Industrial Hygiene in Construction

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!).

Since you are reading this, you probably know the answer. Everyone. But, who is everyone? It should include your CEO/Company President/COO (or similar). If not, I guarantee you aren’t working as safely as possible.

The reason:  The person doing the work usually isn’t involved in the bidding & planning of the project.  It’s not always the President’s fault that the proper safety equipment wasn’t bought, or there are no available tie off points on the roof. (But, it might be their fault if they are willing to press forward without making changes.)

Here is one way to deal with these issues. Train the CEO (President/COO/Project Manager/Estimator) beforehand. Here’s how:

• Make the training for them. 
  • Don’t talk about safety harnesses, or the three different types of asbestos.
  • Go over big items (where are your claims? what are similar claims for your industry?)
• Emphasize the proper methods to control any hazard:
  • #1 engineering controls
  • #2 administrative controls
  • #3 PPE (in that order!)
• Get them to contact you during the bidding process (not after you’ve won it). Talk about what might be dangerous work & plan for it.
• Share a success story. Ask a superintendent to explain how they controlled a possible exposure.
  • Did they make the architect install in a tie-off point?
  • Did they ask the owner to change adhesive products to a less hazardous one?
  • Did they use an abatement contractor who performed the work well?
• Keep it simple & short. You don’t need a lot of time, but you do need them all on the same page.

When everyone in the company has the same interest in safety, it isn’t hard to explain.