Industrial Hygiene in Construction

Are you measuring for zero accidents? Is this even possible? I agree it is a worthy goal. But, if you are presenting this to management, can you actually achieve it?

There is plenty of discussion around this issue. Maybe a better goal is something harder to measure, but more successful/beneficial in the long term. What about measuring one of these? (or a combination)

• response time from complaint to resolution (from employees)
• number of requests for safety related issues
• satisfaction of safety by workers (rate 1-10)
• safety committee interest & interaction
• decrease in airborne exposure levels year over year
• keeping track of engineering/administrative controls put in place per year

My 2 cents.

Background: We arrived at the welding /fabrication shop where they were working on stainless steel. We were the first to arrive and found this next to the project.

I found 3 things that were blatant “no-no’s”. Want to guess? (see my answers below) You might find more.

1. respirator sitting out -not put away in box (actually sitting next to it!)
2. grinder without a guard
3. eating/drinking in the work area (gum, drinking cup)

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

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.

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.