Environmental Health and Safety Blog | EHSWire

Paula Kaufmann, CIH

I just read an article in the New York Times ( Hazards: Watch Where You Point That Laser) about a 15-year boy who bought a laser pointer on the Internet.  He selected this particular model as the light was supposed to be powerful enough pop balloons and burn holes in fabric.  And, it was all he had hoped for and more.  He popped balloons from a distance and burnt holes in his sister’s sneakers.  However, he literally got burned by the “and more” features of his new toy. Tragically, he shined the pointer in a mirror and the light beam reflected back onto one of his eyes causing major damage. 

My first thought was, “How stupid was that”.  My second thought was more balanced, “I guess he wasn’t properly trained or didn’t read the instructions”.  I’ve been told by loved ones that I can be a bit intrusive (if not annoying) with my unconscious monitoring of unsafe behavior in my constant role of “health and safety inspector”.  So be it!  According to the Home Safety Council, every year there are millions of preventable home-related incidents and accidents “ that result in nearly 20,000 deaths and 21 million medical visits”.  

Here are some examples of what I consider stupid (or let’s say shortsighted) actions -- some at work, some at home. Yes, I make these observations all the time to family and friends and, as you can imagine, that can be a bit trying for them but I feel it’s worth the price.

• Using an electric lawn mower on a damp lawn with damaged extension cords repaired with electrical tape AND with the ground prong clipped. Worse yet – asking my child to use this dangerous setup!


• Removing the guard from a circular saw.


• Cutting overhead branches without wearing a hard hat or eye protection.


• Smoking a cigarette, cigar or pipe while filling a car with gas. Worse yet – a gas station attendants smoking cigarettes while pumping gas.


• Construction or utility workers using a jack hammer on a concrete sidewalk and not wearing safety glasses or hearing protection while wearing a hard hat.


• Police directing traffic without wearing a traffic safety vest. Worse yet – doing this after dark in a dark uniform without white gloves.


• Mowing the lawn in sandals and shorts without eye protection while listening to music at full volume (using earphones not noise reducing hearing protection).


• Eating snacks while removing paint from old furniture or woodwork in a house built before WW I, which makes the lead content highly probable.  Worse yet – having your kids help you while you dry sweep or use a regular household vacuum to “clean up” the area.


• Utility worker serving as a confined space watch (at the ground level of an underground manway) talking (and laughing) on a cell phone and drinking coffee (usually about 10 feet from the manway).


• Nail salon workers wearing dust masks while applying acrylics to customers’ nails -- dust masks don’t reduce exposure to the chemicals used during acrylic application. Worse yet - acrylic nail services happening in a tiny storefront with limited ventilation.


• Being “careful” when installing an electrical light by shutting off the switch to the power but not the circuit breaker to the line.


• Applying insect repellant from an aerosol can while sitting by a bonfire.


• Removing a bicycle helmet as soon as your mom can’t see you as it is just too hot to protect your brain.

And, finally, one of my favorite tales is the time that I was away from home on a business trip, and while I was gone, my husband renovated my home office space.  He did a beautiful job, but when I asked him why he went through the effort to surprise me, he said “It is so much easier to get work done when the OSHA inspector is not home”.  I just wish I could have given him a citation.

If you’re interested in home safety, September – National Preparedness Month -- is a good time to begin.  You can start with a visit the website of the Home Safety Council® (HSC), a national nonprofit organization dedicated to preventing home-related injuries. You’ll  find dozens of tips, stories and videos and information about Safety Saturday (September 25) at participating Lowe’s stores.

What are some of your favorite observations of “stupid” health and safety practices outside of the work environment? And, if you’re a health and safety professional, how do you balance maintaining a safe home life without driving your friends and family crazy?

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Topics: health and safety, General Industry H&S, General EHS, Emergency Response, worker safety, Occupational Safety, emergency response training, Fire Safety, Public Safety, water safety, industrial hygiene, home safety

Paula Kaufmann, CIH

In a recent blog about the rapidly approaching Toxic Substance Control Act (TSCA) Form U submission in 2011, I mentioned that the EPA published a Proposed Rule detailing TSCA Inventory Update Reporting Modifications. The EPA anticipates promulgating a final rule by the spring of 2011 as the next scheduled IUR submission period is currently scheduled to run from June 1, 2011 through September 30, 2011.

