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2012-2016 Strategic Plan from the Chemical Safety Board

Posted by Shivi Kakar

May 8, 2012 12:52:36 AM

CSB 5-Year Strategic Plan open for comment - U.S. Chemical Safety Board (CSB) requested comments on its draft strategic plan for 2012-2016. It includes the board’s strategic goals, objectives and associated measures for managing and evaluating agency operations.

The draft plan lists 5 goals in its table of contents:

Goal 1: Select and complete accident investigations and recommend actions with a high potential for protecting workers, the public and the environment.

Goal 2: Select and complete safety studies and recommend actions with a high potential for protecting workers, the public and the environment.

Goal 3: Reduce the likelihood of similar accidents in the future by securing implementation of CSB safety recommendations.

Goal 4:  Promote improved safety practices by broadly disseminating the findings, lessons and recommendations from CSB investigations and studies.

Goal 5: Establish the CSB as a recognized world leader in accident investigation and prevention by continuing to improve our human capital and infrastructure.

Read more here

In a letter to the Office of Management & Budget, CSB Chairman Rafael Moure-Eraso showed strong support for OSHA's Proposal to include an "Unclassified Hazards" category in the current proposal to adopt the UN's Globally Harmonized System (GHS) for classification and labeling of chemicals. He wrote, “…the inclusion of an “unclassified hazards” category would substantially improve the ability of the GHS system to provide crucial information to workers and employers about serious hazards that might otherwise not be included in safety data sheets because they do not fit into the current classification categories of the GHS”

Read more here

CSB Applauds AIChE’s (The American Institute of Chemical Engineers) Response to Including Reactive Hazard Awareness in College Chemical Engineering Curriculum

On  April 2, 2012  at the 2012 AIChE Spring Meeting & 8 th Global Congress on Process Safety” in Houston, TX, Chairperson Rafael Moure-Eraso formally commended AIChE for exceeding the CSB's recommended action resulting from the board’s 2009 investigation report into the fatal reactive chemical accident at T2 Laboratories in Jacksonville, Florida.  As a result of the investigative findings the CSB had called on AIChE to work with the Accreditation Board for Engineering and Technology (ABET) to include reactive hazard awareness in college chemical engineering curriculum.   Read more here

The CSB is an independent federal agency charged with investigating industrial chemical accidents. The agency's board members are appointed by the president and confirmed by the Senate. CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems.  The Board does not issue citations or fines, but does make safety recommendations to plants, industry organizations, labor groups and regulatory agencies such as OSHA and EPA.
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Topics: General Industry H&S, General EHS, unclassified hazards, CSB, CSB Safety, Chemical Safety Board, GHS

New LSRP Rule Changes Remediation Processes in NJ

Posted by Shivi Kakar

May 1, 2012 1:35:03 AM

by Megan Grennille

Mark your calendar for May 7, 2012;  the Site Remediation Reform Act (SRRA) is changing the way contaminated sites in New Jersey are being remediated.  Starting on this date, if you are a remediating party in New Jersey, you will be required to hire a Licensed Site Remediation Professional (LSRP) to work on your site.  The LSRP is a new type of environmental consultant that speeds up the clean up process.  You will no longer need pre-approval from the NJDEP to proceed with a remediation project. However, use of an LSRP will be required to remediate any site, regardless of when the cleanup was initiated.

The LSRP’s role in the LSRP program is to oversee the remediation of contaminated sites according to NJDEP’s applicable standards and regulations for responsible parties. LSRPs are subject to a strict code of conduct established by statute and regulation and must ensure that remediation of contaminated sites are performed in a protective manner of human health, safety and the environment. The conduct of LSRPs is overseen by the Site Remediation Professional Licensing Board.

The LSRP will oversee the daily management of the remediation site while the NJDEP will still have authority on the overall process ensuring that high standards are being kept.  Milestone documents submitted by the LSRP will be reviewed by the NJDEP, including the Response Action Outcome (RAO) which is filed when remediation is complete.  LSRPs will not be required in the remediation of unregulated heating oil tanks (a subsurface evaluator can be used) and may not be needed when someone is conducting due diligence at a site.

