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Environmental Health and Safety Blog | EHSWire

Can Respirator Fit Testing Be Seasonal? You Bet It Can!

Posted by Shivi Kakar

Jul 11, 2011 8:37:07 AM

Paula Kaufmann, CIH

It happens every summer at hospitals and clinics across the country…first-year and advanced residents and fellows start a new training-at-work year. As part of the infection control strategies at these healthcare facilities, respiratory protection training and fit testing campaigns move into full gear to ensure that everyone is covered (literally and figuratively). It is almost like the return of migrating birds as second, third and fourth-year residents and current fellows flock into queues for respirator use training, fit testing and, often, medical clearance for respirator use.

Providing these invaluable respirator program services en masse is a challenge for the infectious disease and industrial hygiene and EHS departments at hospitals and other healthcare facilities. Nationwide, according to the National Resident Matching Program (NRMP), more than 25,000 residents and fellows will begin their new assignments in July!  Without interfering with patient care or hospital services, they all must be medically cleared, trained and fit tested for the site’s selected respiratory equipment (sometimes 2 or 3 different manufacturers or styles) prior to stepping foot on the hospital floor.  If you add nursing and other healthcare staff requiring an annual fit test in June or July, within a 4-6 week mid-summer period respiratory protection program departments at large teaching hospitals must provide OSHA-mandated support to 800 to 1000 (or more!) residents and fellows.  Planning is imperative and cooperation from the medical staff makes the process smoother for everyone.

Do You “Fit” this Fit Test Profile?


In a recent campaign processing hundreds of medical staff, Emilcott provided support to the infectious disease and EHS fit testing teams at a regional teaching hospital.  The fit test campaign coordinators orchestrated this event with military precision.  It was well- planned and appropriately staffed.  However, with so many folks donning respirators and fit test hoods, the lines were long and we encountered an array of challenging and uneducated attitudes.  Here are some of our favorite responses:

  • “I’m a third-year resident, I don’t have to be clean shaven to get fit tested.” (He was promptly handed a shaving kit.)

  • “What do you mean “I” failed? Is this graded? Oh, I see, the respirator failed, not me!”

  • “I never wear those respirators, so can you make it quick.”

  • “I know how to wear that.” (As the respirator was put on upside down…)

  • “I don’t think I can work with this [fit test] hood on every day!”


And, some real doozies during the 7-step qualitative fit test exercises:

  • “Just tell me, what is the “right” answer! Should I taste the Bitrex® or not?” (We sent this doctor to be quantitatively fit tested.)

  • “Isn’t this a bit excessive?” Followed by “Oh, now I think I can taste it!”

  • “Can’t you use that sweet stuff?  I like that better than this bitter taste.”

  • “This respirator fit okay last year … why can I taste the bitter flavor now?”

  • “This process didn’t take this long at the last hospital I worked, you must be doing it wrong.” 

  • And, drum roll please, from an Infectious Disease Fellow, “Thank you for making us go through each step of the fit test procedure, it’s really important!”


As a Certified Industrial Hygienist, my challenge is to convey the why, how and when of respirator use (according to OSHA Respirator Standard training and fit testing requirements) to anyone on my watch – even when my target audience consists of impatient, high achieving and time-pressed medical professionals. In an odd role reversal, I’m doing the life saving…using occupational health and safety standards to protect their bodies as they do their jobs.

When Are Healthcare Providers Required to Use Respirators?


The Centers for Disease Control and Prevention (CDC) indicates the use of respirators for protection from infectious respiratory aerosols specifically those from patients with active tuberculosis and influenza.  

  • The CDC “TB Elimination: Respiratory Protection in Health-Care Settings Fact Sheet” specifies that particulate filter respirators certified by National Institute for Occupational Safety and Health (NIOSH) be used for protection against airborne M. tuberculosis including

    • Non-powered respirators with N95, N99, N100, R95, R99, R100, P95, P99, and P100 filters (including disposable respirators); and

    • Powered air-purifying respirators (PAPRs) with high-efficiency filters



  •  The Department of Health and Human Services “Interim Guidance on Planning for the Use of Surgical Masks and Respirators in Health Care Settings during an Influenza Pandemic” emphasizes that respirator use is a critical component of a system of infection control practices to prevent the spread of infection between infected and non-infected persons. Respirator use is indicated as follows

    • N95 (or higher) respirators should be worn during medical activities that have a high likelihood of generating infectious respiratory aerosols, for which respirators (not surgical masks) offer the most appropriate protection for health care personnel.

