Environmental Health and Safety Blog | EHSWire

Everyone loves that 'new car smell'. Most people do not realize however, that the smell comes from the off-gassing of the materials used to build the car. These gases are often a wide assortment of volatile organic compounds (VOCs) released by the plastic, rubber, adhesives, and fibers used in the interior of the automobile.  Exposure to these should be minimized. 

by: H. Dale Wilson, CIH, LEED AP

Stronger standards aimed at reducing the number of Legionellosis (Legionnaires' disease) cases are being brought about through the proposed American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 188, “Prevention of Legionellosis Associated with Building Water Systems.” Hospitals and other medical facilities are advised to prepare for these changes to get a better grasp of potential problems before the standard is finalized.

According to the CDC, between 8,000 and 18,000 people are hospitalized every year with Legionnaire's disease, which is fatal in 5-30% of cases. It's a serious infection that can affect those with chronic lung conditions, smokers, or individuals with chronic immune system disorders or weaknesses.  It is hoped that these changes to ASHRAE's Legionella standard will prevent thousands of cases every year.

The changes are comprehensive, and include several steps. From the proposed Standard:

• The facility is surveyed to determine its risk characterization, which determines what preventive measures are required under the standard.


• A Hazard Analysis and Critical Control Points (HACCP) team is formed by the building owner, the owner's building management team or both. The team must include at least one person who understands the principles of HACCP and at least one person who understands the building water systems. Members of the HACCP team can be employees, suppliers, consultants or any combination thereof.


• The team identifies the end point uses of potable and utility water systems within the facility.


• The team creates at least two process flow diagrams—one for potable water and another for utility water—to describe how the water is processed and used in their facilities.


• An on-site inspection confirms that the flow diagrams are accurate.


• Using the flow diagrams, the team identifies control points in the process. Control points are any steps at which biological, chemical or physical factors can be controlled.


• The team then determines which control points should be designated as critical control points, which are steps in the process where it is essential to prevent or eliminate a hazard or prevent harm to a person.


• The team establishes critical control limits for each critical control point. These are the specified values for hazard control, such as the amount of chlorine needed or the temperature range needed to control the hazard of Legionella.


• The team creates monitoring procedures for each critical limit as well as a monitoring frequency.


• The team establishes corrective actions to take when deviations from critical limits are found.


• The team validates its selection of critical control points, critical limits and corrective actions.


• The team establishes verification procedures and record-keeping procedures as required by the standard.

The changes incorporate concepts found in Hazard Analysis and Critical Control Point (HACCP) plans, well-established to be effective in the food industry to prevent food-borne illnesses. The HACCP model was also chosen because of the inexpensive (and sometimes free) availability of the plans and the ease of implementation. While some have stated that the changes seem complex, the HACCP model is being incorporated to streamline the processes and standards.

Vapor Intrusion is a hugely important issue to those of us living and working in NJ.  With a statewide focus to maintain our undeveloped land, new construction has been focused on reclaiming Brownfields and Portfields.  However, old industrial properties may contain volatile chemicals in the soil or groundwater with the potential to migrate through subsurface soils into buildings themselves—i.e., vapor intrusion.

The US EPA issued a draft guidance document on the subject in 2002 and 2003. ASTM International released the "Standard Practice for the Assessment of Vapor Intrusion into Structures on Property Involved in Real Estate Transactions," (ASTM E 2600-08).  NJ initially issued its Vapor Intrusion Guidance in October 2005.  This initial guidance document provided some direction but left many decisions of how to investigate, measure and monitor the impact of vapor intrusion to the investigator. Now, with the increased push for the rehabilitation of former industrial sites we now have more specific guidance.

The January 12, 2012 NJDEP Vapor Intrusion Technical Guidance Document is the first update since DEP’s initial document in 2005.  It is well overdue and hopefully worth the wait. Below is a summary of what the guidance document is intended to do.  How well that works will come to bare and may be addressed in future postings.