Other regulations will apply to site remediation projects, such as RCRA and OSHA.  All employees working on these site need to be properly trained.
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Topics: Emilcott, General Industry H&S, General EHS, Construction H&S, LSRP, SRAA, Site Remediation Reform Act

NIOSH performs studies on Sleep Deprivation

Posted by Shivi Kakar

Mar 27, 2012 6:07:47 AM

March 5-11, 2012 marked National Sleep Awareness Week, and all over the Internet, employers, bloggers, researchers, and other scientists have marked the occasion by bringing up studies performed by The National Institute for Occupational Safety and Health (or NIOSH) regarding sleep deprivation, sleep and work schedules, and sleep loss.

At the heart of this research lies an examination of several different types of workers, including nurses, police officers, truck drivers, manufacturing laborers, and white collar workers. Of particular importance to these sleep loss and sleep deprivation studies are those who perform shift work and have night-time work schedules.

Of high interest is the effect of occupational stress and health of police officers studied in Buffalo, New York. Statistically important health issues include tiredness due to lack of quality sleep, especially among those officers who work night shifts, and who report less than six hours of sleep a night. In addition, risk of injury is greater to the night shift workers, because of these “unnatural” sleep and work schedules

There are several research studies that are either ongoing or have been completed regarding sleep deprivation in truck drivers, manufacturing workers, and even white collar workers. Large amounts of data collected (from long-haul truck drivers especially) show a wide array of sleep disorders, including sleep apnea, fatigue and the overall lowered safety expectations from drivers who do not get enough quality sleep.

Another group being studied is American nurses, especially pregnant female nurses. In collaboration with the Harvard Nurses' Health Study, results are showing that an increased number of adverse reproductive outcomes and menstrual cycle abnormalities can be attributed to shift work; especially those studied who work a night shift.

In relation to the sleep deprivation and sleep loss health issues such as fatigue, depression, headaches, malaise, and reproductive issues, the studies point out that work hours that are too long for good health can actually attribute to the decline of healthy white blood cells, which are the first line of defense against such devastating diseases as cancer and autoimmune disorders.

In an effort to stem the adverse health effects and potential safety issues inherent in shift workers and those who work too many hours, NIOSH scientists are seeking development and training programs for managers and workers in several different fields of employ, including those mentioned above. They hope to raise awareness of the problems, encourage healthy sleep habits, and foster a healthier management style that would see more reasonable hours for workers. The dissemination of this information is being brought about through workplace posters, websites, webinars, online training courses, and public service announcements.
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Topics: Emilcott, NIOSH, health and safety, General Industry H&S, General EHS, Sleep and Work Schedules, National Institute for Occupational Safety and Hea, Sleep loss, worker safety, Sleep Deprivation

Regulatory Submissions & Postings Reminder (January thru April 2012)

Posted by Shivi Kakar

Jan 24, 2012 1:55:08 AM

Here is a handy table we recently created for our clients — a gentle reminder to get organized! Even if you miss a deadline, it’s better to start playing catchup as soon as you find out that you are not in compliance.
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Topics: Emilcott, NPDES, OSHA, Emergency Planning and Community Right-to-Know Act, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, EPCRA, Hazardous Waste Management, TSCA & R.E.A.C.H., TSCA, CDR, Toxic Substance Control Act, Biennial Hazardous Waste

Are OSH Professionals Becoming an Endangered Species?

Posted by Shivi Kakar

Nov 7, 2011 4:11:14 AM

Carrie Bettinger, CSP, CHMM

Recently the National Institute of Occupational Safety and Health (NIOSH) commissioned a survey of the Occupational Safety and Health workforce and published their findings in a document called the National Assessment of the Occupational Safety and Health Workforce.

NIOSH reports that the need for OSH professionals will greatly outweigh the supply in the very near future.  If you minored in economics, like me, then this is a very easy concept of supply versus demand: as more OSH professionals are needed, fewer are beginning OSH careers AND a large proportion of the OSH profession will soon be retiring en masse.  Here are some excerpts from the Executive Summary of the survey:
“The survey shows that currently there are over 48,000 OS&H professionals in the U.S. workforce across the nine disciplines of interest to this study: The composition of the current OS&H workforce is primarily safety professionals (59%), followed by industrial hygienists (15%). The other major disciplines represented in the survey data were occupational health nursing (9%) and occupational medicine (3%).”