    • N95 respirators are also prudent for health care personnel during other direct patient care activities (e.g., examination, bathing, feeding) and for support staff who may have direct contact with pandemic influenza patients.




 High Velocity Fit Testing


Another comprehensive qualitative fit test (QLFT) campaign at a large teaching hospital in New York City was scheduled across a broad span of times, crossing many days and weeks to accommodate the schedules of rounds, staff, patients and Human Resources. Emilcott’s fit testing team became considerably more efficient this year by switching to the TSI Qfit to generate the test atmospheres. One touch of a button on these pump-driven nebulizers produces the equivalent of 5 bulb nebulizer compressions and uses quick, pop-on cartridges containing the challenge solutions. The easy and consistent delivery system of the nebulizers enabled us to focus our attention on the respirator user and the respirator fit.

Fit testing of course confirms (or not) the match of each face to the selected respirator. For respirator users who were unable to taste either Bitrex® or Saccharin during sensitivity testing; could not clear the taste of Bitrex® after wearing a poor fitting respirator; or, were extremely uncomfortable wearing the fit test hood, we supplemented the QLFT with quantitative fit testing (QNFT) to ensure an accurate respirator fit test. Staff that did not pass both the QLFT and QNFT with any standard-issue respirator was forwarded to the Respiratory Therapy department for personal respirator attention. In our estimation, more than 1000 staffers, new and seasoned, passed through our fit testing process in a matter of days!

Respiratory Protection is Smart


It is important for medical staff – new or seasoned - to know when and why they are required to wear respiratory protection – the training is an essential part of the OSHA Respirator Standard. While the attitudes we encounter during fit testing at hospitals often include dismay over a failure or impatience and ungraciousness, we do our best to educate each person as they roll through the lines. Many times, the mere mention of antibiotic-resistant TB exposure or gentle reassurance that a failed fit test is not the same as a failed biology test, can shift a nurse or doctor’s perspective. What was a nuisance can quickly turn into a better comprehension of their occupational risk and personal responsibility to protect their health. As for the others? As OSHA mandates, there’s always next year.

As a health and safety professional, have you encountered any resistance to respirator fit testing? How have you responded? As a healthcare provider, what do you think about fit testing? Do you take it seriously? Does your employer?
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Topics: General Industry H&S, OSHA Compliance, General EHS, Emergency Response, H&S Training, indoor air quality, respirator, infectious disease, respiratory protection program, respirator training, fit test

TMI: Is there such a thing as Too Much Information for environmental monitoring?

Posted by Shivi Kakar

Jun 20, 2011 7:25:00 AM

by Barbara Alves

It’s funny, let’s face it. Someone shares some tawdry detail about their personal life and we wince. TMI…please just keep it to yourself! We chuckle or shake our heads. In reality, information equals power. The more we know, the better decisions we can make. If we have only half the important details, we will make weak decisions.

Let’s use some history to drive this home. Although the Allied Forces ultimately won WWII, overconfidence from the D-Day invasion and the quickness with which the Allies pushed the Germans eastward across France, caused Eisenhower to underestimate the tactical abilities and determination of Hitler’s army. This resulted in the disastrous Operation Market-Garden in the Netherlands and the Battle of the Bulge in the Ardennes. Because of lack of current data in the Market-Garden strategy, the Allies were not in Berlin by the end of 1944 as they expected. Instead, by December of 1944 the Germans had broken through into the Allies' line of advance in the Ardennes and caught us ill-prepared. Poor intelligence cost tens of thousands of lives.

This is perhaps one of the most dramatic examples of “not enough information”, but it makes the point. Amazingly, with the communication capabilities of today’s wireless, cellular, Internet and other “instantaneous” technologies, many choose NOT to use this power to gather all the project information that they can get. Like an ostrich with it head in the sand, if they don’t know something, they feel that they don’t have to react or worse, be held accountable. This “ignorance is bliss” type of decision-making is often the primary reason people make the choice to NOT implement real-time environmental monitoring on construction and remediation sites. “If we don’t know that it’s dangerous, than it must be ok, right?” Sounds crazy, but it’s true!

Using a modern and proactive approach, technology is available (right now) to continuously retrieve important and fluctuating intelligence about environmental field conditions. The information is gathered and immediately transmitted wirelessly to smart phones, PDAs, PC and laptops – all accessible by the Internet for all authorized viewers. And the data keeps rolling in throughout the project’s life cycle. What power!  To be able to make an immediate decision (or better yet, a correction) from a remote location and save time, expense, and ultimately, human health.

