EPA Makes Final Rule to Update RMP Requirements

EPA Makes Final Rule to Update RMP Requirements

EPA has issued a change to its Risk Management Program, or RMP regulations for those who process, produce, handle or store hazardous substances or chemicals.  The changes are in an amendment to the rule, officially called the Safer Communities by Chemical Accident Prevention, or SCCAP.  These new rules hope to help increase protection for human health and environment from chemical hazards using lessons learned and process safety procedures.

First, What’s RMP?

RMP can be found in EPA’s Clean Air Act.  If you produce, process, handle or store one of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities, then you fall under RMP requirements.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

Water treatment plants, agricultural COOPs and chemical manufacturers are typical types of companies who need to comply with RMP.

RMPs must include:

  • Hazard assessments
  • Potential effects of a chemical accident
  • 5-year accident history
  • Evaluation of worst-case scenarios and alternative accident release potentials
  • Prevention programs that include safety precautions, maintenance, monitoring, and employee training measures
  • Emergency response program that lists emergency health care, employee training measures, procedures for informing the public.

RMPs are similar to OSHA’s Process Safety Management (PSM) standard, but RMP is concerned with protecting the environment and human health while PSM is focused on protecting the worker.  Unlike PSM, RMPs are directly submitted to EPA and information is input into a public database for transparency purposes.

Program Levels

A number of the changes are related to specific program levels of RMP.  There are 3 levels to RMP:

Program 1

Processes which would not affect the public in the case of a worst-case release and with no accidents with specific offsite consequences within the past five years.  These sites have limited hazard assessment and minimal prevention and emergency response requirements.

Program 3: 

This is for processes not eligible for Program 1 and are either subject to OSHA’s PSM standard or have one of 10 specified North American Industrial Classification System (NAICS) codes (NAICS code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532).  This program requires using OSHA’s PSM standard as your prevention program plus there are additional hazard assessment, management, and emergency response requirements.

Program 2:

If you don’t fit into Program 1 or 3, then you are a Program 2.  This program imposes streamlined prevention program requirements, as well as additional hazard assessment, management, and emergency response requirements.

The Rule Changes

Emergency Response

  • RMP facilities must develop procedures for informing the public about accidental releases.
  • Release notification data must be provided to local responders.
  • A community notification system must be in place for RMP-reportable accidents.
  • Field exercises must be conducted every 10 years unless local responders indicate that’s infeasible.
  • Emergency response exercises are to follow mandatory scope and reporting requirements.

Third-Party Compliance Audits

  • A third-party must do the next scheduled compliance audit when an RMP-regulated facility experiences two RMP-reportable accidents within five years or when a Program 3 facility under NAICS 324 or 325 has one reportable accident within one year AND that facility sits within one mile of another NAICS 324 or 325 process facility.

Program Requirements

  • Facility siting must be considered in Program 2 hazard reviews and Program 3 process hazard analyses.
  • When facilities have a reportable accident, a formal root cause analysis incident investigation must be conducted.
  • Program 2 hazard reviews and Program 3 process hazard analyses must now address natural hazards (including those resulting from climate change) and power losses.
  • Whenever a recommendation from a hazard evaluation, facility siting, or a third-party compliance audit is not adopted, a justification needs to be put into the RMP.

Employee Participation

  • Employee participation is required in resolving process hazard analyses, compliance audit and incident investigation recommendations and findings.
  • Employee participation is required for stop work procedures in Program 3.
  • Program 2 and 3 sites must provide opportunities for employees to anonymously report RMP accidents or issues of non-compliance.

Safer Technologies and Alternatives Analysis (STAA)

  • A STAA evaluation is required for all Program 3 NAICS 324 and 325 processes.
  • A Practicability assessment of inherently safer technologies and designs (IST/ISD) should be considered if your process falls within one of these conditions:
    • It’s a Program 3 under NAICS 324 and 325 within one mile of another Program 3 NAICS 324 or 325 process,
    • It’s a process under NAICS 324 using with hydrofluoric acid alkylation,
    • You’ve had one RMP accident since the facility’s most recent process hazard analysis.
  • Implement at least one passive measure at the facility, or IST/ISD, or a combination of active and procedural measures equivalent to or greater than the risk reduction of a passive measure for the same facilities required to conduct the practicability assessment.
  • When STAA recommendations are not adopted, then you must provide justification.