“Employers expect to hire over 25,000 OS&H professionals over the next 5 years, needing to fill an average of just over 5,000 positions per year;”

“Employers expect about 10 percent of safety professionals to retire within the next year; for the other OS&H professions the retirement projections are lower. “

“The workforce is graying, more among occupational physicians and occupational health nurses than safety and industrial hygiene professionals; however, we estimate that a large number of OS&H professionals in these disciplines are over the age of 50."

Now as an OSH professional in the middle of her career my first thought on seeing this, of course, is “YAY! JOB SECURITY”!  Perhaps I can even name my salary…ahh, the bliss we all look for in a career.  But then the reality hits you a little harder when you think about what the lack of OSH professionals means not only for businesses, worker safety, and public safety but also the impact it will have on our family of OSH professionals.  We are already such a small community and we rely on each other as mentors, sources of inspirations/ideas, and friends.

So as much as I would like to name my own salary, I’d rather not have that luxury if it means losing this OSH community.  Here are a few ideas that we all can do to help us bring in new blood to our OSH family and strengthen the backbone of Public and Occupational Safety and Health in the U.S.

  • Pass the word to the younger generation -- visit your kid’s (or any kid’s!) school on Career Day or Science Day and talk about what you do.  Local schools are actively seeking professionals in scientific fields to model for their students.  (Be sure to bring some cool equipment with you!)

  • Look for local youth groups, especially those who focus on young people from underprivileged families or communities.  These young people may not be aware of careers that involve environmental work or public health which may also benefit their communities.

  • Hire or inspire a veteran returning from Iraq or Afghanistan to enter the OSH field.  Most returning members of the military have great leadership and organizational skills and are instinctively looking out for unsafe situations.  Plus they will be fearless even when faced with a toolbox safety talks for dozens of half-asleep, grouchy construction workers!

  • Obtaining financial aid for OSH programs has been cited as a barrier for a lot of people going into the field so also pass along information or tips about NIOSH Training Grants that provide financial support for many academic programs in the OSH field. And, please support scholarship programs offered by professional organizations such as the ASSE and its local chapters. If you have an annual giving plan, why not support your own very important industry?

  • Know someone in need of a job or career?  Point them in the direction of an OSH career by talking about the wide range of degrees and certificates in our field.  These added qualifications range from full-on college degrees to focused training in very specific OSH sectors depending on their interest and undergraduate achievement.

Degree Programs

Check out Resource Center for a great listing of college/university programs or look at these:

Certificate Programs

Emilcott EHS professionals have achieved many certificate-driven designations such as CHMM (Certified Hazardous Materials Manager), CIH (Certified Industrial Hygienist), CSP (Certified Safety Professional), PE (Professional Engineer), CHMP (Certified Hazardous Materials Professional) and CHST (Construction Health and Safety Technician).  These certifications and more are offered through universities, online programs, professional organizations and OSHA Training Centers.  Here is a list of some common and industry-recognized certification boards:

Like any educational degree, use caution before pursuing any online certificate program from a private business or school as they may not be seen as valid education by many employers.  If you are unsure, ask your own supervisor or HR department for guidance before enrollment. There are many certificate programs developed for  supervisors already working in industry, such as the California State University Dominguez Hills certification program Occupational Health & Safety for Managers and Supervisors. See if your local college offers something similar. OSHA's website provides information on their Training Centers but also has additional OSH degree and certificate program information. And, a comprehensive directory of possible certifications related to EHS professionals is available from the National Environmental, Safety and Health Association.

Know Your EHS Options and Get Started

Whether you are considering a new career in Occupational Health and Safety or you are looking for a next step in your H&S career, there are many options available for all levels of health and safety professionals from technicians in the field to researchers developing new technologies.  A helpful guide for all levels of current and future health and safety professionals is available through the Board of Certified Safety Professionals (BCSP).

At Emilcott, even before the study came out, we could see that the local pool of EHS professionals isdwindling and aging. In response, we have instituted a progressive mentoring program to move recent college graduates into the field, we support advanced degrees and certifications by our staff, we are active in our local chapter, we volunteer at school career day presentations, and were recently featured in a career choice video by the Wall Street Journal.

