Industrial Hygiene in Construction

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.

I was asked to perform asbestos training…and, “…maybe talk a little on lead”. However, I knew the employees needed to hear something totally different.

The firm requesting the training was a large excavation company that does a lot of road work. The training was at their bi monthly company wide meeting . I was given one hour.

So, my idea: Give them a quick overview of asbestos and lead, and then talk to them about silica. I called the training, “IH Health Topics in Construction”. And, as suspected, the questions that were posed all dealt with either: 1. “in my home I have…” or 2. silica and how to protect themselves.

I have made it my personal aim to talk about silica to as many employees as I can. I throw it into any training (even if I have just 5 minutes). Chances are, these guys WILL have overexposure to silica.  The owner did not mind since I told him we were going to talk about a few different kinds of health issues in construction.

My suggestion: see if you can work Silica into your conversations and trainings.

If you use heavy equipment and need to move dirt, rocks or soil, look closely at the buckets. Many times they will be coated with a material called hardfacing. It is a durable (consumable) welding bead laid out in a pattern. This pattern (from what I am told) helps to extend the life of the bucket. Apparently the cost of putting this product on the buckets is well below the cost of replacing the bucket (or teeth, or whatever).

The hazard is really on during the application of hardfacing. See my earlier post here. Hardfacing contains stainless steel (approximately 25%?, but it varies). Heating the stainless steel releases chromium in it’s hexavalent form (Cr6).

If your buckets have this on their exterior, your employees are probably exposed to hexavalent chromium at some point in the year.

However, the pattern is an art & science. Look closely at the side of this bucket…I think I know where this welder got his inspiration.

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.

As you may know, sometimes tin knockers (aka sheetmetal workers)  use sheet lead, or lead soldering, to make flashing on roof vents. Here is a picture of what these commonly look like (if there is (?) a common one).

The lead iron is heated up. Lead solder, or sometimes lead/zinc solder is used. Muratic acid (or similar) is used to clean the stainless steel. The iron is used to heat up the solder and drip it on the stainless surface. Anyways, the process creates lead fumes. This is dangerous both from airborne inhalables to the contact surfaces surrounding the area.

The surfaces around these areas are usually very high in lead content. There is not a OSHA standard for lead wipe tests. However, in the past OSHA has used the HUD standards and cited employers under the general duty clause. If you are performing these tasks, please make sure you are doing everything you can to limit the airborne, dermal, and ingestion exposure.

• Follow OSHA Lead Standard (1926.62).
• Train your employees.
• Ventilation (downdraft is best). This is the best way to control the fumes.
• Post signs in the area “lead work and hazardous”.
• Perform air monitoring. I have found levels both above, and below, the exposure limits.
• Wear a respirator (1/2 face negative air with HEPA).
• Do not: eat, drink or smoke in this area.
• Good hygiene. Wash after doing these activities.
• Use a plastic sheeting on all surfaces. This makes it 100x easier to clean up.

in other words, don’t do what is in this picture below:

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 in the Northwest, rock crushing definately has a season…and that season is now. Road crews are getting set up and now is the time to make sure you get everything is in order…before the MSHA inspector shows up.

Below is my safety punch-list, specific to industrial hygiene:

• Training – I know it’s required for MSHA sites, but double check. Does everyone have it? What about contractors onsite?
• Water controls working & in place? The dust isn’t bad, yet.
• Air monitoring for silica – done it yet? Are you at a new location? New part of the quarry? Better do it again.
• Miner’s hearing checked (audiogram taken?). Anyone with a threshold shift? Make sure you follow up with another test.
• Are the air conditioning units working in the vehicles? – if they’re not= the windows will be down = noise levels WILL be up.
• Noise monitoring (dosimetry) performed 8-hour time weighted averages? If you don’t do it, MSHA will (maybe will be citation too).
• Is your shop done hardfacing the equipment? see my earlier post here.
• Paperwork in order?

Be safe out there!

1. To better understand the levels of exposure(s).

•  avoid possible exposures to employees, document the non-exposure, show how safely you can perform the work

2. To save $.

• Avoid OSHA fines, worker compensation claims, avoid lawsuits, reduce liability

3. To go “Green”.

• reduce airborne emissions, remove harmful chemicals from the environment & employees, recycle & reuse emissions

4. To increase employee morale.

• investigate employee concerns, change environmental conditions to avoid exposures, increase employee involvement, reduce disgruntlement

5. Increase efficiency.

• doing the job right-the first time, less overhead, better prepared for the project and future projects

I have never (as of yet, knock on wood) heard a construction worker say, “you know, Mr. IH,  the air around this construction site is moldy, dirty, full of fungus, and smells. I’m not sure I can work here”. Never heard it. It’s probably because these guys (& girls) are so tough! Right?

More commonly what I hear in construction is:

• I’ve got a client who has some water leaks, what should we so?, or 
• What can we do to help them?
• How much mold can my employees remove?
• Is it OK for my employees to remove moldy building materials?

The most important thing is: make a decision about what you will allow (as a company) your employees to do? What business are you in? Will you let an employee take out a sheet of moldy wallboard? Will you allow them to demo an entire bathroom with black fungi all over the walls?  There are some guidelines (page 2) and here. OSHA does not have specific rules for this type of work. However, OSHA (and you) will be concerned if your employees are exposed to this type of activity. They will cite you under the general duty clause.

So, the next decision is what level of protection (level A? full face respirator? paper dust mask?) will my employees need to wear? again, it depends (see link above). But as a general rule and in most scenarios, a full face respirator with HEPA filters is perfect. A half-face is fine, at times, but the eye protection during construction is easier (less fog on your safety glasses) if you are wearing a full-face.

Finally, decide if you will either:

• clean it (guidelines here)
• replace it (tear it out, and build new)
• subcontract it (please, use a remediation contractor, not your brother in law)

This will depending on many factors including; size of damage, where the damage occurred, access, available workforce, etc.

Stay close, I will attempt to blog more about this topic in the coming weeks.

If you weren’t aware, OSHA is in the process  of establishing a ‘new’ rule (could be years) for confined spaces in construction (here).

In the meantime, if you plan on entering a space that is confined, below is my “standard” answer: Get help!

What I mean by this is; obtain some assistance as early as you can. Ideally this might even be before you bid the job. I often suggest to  send a superintendent or project manager to a 1/2 day training. Do not rely on the owner, or your general contractor to “safely approve” your employees entering this space. It is your job!

Although confined spaces are simple by definition (restricted opening, large enough to be in, and not meant to be occupied) , they can get  complicated easily. The first thing to consider is what is/was in the space. Secondly, what are you bringing into it? If those two questions are answered completely, the dangers are usually identified.

When reviewing, consider: electrical, oxygen, engulfment, entrapment, access (ingress & egress), coatings, noise, slips, temperature and emergency response (this is NOT an exhaustive list).

There are many other items and steps to have a well-run confined space program. Take a class, know the space, and train your employees. There are many resources at Federal OSHA and at your state OSHA, like Washington here, or like this one from Oregon.