The document is designed to be a much more in-depth protocol to those professionals who evaluate and respond to evidence of volatile organic compounds migrating from subsurface soils into overlying buildings.  Its changes and intentions include:

• Necessary changes prompted by the NJ DEP Site Remediation Reform Act (SPRA)


• Specific guidelines on how to comply with the NJDEPs requirements for assessing a vapor intrusion pathway


• Recommended protocols for investigating a vapor intrusion pathway


• Recommendation on sampling, both subsoil and air quality


• A phased strategy for the process in general


• NJDEP regulatory timeframes triggered by specific concerns as they are identified


• Specific information on landfills and methane


• More in-depth information  and procedures for design, mitigation, post-mitigation and environmental monitoring

For more information, you may access the Guidance Document Here

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).

Containment

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.

Housekeeping

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

http://www.ehow.com/list_7716877_statistics-exposure-hospital-construction-activity.html

http://www.cdc.gov/ncidod/eid/vol4no3/weinstein.htm

http://www.mycology.adelaide.edu.au/downloads/Preventing-IFI-Buildings.pdf

Dale Wilson, CIH, LEED AP

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

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

Experts Can Determine Proper Mold Remediation

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

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

Mold Remediation Services

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

Step 1: Initial Assessment

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

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 http://www.nytimes.com/2011/07/07/nyregion/final-defendant-is-acquitted-in-deutsche-bank-fire-trial.html.

Dave Tomsey

On the second day of 2011, the James Zadroga Act was authorized to broaden and renew funding and extend benefits to Ground Zero workers whose death was a result of exposure.  These exposures were directly and indirectly caused by toxins present in the billowing clouds of dusts and smoke following the worst tragedy to happen on American soil in my lifetime.  The tragic sickness of countless rescue workers continues to add heartbreak where there is little room for more.

What Do We Know?

In the 9/11 crisis, workers were really battling two threats:   terrorism and vaporized building materials. The high levels of toxins at the World Trade Center site were identified and measured.  This process was carried out using sampling pumps, associated media and lab results in order to classify possible carcinogens and determine their percentage in a given volume of air.  The process is the same today. Although concentrations may differ from one area to another, the goal is to establish the worst-possible contaminant scenario to protect site workers and the public.  Once the type and levels of hazards are known, engineering controls, PPE and other methods of worker health protection are put in place.

Protecting Emergency Response Workers: What Has Changed?

In the time that has passed since the WTC tragedy, technology has progressed to offer improved worker protection. Just as smart phones have become prevalent in our lives, the same technology has been integrated into measurement devices producing smaller instrumentation with better, faster communication capabilities.  Put together, these smart systems, unthinkable ten years ago, enable real time environmental hazard monitoring.  In a nutshell, as hazards are detected at the site, real time systems send up an immediate flare.  What used to take a day (at best) to reveal is now known instantly at your fingertips.

How Would Real-time Monitoring be Used for Emergency Response Today?

As lab samples are being collected and rescue workers or cleanup crews are in service with respirators, monitoring field stations can be set up and started.  Once samples identify the risk, , the field stations can continuously measure dust and volatile organic compounds (VOCs) in real time as a surrogate for contaminants found in laboratory samples.  Field stations located around and within the work area form multiple monitoring zones to (1) protect workers in close proximity to contaminants, (2) determine an exclusion zone for support personnel, and (3) protect residents and other businesses at an even greater distance from the site. End result? The constant stream of field data, with corresponding weather information such as wind, precipitation and temperature, would either confirm or indicate modified worker protection needs as the project continues.

How Do You Know When Workers Need Some Type of Additional Safety Precautions Beyond Respirators?

A real time environmental monitoring system is designed for continuous monitoring of all aspects of emergency response recovery and cleanup efforts so that risk can be evaluated as the scenarios change. Today’s technology has impacted and improved virtually every aspect of environmental monitoring:

• Authorized personnel can receive constant updates and alarms via multiple means:  text, email or 2-way radios.