And what about the ability to review, store and retrieve project environmental data, which was collected over a period of time, for comparison or trending?  Super powerful! This can only result in better planning. Adding better decision-making abilities to better planning capabilities should ultimately result in doing a better job, a cleaner site and healthier workers. Who wouldn’t want that?  So the real question is, if an environmental monitoring system is NOT collecting reliable, real-time data, aren’t you really just making anecdotal decisions based on guesstimates instead of a foundation of actual data?

Many historians feel that Eisenhower’s planning of Operation Market-Garden was anecdotal because it was based on what the Allied Forces experienced coming out of Normandy. It was certainly wrong. Historians also believe that what turned the war around was the unbelievable ability our forces had to assess the real-time intelligence they gathered as they were “living in the field of battle” to make tactical decisions and outsmart the enemy.

If real-time, reliable data is available to help you make good, solid decisions, get it and use it. You will do a better job and make fewer mistakes. Information is power and you can NEVER have too much of it.  How have you used TMI to develop a better project or framework?
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Topics: General Industry H&S, General EHS, Construction H&S, Emergency Response, Air Monitoring, Hazardous Waste Management, indoor air quality, Air Sampling, construction, remediation, technology, environmental monitoring, environmental air monitoring, Respiratory, perimeter monitoring, air montoring

Expensive, damaging and possibly fatal…the truth about occupational slips, trips and falls!

Posted by Shivi Kakar

Jun 13, 2011 3:00:40 AM

By Eileen Lucier

Slips, trips, and falls aren’t at the top of anyone’s “most glamorous” EHS topics list.  Many people perceive slips, trips, and falls as minor incidents resulting solely from either carelessness or clumsiness. In fact, losing your footing is the basis for basic comedic art (ever watch “The Three Stooges” or “America’s Funniest Home Videos”?)  

Quite the opposite -- slips, trips, and falls are a very costly and serious worker safety issue. In 2008, these incidents cost American businesses a staggering $13.67 billion in direct workers compensation costs. That’s more than any other cause and more than the combined cost of the third through sixth ranked causes. 

Injury, Illness and Death Facts You Should Know


Slips, Trips, and Falls….

How can slips, trips, and falls be prevented?


As with most safety hazards, slip, trip, and fall hazards can be minimized with a combination of good work practices, proper use of appropriate equipment, proper facility and equipment maintenance, and worker training. OSHA’s Walking/Working Surfaces - Safety and Health Topic page provides links to all the applicable standards. Some basic preventive practices include:

  • Good housekeeping

    • Keep floors clean, dry, and sanitary

    • Clean up spills promptly

    • Keep aisles and walkways free of obstructions and clutter



  • Footwear

    • Fit properly

    • Require slip-resistant foot in areas prone to wet or slippery conditions



  • Fall prevention and protection

    • Provide appropriate fall arrest systems



  • Facilities and equipment

    • Walking and working surfaces

      • Floor surfaces should not be slippery or uneven

      • Install non-slip flooring in areas prone to wet or slippery conditions

      • Maintain floors in good condition

      • Equip elevated working surfaces and stairways with guardrails

      • Protect floor holes such as drains with grates or covers

      • Promptly remove ice and snow from walkways, parking lots, etc.

      • Adequate lighting

      • Ladders

        • Provide properly rated ladders

        • Maintain ladders in good condition







  • Training

    • Provide worker training for

      • Slip, trip, and fall hazards

      • Ladder use

      • Personal fall arrest systems






Don’t Slip Up on Safety!


Bruising, twisting or breaking a bone makes your work life and personal life extra challenging – it’s worth it to take a few minutes to prevent the accident from ever happening. On TV and in the movies, slips and other footing mishaps are carefully orchestrated with hidden padding, stunt doubles, some great camera tricks, and, of course, an endless supply of retakes. When you’re working on the job, there’s only one chance! 

Using the tips listed above, take a look around your workplace to see if it meets the criteria to prevent slips, trips and falls.  Don’t forget to look at your own feet to see that you are properly dressed for the environment and job duties. If you see a situation that is unsafe or could potentially be a slip, trip and fall hot spot, make sure you point it out to your coworkers and safety officer so that a permanent solution can be found.

Has it happened to you?


