Environmental Health and Safety Blog | EHSWire

Dale Wilson, CIH, LEED AP

With the departure of Hurricane Irene, many buildings throughout NJ and NY have sustained a wide range of water damage and require action to remediate or otherwise mitigate the impacts of water intrusion:  mold, fungus and structural damage. 

Timing is a key element in this response; immediate action is necessary to minimize the potential for mold growth within the building envelope. As in medicine, early detection leads to an early (and usually less expensive) cure. Time and water combined can grow to be an expensive and time-consuming enemy.  Failure to respond promptly will very likely result in mold growth requiring significantly more demolition than if the condition is handled in a timely manner.  What is the definition of “timely”? As soon as mold is discovered!

Experts Can Determine Proper Mold Remediation

Along with timing, selection of the proper remediation technique for the building’s water intrusion and moisture problem (removal, drying in place using fans and/or dehumidification equipment, cleaning, treatment with biocide, etc.) is essential for maintaining a safe building. Improperly implemented remediation procedures can result in cross-contamination and hidden mold growth areas which could adversely impact occupants as time passes while increasing overall remediation time and costs .

Water and flood remediation procedures vary and are dependent upon the convoluted mix of building materials, building design, furnishings, extent of exposure, and the source of the water. Water intrusion investigations and cleanup can be especially challenging in buildings such as multi-unit residences, hospitals or rehab centers, schools and older buildings. There are a wide range of environmental, health and safety (EHS) issues associated with commercial, industrial and institutional facilities; it is important to manage the project as well as the complex interaction between employees, contractors, and the public within a facility; the buildings themselves; and the physical surroundings where they are located.

Mold Remediation Services

An EHS mold expert will identify and eliminate sources of mold and other Indoor Environmental Quality problems. They will also provide a detailed project roadmap for cleanup and removal as well as project oversight for safe and effective remediation. Emilcott’s mold remediation strategy for safe and effective mold removal (with minimal damage to the building and reduced impacts to building occupants) includes the following steps:

Step 1: Initial Assessment

Locate the source of the moisture without deconstruction or disruption to the building and occupants.  Determine the urgency of the mold problem and its impact upon workers or residents.

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Topics: indoor air quality, General Industry H&S, General EHS, Construction H&S, Emergency Response, Air Monitoring, Mold, water, expert, irene, new york, hurricane, remediation, new jersey, flood, intrusion

Sarah Damaskos with Paula Kaufmann, CIH

When recalling our onsite environmental, health and safety work following 9/11, Emilcott’s health and safety staff often discuss that respirators were either not worn or improperly worn by many first responders and subsequent waves of workers and construction crew members at Ground Zero. Not surprisingly, ten years later the news media are churning out plenty of stories detailing the life-threatening health effects developing in many of these people -- possibly linked to their exposure to airborne dust and chemicals present at the World Trade Center site.

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Topics: Personal Protective Equipment, General Industry H&S, General EHS, Emergency Response, H&S Training, worker safety, 9/11, preparedness, respiratory protection, Exposure, respirators

by Paula Kaufmann

Upcoming TSCA Reporting Period:  February 1 - June 30, 2012.

As of August 6, the EPA has finalized the TSCA IUR -- now named the Chemical Data Reporting (CDR) – Rule. There are many changes with the TSCA IUR to CDR  … some of these will be in place for the 2012 reporting submission and many more for the 2016 submission.

The final rule adopted many of the requirements included in the proposed rule (see What are the Changes?) -- and, thankfully, the majority are not retroactive. At Emilcott, we are asking our clients to define what needs to be collected for the 2012 submission period with 2011 as the Principal Reporting Year. If your facility uses chemicals or is an importer who falls under TSCA’s CDR guidelines (remember, they’ve changed!), your company will need to collect more data and information than that originally planned for the 2011 IUR submission. The chart below is a bare bones list of the inventory, production volume and use information that needs to be collected for the 2012 Chemical Data Report (CDR). And, as stated earlier, your 2016 submission will have even more requirements.