Communication

  • The facility must now provide chemical hazard information, upon request, to residents living within 6 miles of the facility in the language they request.

Other

  • Hot work permits must be kept for 3 years.
  • Program 2 and Program 3 requirements should be consistent for recognized and generally accepted good engineering practices.
  • Program 3 process safety info must be kept up to date.

Compliance Dates

The SCCAP is effective May 10, 2024.  There are two separate compliance dates.  Emergency response field exercise frequencies are due by March 15, 2027, or within 10 years of the date of an emergency response field exercise conducted between March 15, 2017 and August 31, 2022.

The following items are due three years after Final Rule publication (May 10, 2027)

  • Root cause analyses
  • Third-party compliance audits
  • Safer Technologies and Alternatives Analysis (STAA)
  • Employee participation
  • Emergency response public notification
  • Exercise evaluation reports

More Information

If you have questions or need assistance in determining if your facility is required to comply with RMP, or if you need help getting one setup, contact us!

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Grade D Breathing Air:  What Requirements Do I Have to Meet for My Breathing Air System?

Grade D Breathing Air: What Requirements Do I Have to Meet for My Breathing Air System?

Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air and then we’ll cover what its OSHA requirements are.

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility.  Some of the most common include:paint booth worker

  • Confined Space Entry
  • Sand/Media Blasting Operations
  • Working in Paint Booths
  • Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following:breathing testing

  • Oxygen content percentage by volume: Between 19.5% and 23.5%
  • Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
  • Carbon monoxide: maximum of 10 parts per million by volume
  • Carbon dioxide: maximum of 1000 parts per million by volume
  • Lack of noticeable odor

This breathing air gases are also commonly referred to as Grade D breathing air.  There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

Questions?  Need Help?

iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients.  We can also help you with the other breathing air system requirements of OSHA.  Contact us today!

Need Help?

iSi can help with Grade D breathing air testing, required written plans, training and more! 

Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air components, then we’ll cover its OSHA requirements.

paint booth worker

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility.  Some of the most common include:

  • Confined Space Entry
  • Sand/Media Blasting Operations
  • Working in Paint Booths
  • Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following:

  • Oxygen content percentage by volume: Between 19.5% and 23.5%
  • Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
  • Carbon monoxide: maximum of 10 parts per million by volume
  • Carbon dioxide: maximum of 1000 parts per million by volume
  • Lack of noticeable odor

breathing testing

This breathing air gases are also commonly referred to as Grade D breathing air.  There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

Questions?  Need Help?

iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients.  We can also help you with the other breathing air system requirements of OSHA.  Contact us today!

Need Help?

iSi can help with Grade D breathing air testing, required written plans, training and more! 

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

Keith brings over 20 years of industrial hygiene and safety experience to iSi and its clients. An industrial hygienist, Keith jokes that he "sucks air for a living."  He specializes in workplace exposure testing and sampling strategies, safety compliance, ergonomics and training in a variety of topics in both the industrial hygiene and safety field.

Email  |  LinkedIn

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EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

EPA has issued Final Rule updates to 40 CFR Part 63, subpart HHHHHH, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.  This NESHAP standard applies to companies coating miscellaneous parts/products made of metal, plastic or a combination, anyone stripping paint using methylene chloride, or conducting motor vehicle/mobile equipment refinishing.

EPA issued the changes as part of its technology review.  They didn’t find any new developments in practices, processes or controls that warranted changing existing rules, but they did decide to take the opportunity to update and clarify some of the items in the current requirements.

Here is a summary of what has changed in the regulation:

Electronic Reporting

Rather than mailing reports to EPA, you will now be required to be submit electronically through the CEDRI/CDX platform.  This includes initial notifications, notifications of compliance status changes, annual notification of changes reports and the report required in 40 CFR 63.11176(b).

HAP Content

EPA updated the definition of a “target HAP containing coating” to clarify that compliance is based on the hazardous air pollutant (HAP) content of the coating applied to the part, not the content purchased.

Spray Gun Cups and Liners

For spray guns with disposable cap liners, EPA amended “spray-applied coating operations” to clarify that the allowance to use spray guns outside of a spray booth is based on the volume of the spray gun cup liner, not volume of the cup itself.  They also clarified that repeatedly refilling and reusing the 3.0 fl. oz. cup or cup liner, and/or using multiple liners for a single spray-applied coating operation will be considered trying to circumvent the regulation and you can be fined for this.

