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Environmental Health and Safety Blog | EHSWire

Proper PPE? Be SURE It Is!

Posted by Shivi Kakar

Oct 5, 2012 11:20:57 AM

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. While conducting this task, 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?

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Topics: OSHA, Personal Protective Equipment, General Industry H&S, General EHS, Construction H&S, H&S Training, worker safety, hazards, Lab Safety & Electrical, respirator, Exposure, Respiratory

DOT proposes new minimum training standards for Railroad Workers & Contractors under Federal Railroad Administration

Posted by Shivi Kakar

Jun 19, 2012 1:09:49 AM

On February 7, 2012, The Federal Railroad Administration (FRA) published in the Federal Register a Notice of Proposed Rulemaking regarding training and qualifications in federal rail safety laws, regulations and orders.  Train and engine workers, those who inspect and repair freight trains, passenger cars and locomotives, and other “safety sensitive” workers will be affected by the proposed new training programs.

The FRA is seeking training protocols from each railroad (and their contractors) to provide for uniformity in training, and programs that would more clearly define the qualifications of every employee involved in rail safety. Workers would be required to effectively show proficiency in a specific area of expertise, before being trained in more detailed or complicated tasks. Diligent oversight will be encouraged by employers to manage compliance and written reviews would be submitted regarding their training programs and their efficacy in enhanced safety.

Already a requirement of the Rail Safety Improvement Act of 2008, this proposed enhanced rule was developed with the input from officials in numerous federal and state government agencies, industry and labor.  The new training and reporting requirements are seeking to enhance worker safety, close knowledge gaps, and better prepare workers for the very real hazards associated with working for a railroad.

“Well-designed training programs have the potential to further reduce risk in the railroad environment,” said FRA Administrator Joe Szabo. “Better training can reduce the number of accidents, particularly those caused by human factors, which account for the vast majority of reportable accidents each year.”  Experts who seek to raise safety standards and training protocols state that railroads have sought to reduce training costs by offering unsupervised computer-based training, which is not sufficient training before a worker is sent out into the field.

Read More About The Best Type of Safety Training
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Topics: Emilcott, General Industry H&S, Construction H&S, federal rail safety laws, Federal Railroad Administration, regulations and orders, H&S Training, FRA, uniformity in training, Rail Safety Improvement Act

Have You Leaped Over Your HazWOPER Annual Refresher Training?

Posted by Shivi Kakar

Feb 29, 2012 7:35:00 AM

By Paula Kaufmann, CIH

It’s leap day!! If you are born on a February 29 th, then you will really only celebrate your birthday once every four years.  What if you took a 40-hr HazWOPER course that ended on February 29 th or an 8-hour HazWOPER refresher training on leap day?  Does this mean that you only have to ‘celebrate’ your refresher training once every leap year?

OSHA would say “no” as the requirement is for ANNUAL training.  But what if you haven’t taken your HazWOPER refresher training since the last leap day?  What would OSHA think (or cite!) during a records inspection?

The OSHA enforcement office would most likely not be impressed with the one course every leap day concept.  When asked about lapsed 8-hour refresher training, here’s what OSHA wrote in a letter of interpretation

“OSHA's intent is that employees should complete their refresher training within twelve months of their initial training, although we do understand that courses may be missed due to unavoidable circumstances. The employee who misses a refresher training should attend the next available refresher course.”

What about those of us who have not been working on a HazWOPER site and haven’t taken any refresher classes since the last leap day?  What training do we need before we can leap onto a HazWOPER covered site?  Here’s what OSHA wrote about a three or four year and seven year leap …

“…an individual who has been away for three or four years, the employer may determine that, while repeating all of the training materials in the initial course is not warranted, more than eight hours of training would be required to refresh the employee's knowledge and skills. …  However, a seven year absence would clearly indicate a need for extensive retraining, with particular attention given to new technology. In such cases the employer may wish to consider repeating the initial training course.”

When was the last time that YOU attended an 8-hr HazWOPER refresher training course?  Was it within the last 12 months?
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Topics: OSHA Compliance, H&S Training, Hazardous Waste Management

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?
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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

343 + 2 = Changes in NYC Asbestos Regulations

Posted by Shivi Kakar

Aug 29, 2011 7:22:05 AM

Dale Wilson, CIH, LEED AP, Sr. Project Manager

"343" is a symbol of great sadness to members of the FDNY and their families as 343 is the number of FDNY firefighters who died on September 11, 2001. That staggering figure is remembered quite readily when recalling the events of that day and during the remembrances that have followed.  However, almost six years later, the lives of two additional NY firefighters were claimed during the demolition of the 9/11-damaged Deutsche Bank Building.