Submit Your Form U Electronically

For the 2012 CDF, all submissions will be required to use the EPA’s free, web-based reporting tool, e-CDRweb, for completion of Form U. In preparation, the EPA will schedule another informational webinar on the electronic submission tool in late September with beta trials completed by early October. Please ask Emilcott if you will need help with the Form U filing.

Additional TSCA Information

Emilcott has set up an online “ TSCA Resource Center” and over the next few weeks will be creating a dedicated TSCA landing page to contain all the information related to both the CDR Final Rule and other TSCA New and Existing Chemicals topics. Links to all EHSWire TSCA blogs will also be located there for quick reference. If you have any questions or would like to consider Emilcott as a TSCA consultant, please give us a call at 973-538-1110 or send an email to pkaufmann@emilcott.com

Did you miss the TSCA 2006 Form U submission?

You must notify the EPA that you missed reporting for the 2006 IUR within 21 days of your discovery.  The EPA has an Audit Policy for Self-Disclosure in which drastic fine reduction is possible if the requirements outlined by the Agency are met.  This policy is presented on the EPA Compliance Incentive and Auditing web site ( http://www.epa.gov/compliance/incentives/auditing/auditdisclose.html). If you would like help, Emilcott has been brought in to work with multiple US and International clients with US facilities that inadvertently missed the Form U deadline due to either misunderstanding or ignorance of the regulations. Our advice is to not wait!

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Topics: Emilcott, General EHS, EPA, Compliance, TSCA & R.E.A.C.H., TSCA, CDR, Toxic Substance Control Act, submission, IUR, Form U, chemical manufacturer, importer

Dian Cucchisi, PhD, CHMM

“Man is it hot out here.” As the site HSO (Health and Safety Officer), we hear and utter those words quite frequently during the summer. Working outside in 90 degree temperatures with high humidity levels is anything but comfortable. Who doesn’t look forward to the end of the work day when you can escape to an air conditioned environment with a cold drink or jump into the pool?

It’s not just unpleasant -- working in hot, humid temperatures can be very dangerous.  If you don’t take extra care to rest and hydrate you can subject yourself to heat cramps, heat exhaustion, and the deadly heat stroke. So what can you do to protect yourself in hot, outdoor conditions while continuing to work. 

As an experienced Health and Safety professional and working on construction and hazardous waste sites, I make an extra effort to see to it that there is plenty of water and electrolyte drink on hand before the work day begins. Throughout the day, I check on workers to see if any are exhibiting heat-related symptoms. Frequent breaks in a cool, shaded location and hydration (whether you feel thirsty or not) with water and electrolyte drinks are your first and best defenses against heat-related illnesses.

It’s not just construction workers that need to aware of the affect of heat as they work – anyone subjected to a continuous, hot working environment should keep heat-related illness prevention in mind. One of my most memorable projects was a cleanup of an abandoned chicken processing plant in the height of summer heat. The owner had walked away from the plant after the power had been cut off due to non-payment of the bills and there were several tons of chicken in various stages of processing in the freezers. Of course when the power gets cut, the freezers do not remain cold for very long. The odor caused by the decomposing chickens created quite a challenge for determining the proper personal protective equipment. Ultimately, the work on this project was performed in Level B (supplied air respiratory protection) with PVC suits as our protective clothing to block permeation of the odor. 

Prevention of heat-related illnesses for the cleanup workers was a one of the focuses in our pre-project planning as the project began in July and continued through summer into the early fall.  Because of the hot, humid temperatures and the heat-retaining PPE, we set a limit of 45 minutes for a group of workers who were then relieved after that time period by another group of workers. The first group would go through the decontamination process followed by a shower and rest in an area where we had assembled a tent to provide shade.  Despite the challenges, we made it through this hot and truly disgusting project without any workers suffering from heat-related illness. In fact, this long-term and highly publicized remediation project was inspected by OSHA where portions of the project layout and performance were videotaped for use in OSHA training “How-To’s!”

