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.

I find many construction-related companies who operate a spray booth at their shop. Many are used irregularity, depending on the project. As with most things that are used occasionally, they aren’t always in tip-top shape. Below are a few suggestions and questions for construction firms with these types of equipment.

  • Measure the airflow of your booth (there are various ways) but it should be 100 feet per minute. If it isn’t, you need to change something. The filter? the fan size? the exhaust duct size? the make up air (add more)? Please get someone to help you with this. Increasing the motor size is usually the knee-jerk reaction, but NOT usually the solution.
  • Make sure your manometer works. Is there a range written on the gauge for “operational”? see arrows at bottom of picture

  • Do your employees actually spray inside the booth? (seems like an obvious question but….)
  • Are your MSDS nearby?
  • Where do the employees mix the paint? (hopefully in a ventilated area)
  • Do the employees wear the correct PPE? What about during mixing? When the items are drying?
  • Are they covering their necks & arms when spraying? Do they need to? (check the MSDS)
  • What product do they clean their spray guns with?
  • What product do they thin the paint with?
  • Is there a functional eyewash station nearby?
  • Do you know the airborne level of exposures to employees?

 

There is much confusion over the requirements and best practices of employees using respirators voluntarily.

Let me first clarify. You must do air monitoring (or have other verifiable information) that employees are not REQUIRED to wear respirators (if they are overexposed to something, you must protect them). Also, they cannot voluntarily wear a respirators if there is a known hazard above the exposure limit (the employee cannot opt-out of wearing a respirator and be overexposed).

Some points about voluntary use:

  • Assuming the above statement (s) is true, firstly, you do not have to allow them to wear respirators. I am sure this is arguable from a human resources/PR/legal stance. However, if you have documented no overexposure and have not provided a respirator, they should not need to wear one.
  • Next, the employees need to be educated and you need to prove it. Having them sign Appendix D of the OSHA respiratory rule is a minimum. Training them would be better.
  • What respirator are they wearing? A paper dust mask (N95, P100, or similar) is a respirator. If they are wearing anything other than this type of mask they need a medical evaluation (Appendix C of respiratory standard).
  • If they are wearing a 1/2 face tight fitting negative pressure respirators (or more protective ones) the company needs to have a written respiratory program.
  • Fit testing is not required to be performed
  • Maintenance, inspection, storage, and training should always be done. Can you verify that the employee does this?

I personally do not recommend the paper dust masks (N95, or similar) for this simple reason. Why would you wear this type of respirator if you could have a 1/2 face, tight fitting one with the correct cartridge? The cost difference is negligible, the protection is better, and you can be assured of a better fit. If you’re going to do it, do it right.

An agricultural sprinkler and pipe fitting company would not be first on my list for hexavalent chromium exposures. However, they hired a great manager who happens to keep up on safety concerns. He identified the hazard before any work had started.

This company makes custom fittings and pipe for municipals and agricultural systems. The most durable pipes are made of stainless steel. An employee was performing TIG welding for elbows and joints for a new system. In the past I have found that TIG welding produces the least amount of airborne hexavalent chromium (Cr6), so I was not too worried about the airborne levels that might be measured. (keep in mind that there is still a dermal concern, more info here).

However, after interviewing the employee for awhile, he said that plasma cutting and stick welding also occur. Unfortunately air monitoring during TIG welding does not compare with plasma cutting or stick (arc) welding. Additional air monitoring during those activities will have to be performed.

For employees (carpenter, laborer, iron worker, plumber, electrician) using powder actuated tools, please take caution! There are possible airborne lead exposures during powder actuated tool use.

The best safety practice is to eliminate the hazard. In this case there are two easy alternatives;

  1. using lead-free loads, or
  2. using a pneumatic type nailer (like this one made by Pneutek, Hilti makes a CO2 type as well)

However, if you are an employee, I realize there are times that you are not given a choice. If this is the case, please consider:

    • asking for the MSDS for the primer loads (look for lead styphnate, or similar)
    • lead exposure can occur by inhalation and by ingestion (wash!)
    • wash & be diligent around eating & what you “take home” to your family
    • lead exposure to children is serious (they absorb lead better & it causes more detrimental health effects)
    • respirators might be required when using these tools (so wear one!)
    • working overhead (nailing into ceiling) might have higher airborne levels than other positions
    • bringing up these concerns with your safety professional onsite
    • performing air monitoring to determine airborne levels (although for the price of an industrial hygiene consultant, you could own a CO2 actuated tool)
    • reading more about it from my earlier post here.

No, this is not mine. But how funny is this? It is good to be clean!

 

When taking blood lead levels, the occupational health clinic will typically measure both the lead in the blood, and the zinc protoporphyrin (ZPP). The reason for this is the blood lead level measures just that, only the lead in the blood – which can come from previous exposures and whatever amount has been stored in your bones (soft tissues). It really only gives one piece of information. An early indicator of  lead exposure is the ZPP level.

The ZPP level indicates lead absorption. If your ZPP levels are elevated, this may mean that lead is being absorbed into your body (affecting the heme synthesis pathway). However, an elevated ZPP can be caused by other things, including iron deficiency anemia, etc.

If you have elevated ZPPs, you need to find out what is causing it. If you’re working with lead, you may have overexposure. If this is the case, your blood lead levels will most likely elevate in 2-6 weeks.

Ask your occupational health clinic for ranges of acceptable blood lead levels and ZPP levels.

Sometimes when I am at an employer’s site I am amazed at how hard people work and the determination and skills they muster to complete the task at hand. Other times, I realize how hard their job is on their body, health and being. Since I am in the U.S., I rarely get to see “horrific” conditions, but I know they exist.

Pictures are such a great to describe working conditions. If you have time, look at the pictures by Boston.com on coal mining around the world. For me, it is a reminder of how blessed we are to live where we do.

I recently gave a safety presentation to a large group of pile bucks (for those who don’t know, these are highly trained workers who drive pilings into the ground, among other things). All of my preplanning for the presentation was for nothing.

The projector didn’t work (I did have a backup, but not enough time to get it ready). And, as I was being introduced, they requested I also cover an entirely new topic that I hadn’t prepared for… I was scared.

The presentation actually went well. I wasn’t tied to my notes or slides…I had a lot of interaction with the crowd and they asked questions and commented on specific issues they deal with on projects. I didn’t look at my computer, prompter, or behind me. I took less time to cover the same points. I looked at everyone in the crowd and was able to engage them and change my presentation(slightly) based upon their reactions, comments, and interests.

Afterwards, I realized they learned. Maybe not as many “facts”, or points on the subject, but they sure remembered the main objectives:  Be safe. Use caution. Think ahead.

I am going to attempt more presentation just like this.

I have seen presentations given like this, but I never have the guts, or confidence, to do it that way. In fact, thinking back, I had read a blog (Seth Godin) of these exact things to do. I hit almost all of them….by accident.

Background: We arrived at the welding /fabrication shop where they were working on stainless steel. We were the first to arrive and found this next to the project.

I found 3 things that were blatant “no-no’s”. Want to guess? (see my answers below) You might find more.

 

 

 

 

 

 

 

 

 

 

  1. respirator sitting out -not put away in box (actually sitting next to it!)
  2. grinder without a guard
  3. eating/drinking in the work area (gum, drinking cup)

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