Environmental Health and Safety Blog | EHSWire

by Bruce Groves

Through my membership with the New Jersey American Industrial Hygiene Association (NJ-AIHA), I had the opportunity to make a presentation at the New Jersey Clean Air Council’s (NJCAC) annual meeting on April 13 ^th.   This particular meeting sounded intriguing as it would be focusing on a topic of great interest to me – a technical dialogue on how to measure and identify the effect of air pollution (and other environmental stressors) on the cumulative health issues of the public. The meeting aimed to bring professionals from varying disciplines to discuss technical approaches, academic research and general opinions on how to reduce this pollution and therefore improve the health of the affected populations.  

The meeting lasted a full day with contributing presentations from a dozen or so professionals. There were 15 NJCAC Board members at the meeting and 50+ attendees comprised of 11 presenters, NJDEP staff, and members of the public.  As a presenter, we were each given about 20 minutes to make our points regarding specific urban populations that have inordinately higher exposure to air contaminants as compared to people living and working in “cleaner” urban, suburban and rural areas of the state.  The majority of the presentations concluded that there are neighborhoods where pollution levels are chronically and significantly high.  Presented evidence also linked higher incidences of illnesses and disease with these cumulative exposures to contaminants and other environmental (and social) stressors.  

Bob Martin, the NJDEP Commissioner, gave an introductory presentation outlining current and future regulatory initiatives for reducing air pollution in New Jersey. One plan is to ban older diesel equipment in areas that do not have effective emission controls.  Joe Suchecki, a representative of the Engine Manufacturers Association, correspondingly, presented convincing evidence that new diesel technology does not create air pollution problems.  The trick now is to get all the older diesel equipment off all the roads and construction sites replaced by either new equipment or equipment retrofitted to control air emissions.

Ana Baptista, PhD, gave an excellent presentation on the high levels of pollution in the Newark Ironbound district and the resulting links to disease in the residential population resulting from cumulative exposure to these contaminants.  Dr. Robert Laumbach gave a similar presentation about future research that he is leading to test people who live in the Ironbound in an attempt to prove this link of air pollution exposure to increased illness and disease.

My own presentation discussed Emilcott’s experience measuring local air pollution (particulates and vapors) and other environmental parameters (noise, wind speed and direction) using the Greenlight Environmental Monitoring System which collects, in real-time, data for particulates (at multiple particle size ranges) and vapors, coupled with data of wind speed and direction, to identify emission sources and measure their impact on local air pollution.  We have found that “what is measured, improves”, and by using this sophisticated and integrated air monitoring approach, identified emission sources can be controlled to make immediate and sustainable improvements to the local air quality. 

Overall, excellent information was presented, reinforcing the fact that the air quality in much of New Jersey is not very good and, in certain areas (usually in disadvantaged urban neighborhoods), it is extremely poor.    And, residents living in zones with the worst air pollution also show some link to increased disease and illness.     

I left the NJCAC annual meeting knowing that solid academic work was underway to prove that high levels of air pollution causes disease.  What was missing was evidence that effective, short-term actions are being taken, to reduce the levels of pollution and contaminant exposure in these areas to improve overall health for the resident population.

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Topics: indoor air quality, health and safety, General EHS, Air Monitoring, Air Sampling, environmental air monitoring, Public Safety, cumuluative health, perimeter air monitoring, air pollution

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

Paula Kaufmann, CIH

It’s time for an update on the EPA’s proposed changes to the Inventory Update Reporting Rule.  As of January 24, 2011, the EPA has been silent as to what changes will be included in the final rule.  A list of the proposed changes is presented on the Emilcott EHSWire.com blog: “ EPA Proposed Changes to the TSCA Inventory Update Rule ” .  

The EPA has stated that the Agency “expects to finalize the modifications to the chemical information reporting rule in time for the next reporting period, scheduled for June 1 - Sept. 30, 2011. EPA will make the electronic reporting software and associated guidance materials available before the start of the submission period.”  If you’re like me, “expects to finalize” is not very helpful for planning purposes or for engendering confidence.

Pull out the professional crystal ball!

