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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We, in the US, hardly need a reason to celebrate. However, here’s another one.

Most of the time my job feels like a cross between a persuasive speech, an attorney at a deposition, a lab rat, and a mechanic working on a VW. However, once in awhile  you feel like you helped someone live a little better life, or changed things for the better. For those of you doing it…good job!

And, if you feel the urge, share the love! 🙂

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

This blog-post is directed to employees….the drywall framers, hangers, tapers, fireproofers & plasteres who sand and finish mud & drywall.

Question: What type of respirator do you wear when you sand?

…answer? Anything I can find.

This question misleading… and is similar to the one where the attorney asks in divorce court, “Do you beat your wife only when you’re drunk, or all the time?”

But, reiterate.  Do you ever NOT wear a respirator when sanding?  Answer: No. We always wear a respirator. It’s dusty.

So if I may ask a leading question (as a bad attorney): What type of respirator would you wear if you were worried about OVERexposure?

Answer: a tight fitting 1/2 face (or full face, for eye protection & fogging control) negative pressure respirator with HEPA cartridges.

I think I’ve made my point. Why would you choose a paper dust mask? The fit is mediocre, they are disposable, you cannot fit test them (very well). Who cares if it’s a N95 or P100. You can feel the dust escaping around your nose. Below are some “average” pictures of people sanding. What will you do?   more info here

 

 

 

 

Occasionally I hear of certain (construction) trades having to touch asbestos. Usually it is an electrician, sheetmetal worker, carpenter, or plumber.

How it usually happens is that they have a small remodel/install/repair. They must cut through the asbestos to install the item (duct work, electrical, plumbing). Be careful. If you look at OSHA’s definition you may not be able to perform this type of work without specific training. In some cases, 16 hours of asbestos-specific training!

If you work with any type of asbestos (or, are even near it) you must have Class IV (4) training. This is a 2-hour training which is defined as, “…contact, but DO NOT disturb asbestos…”. As a contractor, you want to make sure you fall under this type of training. The alternative is,

Class III (3) training. This type of training where employees are, “likely to disturb” asbestos.  If you think you disturbed asbestos in your activities, you REALLY should prevent it. Here are some suggestions for making sure you never disturb asbestos.

  • Always, always get (in writing) a building survey for asbestos (and leaded paint) before performing work
  • Train your employees in how to recognize asbestos, etc. (Class IV training as a minimum. See my earlier post)
  • Establish procedures for how you will prevent contact with asbestos

If you must touch (and possibly disturb it) asbestos then also,

  • Have specific procedures for how you prevent exposure
  • Have PPE (including respirators)
  • Obtain air monitoring data while you are performing your activities – document that you DO NOT disturb the asbestos
  • Dispose of the material properly

Asbestos is one of those hazards you can’t ignore. If you are not doing the correct procedures, it will bite you (a claim, a citation, a lawsuit, horrible PR, or someone getting ill!).

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)

As continued from my earlier post, and, a little more to the point…What do you ACTUALLY do when you think you have mold?

Test the air! Perform air monitoring for as many different things as you possibly can. Just kidding. Actually, DON”T do this. (caveat: if you plan legal action-then you might do this)

If there is visible mold/fungus. The first step is to find the water.  In order for mold to grow it must have moisture and a place to grow. There are many places to look including; the roof, windows, seams, ANY penetrations into the building envelope, from below (seeping up), water lines, A/C units, condensation, etc. You absolutely cannot fix the damage or test the air until you stop all sources of water.

Second step, assess the damage. The general rule of thumb is if the damage has altered the substrate (ie, the wood is damaged) then you need to replace it. If it is only on the surface, it may be possible to just clean, dry and seal it. If it is more than 10 square feet of damage, consider hiring a qualified specialist.

Thirdly, repair & replace any concerned areas.

Fourthly, dry it thoroughly, then seal it. Look into methods to increase the ventilation into this area.

Fifthly, inspect and finish. A good visual inspection is far better than air monitoring. If you can still see mold growing, you’re not done.

Finally, clean the ducting & surrounding areas. Please choose a qualified inspector. For some reason this industry attracts lots of bogus contractors.

Air sampling vary rarely gives you any information that will assist you in these steps. Some other good information about indoor air quality and mold from California can be found here.

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?
Yep. Federal OSHA has a fact sheet.  EHS Today has an article. OSHA has a guide. AIHA press release.
  • Is there information in spanish?

OSHA has some info here.


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