Industrial Hygiene in Construction

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.

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.

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.

There are two types of fit testing, 1. quantitative and, 2. qualitative. For quantitative fit testing you’ll need a machine (ex. Portacount),  a respirator that will protect more than 50x the limits (>full face).  I will not cover this type of fit testing in this post, but it is very similar.

For qualitative fit testing you will need:

A medical clearance (not needed if you are wearing a paper dust mask) for each employee wearing a respirator.

Respirator w/P-100 filters (1/2 face respirator or more protective), aka HEPA filters, purple in color.

fit test kit -your choices are: saccharine, irritant smoke, Bitrex, or isoamyl acetate-bananas. Buy it online, or at your local safety supplier. Look at their instructions.

My preference is to use irritant smoke. The reasons are;

1.  if they cough, it means they smelled it.
2. it doesn’t require a containment to be built to perform the fit testing.

The employee must be clean shaven around where the mask touches the face.  I allow “short” goaties where the facial hair does not touch the mask. The fit test procedures are easy to follow and found inside the kit. There are 8-steps, do each one for about 1 minute each.

As you fill out each individual’s form, make sure you include:

• if the employee is clean shaven
• what type of respirator is being worn (size, brand, model)
• what type of filters are being worn
• what type of fit test kit you used

While you have the employee captive, you might as well give them some training. Here are some questions and/or points to note.

• did you train them on positive & negative fit checks?
• why are they wearing a respirator?
• what are the limitations of their respirator?
• how will they store the respirator?
• how will they sanitize it?
• will they share their respirator?

Finally, sign and date the form. It expires one year from this date. Simple? yes.  Easy to forget something? yes.

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.

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.

Occasionally I hear of certain (construction) trades having to touch asbestos. Usually it is an electrician, sheetmetal worker, carpenter, or plumber.

How it usually happens is that they have a small remodel/install/repair. They must cut through the asbestos to install the item (duct work, electrical, plumbing). Be careful. If you look at OSHA’s definition you may not be able to perform this type of work without specific training. In some cases, 16 hours of asbestos-specific training!

If you work with any type of asbestos (or, are even near it) you must have Class IV (4) training. This is a 2-hour training which is defined as, “…contact, but DO NOT disturb asbestos…”. As a contractor, you want to make sure you fall under this type of training. The alternative is,

Class III (3) training. This type of training where employees are, “likely to disturb” asbestos.  If you think you disturbed asbestos in your activities, you REALLY should prevent it. Here are some suggestions for making sure you never disturb asbestos.

• Always, always get (in writing) a building survey for asbestos (and leaded paint) before performing work
• Train your employees in how to recognize asbestos, etc. (Class IV training as a minimum. See my earlier post)
• Establish procedures for how you will prevent contact with asbestos

If you must touch (and possibly disturb it) asbestos then also,

• Have specific procedures for how you prevent exposure
• Have PPE (including respirators)
• Obtain air monitoring data while you are performing your activities – document that you DO NOT disturb the asbestos
• Dispose of the material properly

Asbestos is one of those hazards you can’t ignore. If you are not doing the correct procedures, it will bite you (a claim, a citation, a lawsuit, horrible PR, or someone getting ill!).

I recently gave a safety presentation to a large group of pile bucks (for those who don’t know, these are highly trained workers who drive pilings into the ground, among other things). All of my preplanning for the presentation was for nothing.

The projector didn’t work (I did have a backup, but not enough time to get it ready). And, as I was being introduced, they requested I also cover an entirely new topic that I hadn’t prepared for… I was scared.

The presentation actually went well. I wasn’t tied to my notes or slides…I had a lot of interaction with the crowd and they asked questions and commented on specific issues they deal with on projects. I didn’t look at my computer, prompter, or behind me. I took less time to cover the same points. I looked at everyone in the crowd and was able to engage them and change my presentation(slightly) based upon their reactions, comments, and interests.

Afterwards, I realized they learned. Maybe not as many “facts”, or points on the subject, but they sure remembered the main objectives:  Be safe. Use caution. Think ahead.

I am going to attempt more presentation just like this.

I have seen presentations given like this, but I never have the guts, or confidence, to do it that way. In fact, thinking back, I had read a blog (Seth Godin) of these exact things to do. I hit almost all of them….by accident.

Here’s my top 10 recommendations as it relates to Construction Industrial Hygiene: