Environmental Health and Safety Blog | EHSWire

The Office of Management and Budget received the final rule update for the Hazard Communication Standard (1910.1200) on 10/25/11.  The 90 day review period is over but the review period has been recently extended.  There is no notice of the length of the extension and it should be noted that OMB has had the OSHA proposed Occupational Exposure to Crystalline Silica Standard for nearly a year, since 2/14/11, and it is still listed as having an extended review period.

You can view the rule at HERE

One of the changes is the inclusion of an “Unclassified Hazards” category; a definition is provided below.  The U.S. Chemical Safety Board recently released a statement supporting the Unclassified Hazard category to allow for inclusion of combustible dust hazards on safety data sheets and labeling.

“Unclassified hazard” means a chemical for which there is scientific evidence identified during the classification process that it may pose an adverse physical or health effect when present in a workplace under normal conditions of use or in a foreseeable emergency, but the evidence does not currently meet the specified criteria for physical or health hazard classification in this section. This does not include adverse physical and health effects for which there is a hazard class addressed in this section.

It should also be noted that EPA began to make amendments in November of last year to regulations for the "Protection in the Workplace" (40 CFR 721.63) and "Hazard Communication Program" (40 CFR 721.72) components of the Significant New Uses of Chemical Substances regulations at 40 CFR 721 to align them with the GHS changes in the OSHA Hazard Communications Standard.

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Topics: Emilcott, OSHA, OSHA Compliance, EPA, hazards

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

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

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

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

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

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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

Dian Cucchisi, PhD, CHMM

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

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

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

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

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

Symptoms of Heat-related Illness

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

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

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

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

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

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

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

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

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

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

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

Lee Scott Bishop, CIH, MPH

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

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

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

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

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

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

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

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


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


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


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


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


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

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

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

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

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

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


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


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


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


• Finally, you can write to OSHA at:

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

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

Paula Kaufmann, CIH

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

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

Do You “Fit” this Fit Test Profile?

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

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


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


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


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


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

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

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


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


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


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


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


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

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

When Are Healthcare Providers Required to Use Respirators?

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

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


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

 High Velocity Fit Testing

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

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

Respiratory Protection is Smart

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

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

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

By John Defillippo, CHMP

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

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

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

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

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


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


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


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

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

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

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

• Are you keeping up with its requirements?


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


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


• Do you know what OSHA considers “Hazardous”?


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


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

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

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

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

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