular activities? home?
• person might have autoimmune disease and gets sick easier
• sampling is not feasible
• sampling is somehow screwed up (by IH, lab, mail carrier)
• exposure is through food, clothing, etc.

Even with these fallacies, there are things an individual can do to narrow down their ailments:

• create a log. time, type of symptoms, pain scale, others experience/smell, food eaten
• change things and see if it improves/makes it worse
• research – but do it right. Look at the items you use, check the SDS

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?

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:

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 ….

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

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

You probably already knew this. Risk changes over time.

As we start to measure, and value, loss we immediately want to minimize it. However, it’s an unobtainable goal. “Zero losses”. Really? It’s not actually possible, you know (at least in the long term).

Look at this graph of the number of deaths in the US over the years due to silica. In 1968 we had approximately 1,000 deaths. Now, in the year 2005, we are less than 200. Yet, OSHA wants us to lower the exposure limit.  (I am personally not opposed to it – but I am open to debate about it, really)

Our world is becoming smaller. But, you already knew this, too.

To give an example, look at what happened in Bangladesh on November 24/25, 2012. Meanwhile in the US, we were watching football and eating leftover turkey.  Over 100 people died due to safety concerns that turned into a fire. This country is going through what the US experienced pre-1970. Other countries have similar problems.

I suppose living in the US is a yet another reason for thanksgiving. Yes…, But.  What can you do to make the biggest impact? I don’t have the answer, but, I am open to suggestions.

When training people who work around asbestos I usually discuss the word “disturbance” for a LONG time. The reason is simple. If you avoid “disturbing” it, you avoid most of the health issues.

As most people are aware, asbestos is found in many types of materials. Floor tiles, popcorn ceilings, wall panels, etc.

Disturbance relates to the specific activities you perform AND the type of material the asbestos is in.

If the asbestos containing material (ACM) is non-friable, then in theory, it takes more effort to disturb the asbestos. If the material is friable, well, you need to be REALLY careful. – and in some cases, breathing can disturb it. For example, an electrician who uncovers an ancient acoustical ceiling panel and finds damaged asbestos pipe insulation laying on top of it…is probably already in trouble. He has essentially disturbed friable asbestos by merely moving the panel.

In contrast, a remodeling company installing a floating laminate hardwood over asbestos 9×9 inch tiles (without damaging them) is [probably*] NOT causing airborne releases of asbestos.

Most of the OSHA/EPA asbestos rules hinge on the matrix of the material and the activity you are performing on it. The reason is this is what makes the asbestos fiber airborne.

*the OSHA rules are very specific as to work activity, please do your due diligence.

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
   • fill out a questionaiire (just like Appendix C of OSHA)
   • they might have you perform a lung function test (spirometry)
   • you will get a yes/no answer (probably 99% are approved)
   • you might try an online medical evaluation
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.

When clients ask me to assist in choosing a product, I try to recommend a product with the least dangerous chemicals in it. I understand this isn’t always possible. However, I try to emphasize the worst case health scenarios and leave it up to the company to decide how to proceed. There are reasons to use a hazardous (to your health) product.

However, here are some considerations when choosing a hazardous product:

• more hazard vs less cost
• more hazard vs less time actually using product
• more hazard vs cost of PPE
• more hazard vs what the spec says
• more hazard vs different hazard
• more hazard vs terrible health effect/potential
• more hazard vs perception by others on the project (by the GC/public/subcontractors, media, neighbors)

Another issue with chemicals is the names and nomenclature. There are so many different names, common names, chemical names, and sub names of products – it gets confusing.

One solution called, ChemHat.org, offers a unique way of considering other chemicals. Plug in the CAS# (Chemical Abstract Number) or the name, and it gives you some ideas.

Another alternative in choosing the best product is to ask.

• Ask your industrial hygienist if this product is safe and/or are there concerns?
• Ask the GC if this is the only product that can be used
• Ask the architect if there are alternatives that are equally effective
• Ask the manufacturer if they have comparable products without the XXX hazard

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