Industrial Hygiene in Construction

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.

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!).

This is cutting edge here, folks. A “new” mineral has been found to cause mesothelioma. As you might know, asbestos exposure can cause 3 diseases; 1. asbestosis, 2. lung cancer, and 3. mesothelioma. Previously it was thought that only asbestos exposures could cause asbestosis and mesothelioma. (Side: This is why late-night attorney’s wonder if you have those diseases….if you do, you were exposed at some point)

However, there is a new suspect: Erionite. (wiki it here)

This new mineral has been documented to cause mesothelioma and has asbestos-like physical properties.

The mineral is found in many places, near volcanoes. Below is a map from the fairwarning.org site.  Also, here is a link to the MSN republish of the fairwarning article. I guarantee there will be more news  in the media about this in the future. Here is the scientific article from University of Hawaii.

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.

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.

As I compiled information for a presentation titled, “Industrial Hygiene in Construction”, I wondered how to approach this topic. What I decided, is that I would start with the most frequent, the most common, with the most room for improvement. So, my list begins.

The caveat is that this list is NOT a list of the relative hazard compared to each other. This is just the IH hazards I see the most frequently. They should really NOT be compared to each other.

1. Silica – in regards to airborne overexposures and lack of controls.
2. Noise – in regards to overexposures and lack of adequate controls.
3. Lead – in regards to compliance with OSHA / EPA.
4. Asbestos – in regards to training employees and compliance with OSHA/EPA
5. Welding – in regards to overexposures and lack of controls.

Who needs it? And what are the requirements?

IMO every contractor who works on buildings built before 1985 needs it. I know, the rules say buildings 1980 and earlier, but asbestos has been found in buildings built after 1980.  So what kind of training do you need? Well, that depends.

If you work on buildings built before 1985 you will need at least Class IV training. The definition (by OSHA) of Class IV activity is “maintenance and custodial activities during which employees contact but do not disturb asbestos containing materials and activities to clean up dust, waste and debris resulting from Class I, II and III activities“. I believe this includes all construction activities where there might be asbestos present.  Even if the plan is to stop-work, and call the abatement company.

Class III definition is, “– means repair and maintenance operations, where asbestos containing material, including thermal system insulation and surfacing asbestos containing material is likely to be disturbed“.  I can think of many instances where contractors touch and disturb asbestos including, HVAC (Mechanical), Plumbers, Electricians and others.

Classes I and II are strictly abatement activities and, for our purposes, we will not define, or get into.

Comparing Class III and Class IV, we see the real difference is if there is: 1. contact or 2. disturbance.

• Class III – Contact and LIKELY to be disturbed
• Class IV – Contact but DO NOT disturb

Depending on the construction activities  on the structure- will determine which class you’re in…and will determine what type of training you will need.

Class III Training- 16 hours in length, and includes hands on use. Also, as a side- you must also register your project with EPA, depending on the size and type of activity.

Class IV Training- 2 hours in length, and must cover certain assigned topics.

As the saying goes, “if I had a penny for every time someone asked me…” Well, here are my most commonly (frequently) asked questions (FAQs) for dealing with asbestos and lead on a construction job-site.  These are my answers, so consult the appropriate governing body.

LEAD

• Do I need to comply with EPA’s new lead rule? How do I?

If you are working in a public area, or specifically, with kids under the age of 6, you MUST comply. Go to EPA’s website (www.epa.gov) and take an accredited training class and get your company approved for leaded paint activities.

• How do I know if I have leaded paint on my job-site?

If the building was built before 1978, a building survey (performed by an accredited inspector) should be taken. Rumor has it that leaded paint can be found in buildings up to 1985 or later. An accredited inspector can be found by calling the Construction Contractors Board, OSHA,  or the EPA/DEQ.

• Can I use a do-it-yourself lead testing kit?

Yes, but they can sometimes be misleading. They only test the surface paint -not the other layers below. In addition, these kits cannot determine the amount of lead, or the airborne levels of lead on your jobsite.

• I do have leaded paint on my construction project. Where can I find the current regulations on how to handle this situation?