• Incoming and historical data can be viewed by multiple stakeholders at varying locations and allow managers in the field to instantly assess trends with laptops, tablets and smart phones.


• Measurements collected in real time are averaged and processed to show trends in and around the work zone.  These trends are displayed as either a table, graphic plots or shown with contours to establish if a work practice or area is safe for personnel


• Plotting data points with corresponding wind speed and direction allows for managers to determine if offsite sources are impacting the job site or if the vapors and dusts shown on-screen are generated onsite.  Meteorological data showing site conditions (such as high winds) indicates when additional safety precautions should be considered.


• New monitoring equipment now measures multiple levels of dust and vapors into the parts per billion range.  Vapors measured in the parts per billion ranges allow for managers to see if potential toxic vapors are steadily climbing from the lowest detectable levels.  Multiple particle sizing differentiates inhalable dusts from heavier ones that can contain heavy metals.  This allows managers to classify dust readings, watching diesel emissions across site for workers and heavier particulates for neighboring residents and the public.

With such new and remarkable technologies there is no reason to not employ them.

The connected lifestyle and technology of today’s standards help us accomplish many tasks and stay informed.  We are all used to checking our phone or bringing up a website to learn more.  This same connection through real time monitoring to hazardous work sites would be second nature to most and allow for the protection of many.  My hope is that there will never be a need for real time monitoring in response to an incident like 9/11 but, as an American and a CIH working at hazardous sites; it is reassuring to know that there are developed technologies in place to better protect workers if the worst does indeed occur.

Paula Kaufmann, CIH

It happens every summer at hospitals and clinics across the country…first-year and advanced residents and fellows start a new training-at-work year. As part of the infection control strategies at these healthcare facilities, respiratory protection training and fit testing campaigns move into full gear to ensure that everyone is covered (literally and figuratively). It is almost like the return of migrating birds as second, third and fourth-year residents and current fellows flock into queues for respirator use training, fit testing and, often, medical clearance for respirator use.

Providing these invaluable respirator program services en masse is a challenge for the infectious disease and industrial hygiene and EHS departments at hospitals and other healthcare facilities. Nationwide, according to the National Resident Matching Program (NRMP), more than 25,000 residents and fellows will begin their new assignments in July!  Without interfering with patient care or hospital services, they all must be medically cleared, trained and fit tested for the site’s selected respiratory equipment (sometimes 2 or 3 different manufacturers or styles) prior to stepping foot on the hospital floor.  If you add nursing and other healthcare staff requiring an annual fit test in June or July, within a 4-6 week mid-summer period respiratory protection program departments at large teaching hospitals must provide OSHA-mandated support to 800 to 1000 (or more!) residents and fellows.  Planning is imperative and cooperation from the medical staff makes the process smoother for everyone.

Do You “Fit” this Fit Test Profile?

In a recent campaign processing hundreds of medical staff, Emilcott provided support to the infectious disease and EHS fit testing teams at a regional teaching hospital.  The fit test campaign coordinators orchestrated this event with military precision.  It was well- planned and appropriately staffed.  However, with so many folks donning respirators and fit test hoods, the lines were long and we encountered an array of challenging and uneducated attitudes.  Here are some of our favorite responses:

• “I’m a third-year resident, I don’t have to be clean shaven to get fit tested.” (He was promptly handed a shaving kit.)


• “What do you mean “I” failed? Is this graded? Oh, I see, the respirator failed, not me!”


• “I never wear those respirators, so can you make it quick.”


• “I know how to wear that.” (As the respirator was put on upside down…)


• “I don’t think I can work with this [fit test] hood on every day!”

And, some real doozies during the 7-step qualitative fit test exercises:

• “Just tell me, what is the “right” answer! Should I taste the Bitrex® or not?” (We sent this doctor to be quantitatively fit tested.)