Have you experienced a slip, trip or fall on the job?  Could it have been prevented? What was the outcome for you and your company?
Read More

Topics: General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, health and safety, Compliance, worker safety, Occupational Safety, Lab Safety & Electrical, construction, General Industry, Fire Safety, fall protection, trips, slips

Setting up Health and Safety Communications in Remote, Mountainous Work Areas

Posted by Shivi Kakar

Apr 11, 2011 8:46:26 AM

By Don Hoeschele, MS, CHMM

In an age where we are reliant on modern technology as a part of our job, it is difficult to imagine not being able to use your cell phone or access the Internet because of topography.  As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”?  Specifically, I had to meet OSHA’s requirements for communication:  29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”.  

For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help?  In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it!

On this particular project, numerous construction crews were working at different, extremely remote locations with a distance of several miles between each work crew. While the power line tower construction and electric line-stringing companies included requirements for an eventual end-to-end 2-way radio system, the system was not available for at least the first year of the project. And, since cell phones and the average two-way radio systems were not able to be consistently or reliably available to meet the communication needs required for this project, I needed to find an alternative. 

After digging around and countless meetings, calls, and trips to all kinds of communications companies, we settled on a resourceful, cost-conscious and effective method of communicating between the crews, safety personnel, surveyors and managers. The end result was a creative mix of new technologies:

  • Cell phone signal boosters in each vehicle in the field

  • GPS SPOT locator units for each  crew

  • New technology satellite phones for work crews heading into the most remote locations.  


The vendor that built these systems also owned many of the frequencies needed for an end-to-end two-way radio system that would reach across the 275-mile project location.

Of course, the system’s effectiveness had to be proven – we were relying on it! So, I spent hours deep in the mountains field testing the equipment in some of the most remote project locations I have ever seen. Luckily, I was helped by some of the project team members who had spent a great deal of time in this area. Experience also helps communication!

This project had unusual difficulties – a big, remote, mountainous and unpopulated area – that could have thwarted OSHA’s communication requirements.  At any time, it would have been easy to throw in the towel, cross our fingers or perhaps put together a patched-together system and hope it worked.  However, with some tenacious ingenuity and a confidence that a reliable health and safety communication system could be found, we were able to overcome the almost overwhelming challenges and put an effective field communication system into place.

Have you been faced with challenges to provide adequate communication systems for your employees?  What has made a job site seem almost impossible to conquer? What did you do to overcome those challenges?
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Topics: OSHA, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, HazCom, health and safety, Compliance, worker safety, Occupational Health, Occupational Safety, Hazard Communication Standard, communication

Green Buildings –Solving One Problem, Creating New Hazards?

Posted by Shivi Kakar

Mar 28, 2011 6:39:27 AM

Dale Wilson, CIH, LEED AP

We all know what Green Buildings are, right? There are various permutations but generally, to be green, the structure is designed, built, maintained and sustained in an environmentally responsible and resource-efficient manner. The end-all objective is to reduce impact of the “built package and system” on both the environment and mankind by

  • Using energy, water, and other resources efficiently

  • Protecting occupant health

  • Improving employee productivity

  • Reducing pollution and waste


As a LEED AP-certified professional who specializes in Indoor Environmental issues with a focus on fire and life safety, I was very interested in recent articles that are creating awareness of some critical health and safety problems inherent to the green building movement that 1) use innovative, locally-produced products, and 2) implement new design, construction, and operation approaches intended to reduce energy usage and be environmentally sound.

Green Building Fire Safety


In Megan Grennille’s recent EHSWire article about the seminal Triangle Fire, it noted that building and fire code rules caught up with the high rise construction only after the tragedy of 146 worker deaths highlighted the challenges of safety and rescue in the case of a fire. The same situation recently occurred in Bakersfield where a green-constructed Target store highlighted some new concerns for health and safety for emergency responders:
“The fire at the Bakersfield Target started, firefighters learned, at the photovoltaic array [solar] on the building's roof. Even after the firefighters disconnected the electrical mains, they discovered that the solar panels were still energized, presenting a safety challenge in addition to the fire.”

This brings to light how the integration of green building practices on a seemingly typical commercial building can present new hazards that must be identified to protect building occupants and emergency responders.  Fire fighters responding to an alarm may cut electrical power from the supply grid, but what is the procedure if there is an active solar array or an integrated wind turbine generating power as a part of the building?  Other “new” electrical and fire hazards facing unprepared emergency responders include the unknown level of fire resistance of recycled/green building materials, how to control fire spread on green vegetative roofs, and how to control smoke in wide, open atrium areas.
“ owners of green buildings might have to be aware that the green designs can present previously unconsidered challenges that arise as a direct result of construction choices. ...Because codes — even a decade after green design concepts hit the mainstream — still largely deal with traditional building designs and materials, facility managers have to know how to address the intersection of green design and current codes.”