As someone who has been working with the EPA for a long time, I am “reading between the regulatory lines” to forecast that the final rule will be published in April.  I’ve based this guess on information provided at the EPA's November webinar that introduced the new, electronic TSCA Reporting Tool, e-IURweb:

• During the question and answer period  an EPA representative said that the final rule should be published in the Spring 2011-- at least 30 days prior to the start of the reporting period.  So… if the reporting period starts on June 1, then I expect the final rule to be published by May 1st at the latest.


• The electronic tool designers said that a test version of the tool would be available for industry testing in April 2011.  (Emilcott will be posting a blog about this new tool in the next few weeks.)

What to do while we wait for the final rule to be published?

We are advising Emilcott clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Additional data that may be needed for the 2011 reporting are listed below.  Depending upon how you gather your information, you may want to request this along with the import or manufacturing volume information.

• Production volumes at or above 25,000 lbs directly exported and not domestically processed or used.


• All quantities of substances subject to rules and orders in the following sections:
  
  
  
  • Section 5(a)(2) Significant New Use Rules (SNURs)
  
  
  • Section 5(b)(4) Chemicals of concern to EPA
  
  
  • Section 6 Prohibitions for chemicals with unreasonable risks
  
  
  • Section 5(e) Requirements or restrictions on chemical production or use
  
  
  • Section 5(f) Chemical with an unreasonable risk
  
  
  
  

What to do if you need help?

If you need assistance related to the TSCA New Chemicals regulatory requirements or the potential changes due to the Inventory Update Reporting Rule, Emilcott can guide you through the reporting. We can also help you navigate the maze of  reporting a potential Form U violation from prior filing years to the EPA (See http://www.emilcott.com/services/svcenvcompliance.asp).  As more information becomes available from the EPA regarding the IUR and as testing of the electronic tool begins, Emilcott will keep you up-to-date via EHSWire and our “Regulatory Updates” Newsletter. If you have any TSCA IUR questions or concerns, feel free to contact Emilcott or post your question below!

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Topics: EPA, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, IUR, chemical manufacturer, chemicals, Public Safety, reporting tool, Toxics Release Inventory, inventory update rule

Bruce Groves

Why do we care about particles floating around in our air? Small, inhalable particles are themselves pollutants that have shown to cause illness and chronic diseases such as asthma and certain types of lung cancer . Particles are also excellent indicators (or surrogates) for measuring other pollutants such as vapors and gases. By measuring the aerodynamic size of particles in our air, it is possible to identify and sometimes “fingerprint” them so that we can reduce or stop local sources of pollution immediately. The goal AND end result are to develop as clean a living and working area as possible.

What are we doing today?

Today, air monitoring is a piecemeal approach that is government-mandated but generally project related. When the project is over, the problem is essentially considered to be gone. Of course, in areas of high population density or industrial activity, continuous, real-time air monitoring of general conditions does not exist. Other than pollen counts, very little information about these pockets of high pollution and high particulates is available to the public or government agencies. And, the data that is available is generally much later and does not present an accurate picture of today’s problem.

What is the future in environmental air monitoring?

As technology has improved, so have particle detectors and the ease of data transmission and analysis. By 2013, small particle size detectors, such as those found in the Greenlight Environmental Monitoring System, will be consistently deployed in high population areas in such cities such as NYC, Tokyo, London and Los Angeles. These particle size detectors will be coupled with wind-speed and direction detectors and web cameras to pinpoint the exact sources of particle emissions (e.g., construction or industrial equipment, idling vehicles or high traffic transportation corridors) that are creating a measurable increase in local air pollution.

This web of detector stations will form an active or “live” map of a city that continuously measures and reports the concentration of various particle sizes. The “map” will be automatically programmed to provide warning levels and alarms to reveal when and where total particle concentrations exceed warning and safe threshold levels. By locating (in real time) the place, the direction of the pollution source and supporting video evidence, private companies and government agencies can take measures to stop or reduce the indicated pollution sources. Constant real-time monitoring, assessment and action will provide continuous improvement in local air quality that will reduce the onset of disease associated with inhaling dirty air. Warning systems set up through websites will enable agencies and individuals to check on their local air pollution conditions using their computer or smart phone.

What is the first step?

