Industrial Hygiene in Construction

You already knew it. There is a lot to do in industrial hygiene. At times this occupation feels like a safety middleman trying to keep people out of trouble. Occasionally I’m rewarded with really helping someone. In the United States, there is still a lot of occupational hygiene issues and concerns. Overseas, particularly in developing countries, there is even more.

It is hard to obtain accurate exposure data, or illness rates, from these underdeveloped countries. (How does a village of 1,000 people in Kenya report that they’ve had lead exposure to battery recycling?) How these exposures are brought to light is by either a massive death (# of people, quickly) or, someone with a camera able to actually photograph the pollution. As we know, what it looks like doesn’t necessarily correlate with hazardous levels of exposure. But, in some cases, it’s pretty obvious.

I ran across this photo story on pollution (The Guardian, UK). They estimate 125 million people are exposed to industrial pollutants (generic term, I know). This makes occupational related exposures a health risk as big as TB and Malaria! The article is based upon a report from the Blacksmith Institute which included this map of the worst pollution with associated disease.

How does this apply to construction? The worst offenders are lead (Pb) (and other metals), and asbestos.

What can you do? Here’s their recommendation, from the report (p50):

Developing countries need the support of the international community
to design and implement clean up efforts, improve pollution control technologies, and provide educational
trainings to industry workers and the surrounding community

Another NPR article about lead poisoning can be found here.

If you operate a ready-mix plant and have concrete trucks, you are aware of this process. Once a year (hopefully, only once) a person must climb into the drum of the ready-mix truck and chip off excess concrete. What happen during regular use, is that some concrete hardens, which usually sets-up over and around the blades. Access into the drum is by either the 3×4 hole in the side, or down the chute.

Yes, it is a confined space (def’n: 1. large enough to enter, 2. not designed for occupancy, and 3. limited entry/egress).

Here are a list of the possible hazards:

• silica dust (from chipping concrete)
• noise exposure
• hazardous atmosphere (curing concrete uses up oxygen, which we DO need BTW)
• slipping hazard (drum is round inside)
• heat stress (if you’re trying to do this activity in the summer)
• eye hazard (chipping)
• electrical hazard (if you’re using water & have an electric hammer)
• lock out / tag out (if the truck drives away, or if the barrel starts turning)

There are many resources available (see below). Some things to keep in mind; ventilation (fans, etc) to control the airborne silica dust are usually not effective (too much dust versus exhaust). Water controls are best, but you must limit the amount of water and the direction of the sprayer. I suggest looking at what others have done.

Keep in mind, if you perform this activity you will need (as a company):

• respiratory program (medical, fit test, written plan)
• confined space program (multi gas meter, written program, attendant?)
• lock out /tag out policy or procedures
• training (for each of the above, and for this specific activity)

At this point I know what my contractor-friends are thinking…I will subcontract this out!   ha. If you do, please make sure your sub is doing it right.

Resources:

Georgia Tech – good presentation & guidance

Georgia Tech/OSHA – Safe Work Practices (in Spanish too!)

Teamsters H&S hazards & controls

Illinois DCEO – Consultation on ready mix cleaning

Yes. If you are in construction, I recommend it. Here’s why:

First, the rules. OSHA does NOT have a specific construction standard for hearing conservation. Why does this matter? Well, the current OSHA rules state that if you have 1 day (that’s only one day) of average noise level above an average of 85 decibels A-weighted (dBA), called the Action Limit, you are required to start a program. Obviously noise levels vary on construction jobsites. I’d guess that most projects have at least one day of levels above 85dBA’s.

And, these particular OSHA rules are terrible. Well, they are terrible if you care about your hearing. (see my earlier post). The rules are simply not protective enough. If you are exposed to noise for 8-hours a day at 90 dBA (the OSHA average exposure limit) you WILL have hearing loss (this is without hearing protection). Does that seem like a very protective rule?  I’ve heard talk about them changing it, but…I doubt it will ever happen.

Second, let’s consider cost vs. reward. To start a hearing conservation program you must measure your employees hearing , called audiometric testing (and do a few other things). It costs approximately $20/employee to do this per year. Compare this with the average claim (of hearing loss) cost of around $20,000. So, if you have 20 employees, and it costs you $400/year…it takes about 50 years to pay yourself back for NOT starting a program. ($20,000/400= 50 years)

Third, consider your employees. Having their hearing checked may seem like a hassle and a worthless exercise, but, some will appreciate it. I’ve found that employees like to know how they are hearing. It’s good if your employer cares how well you hear. It’s also a yearly reminder in hazard awareness to noise.