Exemptions Became Easier

If motor vehicle/mobile equipment spray coating operations don’t spray apply coatings that contain the target HAP, rather than the current petition for exemption process, the rule now allows companies to submit notifications to the Administrator.  This process is meant to be simplified and easier.  All records to support the notification shall still be kept as a backup to support the notification, but those records don’t need to be sent to the administrator.

Military Equipment: Tanks and Submarines

The NESHAP no longer applies to surface coating or paint stripping on tanks and submarines when that work is conducted onsite at military installations, NASA, or at the National Nuclear Security Administration.  It also doesn’t apply when conducted offsite where military munitions or equipment are manufactured by or for the Armed Forces and that equipment is directly and exclusively used for the purposes of transporting military munitions.

OSHA Carcinogen References

EPA removed references to OSHA’s carcinogens because OSHA no longer spells out what those are.  Instead, EPA will be putting in their own list.  These will include target HAPs that must be counted if they’re present at 0.1% by mass or greater.  All other HAPs will be counted if present at 1.0% or greater by mass.

No Non-HAP Solvents

The term “Non-HAP solvent” will be removed because there’s no requirement in the standard to use them and there is no other place where this is used.

Filter Test Method

EPA updated the spray booth filter test method to the most recent ASHRAE method, ANSI/ASHRAE Standard 52.2-2017 Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size.  The standard also now includes a reference to EPA Method 319-Determination of Filtration Efficiency for Paint Overspray Arrestors as an alternative method.  EPA Method 319 is the same one referenced in the NESHAP for Aerospace Manufacturing and Rework to test paint spray booth filters for hexavalent chromium emissions.

For more information about changes to the rule, you can find the final rule in its entirety here.

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Sustainability is Much More Than Just Being Green

Sustainability is Much More Than Just Being Green

Sustainability…that’s a word that’s been thrown around a lot within the past few years and to many it may conjure images of recycling and being a good environmental steward.  However, sustainability is more than just that environmental “stuff,” it’s actually much broader and you can count a lot of different practices towards it.

Sustainability can be defined as what your company is doing to contribute to society in terms of social responsibility, economic growth, AND environmental protection.  It’s what your company is doing to ensure you are adding value to society by how you manage resources, interact with your community, and work with your employees while staying profitable to sustain jobs for your community.

Large corporations have entire teams dedicated to sustainability strategies.  Medium and small companies are soon going to need to develop sustainability strategies in order to keep up.  Suppliers are already being asked to implement and start showing their own sustainable actions.  It’s not a matter of if sustainability will need to be addressed by your company, it’s when.


Goals of Sustainability

The goal of sustainability is to ensure your company is being a sustainable resource that’s in a way profitable for everyone.  It needs to ensure:

  • Customers will want to buy from you.
  • People will want to work for you.
  • Other businesses will want to do business with you.
  • The community will want to have you there.
  • You’re doing what you need to do to protect natural resources and the environment.
  • You’re finding ways to improve efficiencies and lower risk.


Sustainability Areas

There are a number of areas in your company where you can find and develop sustainable practices.  These include:

  • Community Involvement: How your company is making the community(ies) you’re located in a better place to live.  How do you contribute to improving your community, how do you affect its culture and be a good economic source of jobs?
  • Employment Practices: Being a good place to work by promoting personal and professional development, diversity, empowerment and participation from your employees.

  • Business Relationships: Engaging in fair-trading practices with suppliers, distributors and partners.
  • Morality and Ethics: Setting ethical standards and practices in place for working with all persons who have a stake in the success of your business.
  • Transparency: Timely communications with those affected by your company and being accountable to your internal and external customers.
  • Value of Products and Services: Providing a good quality product and/or service that adds value, while ensuring customer satisfaction.
  • Regulations Compliance: What you are doing to ensure you’re following all local, state, and federal regulations.
  • Resource Management: Managing resources efficiently, conscientiously and effectively.
  • Financial Return: Compensating providers of capital with a competitive return on their investment and protecting your company assets.
  • Protecting the Environment: Promoting restoration of the environment, finding ways to reduce waste, and sustainable development of products, processes, services and other activities.