At Emilcott, we have been working with particulate monitoring on job sites for over 25 years. As an extension of our field experience, we’re working on a solution that meets the needs of our clients (private companies and government agencies) -- the Greenlight Environmental Monitoring System. With multiple project implementations under its belt, the Greenlight System’s particle size measurement, assessment and reporting capabilities are demonstrating how real-time monitoring is helping projects get cleaner each day – reducing the liabilities of our clients while giving them the information to keep the public and workers safe.

As the Greenlight System’s next phase of engineering development is outlined, our goal is to have a universal system that will provide comprehensive sampling in potentially high pollution areas so that neighborhood air quality can be improved and the incidence of lung disease is reduced. It will be a future watchdog for providing cleaner air locally where no such means of protecting local air quality exists today.

What do you think the future of environmental air monitoring holds? What are the benefits or challenges that you associate with monitoring and mapping pollutants in a broad geographic area?

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Topics: Emilcott, indoor air quality, health and safety, Construction H&S, EPA, Emergency Response, Homeland Security, Hazardous Waste Management, Hazardous Materials, worker safety, Occupational Health, Air Sampling, Greenlight System, Exposure, environmental air monitoring, Respiratory, Public Safety, perimeter air monitoring

Paula Kaufmann, CIH

I just read an article in the New York Times ( Hazards: Watch Where You Point That Laser) about a 15-year boy who bought a laser pointer on the Internet.  He selected this particular model as the light was supposed to be powerful enough pop balloons and burn holes in fabric.  And, it was all he had hoped for and more.  He popped balloons from a distance and burnt holes in his sister’s sneakers.  However, he literally got burned by the “and more” features of his new toy. Tragically, he shined the pointer in a mirror and the light beam reflected back onto one of his eyes causing major damage. 

My first thought was, “How stupid was that”.  My second thought was more balanced, “I guess he wasn’t properly trained or didn’t read the instructions”.  I’ve been told by loved ones that I can be a bit intrusive (if not annoying) with my unconscious monitoring of unsafe behavior in my constant role of “health and safety inspector”.  So be it!  According to the Home Safety Council, every year there are millions of preventable home-related incidents and accidents “ that result in nearly 20,000 deaths and 21 million medical visits”.  

Here are some examples of what I consider stupid (or let’s say shortsighted) actions -- some at work, some at home. Yes, I make these observations all the time to family and friends and, as you can imagine, that can be a bit trying for them but I feel it’s worth the price.

• Using an electric lawn mower on a damp lawn with damaged extension cords repaired with electrical tape AND with the ground prong clipped. Worse yet – asking my child to use this dangerous setup!


• Removing the guard from a circular saw.


• Cutting overhead branches without wearing a hard hat or eye protection.


• Smoking a cigarette, cigar or pipe while filling a car with gas. Worse yet – a gas station attendants smoking cigarettes while pumping gas.


• Construction or utility workers using a jack hammer on a concrete sidewalk and not wearing safety glasses or hearing protection while wearing a hard hat.


• Police directing traffic without wearing a traffic safety vest. Worse yet – doing this after dark in a dark uniform without white gloves.


• Mowing the lawn in sandals and shorts without eye protection while listening to music at full volume (using earphones not noise reducing hearing protection).


• Eating snacks while removing paint from old furniture or woodwork in a house built before WW I, which makes the lead content highly probable.  Worse yet – having your kids help you while you dry sweep or use a regular household vacuum to “clean up” the area.


• Utility worker serving as a confined space watch (at the ground level of an underground manway) talking (and laughing) on a cell phone and drinking coffee (usually about 10 feet from the manway).


• Nail salon workers wearing dust masks while applying acrylics to customers’ nails -- dust masks don’t reduce exposure to the chemicals used during acrylic application. Worse yet - acrylic nail services happening in a tiny storefront with limited ventilation.


• Being “careful” when installing an electrical light by shutting off the switch to the power but not the circuit breaker to the line.


• Applying insect repellant from an aerosol can while sitting by a bonfire.


• Removing a bicycle helmet as soon as your mom can’t see you as it is just too hot to protect your brain.

And, finally, one of my favorite tales is the time that I was away from home on a business trip, and while I was gone, my husband renovated my home office space.  He did a beautiful job, but when I asked him why he went through the effort to surprise me, he said “It is so much easier to get work done when the OSHA inspector is not home”.  I just wish I could have given him a citation.