Some of these modifications are really a big deal and will require a lot additional effort for most submitters. We should be seeing some commentary in response to the proposed rule about the cost of compliance with the modifications along with the benefits of having this collection of information about chemical importation, manufacture and use in the US. Hopefully this will be a spirited discussion and we will keep you posted on the outcomes and what they mean to you.

Although we don’t know what the final rule will look…the following is a list of the proposed changes that may affect many of our clients and you:

• Electronic reporting of the IUR data, using an Agency-provided, web-based reporting software
  
  
  
  • After the final rule’s effective date, paper submissions would no longer be accepted.
  
  
  
  


• Form U submission every 4 years (instead of every 5 years)


• All submissions would require processing and use information (Part III of Form U)


• No minimum manufacture (or import) quantity for certain chemical substances
  
  
  
  • This an elimination of the 25,000 lb. threshold for the chemical substances that are subject to rules or orders in following TSCA sections:
    
    
    
    • Section 5(a)(2) Significant New Use Rules (SNURs)
    
    
    • Section 5(b)(4) Chemicals of concern to EPA
    
    
    • Section 6 Prohibitions for chemicals with unreasonable risks
    
    
    • Section 5(e) Requirements or restrictions on chemical production or use
    
    
    • Section 5(f) Chemical with an unreasonable risk
    
    
    
    
  
  
  
  


• IUR exemption changes for the following chemical substances:
  
  
  
  • No exemption for those with an enforceable consent agreement (ECA) to conduct testing.
  
  
  • Full exemption water.
  
  
  • Removal of polymers that are already fully exempt from the partially exempt list of chemical substances.
  
  
  
  


• Significant new reporting requirements Form U completion:
  
  
  
  • Name and address belonging to the parent company.
  
  
  • Current Chemical Abstracts (CA) Index Name, as used to list the chemical substance on the TSCA Inventory, as part of the chemical identity.
  
  
  • Production volume for each of the years since the last principal reporting year. For the 2011 report this would include 2006, 2007, 2008 AND 2009 in addition to 2010.
  
  
  • Production volume directly exported and not domestically processed or used.
  
  
  • Volume of manufactured chemical substance (such as a by product) that is recycled, remanufactured, reprocessed, reused, or reworked .
  
  
  • Company Business Information (CBI)
    
    
    
    • Submission of substantiation for CBI claims in Section III (processing and use information).
    
    
    
    
  
  
  
  


• Proposed changes for AFTER 2011 Form U submissions
  
  
  
  • Require reporting if the production volume of a substance met or exceeded the 25,000 pound threshold in any calendar year since the last principal reporting year.
  
  
  
  

With this significant list of proposed changes, Emilcott is paying close attention to TSCA-related news so that we can advise and guide our clients to be in compliance. We have worked with multiple U.S. and International clients with U.S. facilities that have misunderstood or ignored TSCA regulations resulting in a big problem that could have been avoided. If your facility falls under the TSCA guidelines, are you paying close attention to modifications to the TSCA IUR program? What do you think of the company cost vs. informational and monitoring benefits? What are you doing to be a part of the debate or prepare for submission?

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Topics: Emilcott, General EHS, EPA, Hazardous Materials, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, reporting, chemical manufacturer, regulation, chemicals, regulatory

Paula Kaufmann, CIH

August 2011 Update:   Information from the EPA regarding TSCA requirements and submission has changed significantly since this post was originally written in August 2010. Please also read BREAKING NEWS: New EPA TSCA Inventory Update Requirements (IUR) for 2012   and additional posts following to ensure that you have the most up-to-date information.

-PKaufmann

Is your facility a manufacturer or importer of chemicals in amounts of 25,000 pounds or greater?  If so, your company may need to participate in the next round of the EPA’s Toxic Substance Control Act (TSCA) Inventory Update Rule (IUR) program and submit a Form U to the EPA.

