Industrial Hygiene in Construction

At this point, the OSHA silica rules are forthcoming, what should you be doing to prepare?

• Read the OSHA Small Entity Guide. Initially it is daunting – 103 pages, but much of it is specific to tasks from Table 1 and the full rules are within it, as well. Plus, they have pictures!
• Identify tasks which could have silica exposures 
• Train employees, identify your “competent person(s)” – my suggestion is: Superintendents/Project Managers
  • Warn those on your projects: NO VISIBLE DUST on any tasks (cutting, finishing, dry sweeping, etc.)
• Document activities with airborne silica exposures below 25 ug/m3
• Identify possible solutions for overexposures
  • Verify airborne levels with personal air sampling
• Start a process to log the number of days with (any) exposure – >30 is inclusion into medical
• Find a medical provider that can have medical screen performed & with a B reader

*Thanks Andrew for the photos*

I live in a moderate climate, but we had some 102 degree weather and it reminded me of how important it is to have a heat stress program and educate our workers.

Here are some tips and suggestions for keeping this hazard under control:

• Mandatory rest/water breaks (time between work & break dependent on heat) in shade
• Monitor/measure water consumption (& urine, if extreme)
• Educate employees on symptoms and factors which might contribute (medications, were you drinking last night?= deydration)
• Always work with a partner
• Flexible work schedule (start early, leave when conditions get unbearable)
• Increase ventilation
• Consider the space (attics can be worse than conditions outside)
• Provide easy access to emergency services
• One of the coolest (pun intended) ways is a “smart” vest with a downloadable app – workers wear this safety vest and it will alert people when symptoms/conditions get bad (heart rate, temperature, etc). Developed in Australia by RMIT University in Melbourne.

Sound Level Readings Apps

You’ve probably already seen the sound level apps available on various models of phones and devices. Overall, I’d say they are, “OK“. I would say they’re, “great“, but since I am in a technical field, they actually aren’t that accurate when you figure the amount of error. However, when I consider who might use these: people in the field, I actually think they are, “AWESOME“. It provides an excellent educational tool and a relative-guess as to the noise levels in field conditions. A reading of 95 dBA on your smartphone app, even if it is “inaccurate” isn’t going to be that far off from my certified and calibrated Class II sound level meter. In other words, it will get you close-enough information.

Audiometric Testing Apps

BUT, have you seen the new hearing audiometric testing apps?!  I’m not too sure about these yet. Check out safety awakenings review of these new apps. These are only available on i-devices (ipad, iphone), but their price is worth a look (free & $2.99). The major downside is that these are NOT OSHA approved, so I suppose you would use it as a screening device.  And, in some US states, you must go through specific training to be able to administer the test.

However, there is an “OSHA approved” (I’ve been told, verify yourself please) ipad self-administered audiometric test called, ShoeBox Audiometry, from Canada. They claim their earphones are Class II devices, but you must send these in yearly for recalibration. The portability of this device would be a huge benefit.

Remember to research these on your own before making a decision. Anyone plan on buying audiometric testing equipment for their employees? Or using them now? I’d love to hear your comments.

Old School Portable:

“Do I need a bloodborne pathogens (BBP) program for my construction company?”

Of course, the answer depends, . But, OSHA does have a letter of interpretation.

The basics are: do your employees have DAILY exposure (anticipated exposure) to blood, or blood containing substances? Further defined as; “today we are going to pick up these bloody needles. Or, “this afternoon we are going into this live sewer, which is coming from the treatment plant”.

Here is OSHA Bloodborne construction letter of interp, but interpret the letter of interpretation yourself. 🙂

“…while the bloodborne pathogens standard does not apply to construction work, as defined in 29 CFR 1910.12(b), it does apply to employees performing maintenance activities who experience occupational exposure to blood or other potentially infectious materials. OSHA expects the construction employer performing maintenance activities to take the following precautions as required by the following referenced standards: Section 29 CFR 1926.21(b)(2) requires that the employer instruct each employee in the recognition and avoidance of unsafe condition…”

In summary, most construction firms do NOT need a full blown bloodborne pathogen program. However, you should still train your employees on the hazards they might incur. This might include the hazards of bloodborne pathogens. There may be a time and project where they wished they had the training.