The bottom line is that "green concepts should be reviewed as part of a fire-protection and life-safety analysis”, because buildings, green or not, must meet building and fire code standards to protect the health and safety of both the occupants and emergency responders.

Moisture and Mold Management in Green Buildings


Another potential hazard of green buildings is the management of moisture within the building and how selection of a green design and materials may be inappropriate if the location and weather are not considered:  “the design-and-construction community must not assume that if one builds green, then one will be building regionally correct or even lower risk buildings”.

A recent article, Hidden Risks of Green Buildings, was written from an insurance underwriter’s perspective and centered on the management of moisture.  The article mentioned the trend of using carbohydrate-based building products instead of petroleum-based building products.  That is where my eyes widened! Any indoor quality consultant knows the formula:  moisture + food source = perfect habitat for mold growth.  Carbohydrate-based building products are food for mold!

Moisture comes from many sources in a building: bulk water from a rook, window, or facade leak; water pipe break; HVAC condensate overflow; condensation on cold surfaces; or vapor (relative humidity) in the air.  Additional humidity can be added to the air by introducing humid outdoor air that has not been properly dehumidified or from other sources such as showers, locker rooms, steam rooms, gyms, kitchen facilities, human respiration (particularly if more people are occupying the space than the original design).  ( More information on these moisture-related potential problems including the risk of LEED “flush-outs” can be found here.)

Moisture meeting carbohydrate-based building materials over time certainly does look like the potential beginning of The Perfect Storm, because, in reality, carbohydrate-based building materials, even treated with the best biocide, would only be “mold resistant” not “mold proof”.  Given food, water, and time… mold will grow.  So as a professional IEQ consultant who has seen it all when it comes to mold contamination, I sincerely believe the article’s foreshadowing that “ the design community would be advised to prioritize the lessons…already learned from the waterproofing, humidity control, and building forensics community”.  When using potential mold “food” within a building, moisture control is ever more critical to the air quality of the building as well as the building material’s life cycle.

Are you interested in green construction? Have you thought of the potential hazards that can be created when using new technologies, new materials and tightening up the envelope?
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Topics: General EHS, Construction H&S, Emergency Response, health and safety, worker safety, indoor air quality, Air Sampling, Mold, Fire Safety, Exposure, Respiratory, green buildings, Working Green

The Triangle Shirtwaist Fire (1911) - A Turning Point for Workplace Safety

Posted by Shivi Kakar

Mar 23, 2011 3:39:09 PM

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Topics: OSHA, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, health and safety, worker safety, Occupational Health, Occupational Safety, regulation, Fire Safety, shirtwaist, fire, triangle

You Better be Qualified if You are a Respiratory Protection Program Administrator!

Posted by Shivi Kakar

Mar 21, 2011 2:31:48 AM

by Paula Kaufmann

What’s the job of a Respiratory Protection Program (RPP) Administrator? 


This individual is officially listed in the site’s written Respiratory Protection Program and is accountable and responsible for the day-to-day operation of the program. Some of those “day-to-day” tasks include

  • Maintaining the site Respiratory Protection Program

  • Assessing the workplace for potential respiratory hazards

  • Defining worker exposure for these hazards

  • Selecting appropriate respirators to provide protection from defined hazards

  • Ensuring

    • Medical evaluations are conducted of employees required to wear respirators PRIOR to fit testing

    • Respirators are fit tested for all required users

    • Proper use of respirators during routine and emergency operations

    • Respirators are appropriately cleaned, disinfected, stored, inspected, repaired, discarded, and maintained

    • Adequate air quality air is supplied if supplied air respirators are used.

    • Respirator users are trained in respiratory hazards, and the proper use and maintenance of respirators

    • Periodical evaluation of the Respiratory Protection Program implementation

    • Workers who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation, and cleaning, storing and maintenance requirements of the standard

    • All voluntary-use respirator users understand Appendix D of the standard




Yes, these incessant and critical health and safety tasks can be quite overwhelming!  What’s the big deal? For the company or job site or administrator who does not understand why a qualified and empowered RPP Administrator is a big deal, here is a triple-play of Top 5 facts that illustrate the importance of qualified training for Respiratory Protection Program Administrators!

Top 5 OSHA Violation!


