Industrial Hygiene in Construction

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

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.

You must follow both. (I’ve mentioned this before)

OSHA’s rules are very detailed and apply to any amount of lead in paint (even less than 0.5%) if you are disturbing it. The only time OSHA rules do not apply is:

• if you are working as a sole-proprietor (no employees), or
• if you are in some other country.

EPA’s rules are just a start. They apply to any residential facility where there are kids under the age of 6. OSHA’s rules are much more comprehensive and protective. (in some instances, overkill)

To EPA’s credit, they have done a great job of marketing and letting contractors know they insist on compliance. OSHA, on the other hand, only inspects 2% of businesses/year and does virtually no marketing. The chances of OSHA showing up on any given jobsite, is nearly 0%.

OSHA’s rules are very complete and comprehensive. You WILL need air monitoring, blood monitoring, PPE, change areas, water/sanitation, and training. The worst thing you can do is NOT follow the OSHA rules, find overexposures, and then try to “make up” for it. From my experience this scenario is a bad place to be, and happens all the time.

People who work in industrial hygiene try NOT to admit fault. There are reasons;  legal implications, credibility, and of course, pride. Since this blog is about being transparent, I will confess I made a huge mistake. My mistake wasn’t disastrous, but it could have been.

Background:

Employees were using a hudson sprayer (pump style) to apply a liquid waterproofing material. Air monitoring was performed and found to be 50% of the OELs. However, given the environmental conditions, and different areas they would need to access, I recommended they wear 1/2 face respirators. The hazard was isopropyl alcohol and a 1/2 face respirator with organic vapor cartridges was sufficient, with goggles & protective clothing.

However. It wasn’t isopropyl alcohol….it was methyl alcohol (methanol). And, there is a HUGE difference. Organic vapor cartridges (filters) provide NO protection to methanol. I should have recommended supplied air respirators.

I feel terrible, and I apologized.

“Success does not consist in never making mistakes but in never making the same one a second time” – George Bernard Shaw

The answer is Yes.

If you are working with lead (in any amount) and you are performing any of the “trigger tasks” in construction = you must follow OSHA rules. Trigger tasks are demolition, removal, encapsulation, new construction, installation, cleanup, abrasive blasting, welding, cutting, torch burning, transporting, storing, heat gun work, sanding, scraping, spray painting, burning, welding, etc. What about the EPA rules (RRP)? Look here.

The only exceptions to not measuring employees blood lead are:

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

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.

As you might be aware, there is a loudness of noise which your ears cannot be protected against. Your body’s system of preventing the sound waves from entering your ear are just too much for it to handle. As the noise (sound pressure) hits your inner ear the bones convert the physical energy (noise) into a chemical & neurological process so you are able to hear. Ear plugs and ear muffs are not sufficient enough to protect against the amount of noise exposure.

However! Sometime in the future we might have a pill to prevent this type of hearing loss.

Researchers have found that the chemicals, D-methionine, ebselen & N-acetylcysteine, battle chemical stress on your ears.  We are still a long way from being able to take a pill to avoid hearing loss. They must go through more testing and the FDA approvals.

But, isn’t that cool!?