I’m still startled by how many construction companies have not started a hearing conservation program. However, I do know why: we don’t see a lot of worker’s compensation claims from this injury (we still see them, but not in the numbers we think we should).

Recently I was asked this question: My company is strictly a general contractor. We do not have field employees, only Superintendents, Estimators, Project Managers, Project Engineers, etc. Do we need a hearing program?

Here’s why I think you should start a hearing program:

Start one for risk prevention, maybe not for overexposure to noise.
Most hearing loss claims are around $20k, and the cost of a program is about $15/year/employee. And, in some states, if you are the last injurious employer, you have to prove you WEREN’T the cause of the loss. (So, do noise monitoring/dosimetry semi frequently)

Other reasons:
• it set’s a good example for your subs – when your subcontractor is making noise, it’s hard to tell them they need to start a program when you don’t have one at your company.  Call it ‘credibility’.

• you can roll it into your company’s total worker health (TWH) / health promotion/ wellness program – even if you aren’t required to have it. Wouldn’t it be nice if your company took steps to make sure you still have your hearing?

• if you’re checking their hearing; and they have losses, you can intervene – this might be a big one for construction employees. How many construction workers have noisy tasks? Shooting, hunting, motorcycles, concerts, cutting wood, drag racing, mow their lawn? They may have hearing loss outside of work. If you’re monitoring their hearing, you can maybe influence their behavior while doing these activities.

Obviously starting a program can take time to manage, but there are mobile units which can provide most of the work. And, if you have a workforce above 50-70 employees, it might even make sense to purchase your own booth.

If you haven’t already heard, it is worth while to mention,OSHA now has jurisdiction over confined spaces in construction (in force on August 3, 2015). Hopefully those working in construction have already realized this hazard and have taken steps to prevent injury.

Here are some of my thoughts:

• **although there are many factors, and we should not compare hazards** OSHA estimates an “injury saving” of 780 serious injuries, and 5 lives spared with the confined space rule.  Compare this with the estimated injury saving from the proposed silica: prevent 1,600 cases of silicosis and save 700 lives.  (and, I do realize these cost employers different amounts of $)
• Oregon OSHA – confined spaces already has a (new) construction confined space standard, which is very much different. It will be interesting to see if this; meets/exceeds/or needs to be changed, to comply with the federal rule.
• Since this rule was dropped without much warning, we will wait to see if anyone calls “foul”. Other than political reasons, it is hard to imagine a reason why construction should be exempt from these rules.
• There are some differences in the construction rule and the general industry:
  • Multi-employer work sites are covered
  • Continuous monitoring – when possible engulfment
  • Upstream early warning- when possible
  • Suspension (not cancellation) of a permit

Noise has some interesting health effects. Most people assume the worst that can happen is you will lose part of your hearing. However, a recent (March, 2014) study in Injury Prevention by Girard, et.al, concluded that those employees exposed to loud noise (above 100dBA) were admitted to hospitals more frequently, and at risk for other injuries.

Some other known health effects include (from Medscape & WHO):

• fatigue
• impaired concentration
• behavioral changes
• irritation
• impaired academic performance
• interrupted sleep (during sleep times)
• changes in endocrine & autonomic nervous systems
• increase in heart rate, blood pressure, vasoconstriction
• sexual impotence
• neurosis
• hysteria

Noise is a simple subject, but there are many factors which influence noise exposure to individuals. Some include:

• The individual: age, prior exposure
• The noise: loudness (dB), type of noise (Hz), distance from noise
• Time: exposure vs. non-exposure time per day

More information on how to control this hazard in construction can be found here.

And, as a bonus, the Journal of the Acoustical Society of America has published a review of the top Smartphone Sound Measurement Apps..  The winner (most accurate) was SPLnFFT, at only $3.99. A close runner up was SoundMeter by Faber. Another summary review is here, and here.