As a health and safety professional, what are you doing to bring fresh faces into our peer group? As an employer, have you instituted formalized plans to recruit and develop your staff? And, as a peer, how are you reaching out into the community to ensure that this profession remains healthy and growing?
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Topics: NIOSH, General Industry H&S, General EHS, Construction H&S, H&S Training, health and safety profession, mentor, jobs, career, workforce, H&S, certification, degree, occupational health and safety, OSH, assessment

What Workers and Managers Should Know About Emergency Eyewashes

Posted by Shivi Kakar

Oct 24, 2011 7:54:44 AM

By John DeFillippo, EMT-B, CHMP

The CDC reports that each day more than 2,000 U.S. workers receive some form of medical treatment due to eye injuries sustained at work. More than 800,000 work-related eye injuries occur each year. Most of these injuries result from objects entering the eyes, but many are caused by chemicals. Wearing appropriate eye protection and working safely go a long way toward preventing these types of injuries. However, because nothing is 100%, OSHA requires certain areas in the workplace where chemicals are used or stored to be equipped with emergency eyewash stations and, in some cases, emergency drench showers. The OSHA Medical Services and First Aid Standard covering this area [29 CFR 1910.151 (c)] states:
"Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use."

If you are working with or storing corrosive materials your facility must have such installations.  Like a fire extinguisher on the wall, you hope you never need an emergency eyewash station, but you’d better be able to get to it and it had better work when there is a need. It’s important to know that chemical burns and damage start immediately upon contact. The sooner the rinsing starts, the less damage will occur.

The main function of rinse stations (portable or fixed) is first aid, and it is only step one. Immediate and appropriate medical treatment is the next step  -- whether it is calling 911 or transporting the injured person to the nearest medical facility.  Someone from your facility, preferably a manager, should stay with the injured worker and have a copy of the MSDS and any incident information that could be helpful to the medical personnel.

Emilcott staff work at a variety of industrial, commercial, construction and other hazardous sites. For many facilities and jobs, an eyewash station is an essential part of the health and safety plan. As an EMT and CHMP, these are some of the questions I ask when assessing the suitability of flushing stations:

  • Do area workers know where emergency eyewash and shower stations are located, AND how they operate?

  • Are the stations accessible? Not blocked or obstructed?

  • The route to all flushing stations must be clear and the locations boldly marked; could everyone get to a station when needed—FAST and possibly without looking?

  • Has the equipment been inspected and tested monthly? Has this been documented?

  • Is the system plumbed with fixed piping? Or is it a stored liquid type? The former must be flushed and the latter must have its water supply treated so that it remains stable. Both must be capable of delivering at least 15 minutes worth of flow.

  • Is the water at a comfortable temperature?

While there are many products on the market, we recommend the Speakman Gravityflo® Portable Eyewash & Drench Station and use one as a training tool for students in our Hazardous Waste Operations / Emergency Response training courses.  An important component in an effective HazWOPER (and all H&S) training program is the hands-on experience so that students know what to expect in the field. Instead of a slide on an eyewash station, we roll our portable unit to the front of the class or outside for the field exercise, show them how to use it and why it is critical for the eyewash station to be close, ready, and working in the event of an emergency. If your  job function is near where chemicals are used or stored, you should know as much about your nearest eyewash station as our students do!

If you work at a site with corrosive materials present, how available are emergency flushing stations?  Can these stations be accessed within 10 seconds? Has anyone ever showed you how to use it…blindfolded?
Read More

Topics: OSHA, First-Aid, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, protection, eyewash, emergency, drench, corrosive, flush, Lab Safety & Electrical, injury, eye

Be Sure You Use the Proper PPE...or ELSE!

Posted by Shivi Kakar

Oct 16, 2011 11:02:04 PM

Ed Pearl

If you have a giant stack of the best personal protective equipment (PPE), but don’t use it, or just as important, don’t use it properly, are you trying to become an OSHA statistic? Knowing how to protect yourself from occupational hazards is a critical part of your job.