• “Isn’t this a bit excessive?” Followed by “Oh, now I think I can taste it!”


• “Can’t you use that sweet stuff?  I like that better than this bitter taste.”


• “This respirator fit okay last year … why can I taste the bitter flavor now?”


• “This process didn’t take this long at the last hospital I worked, you must be doing it wrong.” 


• And, drum roll please, from an Infectious Disease Fellow, “Thank you for making us go through each step of the fit test procedure, it’s really important!”

As a Certified Industrial Hygienist, my challenge is to convey the why, how and when of respirator use (according to OSHA Respirator Standard training and fit testing requirements) to anyone on my watch – even when my target audience consists of impatient, high achieving and time-pressed medical professionals. In an odd role reversal, I’m doing the life saving…using occupational health and safety standards to protect their bodies as they do their jobs.

When Are Healthcare Providers Required to Use Respirators?

The Centers for Disease Control and Prevention (CDC) indicates the use of respirators for protection from infectious respiratory aerosols specifically those from patients with active tuberculosis and influenza.  

• The CDC “TB Elimination: Respiratory Protection in Health-Care Settings Fact Sheet” specifies that particulate filter respirators certified by National Institute for Occupational Safety and Health (NIOSH) be used for protection against airborne M. tuberculosis including
  
  
  
  • Non-powered respirators with N95, N99, N100, R95, R99, R100, P95, P99, and P100 filters (including disposable respirators); and
  
  
  • Powered air-purifying respirators (PAPRs) with high-efficiency filters
  
  
  
  


•  The Department of Health and Human Services “Interim Guidance on Planning for the Use of Surgical Masks and Respirators in Health Care Settings during an Influenza Pandemic” emphasizes that respirator use is a critical component of a system of infection control practices to prevent the spread of infection between infected and non-infected persons. Respirator use is indicated as follows
  
  
  
  • N95 (or higher) respirators should be worn during medical activities that have a high likelihood of generating infectious respiratory aerosols, for which respirators (not surgical masks) offer the most appropriate protection for health care personnel.
  
  
  • N95 respirators are also prudent for health care personnel during other direct patient care activities (e.g., examination, bathing, feeding) and for support staff who may have direct contact with pandemic influenza patients.
  
  
  
  

 High Velocity Fit Testing

Another comprehensive qualitative fit test (QLFT) campaign at a large teaching hospital in New York City was scheduled across a broad span of times, crossing many days and weeks to accommodate the schedules of rounds, staff, patients and Human Resources. Emilcott’s fit testing team became considerably more efficient this year by switching to the TSI Qfit to generate the test atmospheres. One touch of a button on these pump-driven nebulizers produces the equivalent of 5 bulb nebulizer compressions and uses quick, pop-on cartridges containing the challenge solutions. The easy and consistent delivery system of the nebulizers enabled us to focus our attention on the respirator user and the respirator fit.

Fit testing of course confirms (or not) the match of each face to the selected respirator. For respirator users who were unable to taste either Bitrex® or Saccharin during sensitivity testing; could not clear the taste of Bitrex® after wearing a poor fitting respirator; or, were extremely uncomfortable wearing the fit test hood, we supplemented the QLFT with quantitative fit testing (QNFT) to ensure an accurate respirator fit test. Staff that did not pass both the QLFT and QNFT with any standard-issue respirator was forwarded to the Respiratory Therapy department for personal respirator attention. In our estimation, more than 1000 staffers, new and seasoned, passed through our fit testing process in a matter of days!

Respiratory Protection is Smart

It is important for medical staff – new or seasoned - to know when and why they are required to wear respiratory protection – the training is an essential part of the OSHA Respirator Standard. While the attitudes we encounter during fit testing at hospitals often include dismay over a failure or impatience and ungraciousness, we do our best to educate each person as they roll through the lines. Many times, the mere mention of antibiotic-resistant TB exposure or gentle reassurance that a failed fit test is not the same as a failed biology test, can shift a nurse or doctor’s perspective. What was a nuisance can quickly turn into a better comprehension of their occupational risk and personal responsibility to protect their health. As for the others? As OSHA mandates, there’s always next year.