The 41-story Deutsche Bank Building stood adjacent to the World Trade Center and was severely damaged by falling debris and smoke when the Twin Towers collapsed. The damage to the skyscraper was so extensive that it had to be demolished. However, as the federal EPA requires, before it could be demolished, all asbestos-containing materials needed to be removed.

By August 18, 2007, demolition was well underway and the building now stood at only 26 stories tall.  Around 3:40 pm, a massive seven-alarm fire broke out as a result of a discarded cigarette in the asbestos decontamination unit on the 17 th floor.  The building had not been inspected by the Fire Department since March, when it should have been inspected every 15 days.  As a result, a crucial but inoperable fire standpipe forced firefighters to raise hoses up from the street to combat the flames.   Inside the building, three firefighters struggled to pull a hose through the deconstructed building. Only one of these men survived. The configuration of the asbestos abatement added to the difficulty of fighting a fire in an already structurally-compromised building.

The National Institute for Occupational Safety and Health (NIOSH), an institute within the Centers for Disease Control and Prevention (CDC), completed a description and evaluation of the incident as part of their fire fighter fatality investigation. Several items stand out from the asbestos abatement as contributors to the fire:

  • White plastic sheeting was used to partition the floor area into separate zones.  All these partitions created maze-like conditions for the firefighters.

  • Numerous zones were under negative pressure, as required for asbestos abatement, possibly drawing smoke and fire into localized areas.

  • Stairwell doors were blocked by wooded hatch covers as part of the construction of the asbestos containments.

  • Plastic sheeting, construction debris, and exposed lumber in partitions provided additional fuel.

These contributing conditions created by the asbestos abatement project have been recognized by several authorities, and in an effort to maximize safety, New York City enacted a number of new laws to ensure that asbestos abatement projects are conducted safely.  These laws impact the ways that asbestos projects are filed, approved and inspected, and involve new levels of cooperation among the agencies that oversee asbestos and construction safety:  the NYC Department of Environmental Protection (NYC DEP), the Department of Buildings (DOB) and the Fire Department (FDNY).  Most notably, the NYC DEP created the Asbestos -Technical Review Unit (A-TRU) to ensure that asbestos abatement is conducted safely and a new process for filing for asbestos permits called Asbestos Reporting and Tracking System (ARTS).

ARTS enables applicants to submit applications and/or receive approvals (or objections) electronically.  During the application process, applicants are asked questions to identify if

  • the building’s fire protection systems (e.g., fire alarm or sprinkler system) will be turned off as a result of the abatement work,

  • abatement work will result in blocked or compromised egress or whether any components of the fire protection system are going to be removed as part of the abatement

  • abatement work entails removal of passive fire protection (e.g., fire resistance rated walls, sprayed on fireproofing, or smoke dampers)

If there is an impact to any of these fire protection items then a comprehensive Work Place Safety Plan must be developed for the project indicating abatement containment areas and systems, obstructed and temporary exits, tenant protection and a description of any measures that will be taken to mitigate compromised fire protection systems or means of egress. As a final item intended to promote life safety during abatement projects, the asbestos supervisor must inspect exits daily to ensure that there are no exterior blockages or impediments to exiting. If any blockages or impediments are identified, work must stop until the blockage has been removed.  Essentially, deconstruction and asbestos-abatement work cannot compromise the safety of workers and firefighters.

As Carrie Bettinger noted in a past EHSWire blog, “ In our society and legal system it seems that, yes, someone (or many) has to tragically die before change and regulation are considered.” In this case, the tragedy was 343+2. Hopefully the A-TRU process and increased oversight from NYC DEP, DOB, and FDNY will prevent another similar tragedy from occurring.

Postscript:  The last of the Deutsche Bank tower criminal trials were completed in July, 2011. More information can be found at
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Topics: indoor air quality, health and safety, Construction H&S, EPA, Emergency Response, Homeland Security, H&S Training, worker safety, regulation, construction, emergency response training, demolition, 9/11, Work Place Safety Plan, asbestos, September 11, Deutsche Bank NYC, A-TRU, 9-11, Fire Safety

Need Respirators for Emergency and Post-Emergency Response?

Posted by Shivi Kakar

Aug 21, 2011 10:36:09 PM

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

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