Environmental Health and Safety Blog | EHSWire

Dian Cucchisi, PhD, CHMM

The Bhopal Disaster has been in the news again with the eight former company executives getting convicted of negligence.     A court in the Indian city of Bhopal returned the verdict on June 7, 2010, more than 25 years after the incident. 

What was the Bhopal Disaster?

For those of us old enough to remember, the words “Bhopal, India” brings to mind the very tragic events of December 2, 1984.  On that day a Union Carbide facility had an accidental release of approximately 40 tons of methyl isocyanate, a chemical used in pesticides.  The chemical plume killed 3,000 people and left an estimated 500,000 people with long-term, damaging health effects.  Amnesty International reports that approximately 15,000 people died in the subsequent years as a result of this incident.  As a result the Union Carbide Bhopal accident is often considered the world's worst industrial disaster.

And then a smaller, but similar event occurred in the USA…

In August 1985 a Union Carbide facility located in Institute, West Virginia experienced an accidental release of toxic chemicals causing more than 100 residents of the area to seek medical treatment.

US Regulators Respond to Community Concerns

In response to these incidents and the growing concern by the American public that this could happen in their backyard, regulatory agencies enacted laws for facilities that manufacture, store, or use certain chemicals above designated threshold quantities.

In 1986 the United States Congress passed the Emergency Planning and Community Right to Know Act (EPCRA). The law requires facilities to annually report the quantities of “extremely hazardous substances” to the facility’s state and the Local Emergency Planning Committee (LEPC).  This information is available to any member of the public upon request to the LEPC.

In late 1985, the Occupational Safety and Health Administration (OSHA) created the Hazard Communication Standard (HCS) (29 CFR 1910.1200) also known as “Right to Know.”  The HCS requires manufacturers and distributors of hazardous materials to communicate to employees the hazards of the chemicals in their workplace by providing Material Safety Data Sheets (MSDS) and ensure that hazardous materials are labeled according to certain requirements.

The Clean Air Act was amended by Congress in 1990, including some regulatory changes intending to create safer workplaces and mitigate the risk of a Bhopal-like disaster in the US, such as:

• Charging the EPA and OSHA with more authority over the chemical industry.
  
  
  
  • OSHA created the Process Safety Management Standard (29 CFR 1910.119), a program that looks in depth at process technologies, procedures and management practices.
  
  
  • The EPA codified Chemical Accident Prevention Provisions (40 CFR Part 68) which requires facilities to conduct a hazard assessment, develop a prevention program, and implement a risk management plan.
  
  
  • Other laws that regulate the use of hazardous materials were enhanced.  These include the Toxic Substance Control Act (TSCA); the Resource, Conservation and Recovery Act (RCRA); and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
  
  
  
  


• Creating the U.S. Chemical Safety and Hazard Investigation Board (CSB). 

The Senate legislative history states: "The principal role of the new chemical safety board is to investigate accidents to determine the conditions and circumstances which led up to the event and to identify the cause or causes so that similar events might be prevented." Congress gave the CSB a unique statutory mission and provided in law that no other agency or executive branch official may direct the activities of the Board. Congress directed that the CSB's investigative function be completely independent of the rulemaking, inspection, and enforcement authorities of EPA and OSHA. The CSB became operational in January 1998.  

Accidents in the U.S. STILL OCCUR

In spite of this, accidents continue to happen.  In 2002, the Chemical Safety and Hazard Investigation Board (CSB) examined 167 chemical accidents that occurred between 1980 and 2001.  More than half of those accidents involved chemicals not covered by the regulations mentioned above.  The CSB recommended that the EPA and OSHA expand their regulations.  The Agencies did not agree with the recommendation stating they feel the best approach is worker education.  In 2004, OSHA formed an alliance with the EPA, the American Chemistry Council (ACC), and others to develop and provide worker education on chemical reactivity hazards. 

How do you feel about the expansion of regulations to include chemicals currently not covered by regulations designed to prevent accidents and reduce health risk?

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Topics: OSHA, health and safety, General Industry H&S, EPA, Emergency Response, H&S Training, Compliance, TSCA & R.E.A.C.H., Air Sampling, emergency response training, Exposure, environmental air monitoring, Respiratory, Public Safety

Capt. John DeFillippo, CHMP, EMT-B

These are tough economic times and businesses are looking to cut costs and save money. A disturbing trend I have noticed is the willingness of many companies to make cuts in safety programs and employee training in a misguided attempt to improve the bottom line.