Here’s how the EPA explains this rule:  “The IUR  requires manufacturers and importers of chemical substances included on the TSCA Chemical Substance Inventory to report site and manufacturing information for chemicals manufactured (including imported) in amounts of 25,000 pounds or greater at a single site.  Additional information on domestic processing and use must be reported for chemicals manufactured in amounts of 300,000 pounds or more at a single site. EPA uses the IUR data to support many health, safety, and environmental protection activities.”  For more information go to http://www.epa.gov/oppt/iur/

When Is the Next Reporting? THIS IS IMPORTANT!!!

The next submission period is currently planned for June 1 - September 30, 2011 when manufacturers and importers will report information on their 2010 production (and the EPA has proposed adding data for years 2006, 2007, 2008 and 2009) . See revised information post:   BREAKING NEWS: New EPA TSCA Inventory Update Requirements (IUR) for 2012

How is IUR Changing for 2011 Reporting?

1. Inorganic chemicals are no longer partially exempt from the IUR rule. This was a one-time exemption for 2006 reporting only.


2. On August 13, 2010 the EPA published its proposed IUR Modifications Rule, beginning a 60-day comment period. The proposal would require electronic reporting and expanded manufacturing, processing, and use information.  The EPA anticipates promulgating a final rule by the spring of 2011. As aspects of the proposed rule have yet to  be finalized, Emilcott will  provide a definitive, easy-to-read list here on EHSWire.

So…stay tuned to EHSwire.com or www.emilcott.com to stay informed about any IUR reporting developments and reporting obligations in 2011 for the calendar year 2010.   If you have any questions about the upcoming IUR reporting or TSCA compliance question, please comment below, contact us directly or read more at http://www.emilcott.com/services/svcenvcompliance.asp.  Emilcott provides comprehensive support for TSCA compliance, including assisting with inventory and chemical substance use information subject to the IUR program.

Some interesting Form U questions and facts -

Did you know that 1,541 companies submitted a Form U in 2006?

Some submitted multiple Forms because as each manufacturing site that originates a chemical substance is required to report. The 2006 IUR public data are available on the IUR web site (www.epa.gov/iur).

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Topics: EPA, Hazardous Waste Management, Hazardous Materials, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, reporting, chemical manufacturer, regulation, chemicals, regul

Dian Cucchisi, PhD, CHMM

Environmental Health and Safety Professionals are often faced with questions that do not seem to have black and white answers, but, in reality, regulatory requirements are not that gray.  A common question: When do the requirements for 29 CFR 1910.120 and 29 CFR 1926.65 (OSHA’s Hazardous Waste Operations and Emergency Response regulations) apply?  The challenge for EHS professionals is to communicate to workers the distinction between what are considered environmental health risks and the risks to human health, and to clarify the difference of the word “hazardous” as used by various environmental protection agencies and Occupational Safety and Health Administration (OSHA).

The Environmental Protection Agency (EPA) and the state environmental protection agencies have standards for soil and groundwater “cleanliness” for residential and non-residential properties.  Soil or groundwater in exceedence of those standards needs to be remediated (usually by removal), but to add to the confusion, sometimes when soil and/or groundwater is removed from the site and transported to a disposal facility it may not fall into the EPA’s definition for hazardous waste.  So here lies the misunderstanding; if it is not classified as “hazardous waste” by the EPA, people often make the determination that it is not considered hazardous to workers and, therefore, it is not necessary to take measures to protect the workers’ health and safety.

When it comes to worker safety and the risks to human health, we must look at the requirements provided by OSHA.   OSHA is focused on exposure potential and the resulting hazard assessment evaluation to workers from the chemicals that may be encountered when working in areas with potentially contaminated soil and/or groundwater.  If the chemicals present are regulated by OSHA with a Permissible Exposure Limit (exposure based on an 8-hour average), the employer is required to conduct exposure assessments and air monitoring to determine potential risks to the workers onsite.  It also requires that workers are protected from these potential exposures through either engineering controls or personal protective equipments (such as tyvek, gloves and respirators).

 There is also a need to protect the workers and meet all the other applicable OSHA standards that mitigate health and safety risks to workers on this site.   Such required protection would include: 

• developing a site-specific health and safety plan,


• training workers in chemical hazards and controls,


• conducting environmental monitoring to determine exposure,


• instituting controls (PPE and Engineering) to protect from exposure potential,


• clean up (decontamination).and a number of other procedures.  