If you’re interested in home safety, September – National Preparedness Month -- is a good time to begin.  You can start with a visit the website of the Home Safety Council® (HSC), a national nonprofit organization dedicated to preventing home-related injuries. You’ll  find dozens of tips, stories and videos and information about Safety Saturday (September 25) at participating Lowe’s stores.

What are some of your favorite observations of “stupid” health and safety practices outside of the work environment? And, if you’re a health and safety professional, how do you balance maintaining a safe home life without driving your friends and family crazy?

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Topics: health and safety, General Industry H&S, General EHS, Emergency Response, worker safety, Occupational Safety, emergency response training, Fire Safety, Public Safety, water safety, industrial hygiene, home safety

Tom Carlson, PE, Sr. Project Manager

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Topics: OSHA, indoor air quality, Personal Protective Equipment, health and safety, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, Respiratory, Public Safety

Dian Cucchisi, PhD, CHMM

The Bhopal Disaster has been in the news again with the eight former company executives getting convicted of negligence.     A court in the Indian city of Bhopal returned the verdict on June 7, 2010, more than 25 years after the incident. 

What was the Bhopal Disaster?

For those of us old enough to remember, the words “Bhopal, India” brings to mind the very tragic events of December 2, 1984.  On that day a Union Carbide facility had an accidental release of approximately 40 tons of methyl isocyanate, a chemical used in pesticides.  The chemical plume killed 3,000 people and left an estimated 500,000 people with long-term, damaging health effects.  Amnesty International reports that approximately 15,000 people died in the subsequent years as a result of this incident.  As a result the Union Carbide Bhopal accident is often considered the world's worst industrial disaster.

And then a smaller, but similar event occurred in the USA…

In August 1985 a Union Carbide facility located in Institute, West Virginia experienced an accidental release of toxic chemicals causing more than 100 residents of the area to seek medical treatment.

US Regulators Respond to Community Concerns

In response to these incidents and the growing concern by the American public that this could happen in their backyard, regulatory agencies enacted laws for facilities that manufacture, store, or use certain chemicals above designated threshold quantities.

In 1986 the United States Congress passed the Emergency Planning and Community Right to Know Act (EPCRA). The law requires facilities to annually report the quantities of “extremely hazardous substances” to the facility’s state and the Local Emergency Planning Committee (LEPC).  This information is available to any member of the public upon request to the LEPC.

In late 1985, the Occupational Safety and Health Administration (OSHA) created the Hazard Communication Standard (HCS) (29 CFR 1910.1200) also known as “Right to Know.”  The HCS requires manufacturers and distributors of hazardous materials to communicate to employees the hazards of the chemicals in their workplace by providing Material Safety Data Sheets (MSDS) and ensure that hazardous materials are labeled according to certain requirements.

The Clean Air Act was amended by Congress in 1990, including some regulatory changes intending to create safer workplaces and mitigate the risk of a Bhopal-like disaster in the US, such as:

• Charging the EPA and OSHA with more authority over the chemical industry.
  
  
  
  • OSHA created the Process Safety Management Standard (29 CFR 1910.119), a program that looks in depth at process technologies, procedures and management practices.
  
  
  • The EPA codified Chemical Accident Prevention Provisions (40 CFR Part 68) which requires facilities to conduct a hazard assessment, develop a prevention program, and implement a risk management plan.
  
  
  • Other laws that regulate the use of hazardous materials were enhanced.  These include the Toxic Substance Control Act (TSCA); the Resource, Conservation and Recovery Act (RCRA); and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
  
  
  
  


• Creating the U.S. Chemical Safety and Hazard Investigation Board (CSB). 

The Senate legislative history states: "The principal role of the new chemical safety board is to investigate accidents to determine the conditions and circumstances which led up to the event and to identify the cause or causes so that similar events might be prevented." Congress gave the CSB a unique statutory mission and provided in law that no other agency or executive branch official may direct the activities of the Board. Congress directed that the CSB's investigative function be completely independent of the rulemaking, inspection, and enforcement authorities of EPA and OSHA. The CSB became operational in January 1998.  