Trained workers are safer workers.  The facts bear this out. Shortsighted statements I’ve heard include; “We don’t have problems in that area, so we’re cutting back on training.”, when the training was most likely the reason for the lack of problems.

Often, it is difficult to see how beneficial training can be until you experience the effects of its absence. Negative indications show themselves in higher EMRs, increased workman’s compensation claims, lost production time, and property damage. Only companies actively tracking and trending incidents are likely to realize this. (By the way, such companies would also be the ones least likely to make such cuts in the first place!)

It takes just one serious incident resulting in injuries to quickly eliminate any savings associated with cutting programs and training.  What’s more, most health and safety training is required by regulations, so there is also the risk of fines for non-compliance. These can be hefty and since most companies don’t budget for them, they become an extraordinary cost – right off the bottom line!

At Emilcott, we have seen firsthand the effects that result from a lack of training.  Recently, we were hired by a client who laid-off their safety director a couple years prior.  After starting our work, we informed the client of numerous safety violations throughout their organization. These appeared to be a direct result of the lapse in proper safety training – since they no longer had a safety director to oversee their program.  Through the Emilcott Training Institute, our client was able to receive the training needed to avoid these safety violations – and keep their employees safe and on the job. However, in their attempt to save money, the client ended up spending more in a short period of time just to catch up.

Making drastic H&S budget cuts just never pay off.  As experienced health and safety consultants, we work with our clients to offer solutions when budgets get tight:

• Outsource until you can hire again – we have provided EHS professionals at our clients’ sites for just this purpose for both short and long term requirements.


• Prioritize your H&S needs – consider the total reduction in your workforce or operations to determine where you can pull back and where you cannot.


• Take advantage of training courses open to the public – it may no longer be economically sound to run a training course in-house, but don’t lapse on required courses.


• Take advantage of FREE resources – many consultants provide lots of free info and OSHA will provide all types of assistance at no cost. As an example, Emicott offers a comprehensive Free Training Needs Assessment at www.emilcott.com!


• Pool resources – look toward your industry’s professional organizations or neighboring companies to share services. Maybe a part-time Safety Director is better than none at all.


• Ask a professional – put together a plan and a program to get you through the lean times

Has your company adjusted their health and safety program for leaner times?

Have you seen a direct effect and how are you compensating?

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Topics: OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Safety Training in Spanish

Diego Tolosa, CHST

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Topics: DOT, Personal Protective Equipment, Construction H&S, Emergency Response, worker safety, Occupational Safety

Dale Wilson, CIH, LEED AP


“Vapor intrusion refers to this migration of volatile chemicals from the subsurface into overlying buildings.”  Vapor intrusion (VI) air sampling is a method to evaluate if chemical vapors are entering a building due to contaminated soil or groundwater that is on or adjacent to the property on which the building is built. In order for vapors to enter a building from the soil or groundwater there have to be pathways such as  cracks in the foundation, openings around piping used for mechanical, pluming, and electrical systems, groundwater entering the basement just to name a few. Once vapors are in a basement or crawlspace, there have to be additional pathways for the vapors to enter the first floor occupied space. 

When it comes to vapor intrusion understanding “why it is happening” is just as important as understanding “what is happening”.

What is Vapor Intrusion?

“Vapor intrusion has become a significant environmental issue for regulators, industry leaders, and concerned residents. Degradation of the indoor air quality can cause fear and anxiety among building occupants, businesses, and other property owners.”

A Vapor Intrusion Project

Recently, Emilcott was hired to review vapor intrusion air sampling data collected by another consultant.  The building site was a large commercial property that was mostly composed of office space, but there was also an onsite daycare center.  After collecting data for several years, the vapor intrusion had not been resolved. 

After reviewing all the data, we made a site visit to help us understand what was contributing to the continued and increased vapor concentrations -- both in the basement of the building, which was used for storage, and in the first floor daycare center.   

