Industrial Hygiene in Construction

I recently heard a very good summary of when (or alternatively when-you-DON’T) need to perform air monitoring when working with lead in construction.

Is there leaded-paint (lead based paint) in your project?

• Then you MUST comply with the OSHA lead in construction rules.

On what occasion do I NOT have to perform air monitoring?

• if you don’t have lead (see the first question)
• if you want to provide the minimum required protection for all of your exposed employees (respirators, blood lead monitoring, etc. etc.)
• if you have historical air monitoring data (from another project) that supports the methods you are using

Otherwise (in summary):

• Take a bulk sample of the paint
• Set up all engineering & administrative controls for controlling dust
• Train your employees
• Perform air monitoring during the FIRST day of actual work
• Continue with all controls through the project
• Notify everyone onsite of results
• Require that all subcontractor do the same process

There are many distinct, separate, and important issues when entering a confined space. The point I would like to make is, as a manager of “safety” , Do you allow your employees to enter a confined space?

Most employers do (with consent, acquiesce ). Below are some questions to consider.

• Do employees know what a confined space is? (see OSHA definition)
• Do they know if it is a permit required space?
• Have they been trained? (this is a separate question)
• Do you control the space? What about the space around it? (what about the space where the air/water comes from?)
• Would you allow any employee to enter?
• Who would you NOT allow? (subcontractors? safety personnel? inspectors?)
• What paperwork/training would you want to see if you did allow these people to enter?

The management of confined spaces is by far the most critical piece. The space could be as innocent as a treehouse, or as dangerous as sewer hole immediately dangerous to life and health.

There is high demand!

See EHS article, which summarizes the NIOSH findings on the future of EHS jobs.

Yahoo Finance  (look at #6, but the information is a bit off)

If you’re wondering what the heck IH’s do…

• Remember that this is a technical-based career….you have to like science, chemicals, or physics.
• an Oklahoma article
• the standard answer: AIHA,
• another source: industrial hygiene support.

It’s a great career that offers challenges, diversity (as opposed to the daily grind) and… sometimes, you even help people! (ha).

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.

How much information should be contained in your written safety programs? There isn’t a right answer, but here are my suggestions and thoughts.

Have two “levels” of programs.

Corporate Safety Programs –

• This type should contain the general overview of the safety at the company. It should speak to the concern that the company has to the safety of the employees.  ie. “we don’t want you to get hurt, so…”
• No details. For example,  an Asbestos Policy statement – “As a company we anticipate that we may encounter asbestos onsite. We train our employees in identifying suspected asbestos containing material (ACM) and subcontract any work where we may disturb potential ACM. “
• Employees should be trained from the Corporate Safety Policies (initially, annually, or periodically thereafter).
• Establishing these programs should take a lot of thought, consideration, and buy-in from management and leadership.
• Do NOT make a policy that you do not plan on keeping. If you are going to occasionally do something which is a direct contradiction to your policy – don’t make it a policy. I know, simple in theory, but…

Site Specific Programs

• These types of programs should contain the details. Who, what, when, where, how.
• Only include the policies that you have at the jobsite- otherwise don’t have this policy on file in the trailer.
• Cut and paste the policies you need for this specific job – from your corporate program list.
• Another example, from the asbestos policy, “on XXX project we have identified asbestos in the blue and green 9×9″ floor tiles to contain 5%asbestos. ABC Abatement Company will abate and remove any asbestos found. If additional materials of this size, shape, color are found, please notify the superintendent immediately”.
• Perform tool-box talks from your site specific programs. These programs should have enough detail that your Project Engineer could read it to the employees and have enough information.

To simplify OSHA’s rules for lead in construction this is how I explain it:

Do you have lead (lead in paint usually) on the construction project? …Then you must comply with the entire rules.

How do you start? You start by listing the tasks where you will disturb the lead. For example, demolition, hand scraping, torch cutting.

After you’ve identified the tasks, then you can look at the OSHA rules and determine the minimum personal protective equipment (PPE) that will be necessary for your employees to wear while they’re performing each individual task.

Next, train your empoyee’s in lead awareness, which is the dangers, prevention and hazards of lead poisoning.

There is one other important aspect. Measuring your airborne levels of lead. This is done by air monitoring with a battery powered pump (and is typically one role of an industrial hygienist). Airborne lead results will indicate if you are generating a lot of lead into the air, or not. If you’re not, you can sometimes downgrade (bad word) the level of respiratory protection for your employees.

• Caveat: this is not a complete summary of the rules. Please know and understand your local and federal rules entirely! This also does not cover the EPA’s Lead Rules which have specific items that you must do.

By definition, “if you work around, or near asbestos”.  Which leads to:

When do I work around it?

• Answer: Buildings build before 1985 (some say 1980) might have it.

How do I know if I’m working around it?

• Answer: Any structure build before 1985 must have an asbestos building survey performed and the contractor have a copy of it on hand. (and while the inspector is onsite they might as well check for lead (Pb)).

So what type of training do I need?

• Answer: It depends. Either Class III or Class IV Training is required by OSHA (see earlier post).

We subcontract any asbestos work, and typically it’s already abated before we arrive onsite. Do we still need training?

• Answer: Yes. OSHA does not define any training shorter (less involved) than Class IV (which is 2 hours). And, what I commonly see is that employers don’t train their employees, they find asbestos, disturb it and then get in trouble.

Any advice for how our company can avoid getting in these situations?

• Answer: Train your office staff before you actually train your hands-on employees. If your estimators, project managers, superintendents and vice presidents know what to look for before bidding a job, then everyone has time to prepare and get the proper surveys, documentation, assistance, and training.

I attended a great session at an Industrial Hygiene Expo and Conference. Nowadays anyone with internet can find these useful apps, but it sure was nice to just sit there and watch them explain what they liked/disliked about each smart phone application.

Here are my top “useful”picks (mostly from their list). I like the free ones…Disclaimer: I didn’t develop these, nor have I loaded them all, or attempted to use them. 

1. Chemical Compatibility Database – might be really handy, if you remember to use it before you mix those chemicals
2. Lightmeter – I can see this one being really useful on those dark construction sites
3. IH Dig – if you r one- you gotta have this game
4. Converter Plus – mg/m3 to ppm, etc.
5. Cargo Decoder – all those DOT placard trucks running down the road- now you  know to be scared of
6. Time Calculator – allows you to add time(s) easier
7. Sound Level Meter – yep. and it works. Well, probably not in court.
8. Velometer – I can’t really tell you how it works, or if it’s accurate, but it might help sometime
9. Floor Plans (on the fly) – if you need a scale or a floor plan from a picture on your phone
10. Translators – these are really handy if you’re not fluent

Governor’s Occupational Safety & Health Conference 2011

March 7 through 10, 2011

www.oregongosh.com

This is an excellent way to learn more about safety and health topics from many industries.