It is surprising and frustrating that this issue is still debated, but if it is, doesn’t it make sense to use the guidelines in these standards to clarify? We are talking about human health and the regulations are clear about the requirements for worker training and personal protection when dealing with chemical contamination.  You can use the environmental classifications to determine how to treat the situation, but you must look to OSHA to protect the workers as they are doing it.

Have you ever had workplace confusion regarding environmental risk and hazardous to human health? If so, I'd like to hear about your situation and how you resolved it.

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Topics: OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety

Barbara Glynn Alves  Oprah calls them the Ah-Ha Moments-- the second you get that one piece of information or insight that connects all the dots.  I recently had an enlightening moment onboard a flight to Mexico. No, nothing life-threatening like engine failure or loss of cabin pressure! Nor did any cabin attendant pull an inflatable slide to escape his dreary existence. But it did involve Mad Men…

The July issue of Delta’s Sky magazine was devoted to the profound change that the advertising world is experiencing.  It was the cover of John Slattery and Christina Hendricks from the hit show that caught my eye, but it was the fantastic reporting and interviews of ad industry movers and shakers that kept me reading. The feature articles were entirely relatable to the change that the environmental, health and safety industry is experiencing as technology puts a quivering arrow through the heart of what has been known as “Industry Best Practices”.

Recently, my colleague Tom Carlson,PE, in an EHSWire post regarding Best Available Technology, posed the question, “Given the availability today, right now, of newer technologies and systems that can easily help reduce the risks from air-borne hazards, shouldn’t these be used on remediation sites to protect workers and the public?”   The Emilcott answer is a resounding YES…of course!  And, until now, our message to stakeholders has been that it’s time to revisit Industry Best Practices for perimeter air monitoring and embrace the newest practices that technology has to offer. It has been a hard sell.

As director of all things sales and marketing at Emilcott, I had been a bit baffled by the resistance to the clear advantages offered by new technologies.  Delta’s Sky gave me the last dot to complete the picture as it explored the evolution of the ad world from the late 1950’s to the present. Decades of advertising best practices centered on the dominant triune media of TV, radio and print have been turned on their proverbial ears (and eyes) by the introduction of cable media and the Internet-driven marketplace.  Madison Avenue, the traditional epicenter of advertising, completely understands the changes and use of the new media outlets. However, the only firms to be successful are those that have been innovative enough to walk their clients through this new territory – most of these firms are far from Madison Avenue and are practicing near technology havens.

This was my Eureka: Our clients understand that change is upon them, but they are afraid. This was most profoundly stated in an interview with Christian Haas, Executive Creative Director with the ad firm Goodby, Silverstein & Partners out of San Francisco, who told Sky, “Best Practices are by definition the antithesis of innovation. And innovation eventually causes discomfort.”  I get it!  Not only do we have to introduce the change in Best Available Technology as changing Industry Best Practices, we also have to tell them how WE will help them make the change.  Wow!

Emilcott is embracing this enlightened sales message whole-heartily so that we can help our clients understand and embrace the NEW Best Practices with the reassurance that the expertise of Emilcott will be with them – for the whole ride. Have you or your clients been reluctant to try new Best Available Technologies in the field because it seems intimidating? What would it take to get you to embrace innovation?

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Topics: Emilcott, General EHS, perimeter air monitoring, best practices, innovation

Paula Kaufmann, CIH

National Public Radio ( NPR) recently reported their findings of an investigation of safety issues at the Upper Big Branch mine in West Virginia.  I was listening to the report while enjoying my morning walk in a nearby park.  It stopped me in my tracks!

As part of their investigative report, NPR discovered that there were situations at the mine when the methane gas monitors on continuous mining machines were disabled because the monitors repeatedly shut down the machines.  The miners interviewed explained that supervisors told them it was acceptable to disable these monitors as long as the miner operating the equipment used a hand-held methane monitor to test the air.  This is the part of the report that stopped me in my tracks!!!

The methane gas monitors are an essential part of the mining machine’s fail-safe system. They are factory-installed and essential components of the machine design; when the monitor senses an explosive atmosphere, the mining machine shuts down automatically.  The ONLY reason that spark-generating equipment can be operated in an environment likely to contain explosive concentrations of methane gas is precisely because the equipment is designed to automatically shut down if an explosive atmosphere is encountered. 