As a health and safety professional, have you encountered any resistance to respirator fit testing? How have you responded? As a healthcare provider, what do you think about fit testing? Do you take it seriously? Does your employer?

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

Summer vacation is what every student dreams of...no school!  While this may be true for the educational calendar, summer is the time of year when schools generally address their big asbestos issues.  So instead of students and teachers filling the classrooms, they are replaced by a range of very specific professionals that are required to get the job done:  the Local Education Agency (LEA), Designated Person, Inspectors, Management Planners, Remediation Contractors, and Asbestos Safety Technicians/Project Monitors.

Regulations for Asbestos in Schools

Asbestos in schools is regulated by the Asbestos Hazard Emergency Response Act (AHERA), promulgated by the US Environmental Protection Agency (EPA) in 1986. AHERA applies to all public and private elementary and secondary schools in the United States and requires LEA’s to identify, evaluate and control Asbestos Containing Building Materials (ACBM).  At each school a “Designated Person” is given the responsibility to be in charge of the school's asbestos control program.  The regulation is meant to protect children, as health issues from asbestos are not immediate, but can take decades to appear. The EPA explains on their website:

“ Although asbestos is hazardous when inhaled, the risk of exposure to airborne fibers is very low. Therefore, removal of asbestos from schools is often not the best course of action. It may even create a dangerous situation when none previously existed. The Environmental Protection Agency (EPA) only requires removal of asbestos to prevent significant public exposure during demolition or renovation. EPA does, however, require an in-place, pro-active asbestos management program for all LEAs in order to ensure ACBM remains in good condition and is undisturbed by students, faculty, and staff.”

Identifying the Problem

The first task of managing asbestos correctly is identifying the location, quantity, and condition of ACBM.  This responsibility is assigned to an AHERA-accredited Building Inspector.  In addition to conducting the initial inspection, Building Inspectors must also re-inspect ACBM every three years. Six- month periodic surveillances are also conducted by a Building Inspector or other individual familiar with the inspection results, such as a member of the custodial staff.  Collectively, the inspections and surveillances help maintain the accuracy of the inventory and identify any damage that requires a response action.

Developing a Plan

The inspection and surveillance results are used by AHERA-accredited Management Planners to develop an Asbestos Management Plan specific to each school.  The Asbestos Management Plan uses the inventory to assess the likelihood of disturbance and recommend appropriate response actions. 

Plan Implementation

Because children are not occupying the school in summer, it is the perfect time to implement response actions that would otherwise disrupt the educational process and present risk. Response Actions include the following activities:

• Removal

• Repair

• Encapsulation

• Enclosure

• Operations & Maintenance (O&M)

Response actions are undertaken by licensed firms who employ AHERA-accredited supervisors and abatement workers.  Many states also require the companies to have a state-issued license for asbestos abatement work and supervisors and workers must carry performance identification permits. In many states, oversight of the work is done by a trained professional such as NJ’s Asbestos Safety Technician (AST)/Project Monitor who works for an independent firm (not the abatement company) to ensure that proper procedures are followed, and performs on-going air sampling and final clearance sampling to document that the response action does not release asbestos particles into the school.  After all, the goal of the response action is to make conditions inside of the school safe!

The AHERA Regulations turned 25 this year. I f you want to find out more about asbestos and the regulations that control its presence in your local schools, visit the EPA website or review this list of FAQ.  Asbestos Management Plans are required to be available to the public, and you can receive a copy from your school district just by asking.

Parents, have you heard about an asbestos removal or management plan in your school district?  To learn more about Asbestos management in schools, the EPA publishes an informative “The ABCs about Asbestos in Schools” If you are part of an asbestos management team, do you have some reassuring information to share with concerned parents?