Environmental Health and Safety Blog | EHSWire

Based on the large numbers of folks who have read our PPE Top 5 Blogs, we can see that they are popular. So, here is the forth installment.

We are keeping those Field Tested Personal Protective Equipment (PPE) recommendations coming! Here is our third installment—again, all field tested and used by EHS professionals.

As promised, the staff at Emilcott is sharing their Top 5 Favorite Personal Protective Equipment (PPE) over the next few weeks or so, and these are field tested by EHS professionals, so the recommendations hold a little water.

We all like to use the beginning of a new year to take stock and evaluate the effectiveness of those things we do! It just lends itself to asking “Why?” and “Is there a better way?”. So—maybe you are doing that with your own personal protective equipment (PPE), or even the effectiveness of your program at work. Maybe we can help!

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?

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!

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

Footwear

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.

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