Did you know that the Respiratory Protection Standard was in the Top 5 most frequently cited standards by OSHA compliance officers last year?  Why be a part of that statistic?  More about 2010’s Top 10 cited violations can be found in a recent EHSwire blog by Emilcott’s Sarah Damaskos.

Top 5 Reasons YOU need to be “Qualified”



  1. Workers at your site are required to wear respirators for protection from respiratory hazards – and you selected these respirators.

  2. You train respirator users on how to put on and take off their respirator – along with the limitations on their use, and their maintenance.

  3. Implementation of the site respiratory protection program (which you wrote) is just another one of your jobs!

  4. Airline (atmosphere-supplying) respirators are used at your site – and you make sure that an adequate air supply, quantity, and flow of breathing air is available.

  5. You coordinate the medical evaluation of employees who must use respirators.


Top 5 OSHA Compliance Indicators!


If you get a visit from an OSHA Compliance Safety and Health Officer, they review these essential factors to help determine if the Respiratory Protection Program Administrator is “Qualified”:

  1. The written Respiratory Protection Program and interviews with the program administrator reveal an understanding of the familiarity with the respirator standard, site respiratory hazards, and the use of the respirators in the workplace.

  2. Respiratory fit testing is conducting annually or at assignment and the program administrator maintains.

  3. Hazardous airborne contaminants that employees may inhale have been identified.  Reasonable estimates of employee exposures were used in determining the appropriate respirator for employees to use.

  4. Recent changes in the workplace such as new processes have been evaluated for necessary respiratory program changes

  5. The program administrator keeps a written assessment of the program operations and implements changes that may be considered as efforts toward improvement.


How to Become a Qualified RPP Administrator


Focused, hands-on training with experienced health and safety instructors can make the difference for a Respiratory Protection Program Administrator – clarifying the waters by understanding the objectives of the law and how it applies to each work site!

As Health and Safety consultants to many types of companies, Emilcott staff are on job sites each day and see health and safety violations such respirators perched on foreheads or tissues jammed in the sides to ensure a bitter fit. Are these problems an employee violation or a company-wide result of not understanding the importance of a competent Administrator who can develop, maintain and enforce a respirator protection program that reduces occupation risk?

In these cases, we conduct urgent and immediate on-site RPP Administrator training that often includes high level managers to ensure that there is a top to bottom understanding of the importance of proper respirator usage. In addition to our private training, the Emilcott Training Institute offers public enrollment Respiratory Protection Program Administrator training courses in two formats:  an intense 3-hour course with a small class size and an in-depth two-day course.  In both classes, students learn the level of information required for their sites and are taught by an experienced H&S instructor that can answer questions. 

So if you are unfamiliar with your required duties as an RPP Administrator or you want a better understanding of how to encourage better respirator usage by your site personnel, look around for an effective RPP Administrator training class. Once complete and in practice, you should dicover aTop 5 list that looks more like this:

  1. OSHA respirator inspection passed without any problems, fines or additional action.

  2. Site personnel actively wear their respirators – the way that they are supposed to!

  3. Site workers reinforce the importance of respirator use to their colleagues (even when you’re not around)!

  4. Managers understand the need for respirator use and support related site activities such as testing of hazardous airborne contaminants.

  5. Written assessments of program changes are treated as a necessity for business to move forward rather than resented.


You ARE a Qualified Respiratory Protection Program Administrator!

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Topics: OSHA, General Industry H&S, OSHA Compliance, Emilcott, General EHS, Construction H&S, Emergency Response, H&S Training, health and safety, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, Personal Protective Equipment, emergency response training, Fire Safety, Exposure, Respiratory, Occupational Training, RPP, respirator protection program, administrator

Hazardous Waste How-To for Manufacturers, Laboratories and other General Industry Companies

Posted by Shivi Kakar

Mar 14, 2011 7:27:43 AM



Carrie Bettinger, CHMM, CSP

As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our “General Industry” clients in an effort to lift their game with dealing with hazardous waste.  There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan!  The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.

The Rules


The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage  and disposal of Hazardous Waste, which “ General Industry” businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; …well, just about everyone) needs to know!
OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA's general industry standards, directives, and standard interpretations.

Give me an R! Give me a C ! Give me an R! Give me an A! What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t have a side business of burying industrial waste on the family farm.   RCRA is a complex law with lots of parts and many industries are affected by its components.  In addition to being complex, the text of the Act with all of its parts and sections is hard to follow.  My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262) . RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training.