OSHA (www.osha.gov), the Environmental Protection Agency (EPA) aka: Department of Environmental Quality (DEQ), the Construction Contractors Board (CCB), and sometimes Department of Human Services (DHS). Many of their rules overlap, but they all have unique rules that are designed for their particular jurisdiction.

• We had a building survey for lead hazards performed. Our accredited inspector had the paint tested and found that it was only 0.3% total lead. It is less than 1%, do we need to comply with the regulations since it is such a small amount?

Yes. Any amount of lead found in lead paint requires that comply with OSHA’s regulations. Depending on the project, you may also need to comply with the standards of other governing bodies (see above).

ASBESTOS

• How do I know if I have asbestos on my jobsite?

Buildings built before 1980 are required by DEQ to have a survey performed before any demolition or renovation.  The survey must be performed by an Asbestos Hazard Emergency Response Act (AHERA) accredited inspector.  They will take bulk samples of the material and determine the amount of asbestos present.

• The accredited laboratory reported the asbestos had less than 1% but more than 0.001%. Does this mean it has asbestos?

Yes, it has asbestos (less than 1%), but OSHA considers it to be non-asbestos containing. However, even at 1% asbestos, you would want to control the possible exposures. Work practice procedures, training, and PPE should be used.

• There is a small quantity (less than 10 linear feet) of asbestos on my jobsite. My employees may have to touch it. What type of training do they need?

There are four classes (or types) of asbestos work. Class I is the most hazardous and Class IV is the least hazardous. To answer your question-you need to compare your situation to the definition of Class III and Class IV asbestos work. Class III work is defined as, “repair and maintenance operations, where asbestos containing material, including thermal system insulation and surfacing asbestos containing material is likely to be disturbed”.  This type of training is 16 hours in length and must be done by a EPA/DEQ certified trainer. Class IV work is defined as, “maintenance and custodial activities during which employees contact but do not disturb asbestos containing materials and activities to clean up dust, waste and debris resulting from Class I, II and III activities”. This type of training is 2 hours in length and is the minimum. The particular type of training needed will depend on your situation.

• We obtained a building survey before starting our job-site. After we started demolition we found some “questionable building materials” that did not look like they had been tested in this report. What do I do?

Stop work. Call an accredited building inspector for the material you need to test and have the material tested. Then report the results to the owner, and others on the jobsite, within 24 hours.

• Our company policy is that we do not touch asbestos or lead. Do I need to write that down as “my company policy”?

Yes. Plus you should include what your employees should do if they run across a “questionable” material and whom they should contact.

• We subcontract all asbestos and lead work. Do I need to have my employees trained in lead and asbestos awareness?

Yes.  There is still a good chance that your employees will see or have to deal with these hazards on the jobsite.

I was requested to perform training for a management team (VPs, Estimators, Superintendents, PMs, PEs) on health topics. The request was specific: asbestos, lead, silica and mold/ IAQ (indoor air quality). I was given an hour, which is hardly enough time. However, the audience took well to it.  I was impressed with the questions and discussion that followed the training. Here are some highlights from that training that the management team adopted as policy. Most of these can be considered tips for good management of IH programs.

ASBESTOS:

• Before the project begins we will have (in writing) an asbestos survey
• As a contractor you typically sub the abatement work
• Employees need awareness training at some level (usually class IV)
• Any asbestos found is to be sampled (by an inspector) and NOT to be touched

LEAD:

• Before the project begins we will have (in writing) a lead survey of the building
• As a contractor we must manage lead on the project (no abatement usually)
• Any lead found on the jobsite WILL BE controlled
• Employees need awareness training – site specific
• Lead ACTIVITY (s)  must be characterized and assessed for possible exposures – and further steps

SILICA:

• There is/will be silica on our jobsite
• We WILL take steps to control the silica exposure when it occurs
• Employees will be trained as to the dangers of silica

MOLD/ IAQ:

• We will manage any mold/fungus found onsite
• We will have a plan for how we handle the situation as we arises
• We will be sensitive to any health or mold/fungus concerns