Our initial site visit revealed multiple pathways that permitted vapors to enter the basement and additional pathways that permitted vapors to enter the first floor occupied space.  It was clear that the owner’s other consultant had focused on What Is Happening through continuous air sampling without understanding the dynamics of Why It Is Happening.  Based upon

• An analysis of the collected air monitoring data,


• A thorough site inspection, and


• An understanding of vapor intrusion causes and migration,

we were able to propose a step-by-step procedure to protect the client’s building and occupants. In addition, by including the client in the process, the client stated that they had learned more about the building from our visit than they had over the several years of data collection.

Vapor Intrusion – A Way Out

When reviewing a VI problem with a building owner or property manager, indoor air quality consultants should have answers to these basic questions to fully understand the problem and suggest a remediation solution:

1. What are the volatile chemicals that we are dealing with?


2. What are the risks of short-term and prolonged exposure to these chemicals?


3. Why and where are they getting into my building?


4. Can I stop the VI chemicals from getting in?


5. If I can’t stop the VI chemicals from getting in, what are the alternatives?

Interrupting and sealing the pathways is the only way to prevent building occupants from exposure to vapors. 

For our client the process of sealing pathways has been accelerated and should be complete in a few weeks.  With the complete understanding of vapor intrusion What? and Why?, a plan to seal the pathways between the ground and the basement, and the basement and the first floor, may reduce the occupants’ exposures to the vapors and avoid any increased levels of regulatory oversight and accelerated response actions.

Have you experienced a vapor intrusion problem that remains unresolved or puzzled the experts? Do you have questions about indoor air quality issues and evaluation techniques and best practices? Please share your story or questions below and we’ll respond quickly.

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Topics: indoor air quality, General Industry H&S, Construction H&S, Air Sampling, environmental air monitoring, Public Safety

Capt. John DeFillippo, CHMP, EMT-B

Does your company have employees that work on, near or over water? Hazardous waste site and emergency response workers, those in the construction trades, surveyors and bridge inspection/repair crews are but a few occupations where this applies. OSHA regulations (29 CFR 1926.106 for example) cover the safety of such workers including training and protective equipment requirements. Other federal and state (USCG and TSA) regulations may also apply to your operation. For example, if you are working over water, such as bridge work, you must have a rescue skiff at the ready, with trained personnel to operate it, in case someone falls in. Working at piers, refineries or other marine facilities may entail very specific security requirements.

Water can be unforgiving of carelessness. As a veteran of the U.S. Coast Guard, an EMT and a licensed captain working in the marine salvage industry, I’ve seen plenty of tragedies on the water. Nearly all were avoidable. Here are some essential questions to help you assess your water safety knowledge:

• Is everyone wearing personal flotation devices? Are they the right type, worn correctly, and U.S. Coast Guard approved?


• What is the water temperature? In April in the mid-Atlantic region, the water is about 45 degrees F which means you can last about 15 minutes before hypothermia sets in.


• Do you understand the risk of hypothermia? Even if the water is at 80 degrees F, it’s the same as being in air of 42 degrees F. And, water removes heat from the body 25 times faster than air of the same temperature.


• Does everybody know how to swim? What to do if caught in a current? Will they know to swim parallel to the shore or go with it until you out of it? You can't swim against a current, even a gentle one, for very long, so don’t try.


• If someone does fall in, what’s the plan? Formulating a plan when you hear the splash is too late! Having the proper rescue equipment and understanding how to use it is essential.


• Who is trained in CPR and Basic First Aid? Knowing what to do in an emergency saves lives! Too many would-be rescuers become victims themselves, so leave water rescue to those who have the training and tools.


• Is the boat operator trained? Employers who would never think of allowing an untrained person to operate a crane often have no problem letting someone without proper training operate a boat on a navigable waterway. Many states, including New Jersey, now require all operators of power-driven vessels to take an approved Safe Boating Course. Fines can be steep and may get the vessel impounded.

The Emilcott Training Institute offers many training programs that can help keep workers safe, including an 8-hour Water Safety and Boating Basics that is approved by the NJ State Police and recognized in several other states as well. Fall Protection, Water Safety and Red Cross CPR and Basic First Aid are also offered in-house or on-site. If you have ANY questions about water safety at work, give Emilcott a call or comment below.