Symptoms of Heat-related Illness

These indicators can, but do not have to, begin in progression starting with heat rash, heat cramps, heat syncope, heat exhaustion, and heat stroke.

Heat rash is a skin irritation caused by excessive sweating during hot, humid weather.  In high humidity, the sweat does not evaporate quickly from your skin’s surface, and as clothing rubs against the wet skin, irritation can develop resulting in a rash.

Heat cramps are involuntary muscle spasms within the large muscles of your body.  Heat cramps typically occur in the thigh, core, and arm muscles.

Heat syncope is a fainting or dizziness episode that can occur as a result of dehydration or lack of acclimation.

Heat exhaustion is the body’s response to loss of water and salt usually as a result of excessive sweating.  Symptoms include heavy sweating, extreme weakness or fatigue, dizziness, clammy moist skin, muscle cramps, elevated temperature, and fast, shallow breathing.

Heat stroke is a medical emergency.  As the body temperature rises, the sweating mechanism fails and the body is not able to cool down and control its temperature And, beware, this severe reaction can happy quickly:  the body temperature can rise to 106 degrees within 10 to 15 minutes!  Without emergency treatment, heat stroke can cause death or permanent disability.  Symptoms of heat stroke include hot, dry skin or profuse sweating, hallucinations, throbbing headache, high body temperature, confusion/dizziness, and slurred speech.

What should you do if you start to experience any of these symptoms?

First of all, take a break. Move to a cool, shaded area and drink plenty of non-alcoholic, caffeine-free liquids.  If possible take a cool shower or dip an article of clothing in cool water and place on your body.  If you are suffering from heat rash do not apply wet clothing – instead dry off and remain in a cool area until the sweating ceases.  Resume work only after your body has cooled to normal temperature.

It is very important for Supervisors and Health and Safety Officers to keep a close watch on workers especially on hot, humid days and to allow them (as well as require them) to take frequent breaks.  Workers exhibiting any of the symptoms listed above should be removed from the work area and instructed to take a break in a cool, shaded area and to drink water or an electrolyte drink.

How do you “keep your cool” on hot, humid days?

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Topics: General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, health and safety officer, occupational, heat exhaustion, heat stroke, humid, heat rash, heat, HSO, heat syncope, heat-related illness, hot, heat cramps

Lee Scott Bishop, CIH, MPH

Have you ever driven by a crew constructing a new house or installing a new roof?  Have you noticed a guardrail system in place to keep workers from falling when working on the upper levels?  Or have you seen a personal fall arrest systemsthat will lock and hold a falling worker like a seatbelt in your car?  Most likely you have not seen either of these fall protection systems in place for residential projects!

Nearly one residential construction worker dies each workday as a result of falls.  OSHA believes that no job is worth a life.  Dr. David Michaels, Assistant Secretary of Labor for OSHA has said “ Fatalities from falls are the number one cause of workplace deaths in construction.”  “ We cannot tolerate workers getting killed in residential construction when effective means are readily available to prevent those deaths.”

For workers employed by a mid-sized contracting group or a small crew engaged in house painting or outside repairs, OSHA has published a new directive which mandates the use of fall protection for all residential construction workers at heights of 6 feet off of the ground. The Occupational Safety and Health Administration’s (OSHA) Fall Protection Policy for Residential Construction went into effect on June 16, 2011. Employers engaged in residential construction are required to follow the provisions of 29CFR1926.501(b)(13) which states:

"Residential construction." Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

This is not a new Standard.  Previous to 6/16/11, the existing policy directive (which was never intended to be a permanent solution) allowed residential construction employers to follow alternative fall protection methods instead of using conventional fall protection, like safety nets, personal fall arrest or guardrail systems.  OSHA INSTRUCTION DIRECTIVE NUMBER STD 03-11-002, Compliance Guidance for Residential Construction has replaced that policy.  The Agency is also reviewing all letters of interpretation that referenced the cancelled directive.  This new directive neither creates new legal obligations nor alters existing obligations created by OSHA standards or the Occupational Safety and Health Act.  The new policy directive merely implements the Standard as originally intended.

