January is Radon awareness month. I posted this same topic last year.

As a reminder, if you have not measured the radon in your home, do it. Winter is the perfect time (since there is less airflow with the house buttoned up- and you’ll get a worst-case reading).

If your neighbor said he took readings and they came back fine, it doesn’t necessarily mean your home is ok. Check it!

Also, if your kids stay at a daycare, grandparents, or other place for a long period of the day/evening…you might also check the levels there.

Here’s my top 10 recommendations as it relates to Construction Industrial Hygiene:


  1. Review your safety programs. -even if you don’t make changes, mark the date and have your safety committee approve it.
  2. Plan your safety meetings & topics. – you’ll never do all of the training if you don’t plan for it now
  3. Button-up/Consolidate/Finish any unfinished safety business. – old notes that you need to write? a follow up with an employee on a safety task?
  4. Observe employees while they are working. – you will learn something, listen and they will appreciate it and, it will make your job easier (in the long run)
  5. Decrease lost-time-workdays. – hopefully this won’t happen, but decreasing this number is something you can have some control over
  6. Discipline unsafe behavior – and document it. It’s not fun to be the safety-cop, but your enforcement of it is necessary. Even if you are titled, “Global Corporate Safety Director”  and in charge of 10 Safety Managers, you need to do it.
  7. Reward good behavior. – same thing, but opposite…and instead of documenting it, you should throw a party and invite everyone
  8. Focus on addressing the worst-first. The top hazards in construction are falls, trenching, scaffold, electric, PPE, repetitive motion…take your pick
  9. Hire an IH / Safety consultant. Interview a few, focus on a specific area or concern, take copious notes, and use the information. It will be worth the $ spent.
  10. Be safe. Do as you say and don’t be a hypocrite. If you get hurt falling off a ladder at home, what message does that give?

You know those lead testing kits from the hardware store?  They seem extremely handy, however, they are a bit misleading.

LEAD CHECK ™ and LEAD ALERT ™ use a chemical (rodizonate-based) to instantly tell you if you have lead in your paint. If you use this kit, and the color changes, you have lead present.

They are quick and easy, but have a few HUGE downsides.

  • OSHA has stated in a letter of interpretation (7/2003) that these should not be used for determining if lead isn’t present. In other words, you can’t rely on a test that says, “no lead!”
  • These kits only check the “top layer” of paint – not the coat of paint below the one you are testing. You must test each layer.
  • These kits will not tell you how much lead you have (what percentage). You knew these kits didn’t do this already, but this is useful information!
  • Some chemicals may interfere with these type of kits. If you have chromium in your paint, the kit may say there is no lead present, but in fact, the chromium has interfered with the true results.

The biggest issue is that you need to have objective air monitoring to prove that your airborne levels of lead are not overexposing your employees.  A true bulk test (of paint) gives you great information. It tells you the percentage of lead in the paint. This, and your air sampling data, can be used again for future projects. It will also tell you which colors of paint have the highest lead.  Be safe out there!

I recently heard a very good summary of when (or alternatively when-you-DON’T) need to perform air monitoring when working with lead in construction.

Is there leaded-paint (lead based paint) in your project?

  • Then you MUST comply with the OSHA lead in construction rules.

On what occasion do I NOT have to perform air monitoring?

  • if you don’t have lead (see the first question)
  • if you want to provide the minimum required protection for all of your exposed employees (respirators, blood lead monitoring, etc. etc.)
  • if you have historical air monitoring data (from another project) that supports the methods you are using

Otherwise (in summary):

  • Take a bulk sample of the paint
  • Set up all engineering & administrative controls for controlling dust
  • Train your employees
  • Perform air monitoring during the FIRST day of actual work
  • Continue with all controls through the project
  • Notify everyone onsite of results
  • Require that all subcontractor do the same process

To calculate the number of air changes per hour (N) you will need:

  • area of the space (length, width, height) in cubic feet (ft3)
  • fan or ventilation (in cubic feet per minute, or CFM)

The number of air changes per hour is calculated by:

N= (60 min/hour) (CFM of ventilation) / Total Cubic feet

How useful is this? Well, it’s a mixed bag.

On the downside:

  • It assumes that the air mixes perfectly (which it never does) and that the fan is running properly and accurately. 

On the plus side:

  • It does give you an idea of how fast the air is moving in proportion to the total area. That information can be very useful when comparing spaces, comparing the types of ventilation available, or attempting to control a hazardous atmosphere by dilution ventilation.

But, be warned: dilution ventilation is NOT a recommended control for a “dangerous” hazard. As they say, “dilution is not the solution to pollution”.

Did you know that there are two ways to get industrial hygiene sampling for free? I know, there’s always a catch, but below are my favorites.

  1. OSHA
  2. Obviously if you have an inspection and they perform air monitoring, you can use this information. Hang onto it! Get the field notes from the inspector so that, if necessary, you can reproduce these results. There is also (in some states with state-run plans) a separate division who can provide consultative air monitoring and/or assessments. I strongly urge employers to use this method. While your company is under consultation, they are under obligation to NOT allow an inspection (there are caveats).