But the EPA’s RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site.  The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H.   The International Air  Transport Association (IATA) has rules for the air transport of hazardous materials ( http://www.iata.org/) including training requirements.

To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s hazardous materials in DOT and IATA eyes.  For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.

The Required Training


So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have -- per both EPA and DOT/IATA.

All employees at sites that generate hazardous waste need to be trained in how to:

  • Properly identify what qualifies as regulated “Hazardous Waste” per federal (EPA) or your state requirements.

  • Know where to properly dispose of any hazardous waste you may generate (I will give you a hint:   It’s NOT down the sink drain!).

  • Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.


Employees who are designated as responsible for the management and control of this hazardous waste need additional training. And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to

  • Properly label containers

  • Implement accumulation area requirements and time-on-site limits

  • Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems

  • Complete Hazardous Waste shipping manifests

  • Ensure proper shipping methods and a qualified transporter are used

  • Develop site-specific procedures

  • Know and implement emergency procedures and site contingency plans


Refresher Training


A common point of confusion is when refresher training is needed for employees.  The DOT and EPA have two separate requirements:

  • The EPA requires annual refresher training for their regulations.

  • The DOT requires refresher training every 3 years for their regulations.


And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations .

The Bottom Line

We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans – everything that DOT/IATA and RCRA training develops for your company – are vital in the cleanup of the environment and protection of employee and public health and safety.

For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott.  As part of  The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA:
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Topics: OSHA, Emilcott, General EHS, EPA, Emergency Response, H&S Training, DOT, Hazardous Waste Management, Hazardous Materials, Compliance, Lab Safety & Electrical, regulation, General Industry, emergency response training, Occupational Training, IATA, Resource Conservation and Recovery Act, Lab Safety, hazwaste, transportation, hazmat, generation, RCRA

The Future of Air Monitoring: Real-time Particle Size Measurement

Posted by Shivi Kakar

Dec 12, 2010 9:31:15 PM

Bruce Groves

Why do we care about particles floating around in our air? Small, inhalable particles are themselves pollutants that have shown to cause illness and chronic diseases such as asthma and certain types of lung cancer . Particles are also excellent indicators (or surrogates) for measuring other pollutants such as vapors and gases. By measuring the aerodynamic size of particles in our air, it is possible to identify and sometimes “fingerprint” them so that we can reduce or stop local sources of pollution immediately. The goal AND end result are to develop as clean a living and working area as possible.

What are we doing today?


Today, air monitoring is a piecemeal approach that is government-mandated but generally project related. When the project is over, the problem is essentially considered to be gone. Of course, in areas of high population density or industrial activity, continuous, real-time air monitoring of general conditions does not exist. Other than pollen counts, very little information about these pockets of high pollution and high particulates is available to the public or government agencies. And, the data that is available is generally much later and does not present an accurate picture of today’s problem.

What is the future in environmental air monitoring?


As technology has improved, so have particle detectors and the ease of data transmission and analysis. By 2013, small particle size detectors, such as those found in the Greenlight Environmental Monitoring System, will be consistently deployed in high population areas in such cities such as NYC, Tokyo, London and Los Angeles. These particle size detectors will be coupled with wind-speed and direction detectors and web cameras to pinpoint the exact sources of particle emissions (e.g., construction or industrial equipment, idling vehicles or high traffic transportation corridors) that are creating a measurable increase in local air pollution.

This web of detector stations will form an active or “live” map of a city that continuously measures and reports the concentration of various particle sizes. The “map” will be automatically programmed to provide warning levels and alarms to reveal when and where total particle concentrations exceed warning and safe threshold levels. By locating (in real time) the place, the direction of the pollution source and supporting video evidence, private companies and government agencies can take measures to stop or reduce the indicated pollution sources. Constant real-time monitoring, assessment and action will provide continuous improvement in local air quality that will reduce the onset of disease associated with inhaling dirty air. Warning systems set up through websites will enable agencies and individuals to check on their local air pollution conditions using their computer or smart phone.

What is the first step?


At Emilcott, we have been working with particulate monitoring on job sites for over 25 years. As an extension of our field experience, we’re working on a solution that meets the needs of our clients (private companies and government agencies) -- the Greenlight Environmental Monitoring System. With multiple project implementations under its belt, the Greenlight System’s particle size measurement, assessment and reporting capabilities are demonstrating how real-time monitoring is helping projects get cleaner each day – reducing the liabilities of our clients while giving them the information to keep the public and workers safe.

