Industrial Hygiene in Construction

I have never (as of yet, knock on wood) heard a construction worker say, “you know, Mr. IH,  the air around this construction site is moldy, dirty, full of fungus, and smells. I’m not sure I can work here”. Never heard it. It’s probably because these guys (& girls) are so tough! Right?

More commonly what I hear in construction is:

• I’ve got a client who has some water leaks, what should we so?, or 
• What can we do to help them?
• How much mold can my employees remove?
• Is it OK for my employees to remove moldy building materials?

The most important thing is: make a decision about what you will allow (as a company) your employees to do? What business are you in? Will you let an employee take out a sheet of moldy wallboard? Will you allow them to demo an entire bathroom with black fungi all over the walls?  There are some guidelines (page 2) and here. OSHA does not have specific rules for this type of work. However, OSHA (and you) will be concerned if your employees are exposed to this type of activity. They will cite you under the general duty clause.

So, the next decision is what level of protection (level A? full face respirator? paper dust mask?) will my employees need to wear? again, it depends (see link above). But as a general rule and in most scenarios, a full face respirator with HEPA filters is perfect. A half-face is fine, at times, but the eye protection during construction is easier (less fog on your safety glasses) if you are wearing a full-face.

Finally, decide if you will either:

• clean it (guidelines here)
• replace it (tear it out, and build new)
• subcontract it (please, use a remediation contractor, not your brother in law)

This will depending on many factors including; size of damage, where the damage occurred, access, available workforce, etc.

Stay close, I will attempt to blog more about this topic in the coming weeks.

Here are the questions I’ve been hearing in regards to the MSDS changes with respect to the new GHS (globally harmonized system of classification & labeling of chemicals)…

I am going to keep the answers REALLY short so you’ll actually read it. Keep in mind, I’m leaving some information out.

• What do I need to do?

As an employer you need to train your employees on how the new MSDS will look.

• How soon do I need to comply?

For contractors, you’ll need to train your employees by Dec 1, 2013.

• What is it?

It’s a universal (global) method to make MSDS have more information and make them all look the same.

• Why are they doing this?

Well, MSDS’s are very good. They’re supposed to be written with the same 15 sections with no-blanks. But, some people don’t do a very good job. Or, in some cases, do an really good job of hiding harmful chemicals, but, legally cover themselves.

• Where can I get help? Right now?!

There will be FREE training (you may have to search for it though) and more information being published. This is a topic you can learn and present to your employees. Since the deadline is a year and 9 months away, you have some time.

• Ok, do you have any places for additional information?

If you weren’t aware, OSHA is in the process  of establishing a ‘new’ rule (could be years) for confined spaces in construction (here).

In the meantime, if you plan on entering a space that is confined, below is my “standard” answer: Get help!

What I mean by this is; obtain some assistance as early as you can. Ideally this might even be before you bid the job. I often suggest to  send a superintendent or project manager to a 1/2 day training. Do not rely on the owner, or your general contractor to “safely approve” your employees entering this space. It is your job!

Although confined spaces are simple by definition (restricted opening, large enough to be in, and not meant to be occupied) , they can get  complicated easily. The first thing to consider is what is/was in the space. Secondly, what are you bringing into it? If those two questions are answered completely, the dangers are usually identified.

When reviewing, consider: electrical, oxygen, engulfment, entrapment, access (ingress & egress), coatings, noise, slips, temperature and emergency response (this is NOT an exhaustive list).

There are many other items and steps to have a well-run confined space program. Take a class, know the space, and train your employees. There are many resources at Federal OSHA and at your state OSHA, like Washington here, or like this one from Oregon.