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Topics: OSHA, Personal Protective Equipment, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, worker safety, Occupational Safety, emergency response training, Occupational Training, water safety, Water Response Plan

Paula Kaufmann - CIH
The Occupational Safety and Health Administration (OSHA) recently issued a few memorandums that indicate a strong emphasis on enforcement of existing standards. One very important action is OSHA directing its compliance officers (the enforcers!) to check and make sure that workers are being trained in a language or a vocabulary they can understand.  A very recent OSHA directive applies to training workers in agriculture, construction, general industry, and maritime work places.

Since understanding the health and physical hazards present in the workplace along with the appropriate controls for protection is fundamental to a safe work environment, it is obvious that one needs to be trained in a language that is understood. Health and safety programs cannot be effective if the folks that programs are intended to protect cannot understand them!

Effective training (good teaching) is the key to transferring information from the experts to the workers who use this information. As we all learned during our school years, we learn best from teachers who are prepared, knowledgeable, engaging AND teach us at the level (or language) we understand. I learn the most from courses that encourage student interaction and involvement. At Emilcott, our goal is that our students learn how to identify hazards and properly use the workplace controls available to protect them from exposure to these hazards. Emilcott offers health and safety training classes in English and Spanish and more for just that reason!!

Some thoughts to consider, in writing this directive, OSHA did not need any new regulations or standards; it has always existed in the regulations and standards ( as Diego Tolosa mentioned in a blog posting last year). Also, this is the first time such a clear directive has been written to the compliance officers (and OSHA-required training has been “on the books” for about 40 years)!!!

Cheers to OSHA for clarifying these requirements as many workers will benefit. Let’s get the news out to employers.

Have you experienced a situation where health and safety training was presented only in English and some of the students only had minimal English fluency? Perhaps these workers spoke Spanish, Polish, Chinese, or Portuguese (this is common in the New York City metropolitan area). How did the course subject matter get communicated to these students? If tested in their native language, could these students demonstrate that they learned “enough” from the English-only training? How do you accommodate a multi-lingual workplace (our melting pot)?

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Topics: Uncategorized

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Topics: health and safety, General Industry H&S, Construction H&S, worker safety, Occupational Health, Public Safety

Genya Mallach - CSP
Most recently, we have had to educate ourselves on the wide-spread outbreak of influenza virus, H1N1, and the precautions necessary to break the pandemic, which is far from over. Not to downplay the risk of the H1N1 virus, a virulent, drug resistant form of Tuberculosis (TB) has appeared in the United States. This disease is so ancient that it has been found in the spine of a 4,400-year-old Egyptian mummy. Tuberculosis is still the top single infectious killer of adults worldwide. According to the World Health Organization, it lies dormant in one out of three people. Of those, 10 percent will develop active TB, and about 2 million people a year will die from it.

It was just six months ago that word was leaked to the public of a case of TB that was originally diagnosed in 2007, and has greatly alarmed the medical community. Oswaldo Juarez, a then 19-year old Peruvian visiting US to study English was diagnosed with XXDR (Extremely Drug Resistant) TB. This is a strain of TB that had never before been seen in the U.S.

Dr. David Ashkin, one of the nation’s leading experts on tuberculosis, described this form of tuberculosis as so rare that only a handful of people in the world are thought to have had it.The treatment of an XXDR TB is an equivalent to aggressive chemotherapy, requires strict quarantine and costs hundreds of thousands of dollars to treat.

The questions we must now ask are: Should we consider testing of TB in the work environment? Should periodic testing of all workers be required? Should we be worried of another pandemic?

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Topics: indoor air quality, health and safety, General Industry H&S, Emergency Response, H&S Training, worker safety, Occupational Health, emergency response training, Exposure, hygiene standard

Topics: Emilcott, indoor air quality, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, worker safety, Lab Safety & Electrical, Fire Safety, Public Safety, Working Green

Carrie Bettinger - CSP, CHMM
As a seasoned safety instructor I have learned that providing real examples of injuries or fatalities that have occurred is a way to really reach workers and begin to change their attitude toward safety.  Recently I conducted fall protection training and was on the new and improved OSHA website looking at a running tally of worker fatalities per week featured on the homepage.  While looking through these fatalities you see a tragic and consistent pattern of worker cause of death: Falls.

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Topics: General Industry H&S, Construction H&S, H&S Training