A Real Life PPE Correction

A few years ago, I was taking my annual HazWOPER 8-Hour Refresher class and a fellow student shared his story about PPE.
Part of his job was to open and close valves that allowed aviation fuels to flow to pumps used to fill airplane fuel tanks. As most of these valves were in confined space vaults without proper ventilation, he was often exposed to fuel vapors. After complaining about the headaches and dizziness that he was experiencing, his employer had him fit tested for a respirator. However, even with the proper-fitting respirator, he still had the same symptoms of overexposure.

Why didn’t the respirator control the exposure?  As a health and safety professional, the answer was obvious to me! I asked him, “What type of cartridge are you using?”
His reply, “I am using what was given to me.” Two days later he called me to tell me that he had been given HEPA filters – the WRONG cartridge for his petroleum vapors.

Instead he should have been using organic vapor cartridges. Without correction, this COULD have been become a very dangerous problem – just because of the wrong cartridge in the right respirator.

Proper Protection: Where Do You Start?

A perfect place to start understanding how to protect yourself is to know what you are dealing with on the job.

  1. What are the potential hazards? Is there more than one? Not sure? Ask questions! Make sure that you understand the hazards and risk before you are satisfied?

  2. Are there chemicals? Read material safety data sheets (MSDS) which have standardized information required by OSHA. MSDSs for all chemicals at your worksite must be made available by your employer for your review.  So that you, the worker, can read about the chemical hazards’ AND methods of protection. It’s the law!

  3. Review your job duties and PPE with your job site safety officer or a health and safety professional.

Proper Protection:  A Quiz

Q: If a person is working with an acid and they are wearing cloth gloves, who are they protecting?

A: Nobody!  The proper glove is a “chemical resistant” polymer for protection from acids (usually a neoprene or polyvinyl chloride (PVC) glove). Depending on the risk of splash, this worker may also need goggles, a face shield, and chemical resistant garments (apron, or partial or full body protection).

Q: If a worker is welding and only wearing a face shield designed for grinding, are they properly protected?

A: Absolutely not! The proper protection for a welder includes a welding shield equipped with filter lenses that have a shade number appropriate for the welding operation

Q: What happens when you wear a respirator that is not properly fitted?

A: You are potentially letting in the very substance you are SUPPOSED to be protecting yourself from! OSHA mandates that all required use respirators be tested for proper fit using “fit test” procedures detailed in the OSHA Respirator standard (1910.134).

The point is, there is the right PPE for the job…know what it is, and use it correctly!

Proper Protection:  Personal Responsibility

Today, information is at our fingertips on ALL subjects including PPE. Take the time to hunt around and find the information you need to properly protect yourself. There are all types of online courses and local resources including those provided by unions and insurance companies that welcome your questions and interest. Whether it’s the Internet or real, live health and safety professionals, ask questions to ensure that your PPE is right for you and the hazards you encounter.  If you find out that don’t have the proper PPE, don’t do the job or you’ll eventually become an OSHA statistic – or worse!
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Topics: OSHA, Personal Protective Equipment, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, cartridge, construction, respirator

Who Pays for PPE? A Guide for Employers and Employees

Posted by Shivi Kakar

Oct 9, 2011 11:09:05 PM

by Paula Kaufmann

When providing guidance on the selection and use of PPE, it is critical for occupational safety and health experts to understand not only the technical issues surrounding the use of PPE as an exposure control method, but also the regulatory compliance burden placed on the employer.  I recognize that “just” complying with OSHA standards is not equivalent to meeting industry best practices, but is important to understand the what might be considered the ‘back-bone’ of PPE programs in the US.

In February, OSHA announced the publication of an update of “ Enforcement Guidance for Personal Protective Equipment (PPE) in General Industry”.  This update establishes OSHA’s general enforcement and guidance policy for its Standards addressing PPE.  The PPE Standards had been revised by OSHA in 2007 and 2009.  These changes had not been reflected in the former enforcement Instruction.

The updated information provided to the OSHA Compliance Officers is helpful for all of us to review.  The revised OSHA Enforcement Guidance spotlights the following:

  • Employer-provided (purchased) PPE requirements (Who, What, Which)

  • Clarification of payment requirements for PPE worn off the jobsite, for PPE that must remain at the jobsite, and for employee-owned PPE.

Who: Employers must provide PPE to all affected employees with an established employer-employee relationship. These employees include short-term employees which may be referred to as temporary employees, piece workers, seasonal employees, hiring hall employees, labor pool employees, or transient employees.