While sharing the procedures and equipment available to employers and in use in the industry, OSHA itemizes other forms of protection against falls such as

• 1926.501(b)(2)(ii) - Controlled access zones and control lines - leading edge applications.


• 1926.501(b)(4)(i) and (ii) - Covers - falling through holes.


• 1926.501(b)(5) - Positioning devices - face of formwork or reinforcing steel.


• 1926.501(b)(7)(i) and (ii) - Barricades, fences and covers - falling into excavations.


• 1926.501(b)(8)(i) - Equipment guards - falling into dangerous equipment.


• 1926.501(b)(10) - Warning line system and safety monitoring system - roofing work on low-slope (4:12 or less) roofs.  Or, on roofs 50-feet (15.25 m) or less in width, the use of a safety monitoring system without a warning line system is permitted.

The Directive/Standard requires training of workers, by the employer, so they can recognize potential hazard areas and are familiar to the resources they can implement to protect themselves from those hazards.  Trained workers receive certification which must be updated when the tools used change.  There is an option for the employer to find this Standard “not feasible”.  However, this avenue requires a written Fall Prevention Plan which is site specific, approved by a “qualified person”, kept up-to-date, and kept on the premises where the work is being conducted, and addresses all of the requirements found in section K of the standard.

OSHA further allows fall protection elements not covered in the “501” Standard such as Scaffolds, Ladders, and Aerial lifts which can be found covered in 29 CFR 1926.453.

Information for this blog was obtained from http://www.osha.gov/doc/residential_fall_prevention.ppt.  This presentation is an excellent resource for identifying acceptable fall protection options.  Pictures portray each type of protection as well as Bakers and Perry scaffolds; wall bracket, or top plate, scaffold system; Pump-jack Scaffold; and other options such as Extensible Boom Aerial Lifts.

So, if you are a residential contractor who needs fall protection, what’s the next step for you?  First, be aware that if you ignore the OSHA compliance laws, you are still accountable (ignorance is no excuse!).    OSHA has developed a dedicated and easy-to-understandOSHA Construction webpage with  a variety of comprehensive residential fall protection compliance assistance and guidance materials at www.osha.gov/doc/residential_fall_protection.html.  For more information and research

• For Fall Protection Standards for States with OSHA-approved State Plans, please visit http://www.osha.gov/dcsp/osp/statestandards.html. 


• If you have further questions OSHA can be scheduled for On-site Consultation by accessing http://www.osha.gov/dcsp/smallbusiness/consult.html.


• To submit an information inquiry by Electronic Mail Form, follow the directions at http://www.osha.gov/ecor_form.html.


• To contact OSHA by Phone, dial 1-800-321-OSHA (6742) Toll Free in the U.S.


• Finally, you can write to OSHA at:

U.S. Department of Labor
Occupational Safety & Health Administration
Directorate of Construction – Room N-3468
200 Constitution Avenue
Washington, D.C. 20210

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Topics: OSHA, OSHA Compliance, General EHS, Construction H&S, H&S Training, Compliance, construction, safety, residential, fall, fall protection, workers

Laurie deLaski, CIH

It’s summertime again... time for barbeques, bathing suits, and sunscreen.  We all know we should protect ourselves from the sun damage to skin, eyes, and possible skin cancer.  I remember as a child the only available sun lotion was 2, 4, and 8, and it was considered healthy to get a little red.  A result of that latent exposure to the sun was Melanoma that killed my sister at age 47.

When asked about potential occupational “overexposure” to sunshine, I had to ask:

• Is there more to know about protecting workers from sun exposure?


• What are the regulations and occupational exposure recommendations for exposure to ultraviolet (UV) radiation?

Here are some answers ….

It is well established that UV light is the part of sunlight that causes “sunburn”.  UV light is a type of non-ionizing radiation with very high energy, which is why it can cause tissue damage.  So, it follows that one should protect themselves from overexposure to this commonplace yet risky energy source.

