Environmental Health and Safety Blog | EHSWire

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

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

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

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

Topics: Emilcott, OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Emergency Response, H&S Training, Hazardous Waste Management, HazCom, worker safety, Occupational Health, Occupational Safety, MSDS, Hazard Communication Standard, Occupational Training, Safety Training in Spanish

Topics: indoor air quality, EPA, Hazardous Waste Management, Air Sampling, environmental air monitoring, Public Safety, Clean Air Act

Businesses, Charities & Groups that Can Help You be Green

Barbara Glynn Alves

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Topics: health and safety, EPA, Compliance, Working Green, landfill

Get an EHS Design Expert at the Table!

Paula Kaufmann - CIH

I recently read an article titled “Implementing Safety during Design: a Case Study” in the March 2009 edition of AIHA publication, The Synergist. The authors discuss how incorporating safety systems or measures in the design phase of a construction project can result in large cost savings for the overall project budget. Studies have shown that implementing safety during the planning phases of a project, compared with after construction costs, have a 1:10,000 ratio. This equates to $1 pre-construction costs versus $10,000 post-construction abatement. The authors focus on safety concerns following the guidelines established by The Institute for Safety through Design (established in 1995 by the National Safety Council's Business and Industry Division).

As an industrial hygienist, I have often been frustrated when working on remedies for minimizing exposure to chemicals, immediate safety concerns, chemical storage and waste handling concerns after the occupancy of new laboratory facilities. Construction design planners rely heavily on architects that create beautiful layouts, but often fail to incorporate the fire safety, hazardous material handling and life safety issues that are detailed in NFPA 45: Standard on Fire Protection for Laboratories Using Chemicals and NFPA 101: Life Safety Code®. The design planners and architects frequently look to the local fire department or permit authorities to approve the plans. These groups may be well versed in commercial building codes, but often are not experts in the potential hazards present in a laboratory operation. The costs of retrofitting a new facility to meet NFPA guidelines and OSHA standards can be staggering. The “take away” is to get an EHS professional involved in the upstream design process. Often cost of another “expert” is discouraged by the planners. Then again, studies (and our experiences) have shown that not getting the right experts at the planning table can be “penny wise but pound foolish”.

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Topics: OSHA, health and safety, General Industry H&S, EPA, H&S Training, Hazardous Materials, Compliance, Occupational Safety, TSCA & R.E.A.C.H., TSCA, Lab Safety & Electrical, Fire Safety, R.E.A.C.H.

Compact Fluorescent Light Bulb Rules and Regulations

Dian Cucchisi - PhD - CHMM

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Topics: Emilcott, EPA, Hazardous Waste Management, Working Green