What: Employers must pay for PPE that is required to comply with OSHA Standards, except in the limited cases specified in the Standards. Employers must provide, at no cost to employees,  the PPE that is necessary to protect against the hazards that the employer is aware of as a result of any hazard assessments required and specified in the OSHA standards.  An employer must provide, at no cost to employees, upgraded PPE that the employer chooses to use to meet OSHA PPE requirements.

Which: OSHA is updating the references in its regulations to recognize more recent editions of the applicable national consensus standards, and is deleting editions of the national consensus standards that PPE must meet if purchased before a specified date. In addition, OSHA is amending its provision that requires safety shoes to comply with a specific American National Standards Institute (ANSI) standard.

So – what PPE must employers provide with no cost to their employees? And what PPE are employers not obligated by OSHA to purchase for use by the employees? It can be confusing!  The following is a list of examples and exceptions:

  • those highlighted in GREEN are “must purchase” items

  • those highlighted in red are “not required” to be purchased by the employer.

In most cases, the determining factor for “who pays for the PPE” is whether the PPE is required to comply with a specific standard.  The outcome of site-specific PPE hazard assessments will determine what PPE is required. (Some of the exceptions seemed counter-intuitive to me ... what do you think?)

PPE that an Employer Must Purchase (when required to comply with a standard)

  • Metatarsal foot protection

  • Chemical resistant boots with steel toes

  • Shoe covers – toe caps and metatarsal guards

  • Non-prescription eye protection (safety glasses)

  • Prescription eyewear inserts/lenses for full-facepiece respirators

  • Prescription eyewear inserts/lenses for welding and diving helmets

  • Goggles

  • Face shields

  • Laser safety goggles

  • Firefighting PPE (helmet, gloves, boots, proximity suits, full gear)

  • Hard hats

  • Hearing protection

  • Welding PPE

  • Items used in medical/laboratory settings to protect from exposure to infectious agents (aprons, lab coats, goggles, disposable gloves, shoe covers)

  • Non-specialty gloves for protection from dermatitis, severe cuts/abrasions.

    • Payment is not required if they are only for keeping clean or for cold weather (with no safety or health considerations)

  • Chemical-resistant gloves/aprons/sleeves/clothing

  • Encapsulating chemical protective suits

  • Aluminized gloves

  • Rubber insulating gloves

  • Mesh cut-proof gloves, mesh or leather aprons

  • Self Contained Breathing Apparatus, atmosphere-supplying respirators

  • Air-purifying respirators

  • Personal fall protection

  • Ladder safety device belts

  • Climbing ensembles used by linemen (for example, belts and climbing hooks)

  • Window cleaners’ safety straps

  • Personal Flotation Devices (life jackets)

  • Reflective work vests or clothing

  • Electric arc and flame-resistant garments

Some exceptions to the employer purchase requirement:

Non-specialty PPE - if the employer allows the employee to wear it off the job site


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Topics: OSHA, Personal Protective Equipment, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, General Industry, employer, purchase, employee, requirements

Heads Up! A quick look at hard hats…

Posted by Shivi Kakar

Oct 2, 2011 11:01:02 PM

By John Defillippo, CHMP

It makes sense, if you are injured in the head at work – you weren’t wearing a hard hat!

In 1980, Bureau of Labor Statistics (BLS) conducted a survey that indicated that about 80% of the workers sustaining traumatic head injuries each year do not wear head protection. Most of those injured were performing their normal jobs at their regular worksites with 70% indicating that they had had no instruction concerning hard hats. With this information, OSHA started the process to revise the PPE (personal protective equipment) standards and in 1994, the current version of the OSHA PPE standards was published.

So let’s move through time to the present – 30 years after the BLS survey… in 2010 OSHA handed out over $ 1.2 million in proposed penalties for about 2,000 head protection violations ( 29 CFR 1926.100 and 29 CFR 1910.135 ).  Most of these violations were for workers failing to wear hard hats when required.

When are hard hats required to be worn?

The Simple Answer:  If you are working where ANYTHING MIGHT fall, drop, fly, splash, or land on your head OR your head could come into contact with ANYTHING that MIGHT injure you, like moving equipment, chemicals or electricity, you need to be correctly wearing a properly fitting, ANSI-approved hardhat.