What do the government regulators and research institutions recommend?

The only reference in the Occupational Safety and Health Administration (OSHA) standards to UV radiation regards eye protection from UV radiation generated by welding arcs.  OSHA does have an informational webpage titled “ Protecting Yourself in the Sun”.

The American Conference of Governmental Industrial Hygienists (ACGIH) has a recommended standard for employee exposure to UV radiation; however, this standard relies on measurement of the UV exposure and is intended for indoor/manmade sources of UV radiation.

The National Institute of Occupational Safety and Health (NIOSH) Workplace Safety and Health Topics  webpage, UV Radiation, is devoted to providing information to workers and employers regarding the risks, health hazards, and recommended control methods for reducing the risks of sunburn and skin cancer from sun exposure.  NIOSH recommends the following for protection from occupational exposure to UV radiation:

• Wear sunscreen with a minimum of SPF 15.
  
  
  
  • SPF refers to the amount of time that persons will be protected from a burn. An SPF of 15 will allow a person to stay out in the sun 15 times longer than they normally would be able to stay without burning. The SPF rating applies to skin reddening and protection against UVB exposure.
  
  
  • SPF does not refer to protection against UVA. Products containing Mexoryl, Parsol 1789, titanium dioxide, zinc oxide, or avobenzone block UVA rays.
  
  
  • Sunscreen performance is affected by wind, humidity, perspiration, and proper application.
  
  
  
  


• Old sunscreens should be thrown away because they lose their potency after 1-2 years.


• Sunscreens should be liberally applied (a minimum of 1 ounce) at least 20 minutes before sun exposure.
  
  
  
  • Special attention should be given to covering the ears, scalp, lips, neck, tops of feet, and backs of hands.
  
  
  
  


• Sunscreens should be reapplied at least every 2 hours and each time a person gets out of the water or perspires heavily.
  
  
  
  • Some sunscreens may also lose efficacy when applied with insect repellents, necessitating more frequent application when the two products are used together.
  
  
  
  


• Follow the application directions on the sunscreen bottle.


• Another effective way to prevent sunburn is by wearing appropriate clothing.
  
  
  
  • Dark clothing with a tight weave is more protective than light-colored, loosely woven clothing.
  
  
  • High-SPF clothing has been developed to provide more protection for those with photosensitive skin or a history of skin cancer.
  
  
  
  


• Workers should also wear wide-brimmed hats and sunglasses with almost 100% UV protection and with side panels to prevent excessive sun exposure to the eyes.

The International Commission on Non-Ionizing Radiation Protection (ICNIRP) and World Health Organization (WHO) published a recommendation paper “ Protecting Workers from Ultraviolet Radiation, 14/2007”.  This document addresses both natural and manmade UV sources.  It provides an interesting risk matrix based on latitude, work conditions, work environment and clothing and makes recommendations for additional protection based on the combination of these factors. The book is comprehensive and full of interesting facts for anyone interested in diving in.  For example, dark sunglasses without the dark side shields (or wrap-around design) will allow a substantial amount of UV exposure to the eyes.  This is because when wearing sunglasses the pupil and eyelids open proportionally to the darkness of the sunglass then the light exposure comes in from the sides!

Occupational health programs for outdoor workers at risk from UV exposure include the classic industrial hygiene elements:

Engineering Controls

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Topics: health and safety, General Industry H&S, General EHS, Construction H&S, Exposure, occupational, UV radiation, worker, sun exposure, ultraviolet, UV exposure, UV

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: indoor air quality, General Industry H&S, OSHA Compliance, General EHS, Emergency Response, H&S Training, respirator, infectious disease, respiratory protection program, respirator training, fit test

By John Defillippo, CHMP

Do you have hazardous chemicals in your workplace? If you think the answer is no, are you sure?

OSHA defines a hazardous chemical as one that presents either a physical or a health hazard. Many common and readily available products such as paints, cleaners, and other materials found in the workplace meet this definition. In fact, last year OSHA issued over 6,300 violations to companies that failed to comply with this standard. As we noted in a previous blog, non-compliance with the Hazard Communication standard was the third-largest source of OSHA violations in 2009 and 2010!