Because in construction, we know there’s noise!

If you’re dead-set on NOT having a program, you’ll need documented noise dosimetry for each employee, job task, and possible overexposure above 85 dBAs. It is possible  for a construction company to avoid having a program, but you have the burden to prove there isn’t noise. Call your favorite industrial hygienist for help.

The new standard for material safety data sheets (MSDS) which incorporate the global harmonization system (GHS) rules are coming.

Federal OSHA has approved the rules, and in our state, Oregon, they have been proposed, with an adoption to take place in December 2013.

It’s time to panic!… No. Not really.

Most employers will have until December of 2013 to implement the rules. OSHA will be publishing additional (and hopefully, helpful) information on what to do. For most employers it will mean you need to do a few major things:

• Train your employees on the new rules
• Reclassify (rename) the hazards, mainly the flammable ones, which have changed the most.

If you really need help with this, or feel like you can’t wait until OSHA publishes more information, email or find me here and we can discuss.

After performing an industrial hygiene survey (air monitoring), have you considered when you should resample? Here are some considerations that might help you in determining when.

• Are there specific rules that state when you must resample? For example, the construction lead standard (1926.62) states that you must resample yearly (or actually, that you can only use relevant results for one year).
• Has the process changedsince the last time you sampled? This one is hard to determine. Lot of things can change air monitoring results, here’s a “starter list” of things that can change a process.
  • Different employee?
  • Time of year? Summer versus winter? (closed up/open and humidity)
  • Is a new tool in place?
  • Has the ventilation changed?
  • Have new controls been put in place? (administrative, systems operations)
• Has the product changed? Check the safety data sheet (aka MSDS).
• Are more (or less) employees exposed to this hazard? This might change some assumptions you have made about your risk.?

If you have air sampling performed, make sure you have a written report of your findings. Laboratory results without an explanation of how they sampled, where, # of employees, process description, PPE used, safety data sheets, etc….is worthless. You may remember is well enough, but OSHA will have a hard time believing that it is a similar exposure the next time you do the “exact same thing”.

Having this report and sharing it with the employees will fulfill (part of) the hazard communication standard requirement to employees.

I love the show, “Dirty Jobs” with Mike Rowe. I find it fascinating what people are willing to do for work. Many of the jobs on the show have a true element of danger. Either a pinch point, an animal bite/kick, struck-by, heat/cold extreme, confined space, etc.

Did you ever consider what makes something hazardous?

My “deep thought for today” (thanks Jack Handy) is that education and training can make a job less hazardous. If you know how to do it right, and you know the risk, it doesn’t seem as dangerous anymore. The risk is there, but you know how to handle it, so the “hazard” seems to fade. This week I’ve given two separate asbestos classes to two different employers. At the beginning the employees were genuinely concerned about the hazards. By the end, they looked a lot more comfortable about upcoming project.

Is it any surprise that the HazCom standard is the most OSHA cited rule year over year?

So, keep up the training! Educate the employees on the dangers.

Occasionally (actually, far too often), I hear from a subcontractor who was told by the General Contractor (or owner) there is no asbestos onsite. Then, after they have been working for a month they find out it actually IS asbestos, and they were disturbing it. What do you do?

The first thing to do is stop work. Do not try to clean it up. Call an abatement contractor. They will identify the asbestos onsite, clean it up, and provide an airborne clearance test.

Next, you will need to provide awareness training (or better, let the abatement company provide it). Ideally this will occur on the day you start back working. Train everyone onsite about asbestos.

Finally, you (as the safety manager), need to identify and characterize the exposure to the employees. It should probably be a formal letter written to the owner, general contractor and employees.

Here are some tips on writing the letter:

• include employee names, work hours, type of work, PPE worn, and locations they were working
• describe the asbestos. Amount found, locations, type, estimated amount disturbed.
• describe remedy process and steps taken. Names of GC, owner, abatement company, airborne levels found. Who was trained afterwards.
• describe how things will change in the future. Here’s a tip:  any building before 1985 WILL have a building survey performed for asbestos….in writing.

Really, one exposure to asbestos is probably* not enough to contract a disease (asbestosis, or mesothelioma). It will take 15-30 years for symptoms to appear. But, it might be worth the “goodwill” to send affected employees into a occupational health doctor for a check up. The physician will reassure the employee and may provide some comfort.