All hard hats should have an ANSI certification label on the inside of the hard hat’s shell. This label will clearly identify what type and class standards it was designed to meet. If this label is missing or cannot be read it should be replaced. Hard hats are classified according to the specific impact and electrical performance requirements they meet.  The details are specified in ANSI Z89.1-2009, American National Standard for Personal Protection—Protective Headwear for Industrial Workers.

Wearing them correctly means in accordance with the manufacturer’s recommendations. Not backwards (unless specifically so designed) and no hats underneath (except a proper hardhat liner).  A hard hat works by the shell deflecting the blow and absorbing shock and distributing the force of the impact over the suspension system. Wear it backwards or wearing hats (especially baseball caps) or carrying something inside is a really bad idea as it can adversely affect the way it works. Any stickers on the hat must be removable so the hard hat can be inspected and no paint is allowed.

If you are an employer you must determine if and when hard hats are required, provide the correct type and enforce their use.

All hard hats don’t protect our heads from all hazards!

How do you choose the right hard hat?  Do you need protection from just impact or do you also need protection from electrical hazards as well?

Impact Protection

Type I Hard Hats

Type I hard hats are intended to reduce the force of impact resulting for a blow to the top of the head only.

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Topics: OSHA, Personal Protective Equipment, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, construction, class, electrical hazard, protective headwear, impact, ANSI, head protection, hard hat

Indoor Air Quality in Healthcare Facilities During Construction and Renovation

Posted by Shivi Kakar

Sep 25, 2011 11:49:48 PM

Daniel Senatus

A construction and renovation project within any facility creates a range of situations which can release debris, pollutants and contaminants that can impact the indoor air quality. These contaminants may be transported to other areas via HVAC systems, personnel coming and going through encapsulation barriers, and other factors that can subsequently affect people beyond the project area. Consideration of the effect upon indoor air quality is particularly important in healthcare settings when performing construction or renovation projects. Under these conditions, patients and other people with existing health problems that are in the hospital for treatment are at increased risk of contracting nosocomial infections.

Planning and Administrative Controls

All hospital construction projects must go through an Infection Control Risk Assessment (ICRA) to determine the impact of the project on patient care. The ICRA process is usually lead by the Infection Control staff with additional input from the construction company, engineering, and safety managers. See ICRA Sample here.

Advance planning by all project managers, combined with proactive communication efforts, can successfully allay concerns during and after construction activities. Healthcare facilities must consider other factors that may be a potential hazard as a result of the project and then determine the controls that must be put in place to mitigate them. Other critical factors include knowing what areas will be unusable for the extent of the project, and the time of day that will minimize disruption of services (which is variable depending upon whether it is an ambulatory or inpatient facility). It makes sense that most construction in hospitals should be done in a part of the hospital that is not operational or is vacant.

Hazards to Consider

PM (Particulate Matter)

Construction and demolition activities may introduce particulate matter such as dusts and fibers into an environment. Most concerning is respirable dust; these are dust particles that are small enough to bypass the body’s natural defense and clearance systems (mucous, cilia) and not trigger the coughing reflex which is the body’s way of removing mucous and foreign material from the lungs and upper airway passages. Once these particles get deep in the lungs, they are more likely to be retained and can lead to a whole host of health issues including altered lung function, lung cancer, and even heart problems later on.
Biological Hazards

Construction and demolition of materials may contribute to the release of and exposure to a variety of microorganisms: fungi (Aspergillus, Candida, etc.), bacteria, and medical waste. There is also a good chance that animal droppings, insect parts and standing water may be encountered when breaking into areas not normally accessed. Building materials that are constantly damp or wet may serve as breeding grounds for microorganisms. Workers can come into contact with bodily fluids and bloodborne pathogens originating from leaking medical equipment (suction lines, etc).

According to OSHA “ bloodborne pathogens are infectious organisms present in blood that can cause diseases in humans. These pathogens include, but are not limited to Hepatitis B, Hepatitis C and HIV (Human Immunodeficiency Virus), the virus that causes AIDS.”  Hepatitis B and C are of the most concern in the healthcare construction and renovation setting because they can survive outside of the body for up to a week in the right conditions. Construction activities can make these microorganisms airborne, affecting the indoor air quality and posing a threat to workers and immunocompromised patients.