Can we measure an exposure accurately with just one sample? (statistically, no.) Also consider: Can we measure a “worst case” scenario and be OK for the rest of the project? (again, hypothetical question)

There was a blog post, here by Mike Jayjock, which reminded me of how silly our data points (aka industrial hygiene sample results) are in the big picture of statistics.  I’m slowly reading a book titled, “Control Banding” by David Zalk who is with Lawrence Livermore National Labs. The CDC also has a section on control banding here.

Another side of this is a common practice we all perform called Risk Analysis. There is much on the subject, but essentially it’s similar to triage at an emergency room. What is the easiest, best thing you can do: given what you have available and what you are able to muster?

Too often (myself included) we perform air monitoring for a specific situation and use that information as the gospel-truth. Well, this might be like living in the United States and never traveling. We meet a very nice person from the Ukraine. They seem very typical Eastern European and have a thick accent, but are they really like everyone in Russia? Is this person typical? Are they exactly like every other person from Russia?

This type of stereotyping is the same as taking one sample and drawing conclusions about all exposures. You might be right, BUT…you might be wrong.

There is a fun app you can download called, IH DIG by Adam Geitgey (Apple & Android).  This app illustrates the importance of using statistical tools, rather than guessing. (It’s a game)

Sorry I do not have many answers in this post, just a lot of questions.

If you live in the United States, you have less than one month to train your employees on the new Hazard Communication standard (1910.1200(h) & 1926.59), which should include information about the new types of Safety Data Sheets (formerly known as MSDS) and the adaptation with the Global Harmonization System (GHS). December 1, 2013 is the enforcement start date for OSHA. Don’t make this complicated, it is straightforward. Here’s what you should do:

• Train employees in hazard communication (simply: so they know the hazards they are working with)
• Document your training (in case of an OSHA inspection)
• Show them a sample Safety Data Sheet (SDS), compared with the old MSDS
  • Explain the new standard hazard phrasing & pictograms
  • Explain how to review a SDS
  • Remind them about container labeling
• Explain that the new SDS will not be available immediately, but will roll-out over a few years (or more)

*Please note the “Beer” hazard warning on the right is not GHS compliant. 

For Help:

• Oregon OSHA (OR-OSHA has a new fact sheet on what you need to do for compliance.
• Here’s a link to a sample hazard communication plan (in Word!). More help here.
• AND, a free training guide for employers, another here. Shout-out to Siobhan & Dan at SAIF for this.
• Also, some Susan Harwood free training materials here (spanish too!).

It’s sad to say, but many construction companies have not yet started a formal hearing conservation program. Their solution is to purchase the best earplugs, for the lowest cost, and give them away like candy.

As I’ve mentioned before: Sometimes OSHA’s rules are protective (meaning: you will be safe) and other times they are really not on par with the health research. Hearing loss and OSHA’s method of measuring noise are NOT protective to employee health (your hearing). For the best method of measuring noise, look to the recommended guidelines of the ACGIH. In order to get the exact parameters, you must purchase their Guide to Occupational Exposure Values (TLVs) booklet. It hasn’t changed (at least for noise) for a few years, but it is still the most up to date on health for your hearing. Here’s a summary of some differences:

• Exchange rate (how noise doubles and is averaged over time)
  • OSHA uses 5, ACGIH uses 3 >>which means noise doubles every 5, or 3 dB increase
  • this makes a BIG difference in your accumulated average noise level (TWA).
• Exposure Limit, or Criterion Level
  • OSHA says 90 dBA, ACGIH says 85 dBA
  • Doesn’t seem too different (-5), but remember noise is logarithmic and it’s measured different by OSHA & the ACGIH

NIOSH also has some guidelines, which are very similar to the ACGIH.

There are some strong benefits to having a hearing conservation program. Here are some examples and suggestions for bettering your own program.

• You can be recognized
• Win an award. 
• Have less (or even better: none) hearing loss claims
• What about just hearing soft noises? kids? hunting? sports? the TV?

If you have worked in construction for any period of time, you know how loud it can be, and how much exposure is out there. Don’t assume working in this industry that hearing loss will to happen to you. Do something about it. Here’s a presentation from CDC/NIOSH a few years back on how to start.