  3. Insurance carrier
    Your company’s insurance carrier can many times provide industrial hygiene services. This might come from your worker’s compensation carrier, your general liability carrier, and sometimes even your agent. If you have a legitimate concern and are able to wait to meet their schedule, this is a very attractive option.
  4. The General Contractor
    If your GC has hired an IH consulting firm for a similar type process that you are performing, see if they will also take a sample on one of your employees.
  5. Your Sub Contractor
    If you’ve hired a subcontractor to provide abatement for asbestos, or lead, request that they also perform a test on one of your employees. Sometimes even a sub-level tier will provide this as a courtesy.

I think the key to each of these is being nice. If you are a jerk, or attempt to strong-arm your GC or sub into this, it will never happen. In the safety world, most people want to help- that is why they got into this business in the first place.

Industrial hygienists are usually defined by the job functions they provide. Many of these activities overlap with safety, environmental, toxicology, compliance, scientific, mathematics, physics, medical, and sometimes legal.

The AIHA’s definition is (and I summarize):

  • to recognize, evaluate and control environmental factors, elements, and stresses in the workplace which might affect the health of workers

Primarily the job functions include:

  • investigating & examining workplace hazards
  • training & educating employees on health risks in the workplace
  • reviewing MSDS
  • performing air monitoring to assess employee exposures
  • making recommendations to control workplace hazards
  • recommending personal protective equipment
  • providing insight/counselling for an employer, or for employees on hazard risks

I don’t have a good “elevator pitch” when describing my work. It’s just too complicated. I usually start out with, “I sort of work with employers and employees in regards to safety & OSHA”. It’s a horrible intro and I wish I could get away from it. Unfortunately, most people know and understand OSHA. We need to do a better job of, 1.explaining what we do and, 2. educating people that there are more effective ways to protect employees than OSHA compliance.

I’ve also heard the jokes. IH = industrial hyenas. 

OSHA states that:

  • Medical exam – must be completed prior to wearing a respirator. The individual must be examined again if there are significant changes to their medical/respiratory system.
  • Fit Testing– this must be performed yearly (either qualitative or quantitative fit test, depending on the respirator) and be performed for each type of respirator worn (not for each filter used)
  • Fit Checks- these are performed every time an individual puts on a respirator. Cover the inlets and breathe in (mask should collapse). Cover the exhale valve and breathe out (mask should expand)

Individual cards for employees are not required. Sometimes, when filing the medical exam, the physician/medical reviewer, will not require the individual to come into the office. As a best practice, I would have every employee fill out the paperwork and see someone in the medical office. Employees have every reason to want to pass this “exam” and they may leave out things on the written exam that are easily discovered (or may be obvious) when someone sees them in person.

…..: Red paint.

The point for the day is to remember that your sense of smell can be very good, or very misinformed depending on what you’re smelling (and who you are).

Sulfur (sulfur dioxide) can be smelled when it’s as low as 0.009 parts per million (ppm). The exposure limits are at 5 ppm. There are many chemicals that work just the opposite.

Before you make an assumption, figure out what you are smelling.

This question, at times, can really make a difference with how you proceed. Where you get your information, and, more importantly, who provides the information is essential. Not only for compliance, but also for how your employees are protected.

Unfortunately, the answer is often complicated.

To address this question, the answer is YES. They all might overlap depending on what you are doing, and in what situation. I will attempt to briefly summarize when each specific rule or standard might apply.

  • OSHA – if you have employees and they work for you – you must comply. Sometimes each state (Washington, California, Oregon all have their own) may have a specific rule that enforces a bit differently, but Federal OSHA is the minimum rule.
  • MSHA – if you are operating in a mine (surface or underground) they have jurisdiction. Your shop may (or may not) be in their umbrella.
  • ACGIH – If they are referenced, it is usually a good practice to follow their rules. Look specifically at the date of the information. ACGIH updates their information yearly and is protective of the employee. Follow these rules if at all possible.
  • AIHA – Another good recommended source of information (like ACGIH). However, they just announce they will not be updating (due to funding) their WEELs and BEELs.
  • State rules – Occasionally, or more likely, depending on the specific issue, states will make specific rules. The Department of Human Services or similar will provide protective rules for the public. This may be an issue if your are working on a public project, or where small children, HUD, or other specific situations arise.
  • Local rules – Similar to the state rules, sometimes a city will make rules to protect it’s citizens. Being active in the local community is the easiest way to find these rules. Searching through the local city or county rules is a chore, but may reveal some obscure rules.

Finally, at more importantly, why are we looking at rules?

I would suggest focusing on employee health, employee concerns, best practices, and available data to best help our employees. They perform their jobs for a long duration in the day. They usually have the answer, or the best suggestion for fixing it…if we would listen.

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