Industrial Hygiene in Construction

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.

As common as it sounds, falls in construction are still the #1 killer.

Go to www.osha.gov/stopfalls

This site has good information, reminders, training, and resources.

Living in the NW, stucco is not as prevalent, compared to other areas of the US, as a building material. I finally got the opportunity to perform air monitoring for silica during stucco crack repair. From what the contractor explained, only the top layer of stucco (1/8 inch) is removed. He claimed the top layer is mostly an acrylic. The employee was wearing a 1/2 face tight fitting respirator with P100 (HEPA) cartridges. In addition, engineering controls were used.  The contractor had a grinder with a shroud and vacuum to remove the dust. This would not be considered a worse-case sampling scenario. From conversations with the plasterer-employees onsite, grinding is usually “VERY dusty”.

Sampling performed only for the duration of the grinding (3 hours). Conclusion?: We did not find any detectable levels of silica or respirable dust.

Please don’t use this sampling as the only information on how to proceed for your project. However, here are my observations:

• If acrylic material is the top 1/4 inch, you may not impact silica (or have any airborne).
• Airborne dust was very well controlled by grinder with shroud & vacuum (see pic below).
• Assume you will have dust until you can observe (or prove) otherwise. Wear a respirator.
• Perception is huge. If there is a big dust cloud coming from your grinder—even if there’s no silica… the observers don’t know the difference, and, well,…you know the story.

 

‘Tis the season for silica (here, and here too).

I had four observations about this picture,

1. paper dust masks are totally inadequate for this task, and
2. why isn’t there any engineering controls (water?, vacuum?), and
3. why is the observer standing in the dust plume?, and
4. what does the employees do with their clothes after work?

Please be safe out there.

There is much confusion over the requirements and best practices of employees using respirators voluntarily.

Let me first clarify. You must do air monitoring (or have other verifiable information) that employees are not REQUIRED to wear respirators (if they are overexposed to something, you must protect them). Also, they cannot voluntarily wear a respirators if there is a known hazard above the exposure limit (the employee cannot opt-out of wearing a respirator and be overexposed).

Some points about voluntary use:

• Assuming the above statement (s) is true, firstly, you do not have to allow them to wear respirators. I am sure this is arguable from a human resources/PR/legal stance. However, if you have documented no overexposure and have not provided a respirator, they should not need to wear one.
• Next, the employees need to be educated and you need to prove it. Having them sign Appendix D of the OSHA respiratory rule is a minimum. Training them would be better.
• What respirator are they wearing? A paper dust mask (N95, P100, or similar) is a respirator. If they are wearing anything other than this type of mask they need a medical evaluation (Appendix C of respiratory standard).
• If they are wearing a 1/2 face tight fitting negative pressure respirators (or more protective ones) the company needs to have a written respiratory program.
• Fit testing is not required to be performed
• Maintenance, inspection, storage, and training should always be done. Can you verify that the employee does this?

I personally do not recommend the paper dust masks (N95, or similar) for this simple reason. Why would you wear this type of respirator if you could have a 1/2 face, tight fitting one with the correct cartridge? The cost difference is negligible, the protection is better, and you can be assured of a better fit. If you’re going to do it, do it right.

OSHA states that:

• Medical exam – must be completed prior to wearing a respirator. The individual must be examined again if there are significant changes to their medical/respiratory system.
• Fit Testing– this must be performed yearly (either qualitative or quantitative fit test, depending on the respirator) and be performed for each type of respirator worn (not for each filter used)
• Fit Checks- these are performed every time an individual puts on a respirator. Cover the inlets and breathe in (mask should collapse). Cover the exhale valve and breathe out (mask should expand)

Individual cards for employees are not required. Sometimes, when filing the medical exam, the physician/medical reviewer, will not require the individual to come into the office. As a best practice, I would have every employee fill out the paperwork and see someone in the medical office. Employees have every reason to want to pass this “exam” and they may leave out things on the written exam that are easily discovered (or may be obvious) when someone sees them in person.

In construction there may be a time when employees need to weld on galvanized metal. This poses a unique problem since the zinc oxide fume can cause metal fume fever.  Should employees wear a respirator? Should mechanical ventilation be used? Should they drink milk? before? during and after welding? 

As with my answers to all welding types:  it depends.

However, I will make some generalizations. I have not seen a lot, or high airborne exposures (to zinc oxide) during galvanized steel welding. But, I typically recommend that welders are prepared and ready to wear a respirator if the need occurs. Welding is so variable, it is hard to make generalizations that cover all aspects.

Some questions that I ask before issuing respirators include:

• Does the welder have experience and training with this type of welding?
• How long will the welding occur?
• Is it spot welding? or for a duration of time?
• Is there mechanical ventilation in place, and can it be used for the entire project?
• Is there any portion of the welding that will be in a confined area with limited ventilation?
• Are there any coatings on the metal? Lubricants?

Once a respirator is decided to be issued, I only recommend a 1/2 face tight fitting respirator with HEPA filters. I know that N95 and other types of filtering dust masks do provide protection, but they, in my opinion, are not adequate if you really need them.

And, as far as drinking milk. If you feel sick after welding- drink it. It won’t hurt.

During mild steel welding I very rarely see respirators being worn. I believe this to be “standard practice” (the act of NOT wearing a respirator). However, is this a good idea?

The correct answer is:  It depends.

Explanation:

• I actually think during common mild steel welding, respirators should not usually be required. My experience in air monitoring has demonstrated that most “average” levels are well within occupational exposure levels (OELs).  While sampling under the hood (placing the filterpiece inside the welding hood), the flash hood protects from a lot of exposure. Most of the particulate that is seen-visually is iron.

Caveats:

• “average” welding changes everyday. What is average at one fabrication shop may be totally different from another. Each project may have different welding exposures. Welding inside a 36 inch tube is different than in an open field. You should roughly know what airborne levels you have at your site.
• If the welding contains metals other than what is in typical mild steel (and many times there are other stuff), the air levels can vary. Steel nowadays is so much recycled metal that there is a huge variability in the makeup of new product. Exotics (stainless steel, etc)  and known contaminants (leaded paint, coatings, oils, etc) should be treated very different.
• Long term exposures from metals might be a real health concern. There aren’t many metals in mild steel that you need to inhale.

Finally:

To wear respirators is a good decision. Conditions change and, in construction, this might be every hour. When the project needs to be completed quickly, most welders will not run to the store for a respirator. It is nice to be prepared.

My advice is to issue half-face tight fitting respirators with HEPA (high efficiency particulate air) filters. Train employees WHEN to use them and, if you have safety culture that permits it, trust them to use it when conditions warrant their use.

One of my pet-peeves is reporting industrial hygiene results with absolutely no explanation of what happened (or the conditions) on the day of the survey. The results will never be reproducible, verifiable, or really ever used again. If you are going to perform the exposure assessment, tell us what happened. We all know that an “average day” is rarely ever the average.

Sometimes you are not able to choose the time when you are able to perform air sampling or monitoring. But, that is a very important part of the overall picture of the exposure. When sampling I very frequently hear, “You should have been here yesterday”, or “Today is really slow”, or “Can you come back next week when we are doing XXX activity?”.

Those phrases and employee interviews are almost as critical as the air sampling results. They tell you what you DIDN’T see, or capture in your exposure monitoring.

At a minimum you should tell a story about:

• what engineering controls are in place
• what administrative controls are used
• what are the employees doing
• how often does this occur
• is this a worst-case scenario, or just average day
• what happens during set up and clean up
• what products are they using (MSDS)
• what PPE are they using