As the Greenlight System’s next phase of engineering development is outlined, our goal is to have a universal system that will provide comprehensive sampling in potentially high pollution areas so that neighborhood air quality can be improved and the incidence of lung disease is reduced. It will be a future watchdog for providing cleaner air locally where no such means of protecting local air quality exists today.

What do you think the future of environmental air monitoring holds? What are the benefits or challenges that you associate with monitoring and mapping pollutants in a broad geographic area?
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Topics: Emilcott, Construction H&S, EPA, Emergency Response, Homeland Security, Hazardous Waste Management, health and safety, Hazardous Materials, worker safety, Occupational Health, indoor air quality, Air Sampling, Greenlight System, Exposure, environmental air monitoring, Respiratory, Public Safety, perimeter air monitoring

PPE: Dress for Success = Dress for Survival

Posted by Shivi Kakar

Nov 21, 2010 9:15:00 PM

by: Capt. John DeFillippo, CHMP, EMT-B

When some of us head to the “office” the decisions we make about what to wear go way beyond fashion…our very lives could depend on our wardrobe choices. For many workers, Personal Protective Equipment, or PPE, protects them from slight and serious workplace injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other hazards. Here’s a rough guide to occupational “Dress for Success” (and survival!).

Let’s start with the head.


A properly fitting, ANSI-rated hard hat will do more than protect you from falling stuff. They’re rated to provide protection against electric and chemical hazards as well. By the way, you have to wear your hard hat correctly if you want it to protect your noggin:  Do not wear it backwards. Do not wear another hat underneath (except a proper hardhat liner).  Any stickers have to be removable so that the hard hat can be inspected for integrity.

Next, Move Down to the Eyes


According to OSHA, Not all eye protection is the same. Start by looking at the ANSI-89 rating on the specs. Does the rating match your job function?  And, don’t let style issues affect your decision whether or not to wear them. Safety glasses used to be big, unattractive, and were often uncomfortable. Not anymore! There are styles and sizes for everybody and most “well-dressed” workers have at least two pair:  sunglasses and clear. Keep in mind that eye injuries, including permanent blindness, occur on the job every day. According to OSHA, “ eye injuries alone cost more than $300 million per year in lost production time, medical expenses, and worker compensation”. Don’t let it happen to you.

Face Protection


OSHA considers face protection separate from eye protection - one is never a substitute for the other. This OSHA powerpoint is a great overview of eye and face protection requirements. Find out if your job (grinding and pressure washing for example) requires a face shield.

Don’t Forget Your Ears!


Your hearing is a delicate tool that, once damaged, cannot be repaired. Did you know that most cases of hearing loss in the US are the result of occupational exposure? Hearing protection, like respiratory protection, can get a little complicated so if you’re confused, ask an expert. EHS experts like Emilcott can perform quantitative noise analysis and provide best recommendations to protect hearing for your worksite. To start, a good rule of thumb is that if you need to raise your voice in normal conversation, you probably should be wearing hearing protection.

Body Protection


Protection for the body varies greatly depending on the hazard(s) encountered. At a minimum,   make sure you can be seen! High visibility garments are required by OSHA and DOT when working around traffic and are a good idea all the time.

Last (But Not Least), Your Feet


Safety footwear is required by OSHA if your feet are subject to injury. They also must be ANSI- approved -- look for the markings on the shoe or boot to be sure. 

The Final Word


Keep these points in mind the next time you get dressed for work:

    • While individual PPE items may not go “out of style”, they do go out of date. Check your gear to make sure it’s still within the expiration date.

    • Once your PPE has protected you from an injury, replace it.  It did its job and you don’t know how it will hold up a second time.

    •  And, finally, get the good stuff. Those cheap boots may seem like a bargain until your feet start hurting.


By the way, the Dress for Survival list above, with the exception of respirators (a blog in itself!), is considered “minimum PPE” on most sites. You need proper protection for each body part just to get in.  Don’t know what to use?  For every job, there are specific OSHA requirements that are designed to keep you safe – your health and safety office or EHS group should be a resource for information as well as monitoring the worksite for safety needs. 

Does your company keep employees protected by dressing them in the appropriate safety PPE?  Have you ever done a self-evaluation, head to toe, of what you are wearing and if it adequately protects you from the job hazards that you may encounter?  Has your safety clothing ever protected you and how?
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Topics: OSHA, General Industry H&S, General EHS, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, health and safety, Compliance, worker safety, Occupational Health, indoor air quality, Personal Protective Equipment, Fire Safety

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