Industrial Hygiene in Construction

Did you know that there are two ways to get industrial hygiene sampling for free? I know, there’s always a catch, but below are my favorites.

1. OSHA

Obviously if you have an inspection and they perform air monitoring, you can use this information. Hang onto it! Get the field notes from the inspector so that, if necessary, you can reproduce these results. There is also (in some states with state-run plans) a separate division who can provide consultative air monitoring and/or assessments. I strongly urge employers to use this method. While your company is under consultation, they are under obligation to NOT allow an inspection (there are caveats).

2. Insurance carrier
   Your company’s insurance carrier can many times provide industrial hygiene services. This might come from your worker’s compensation carrier, your general liability carrier, and sometimes even your agent. If you have a legitimate concern and are able to wait to meet their schedule, this is a very attractive option.
3. The General Contractor
   If your GC has hired an IH consulting firm for a similar type process that you are performing, see if they will also take a sample on one of your employees.
4. Your Sub Contractor
   If you’ve hired a subcontractor to provide abatement for asbestos, or lead, request that they also perform a test on one of your employees. Sometimes even a sub-level tier will provide this as a courtesy.

I think the key to each of these is being nice. If you are a jerk, or attempt to strong-arm your GC or sub into this, it will never happen. In the safety world, most people want to help- that is why they got into this business in the first place.

…..: Red paint.

The point for the day is to remember that your sense of smell can be very good, or very misinformed depending on what you’re smelling (and who you are).

Sulfur (sulfur dioxide) can be smelled when it’s as low as 0.009 parts per million (ppm). The exposure limits are at 5 ppm. There are many chemicals that work just the opposite.

Before you make an assumption, figure out what you are smelling.

This question, at times, can really make a difference with how you proceed. Where you get your information, and, more importantly, who provides the information is essential. Not only for compliance, but also for how your employees are protected.

Unfortunately, the answer is often complicated.

To address this question, the answer is YES. They all might overlap depending on what you are doing, and in what situation. I will attempt to briefly summarize when each specific rule or standard might apply.

• OSHA – if you have employees and they work for you – you must comply. Sometimes each state (Washington, California, Oregon all have their own) may have a specific rule that enforces a bit differently, but Federal OSHA is the minimum rule.
• MSHA – if you are operating in a mine (surface or underground) they have jurisdiction. Your shop may (or may not) be in their umbrella.
• ACGIH – If they are referenced, it is usually a good practice to follow their rules. Look specifically at the date of the information. ACGIH updates their information yearly and is protective of the employee. Follow these rules if at all possible.
• AIHA – Another good recommended source of information (like ACGIH). However, they just announce they will not be updating (due to funding) their WEELs and BEELs.
• State rules – Occasionally, or more likely, depending on the specific issue, states will make specific rules. The Department of Human Services or similar will provide protective rules for the public. This may be an issue if your are working on a public project, or where small children, HUD, or other specific situations arise.
• Local rules – Similar to the state rules, sometimes a city will make rules to protect it’s citizens. Being active in the local community is the easiest way to find these rules. Searching through the local city or county rules is a chore, but may reveal some obscure rules.

Finally, at more importantly, why are we looking at rules?

I would suggest focusing on employee health, employee concerns, best practices, and available data to best help our employees. They perform their jobs for a long duration in the day. They usually have the answer, or the best suggestion for fixing it…if we would listen.

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.

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.

Some people really know how to stir it up, don’t they?

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.

A suggestion brought to one of my postings was, “how do you control the exposures?”. The answer, …in my best legalese was, “it depends”.

There are many ways to control the exposures.  However, as an general rule there is a method of approach that is best. OSHA describes it in some of their rule-language (such as lead 1926.62, and others).  So the first step in controlling an exposure is:

1. Engineering controls

What this means is: Can we remove the hazard from the employee. The best method is elimination. Using a different product that is less harmful can sometimes be discussed. Next, can we control the substance so that it is not harmful- like using a local exhaust ventilation? Can we use water to control airborne releases? Engineering controls should always be considered first. I suggest that when you have an exposure situation, have your safety committee brain-storm these types of controls and document them. OSHA has issued citations for employers who choose NOT to consider this control.

2. Administrative controls

These types of controls are a bit harder to describe. Suppose your worker must go into a high noise area multiple times during their shift – the answer might be limiting their time in this area. And possibly allowing other employees to “share” this exposure during their shift.  Another example would be having a protocol that minimizes airborne exposure by a method of work that is enforced by management.

3. Personal Protective Equipment (PPE)

This should be used as a last-resort. Most times it’s not. The reason it is NOT used is usually because of convenience.  However, there are many ways this control can fail including, improper use, breakthrough, permeation, penetration, degradation, and failure.

As a guy, I must admit… these tools are really cool. They’re loud, look like a space-age pistol, and have loaded bullets.  They use a .22 or .27 round casing  to drive the nail through the wood (or steel) stud (or bracket) and into the concrete.  It is really fast and …essentially a gun.

Powder actuated tools (sometimes confused with power, but it’s not) are typically used as  a quick method to anchor into concrete. There are a few types of these tools (Hilti, Simpson, Ramset) and there are specific safety precautions and controls that must be in place during use. However, I will focus on the newer hazard that was brought to my attention:  airborne lead exposure during their use.

I have seen these in use for many years, and at one point it was brought to my attention that lead was listed in the MSDS in section 2 Hazardous Ingredients (lead styphnate) and some of the manufactures caution the extended use of the tool. I actually dismissed the concern for airborne releases.   Well, I was corrected.

A study done by Liberty Mutual’s Mark Wiggins, CIH, CSP, ARM found that when as few as 50 to 90 loads are used per shift, the OSHA Action Limit can be exceeded.  It depends upon the type of load, where work is being done (location), and the type of work (overhead, etc).  He also suggests that the airborne exposure can be estimated based upon the number of rounds.

There are many alternatives to minimizing this exposure including: using battery-operated, or pneumatic anchoring tools, loads without lead, decreasing the frequency of use, and finally- respirators. A half-face, tight fitting negative pressure respirator is suggested to be adequate.

Leave me a comment if you would like the more information about this study.