Industrial Hygiene in Construction

As common as it sounds, falls in construction are still the #1 killer.

Go to www.osha.gov/stopfalls

This site has good information, reminders, training, and resources.

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.

There are two types of fit testing, 1. quantitative and, 2. qualitative. For quantitative fit testing you’ll need a machine (ex. Portacount),  a respirator that will protect more than 50x the limits (>full face).  I will not cover this type of fit testing in this post, but it is very similar.

For qualitative fit testing you will need:

A medical clearance (not needed if you are wearing a paper dust mask) for each employee wearing a respirator.

Respirator w/P-100 filters (1/2 face respirator or more protective), aka HEPA filters, purple in color.

fit test kit -your choices are: saccharine, irritant smoke, Bitrex, or isoamyl acetate-bananas. Buy it online, or at your local safety supplier. Look at their instructions.

My preference is to use irritant smoke. The reasons are;

1.  if they cough, it means they smelled it.
2. it doesn’t require a containment to be built to perform the fit testing.

The employee must be clean shaven around where the mask touches the face.  I allow “short” goaties where the facial hair does not touch the mask. The fit test procedures are easy to follow and found inside the kit. There are 8-steps, do each one for about 1 minute each.

As you fill out each individual’s form, make sure you include:

• if the employee is clean shaven
• what type of respirator is being worn (size, brand, model)
• what type of filters are being worn
• what type of fit test kit you used

While you have the employee captive, you might as well give them some training. Here are some questions and/or points to note.

• did you train them on positive & negative fit checks?
• why are they wearing a respirator?
• what are the limitations of their respirator?
• how will they store the respirator?
• how will they sanitize it?
• will they share their respirator?

Finally, sign and date the form. It expires one year from this date. Simple? yes.  Easy to forget something? yes.

Construction and exposure to Hepatitis B (or C or HIV) doesn’t arise very often since construction workers are usually not around blood, bodily fluids, or patients. There are times when construction must occur at wastewater treatment facilities, municipals, or in active sewers. Occasionally exposure can come from illegal drug use or the remnants of it (think of a project underneath a downtown bridge).

Currently there is not a specific rule for bloodborne pathogens in construction (1926). However, if it is reasonably anticipated that an employee might have exposure, you should take precaution.

What are the dangers? First, you must have occupational exposure to skin, eye, or mucous membrane with contact to blood or infected material.  Exposure may then cause the employee the diseases of Hepatitis B, C and HIV. Occasionally construction companies want to know if they need to offer their employees the Hep B vaccine.

The real-threat is contact with blood. Here is a question to ask… Do you anticipate seeing any blood on the jobsite? If the answer is NO…then you probably are under what is called the COLLATERAL DUTY clause. In this case, the hepatitis B vaccination does not need to be given…until the presence of blood. Once this happens (and employees must be trained beforehand) you have certain steps to take in order to offer the Hep B vaccination. Oregon OSHA (and others) have adopted this stance.

If you have probable exposures you must:

• make an exposure control plan
• train your employees
• universal precautions – google it…there’s a lot to know
• protect your employees (engineering controls, work practices)
• housekeeping – cleanup
• label
• keep records

Oregon OSHA has some good info here.

1. To better understand the levels of exposure(s).

•  avoid possible exposures to employees, document the non-exposure, show how safely you can perform the work

2. To save $.

• Avoid OSHA fines, worker compensation claims, avoid lawsuits, reduce liability

3. To go “Green”.

• reduce airborne emissions, remove harmful chemicals from the environment & employees, recycle & reuse emissions

4. To increase employee morale.

• investigate employee concerns, change environmental conditions to avoid exposures, increase employee involvement, reduce disgruntlement

5. Increase efficiency.

• doing the job right-the first time, less overhead, better prepared for the project and future projects

There is much confusion over the requirements and best practices of employees using respirators voluntarily.

Let me first clarify. You must do air monitoring (or have other verifiable information) that employees are not REQUIRED to wear respirators (if they are overexposed to something, you must protect them). Also, they cannot voluntarily wear a respirators if there is a known hazard above the exposure limit (the employee cannot opt-out of wearing a respirator and be overexposed).

Some points about voluntary use:

• Assuming the above statement (s) is true, firstly, you do not have to allow them to wear respirators. I am sure this is arguable from a human resources/PR/legal stance. However, if you have documented no overexposure and have not provided a respirator, they should not need to wear one.
• Next, the employees need to be educated and you need to prove it. Having them sign Appendix D of the OSHA respiratory rule is a minimum. Training them would be better.
• What respirator are they wearing? A paper dust mask (N95, P100, or similar) is a respirator. If they are wearing anything other than this type of mask they need a medical evaluation (Appendix C of respiratory standard).
• If they are wearing a 1/2 face tight fitting negative pressure respirators (or more protective ones) the company needs to have a written respiratory program.
• Fit testing is not required to be performed
• Maintenance, inspection, storage, and training should always be done. Can you verify that the employee does this?

I personally do not recommend the paper dust masks (N95, or similar) for this simple reason. Why would you wear this type of respirator if you could have a 1/2 face, tight fitting one with the correct cartridge? The cost difference is negligible, the protection is better, and you can be assured of a better fit. If you’re going to do it, do it right.

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

OSHA states that:

• Medical exam – must be completed prior to wearing a respirator. The individual must be examined again if there are significant changes to their medical/respiratory system.
• Fit Testing– this must be performed yearly (either qualitative or quantitative fit test, depending on the respirator) and be performed for each type of respirator worn (not for each filter used)
• Fit Checks- these are performed every time an individual puts on a respirator. Cover the inlets and breathe in (mask should collapse). Cover the exhale valve and breathe out (mask should expand)

Individual cards for employees are not required. Sometimes, when filing the medical exam, the physician/medical reviewer, will not require the individual to come into the office. As a best practice, I would have every employee fill out the paperwork and see someone in the medical office. Employees have every reason to want to pass this “exam” and they may leave out things on the written exam that are easily discovered (or may be obvious) when someone sees them in person.

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.