Engineering Controls

Typically these are implemented as part of the Infection Control Risk Assessment (ICRA).

Create a containment barrier with fire-rated 6 MIL polyethylene sheeting around the source and isolate it from other areas of the building so that there is no recirculation of air from the work area into other spaces. HVAC intakes within the containment should be sealed to isolate the containment from general ventilation. Create a second barrier directly outside of the containment barrier (this is considered the “dirty” area) with a sticky mat on the floor, this is where used PPE (personal protective equipment) can be discarded. Create a third barrier (clean area) where clean PPE can be stored; this will actually be the space between the dirty area and the occupied spaces. High traffic zippers should be used on all openings and sticky mats should extend six feet from the clean containment entrance to the occupied areas. These mats should be replaced daily or whenever they look dirty, whichever comes first.
Air Cleaning and Negative Pressure

Use NAM (Negative Air Machines) with HEPA (High Efficiency Particulate Air) filters inside the enclosure. Filters should be changed as needed. Create a negative pressure environment so that lower pressure inside the containment pulls outside air in and prevents the contaminated air from escaping. The NAM should be on prior to construction being started and stay on for the duration of the project whether construction is going on or not. A micro-manometer can be used to verify that negative pressure is established and maintained.
Dust Monitoring and Microbial Sampling

Continuous dust monitoring outside of the area can help determine the success of the control measures put in place. This can be accomplished using direct reading instrumentation that is equipped with alarms which notify personnel when dust is escaping from the enclosure so that corrective action can be implemented before patients and staff are impacted.

Collecting surface and air samples to evaluate microbiological impacts can also aid in establishing additional preventive measures to protect health and safety of patients and staff.

PPE (Personal Protective Equipment)

Prophylaxes and PPE

Construction in certain places in a hospital can increase a construction worker’s chance of being exposed to contaminated waste and bodily fluids. It is good practice to inoculate personnel with the Hepatitis B vaccine in addition to PPE if there is enough time before the project (4 to 5 months) or if the construction company does a lot of work in functioning hospitals. The vaccine is given in a three dose series to reach immunity:

  • Dose #1 – Initial dose

  • Dose #2 – 30 days after dose #1

  • Dose #3 – 4 months after dose #2

All PPE selected for construction use at any healthcare facility must be “appropriate” for the task at hand. OSHA 1910.1030(d)(3)(i) states that personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

In damp areas or places with medical waste or other contaminated fluids, liquid-resistant Tyvek suits, gloves, shoe covers, respirators/N95 masks, and goggles should be worn. All PPE must be discarded before exiting the containment area.


Post-construction cleanup in healthcare facilities is the final stage but is just as important as any other phase. A combination of damp wiping and HEPA vacuums should be used to clean all dusty surfaces. After all trash, dirt, and debris have been removed, wet rags should be used to wipe down all areas within the containment and other areas immediately surrounding it.

Removal of trash may require that the trash be wiped down and clean and/or placed in a covered cart for transport away from the construction site to the waste dumpster so as not to spread contamination in sensitive areas. The renovated or constructed area should be in a sanitary condition before it is turned over to hospital staff. A careful inspection and testing program can aid in documenting the level of cleanliness.

Planning and Partnership

Construction in any healthcare facility is a necessity – whether it is a long-awaited and carefully planned renovation or a response to an urgent problem within the building envelope. In either case, protecting the health and safety of patients and caregivers in the facility and the construction workers can be achieved through planning, communication, and a thorough knowledge of indoor environmental quality (IEQ) and industrial hygiene (IH) procedures and best practices. The success of the project is also dependent upon the partnership of the medical staff, management personnel and all the outside resources that will address the problem and ensure that the construction is completed without creating any additional health issues.

If you have any questions about construction or renovation at a healthcare facility or clinic, please comment below or c ontact us and an Emilcott IEQ specialist will respond.

References and Further Reading

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Topics: indoor air quality, Personal Protective Equipment, Renovation, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, Air Monitoring, construction, respirable dust, remodel, ICRA, protect, biological hazards, health and safeety, containment, particulates, hospitals, sampling, demoliton, healthcare

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