Industrial Hygiene in Construction

The new standard for material safety data sheets (MSDS) which incorporate the global harmonization system (GHS) rules are coming.

Federal OSHA has approved the rules, and in our state, Oregon, they have been proposed, with an adoption to take place in December 2013.

It’s time to panic!… No. Not really.

Most employers will have until December of 2013 to implement the rules. OSHA will be publishing additional (and hopefully, helpful) information on what to do. For most employers it will mean you need to do a few major things:

• Train your employees on the new rules
• Reclassify (rename) the hazards, mainly the flammable ones, which have changed the most.

If you really need help with this, or feel like you can’t wait until OSHA publishes more information, email or find me here and we can discuss.

After performing an industrial hygiene survey (air monitoring), have you considered when you should resample? Here are some considerations that might help you in determining when.

• Are there specific rules that state when you must resample? For example, the construction lead standard (1926.62) states that you must resample yearly (or actually, that you can only use relevant results for one year).
• Has the process changedsince the last time you sampled? This one is hard to determine. Lot of things can change air monitoring results, here’s a “starter list” of things that can change a process.
  • Different employee?
  • Time of year? Summer versus winter? (closed up/open and humidity)
  • Is a new tool in place?
  • Has the ventilation changed?
  • Have new controls been put in place? (administrative, systems operations)
• Has the product changed? Check the safety data sheet (aka MSDS).
• Are more (or less) employees exposed to this hazard? This might change some assumptions you have made about your risk.?

If you have air sampling performed, make sure you have a written report of your findings. Laboratory results without an explanation of how they sampled, where, # of employees, process description, PPE used, safety data sheets, etc….is worthless. You may remember is well enough, but OSHA will have a hard time believing that it is a similar exposure the next time you do the “exact same thing”.

Having this report and sharing it with the employees will fulfill (part of) the hazard communication standard requirement to employees.

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.

As I have said in an earlier post, some OSHA, EPA, and MSHA rules are a good fit. They blend well with health research, scientific technology, good practices, and a low-cost-of-compliance for employers. Other rules are just bad. They are  totally out of date, not protective enough, or just not feasible/practical. Here’s my plug for a good safety manager/industrial hygienist – A good one will know which rules/guidelines to follow.

The New York Times (July 19, 2012, Cara Buckley) recently wrote an article on the US noise standards which are not protective enough for employees. In construction we also have three additional problems.

1. hearing loss is expected (or at least assumed in certain fields – carpenters, sheetmetal, ironworkers, etc.) and,
2. work shifts are usually over 8-hours. Noise exposure is usually calculated on an 8-hour time weighted average. During the busy months, an 8-hour work day is rare. It’s at least 10, maybe 12-14 hours. This doesn’t allow your ears to “rest” between shifts. For more information on extended work shifts go here.
3. extracurricular activities contribute to overall hearing loss – my point is that most construction workers don’t sit at home at the end of their shift. Almost everyone I know in construction is involved in one of these activities: hunting, shooting, motorcycles, water sports, yard work, cars, wood working/cutting, concerts, music, etc. Each of these activities contribute to their overall hearing loss, and again, doesn’t allow your ears to “rest”.

…which reminds me that I need to keep a set of ear plugs in my motorcycle jacket.

On occasion, owners say they just want to do the minimum to be in compliance with OSHA. Most times this is due to lack of understanding.

For some rules OSHA’s standard is right on the money. Take, for instance, lead (leaded paint) exposure. They have specific rules and guidelines that, if followed, keep virtually everyone protected*. The trouble is that some of OSHA’s rules have not been updated since 1973. New research and industry practices have found these levels to be unsafe even at current standards and exposure limits (PELs).

So, how do you know if the OSHA standards are current?

The quick answer is, you don’t.

Good safety professionals and industrial hygienists study the standards, recommended guidelines, and occupational limits worldwide.  In the US, the American Conference of Governmental Industrial Hygienists (ACGIH) provides the most current best practices. However, there are other methods and standards for specific hazards. ANSI, AIHA (although getting more dated due to lack of funding), European OELs (occupational exposure limits), and others.

It is rare that an employer knowingly exposes employees to a hazard. On the other hand, ignorance isn’t acceptable either….which might be the best reason for OSHA to be in existence. I wish they would spend more money on resources, information and training.  Consult your safety professional!

*recently there is some discussion about low level lead exposure to children

As you may know, sometimes tin knockers (aka sheetmetal workers)  use sheet lead, or lead soldering, to make flashing on roof vents. Here is a picture of what these commonly look like (if there is (?) a common one).

The lead iron is heated up. Lead solder, or sometimes lead/zinc solder is used. Muratic acid (or similar) is used to clean the stainless steel. The iron is used to heat up the solder and drip it on the stainless surface. Anyways, the process creates lead fumes. This is dangerous both from airborne inhalables to the contact surfaces surrounding the area.

The surfaces around these areas are usually very high in lead content. There is not a OSHA standard for lead wipe tests. However, in the past OSHA has used the HUD standards and cited employers under the general duty clause. If you are performing these tasks, please make sure you are doing everything you can to limit the airborne, dermal, and ingestion exposure.

• Follow OSHA Lead Standard (1926.62).
• Train your employees.
• Ventilation (downdraft is best). This is the best way to control the fumes.
• Post signs in the area “lead work and hazardous”.
• Perform air monitoring. I have found levels both above, and below, the exposure limits.
• Wear a respirator (1/2 face negative air with HEPA).
• Do not: eat, drink or smoke in this area.
• Good hygiene. Wash after doing these activities.
• Use a plastic sheeting on all surfaces. This makes it 100x easier to clean up.

in other words, don’t do what is in this picture below:

Who has jurisdiction over lead based paint? Are the EPA’s lead rules all I need to follow? Or, do I follow OSHA?

Well, the short answer (for those in construction) is YES. Usually OSHA, but maybe both EPA and OSHA (*and others, HUD, etc).

OSHA’s focus (as I’m sure you know) is to protect employees. If you are removing leaded on your own home, OSHA has no jurisdiction. However, if you have employees and are working with lead based paint, you must follow OSHA.

The EPA is focused on the environment (of course). They have implemented (April 22, 2008) a rule called the Renovation, Repair & Painting Rule. This rule applies when you are working on any facility which effects kids under the age of 6. If you are contractor looking to work on a project (s) with this demographic, you need to be certified by the EPA. Here is a good starting spot.

It is interesting (maybe just to me) but the EPA has very little enforcement, compared to OSHA. Yet, most people are very aware of the EPA rule. In contrast, I find contractors working with leaded paint who don’t know that they are under OSHA’s rules. I suppose the EPA has done a great job of marketing.

Another interesting comparison is that the EPA and OSHA rules are actually very similar. There are differences, but in general, if you are following the OSHA rules correctly, you are most likely very close to complying with the EPA. (one difference: the EPA requires certification)