Industrial Hygiene in Construction

Background: A new client recently had an OSHA health inspection (industrial hygiene). He received citations stemming from overexposures(they found levels above the PELs) to airborne particulates.

The company wondered what to do next. Here were my suggestions:

• Fix the problem. You will need to comply and assure that your employees aren’t overexposed. Even if the inspection made you upset, use your energy to make the situation right. Focus your energy on removing the hazard, not complaining about how you were treated.
  • Engineer the problem out. Remove the hazard. If not,
  • Change your policies so no one is further overexposed. If you can’t fix it by the this, or the above method, then,
  • Provide personal protective equipment to affected employees.
• Request the full inspection package. – this will include the officer’s field notes, interview questions, observations and sampling methodology.
  • look through these documents carefully
  • keep them for your records
•  Informally appeal the citations.
  • at the appeal show them you have complied/changed
  • ask for a reduction in fines (it never hurts to ask)
  • ask to group the citations together – instead of citation 1 item 1a, 1b, item 2, etc. ask to narrow it down to just one
  • bring any additional information which supports your side and/or the changes you’ve made (including training docs, programs, policies, etc.)
• Resample the areas.
  • make significant changes to these areas. Then,
  • hire an industrial hygienist to perform additional sampling in these areas
  • ask them to document the changes you have made to reduce the exposures
  • review this with your safety committee & those affected

In  the trainings I perform for employers, I try to explain to them that there IS overexposure to silica on their jobsite. I tell them that if I could be at their site everyday, and be ready to perform air monitoring at a moments notice, I could find overexposures.

Here is an example of a road crew cutting asphalt with a concrete saw. I’m sure it was a small cut (since they were not a concrete cutting subcontractor, and it was a tiny little saw). But the haze you see is the dust plume from the cutting.

I just happened to drive by and be stopped at a red light when this occurred. I know, I probably shouldn’t have touched my phone (while in my car) to take a picture…but I couldn’t resist. And, with that same train of thought, the road construction crew probably thought, “it’s just a small cut and it will only take 5 minutes”. So, neither of us are innocent

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