Environmental Health and Safety Blog | EHSWire

Dale Wilson, CIH, LEED AP

When the National Weather service issues a forecast calling for 3 to 4 inches of rain, most people react by wondering how it will affect their plans or travel.  I think about what water damage will occur.

 When heavy rains are forecast, are you ready? Do you know what to do if your building is affected by rain penetration through the roof or walls? What is your plan if your building is flooded by a local stream or river?  Even without bad weather, water damage is always a possible threat if your building has a water line break.  Or worse yet, do you know how to react if there’s a sewage back-up?

Depending on the water source your options for cleaning up and salvaging property vary greatly.  But for all kinds of damage, you need to have a plan in place anticipating what you will do, who you will call, and how quickly they will respond.  Emilcott was recently asked to work in four, very different, water-damaged commercial and/or multi-tenant residential properties.   These events included:

• Retail and Office Complex – Roof and Façade Leak


• Office and Warehouse – Broken Water Supply Main


• Multi-tenant Apartment building – Sprinkler Activation


• Public Housing Complex – Steam Leak

What did all four projects have in common?  The answer is time.  Lots of time!  Too much time between the initial event, the response and Emilcott’s resulting late involvement!  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 within the building requiring significantly more demolition than if the condition is handled in a timely manner.  What is the definition of timely? As soon as it is discovered!

With the retail complex, we were called in approximately one month after the roof and walls began leaking.  An employee actually complained to their nearest OSHA office and OSHA issued a notice of potential violation to the employer.  Mold was present in a localized area of the store, along with a significant insect infestation due to wet, damp conditions of building surfaces.   Unfortunate results of the delay:  a mold remediation project was required and portions of the retail space were out of use for weeks.

The damage to the office and warehouse operation was more significant.  Water from the broken water main filled the 5400 sq. ft.  office to several inches and made its way to the adjacent warehouse.  The initial response by the building owner seems logical:  removal of standing water, placement of a few box fans to attempt to dry the carpet, and operating the air conditioning 24/7 as cold as the occupants would tolerate.  By the time we arrived just 5 days after the event, sheetrock walls were saturated at the base of every wall and elevated moisture readings were present up to 8 feet above the floor. Relative humidity was close to 70%, carpets had a strong musty odor, and internal wall cavities were impacted by mold growth even though no visible growth was observed on the exterior of the wall.  Final results of a mere 5 day delay in appropriate responsiveness:  the tenant and their sub-tenants loss use of the office area as trailers were brought in to house them while remediation and reconstruction occurred over a two week time period.

A kitchen fire occurred in the residential apartment complex triggered sprinklers to turn on which caused water to run from the sixth floor down to ground level.  Removal of standing water was the only initial response.  When Emilcott arrived 2 weeks later sheetrock walls were still saturated with water, visible mold was appearing in multiple, occupied apartments, and paint was bubbling and peeling from the walls.  Another significant mold remediation project was required, which in turn required relocation of tenants while remediation was in progress.

Finally, the public housing complex had experienced a steam leak for a period of several months.  Tenants in effected units were relocated and those apartments remained unoccupied.  However, an unusual occurrence happened with this steam leak as these apartments had plaster walls.  Mold grew quite well on the painted surface of the walls, something that may be expected, but due to high, high humidity and moisture levels in the plaster for extended periods of time, the analytical laboratory verified that the mold growth penetrated into the plaster from the surface.  This resulted in the demolition of the plaster walls and loss of effected housing units for several additional months.

For each of these properties and water-related circumstances, delayed and improper response increased the magnitude of the problem resulting in increased time that each space was unusable, and increased the total cost of response and repair. What should you do instead?  Bringing in a water-remediation expert immediately to identify the scope of the problem, develop a water response action plan, and implement that plan right away will minimize the damage to building materials and reduce impacts to building occupants.  In each of the four instances listed above, response actions like relocating furnishing away from walls or out of the area completely, immediately removing cove moldings, installing commercial grade dehumidification equipment, installing commercial grade floor fans, selective limited demolition, and actively monitoring and evaluating the drying process would have significantly reduced the duration of the response activity and the overall cost of each event. 

So, how can you reduce the costs of the surprise water problem? My advice is to plan now -- whether it is for rain and flooding that may occur due to weather conditions or for the pipe break that always happens unexpectedly.  Knowing who to call to determine the scope of the problem and who can implement the recommended response will save you significant time, money, property and hassle.

Capt. John DeFillippo, CHMP, EMT-B

Every organization develops a “safety culture”, be it good or bad. It is immediately observable to anyone who cares to look, and more people are – particularly prospective clients and business partners.  When evaluating vendors and business partners, companies with strong safety cultures will steer clear of doing business with companies with poor safety records; the risks and exposures are too great.  In addition to the obvious reasons of possible injury or death to workers or the public, there is the potential for serious damage to a company’s image and reputation should their vendor or subcontractor have an incident or accident.  We’ve all heard some of the stories recently in the news; reporters will highlight a major construction accident and all the players are named, regardless of their culpability.

Government agencies also use strong criteria to evaluate potential vendors. The State of New York has severely tightened up its safety and health requirements following the series of construction accidents that have plagued NYC in recent years.

A company can develop a comprehensive health and safety programs. It can post attention-getting signs and posters warning workers of hazards. It can also provide all manner of safety and personal protective equipment and conduct training for employees. These measures are good, but as soon as a supervisor or company owner walks onto a site ignoring the PPE requirements, all this good goes out the window. “Do as I say, not as I do” is not the way lead. The rules must to apply to all, without exception. Even more importantly, owners and managers should set a proper example. Professional experience has shown me that when management creates and “lives” a proactive safety culture, it will get the best results. It’s the front-line managers and supervisors that make the difference.

And it’s a never ending task. Maybe your company has a few workers who constantly violate the safety rules without any real consequences or discipline. The message being sent is pretty clear: the company doesn’t take safety seriously. Most people realize that the rules are there for a reason; their protection and it’s the law.  However, there will always be a small percentage of people that just don’t get it. Without enforcement of the policies, there is not only the risk of worker injury, but an erosion of the “safety culture” of the organization and a negative impact on morale. Plus, it is the employer and management who will be responsible for any fines or penalties handed out as well as increased insurance premiums, particularly workman’s compensation. Often, they are found personally responsible. Why would anyone risk this?

The point is that paying lip service to safety won’t fly anymore -- proactive is best. There are all kinds of resources to help your company succeed. OSHA even offers free services:    http://www.osha.gov/dcsp/smallbusiness/consult.html and http://www.osha.gov/dte/outreach/construction_generalindustry/index.html.  You may also get help from a trade or professional association that you belong to. Health and safety consulting services from companies like Emilcott who are experienced in honing in on risk and compliance can be a great investment to shift your company onto the right track.

Have you ever worked for a company that has an ineffective or sham health and safety policy? How did it make you or fellow employees feel? Was there a tipping point event that made them switch to being proactive and how did they implement a new, comprehensive program (that worked)?

Image Credit:  www.lumaxart.com

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?

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?