Accidents in the U.S. STILL OCCUR

In spite of this, accidents continue to happen.  In 2002, the Chemical Safety and Hazard Investigation Board (CSB) examined 167 chemical accidents that occurred between 1980 and 2001.  More than half of those accidents involved chemicals not covered by the regulations mentioned above.  The CSB recommended that the EPA and OSHA expand their regulations.  The Agencies did not agree with the recommendation stating they feel the best approach is worker education.  In 2004, OSHA formed an alliance with the EPA, the American Chemistry Council (ACC), and others to develop and provide worker education on chemical reactivity hazards. 

How do you feel about the expansion of regulations to include chemicals currently not covered by regulations designed to prevent accidents and reduce health risk?

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Topics: OSHA, health and safety, General Industry H&S, EPA, Emergency Response, H&S Training, Compliance, TSCA & R.E.A.C.H., Air Sampling, emergency response training, Exposure, environmental air monitoring, Respiratory, Public Safety

Dale Wilson, CIH, LEED AP


“Vapor intrusion refers to this migration of volatile chemicals from the subsurface into overlying buildings.”  Vapor intrusion (VI) air sampling is a method to evaluate if chemical vapors are entering a building due to contaminated soil or groundwater that is on or adjacent to the property on which the building is built. In order for vapors to enter a building from the soil or groundwater there have to be pathways such as  cracks in the foundation, openings around piping used for mechanical, pluming, and electrical systems, groundwater entering the basement just to name a few. Once vapors are in a basement or crawlspace, there have to be additional pathways for the vapors to enter the first floor occupied space. 

When it comes to vapor intrusion understanding “why it is happening” is just as important as understanding “what is happening”.

What is Vapor Intrusion?

“Vapor intrusion has become a significant environmental issue for regulators, industry leaders, and concerned residents. Degradation of the indoor air quality can cause fear and anxiety among building occupants, businesses, and other property owners.”

A Vapor Intrusion Project

Recently, Emilcott was hired to review vapor intrusion air sampling data collected by another consultant.  The building site was a large commercial property that was mostly composed of office space, but there was also an onsite daycare center.  After collecting data for several years, the vapor intrusion had not been resolved. 

After reviewing all the data, we made a site visit to help us understand what was contributing to the continued and increased vapor concentrations -- both in the basement of the building, which was used for storage, and in the first floor daycare center.   

Our initial site visit revealed multiple pathways that permitted vapors to enter the basement and additional pathways that permitted vapors to enter the first floor occupied space.  It was clear that the owner’s other consultant had focused on What Is Happening through continuous air sampling without understanding the dynamics of Why It Is Happening.  Based upon

• An analysis of the collected air monitoring data,


• A thorough site inspection, and


• An understanding of vapor intrusion causes and migration,

we were able to propose a step-by-step procedure to protect the client’s building and occupants. In addition, by including the client in the process, the client stated that they had learned more about the building from our visit than they had over the several years of data collection.

Vapor Intrusion – A Way Out

When reviewing a VI problem with a building owner or property manager, indoor air quality consultants should have answers to these basic questions to fully understand the problem and suggest a remediation solution:

1. What are the volatile chemicals that we are dealing with?


2. What are the risks of short-term and prolonged exposure to these chemicals?


3. Why and where are they getting into my building?


4. Can I stop the VI chemicals from getting in?


5. If I can’t stop the VI chemicals from getting in, what are the alternatives?

Interrupting and sealing the pathways is the only way to prevent building occupants from exposure to vapors. 

For our client the process of sealing pathways has been accelerated and should be complete in a few weeks.  With the complete understanding of vapor intrusion What? and Why?, a plan to seal the pathways between the ground and the basement, and the basement and the first floor, may reduce the occupants’ exposures to the vapors and avoid any increased levels of regulatory oversight and accelerated response actions.

Have you experienced a vapor intrusion problem that remains unresolved or puzzled the experts? Do you have questions about indoor air quality issues and evaluation techniques and best practices? Please share your story or questions below and we’ll respond quickly.

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Topics: indoor air quality, General Industry H&S, Construction H&S, Air Sampling, environmental air monitoring, Public Safety

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tp://ehswire.com/writers/">John DeFillippo, CHMP

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Topics: health and safety, General Industry H&S, Construction H&S, worker safety, Occupational Health, Public Safety

Topics: Emilcott, indoor air quality, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, worker safety, Lab Safety & Electrical, Fire Safety, Public Safety, Working Green