The procedures followed at the mine undermined (no pun intended) a fundamental safety feature of the continuous mining machine. 

The problem with using a hand-held monitor as a substitute for the interlock monitor is that the miner operating a continuous mining machine is 25 to 30 feet behind the face of a machine that is a continuous source of ignition (lots of sparks from metal cutting coal and rocks).  The monitor must be located directly at the source of the spark.  The miner isn’t at the source.

How could the mine leadership eliminate a critical risk management feature?  When deciding to override a critical safety system, the mine leadership should have considered the potential for loss of life AND damage to the mine AND damage to operating equipment.  You have to wonder if anyone really thought about “what if?” especially as Upper Big Branch was a notoriously “gassy” (methane producing) and, therefore, dangerous mine.  I wonder if any hazard or risk analyses were ever conducted for operating the mining machine without an operational methane monitor.   For clarity – here is a brief explanation about the hazards and risks of overriding a safety critical system and the outcome of their analyses:

What’s the difference between hazard and risk?

• A hazard is the source of potential damage, harm or adverse health effects on something or someone (i.e., explosive concentration level of methane gas, source of ignition).


• A risk is the chance or probability that damage, harm or adverse health effect will occur if something or someone is exposed to a hazard (i.e., a chance of the methane gas concentration would reach explosive levels in the presence of a source of ignition).

 A risk assessment is the process where one

• Identifies hazards,


• Evaluates the risk associated with that hazard, and


• Determines appropriate ways to eliminate or control the hazard.


• Safety controls minimize the risk by “controlling” the hazard (i.e., shutting down the mining machine eliminates the source of ignition)

Managers must understand the risk and the systems that put in place to control the hazard.  This is “managing the risk”. 

At the Upper Big Branch mine, the life-saving interlock system in a known high risk environment was disabled while workers were assured that an inappropriately-located substitute would be effective and work continued without interruption. It appears that appropriate risk management was not the goal since the presence of combustible concentrations of methane gas at sources of ignition might not be detected using the hand held monitors.   

The integrity of an organization depends on a leadership commitment to understanding and managing risk to protect their employees and assets as well as their reputation. This NPR report highlights what can happen when leadership is focused on one measure of success, in this case, production. Another recent example of compromised risk in exchange for uninterrupted production is the BP oil leak. Have you ever encountered myopic leadership in your workplace that trades risk management for another benefit. What happened? How do employees feel?

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Topics: General Industry H&S, Emergency Response, Hazardous Materials, Compliance, worker safety, Occupational Safety, Fire Safety, Exposure, Respiratory, Confined Space

By Don Hoeschele, MS, CHMM

The U.S. Chemical Safety Board (CSB) recently approved recommendations to the Occupational Safety and Health Administration (OSHA), the National Fire Protection Association (NFPA) and other organizations to help prevent explosions and fires during pipe cleaning and purging operations.  As recently as February 7, 2010 at the Kleen Energy power plant in Middletown, CT, an explosion caused six fatalities and numerous injuries during the cleaning of a natural gas pipe system. Another similar explosion occurred at the ConAgra Foods Slim Jim plant in Garner, NC on June 9, 2009 and caused the death of four workers. In both instances, an operation termed “natural gas blow” was utilized to force natural gas under pressure through a piping system during construction and prior to startup of the plant’s turbines to rid the pipe system of non-natural gas impurities and debris. The gas was vented to the ambient atmosphere at open pipe ends less than 20 feet from the ground, and in worker areas where the gas easily found a source of ignition.  It seems that common sense would lead one to never vent natural gas near sources of ignition.

• At Kleen Energy the potential ignition sources included electrical power to the building, welders actively working and diesel-fueled heaters running in the vicinity.


• Approximately TWO MILLION cubic feet of natural gas were released at Kleen Energy on February 7, 2010 during the “natural gas blow”, enough natural gas, according to the CSB, to provide heating and cooking fuel to the average American home every day for more than 25 years.