If you are an employer, you have a legal obligation to provide a workplace that is free of recognized hazards and to communicate any hazards present to those in the workplace.  In 1985, OSHA established the Hazard Communication Standard ( 1910.1200) to ensure, in part, that all workers have the "right-to-know" about the hazardous chemicals in their workplace.

Essentially, employees have a Right-to-Know about any hazardous substances that they may come into contact with at work and how to protect themselves from adverse affects. Employees, for their part, have a responsibility to follow directions and work safely by using products for their intended purpose and in accordance with the manufacturer’s instructions to reduce risk and chance of exposure. This is where the Hazard Communication Standard “kicks in”, as all workplace information about hazardous substances needs to be in a Written Hazard Communication Program.  This "HazCom" program must contain

• A list of all hazardous chemicals in the workplace and a Material Safety Data Sheets (MSDS) for each chemical (or product) on that list


• All employees must have access to that list and the MSDS’s during their work shift


• Methods to communicate hazards of these chemicals to employees, on-site contractors and visitors such as signs and labels


• Records showing that all employees have been properly trained to understand the hazards, read the MSDSs and understand labeling and signs.

In addition to the federal OSHA requirements for labeling, the State of New Jersey has specific labeling requirements for all vessels, piping and containers that contain hazardous chemicals.

So, do you have hazardous chemicals in your workplace? Are you rethinking your answer?

If you have products that arrive with an MSDS, and you have not implemented a written HazCom Program, you’ll need to get a program in place to be OSHA compliant. If you have been following the standard, consider the following:

• Are you keeping up with its requirements?


• When was the last time your HazCom Program was reviewed?


• Is your hazardous chemical list and MSDS collection up-to-date?


• Do you know what OSHA considers “Hazardous”?


• Is every hazardous chemical container labeled properly – even the transfer containers?


• Are ALL your employees trained about the workings of your HazCom program and the hazards of each chemical in their workplace?

Now do you know the answer? Or, do you have more questions?

If you are confused or intimidated, don’t worry.  A great resource is the Institute of Hazardous Materials Managers which certifies individuals as Hazardous Materials Managers (CHMM) and Hazardous Materials Practitioners (CHMP). These trained professionals must demonstrate various levels of knowledge, expertise, and excellence in the management of hazardous materials. And, there are EHS (Environmental, Health and Safety) experts like Emilcott everywhere – their job is to help companies stay in compliance with state and federal regulations while protecting employees. No matter what resource you find, just ask if they are experienced in developing Hazardous Communication programs. Not only will workers stay health and safety, you’ll see added benefits like prevention of property damage, reduced insurance claims and costs, and, of course, your company will not be cited for OSHA’s third most-common violation!

Have you found any chemicals in your workplace that you didn’t know are hazardous? Does your “right-to-know” increase your job comfort level or concern you? And, have you carefully reviewed the company HazCom plan so that you understand “what to do if…”?

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, H&S Training, Hazardous Waste Management, HazCom, Compliance, regulation, General Industry, emergency response training, Exposure, hazardous chemicals, chemicals, MSDS, Hazard Communication Standard

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: indoor air quality, General Industry H&S, General EHS, Construction H&S, Emergency Response, Air Monitoring, Hazardous Waste Management, Air Sampling, construction, remediation, technology, environmental monitoring, environmental air monitoring, Respiratory, perimeter monitoring, air montoring

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….

• Result in back injuries, strains, sprains, bruises, broken bones, concussions, and even death!


• Cause 15% of all accidental deaths, and are second only to motor vehicles as a cause of fatalities.


• Were the fourth leading cause of fatal work injuries in 2008 (13.4%, or 700 out of 5,214 fatalities).


• Rank as the second leading cause of disabling occupational injury.


• Are the third leading cause of all occupational injuries/illnesses (21.8%) and injuries/illnesses resulting in days away from work (21.4%).

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?

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