*asbestos is a carcinogen. Greater exposure = greater chance of cancer. no amount is safe.

The big industrial hygiene conference (AIHCe) is held in a different city each year. This year was Indy, Indiana. Below is my personal top ten list  of “lessons learned” from last week.

1. IH’s need to do a better job of sharing. We don’t share data, experiences, information, knowledge or our ideas well.
2. CPWR is trying to share. Center for Construction Research & Training.  I’m looking forward to seeing their published independent review of local exhaust ventilation (LEV) units.
3. The minimum exhaust rate for a portable exhaust unit must be 106 cfm (cubic feet per min) to capture particulates (dust, silica) during tuckpointing with a 5 in grinder (but it’s also a good rule of thumb).
4. Asphalt milling machines are still a huge silica problem. Water controls are NOT enough. You need a local exhaust system too. (here’s an earlier post I made on it)
5. GHS Safety Data Sheets – it’s not as complicated as you think. There are some significant changes, but don’t worry, OSHA’s here to help (ha). Seriously, more information will be available soon.
6. Ignite. Have you seen these before? Short, stand up speeches about their ideas/passions. Similar to TED. Some were better than others. But, did I mention they were short?
7. Committees. Be careful when you open your mouth. My idea was so great, they are making me do it.
8.  ANSI A10.49! A health standard for construction. Great idea, but lots of work.
9. Check out Environment for Children. I don’t know much about it, but they have a great mission.  Believe me, in the US, we’re WAY ahead.
10. Presentation. It’s all up to you to make it. I will not cast blame on those who had bad presentations. BUT, it reminds me that I should work on this skill. Even if you have something good to say, if you give a horrible presentation, it’s likely no one will notice. On the other side, if your presentation is good, people will listen, even if you’re talking about nothing!  My favorite of the week: Dr. Mike Morgan (Univ. of Washington) on Chromium VI. He was very factual, not too flashy, and make the point without needless details.

Construction and exposure to Hepatitis B (or C or HIV) doesn’t arise very often since construction workers are usually not around blood, bodily fluids, or patients. There are times when construction must occur at wastewater treatment facilities, municipals, or in active sewers. Occasionally exposure can come from illegal drug use or the remnants of it (think of a project underneath a downtown bridge).

Currently there is not a specific rule for bloodborne pathogens in construction (1926). However, if it is reasonably anticipated that an employee might have exposure, you should take precaution.

What are the dangers? First, you must have occupational exposure to skin, eye, or mucous membrane with contact to blood or infected material.  Exposure may then cause the employee the diseases of Hepatitis B, C and HIV. Occasionally construction companies want to know if they need to offer their employees the Hep B vaccine.

The real-threat is contact with blood. Here is a question to ask… Do you anticipate seeing any blood on the jobsite? If the answer is NO…then you probably are under what is called the COLLATERAL DUTY clause. In this case, the hepatitis B vaccination does not need to be given…until the presence of blood. Once this happens (and employees must be trained beforehand) you have certain steps to take in order to offer the Hep B vaccination. Oregon OSHA (and others) have adopted this stance.

If you have probable exposures you must:

• make an exposure control plan
• train your employees
• universal precautions – google it…there’s a lot to know
• protect your employees (engineering controls, work practices)
• housekeeping – cleanup
• label
• keep records

Oregon OSHA has some good info here.

Here are the questions I’ve been hearing in regards to the MSDS changes with respect to the new GHS (globally harmonized system of classification & labeling of chemicals)…

I am going to keep the answers REALLY short so you’ll actually read it. Keep in mind, I’m leaving some information out.

• What do I need to do?

As an employer you need to train your employees on how the new MSDS will look.

• How soon do I need to comply?

For contractors, you’ll need to train your employees by Dec 1, 2013.

• What is it?

It’s a universal (global) method to make MSDS have more information and make them all look the same.

• Why are they doing this?

Well, MSDS’s are very good. They’re supposed to be written with the same 15 sections with no-blanks. But, some people don’t do a very good job. Or, in some cases, do an really good job of hiding harmful chemicals, but, legally cover themselves.

• Where can I get help? Right now?!

There will be FREE training (you may have to search for it though) and more information being published. This is a topic you can learn and present to your employees. Since the deadline is a year and 9 months away, you have some time.

• Ok, do you have any places for additional information?