The CSB determined that no specific federal workplace safety standard exists that would prohibit the intentional release of natural gas into the workplace. Yes, I was shocked when I read that, too! Eighteen urgent recommendations were provided and voted on by the CSB to prevent future disasters. Some of the recommendations include – Prohibiting the use of natural gas for pipe cleaning and using alternatives such as compressed air, steam and other chemical substitutes, and upgrading the current gas safety standards for general industry and construction that are considered by the CSB to contain “significant gaps” that threaten the safety of workers at such facilities.

In February 2010, the CSB issued a safety bulletin titled “ Seven Key Lessons to Prevent Worker Deaths During Hot Work In and Around Tanks”.  This bulletin highlights another gap in the OSHA standards, “While the OSHA standard prohibits hot work in an explosive atmosphere, it does not explicitly require the use of a combustible gas detector”. 

It is an unfortunate fact that such regulatory “gaps” can be found in many industries. We are reminded of these gaps while reading of disasters such as these, or more currently, watching the daily updates of oil washing ashore in the Gulf of Mexico.  It is certainly welcome news that these CSB draft recommendations were quickly approved without amendments to help prevent future explosions during pipe cleaning operations.

Do you know of other examples of what would seem to be ‘common sense’ safety measures that are not utilized because “this is the way we have always done it” wins over common sense?

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Topics: OSHA, health and safety, General Industry H&S, Emergency Response, Chemical Safety Board, Hazardous Materials, Compliance, worker safety, emergency response training, Fire Safety, NFPA

Tom Carlson, PE, Sr. Project Manager

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Topics: OSHA, indoor air quality, Personal Protective Equipment, health and safety, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, Respiratory, Public Safety

John Quatermas - EHS Consultant

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Topics: Personal Protective Equipment, health and safety, General Industry H&S, Construction H&S, H&S Training, Respiratory, water safety

Lee Bishop, CIH

Have you ever wondered if the air your kids are breathing at their school is safe?  Well, so has the United States Environmental Protection Agency (US EPA).

The US EPA has completed sampling outside air at 63 elementary, middle, and high schools in 22 states.  Even better yet, they have completed the analytical work associated with these samples and have uploaded more than 22,500 results to the EPA website.

The EPA is now analyzing the sampling results to see if there may be long-term health consequences for young people attending these schools.  Reports of the analysis have been released for two schools:  Pittsboro Elementary School in Pittsboro, Ind. and Minnesota International Middle Charter School in Minneapolis.  At both schools, levels of the high-profile pollutants monitored were below levels of both short-term and long-term concern.  EPA previously released analyses for two schools in Tennessee.  These results will also be used for air contaminant modeling programs.

The samples were analyzed for 6 distinct pollutant groups:

1. Carbonyls such as acetaldehyde,


2. Diisocyanates such as methylene diphenyl diisocyanate, 2,4-toluene diisocyanate, and 1,6-hexamethylene diisocyanate,


3. Metals such as arsenic, cobalt, lead, manganese, and nickel,


4. Polycyclic aromatic hydrocarbons (PAH)s such as benzo(a)pyrene, and naphthalene,


5. Volatile organic compounds (VOCs) such as acrolein, benzene, and 1,3-butadiene, and


6. Other specific pollutants such as 4,4’-methylenedianiline, and hexavalent chromium (Chromium VI).

While some of these materials may be found in nature, they are concentrated in processed materials and uses related to dyes, plastics, tobacco, transportation, pesticides, and steel / energy production activities.  Many of the emissions related to these products can become concentrated in some areas.  Where schools existed in such areas, outside air was tested.

Particulates were collected by using the EPA’s PM10 method (for dust less than 10 um [microns] in diameter that can enter and be impacted in the lungs), and by the TSP method for particulate matter greater than 10 um in diameter and can be a human health hazard due to dermal contact and subsequent ingestion, or by drinking water contaminated with these materials.

Since these are OUTDOOR air samples – the results tell us a lot about the air quality not just at the schools, but in the communities around these schools.  Check out these data for schools in your community at http://www.epa.gov/schoolair/schools.html.

I’ve looked at the results for schools in New Jersey, and even though they are schools close to or in urban areas, the levels measured were well below the Short Term Screening Limits established by the EPA.  While the results are reassuring, they do reinforce that we do live in a chemical world!  I wonder what the air quality is like INSIDE my house. What do you think?

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Topics: indoor air quality, EPA, Exposure, environmental air monitoring, Respiratory