Every department of your company can get involved to affect the process.  For example, it can start with Procurement finding raw materials with lower environmental impacts and socially-responsible suppliers, to Production devising processes that are more efficient while maintaining environmental and safety standards, to Marketing who can look at how sales and distribution methods can reduce adverse social and economic impacts.


What Can Sustainability Include?

Sustainability efforts can be internal or externally focused.  Some examples of each include:

Internal

  • Energy efficiency
  • Process innovations
  • Research and development
  • Plant certifications such as ISO 14001, 45001 and 9001
  • Process Safety Management
  • Audits for environmental standards and practices
  • Employee programs and benefits
  • Training
  • Assessing impacts of new or expected regulations and auditing areas of potential noncompliance
  • Minimizing liabilities
  • Standardizing systems and measures

External

  • Community involvement and philanthropy
  • Regulations compliance
  • Supplier audits and requirements for work practices
  • Supplier certification requirements
  • Public disclosure of sustainability reporting
  • Including sustainability information in shareholder documents
  • New market opportunities and sustainable or environmentally-affected product advances
  • Waste minimization
  • Social policy statements/guidelines
  • Environmental policies
  • Avoiding creating contamination


Other Applicable ISO Standards

There are ISO standards for other items that would be included in sustainability efforts.

There is an ISO 50001 for Energy Management.  Its focus is on how to improve energy use through the development of an energy management system.  This management system is the same used for ISO 14001 and 9001.

There is also a standard for social responsibility, ISO 26000.  ISO 26000 is a guidance only and cannot be certified like other ISO standards.  This standard helps clarify what social responsibility is and gives best practices relating to social responsibility globally.


Where Do You Start?

Just saying you’re committed to sustainability isn’t going to make it happen.  You need to incorporate it into your company culture.  Very much like any effective safety program, this too needs to start with support from top management and become an expectation that trickles down into each and every part of your company until it becomes a part of your corporate culture.

First, you need to decide how sustainable you want to be and what resources you want to dedicate to it.  Decide which areas you want to tackle.  For it to be successful what you choose to do needs to make financial sense and fit well with your company culture, your products, your location, and/or your customers.

Take a look at what you’re already doing.  What else can be done?  What are the costs and benefits of what you could do?  How can future costs be impacted by improvements you can make today?

Are there companies that you are working for who are requiring (or considering) requiring sustainability efforts?  What are those?  Are certain certifications such as the ISO 14001 environmental management system going to be required?  We are finding that many companies, especially those who work globally, are starting to require suppliers to get ISO certifications like the ISO 14001 because they are a recognized standard for implementing an overall environmental management system. 

ISO certifications have a set framework that looks at internal and external policies, communications and procedures.  Certification also helps demonstrate you are committed to putting standards and procedures in place to comply with regulations.  Once you’ve been through one ISO certification, you’ll find the others are very similar, including the ISO 45001 certification for safety because it uses many of the same methods.

Once you decide what you want to do, how far you want to go, and what your budget is going to be, then you’ll need to get different stakeholders involved.  You can have an outside company help you get organized, or you can develop your own in-house team.  Some companies have created internal committees like they do with safety committees, and some have hired full-time sustainability managers to make sure the effort stays on track.


How Do You Track Success?

Sustainability isn’t like sales or other goals your company is used to tracking, it can be hard to put a metric to it.  Sustainability is often a long-term goal and harder to predict.  It is sometimes harder to implement than other goals because it can be more abstract, but nonetheless important.

Besides typical measures like waste reductions, energy savings, and cost savings, there are other metrics that can be counted towards sustainability.  These could include metrics such as

  • Recycling savings;
  • Training expense per employee;
  • Number of sites with environmental or safety certifications;
  • On-time delivery;
  • Number of jobs posted and filled internally;
  • EHS capital expenditures;
  • Number of customer complaints;
  • Positive reviews;
  • Purchases from minority businesses; and,
  • Number of workers participating in industry or community organizations.


In Conclusion

We at iSi are already hearing that some of our major clients are looking to requiring their suppliers to have sustainability programs in place.  We have also had to start developing specific programs related to social issues, not just compliance issues any more.

It looks like sustainability is here to stay and will only continue to grow as an expectation.  iSi has a number of services in place to help you with your sustainability efforts and we are here to help in any way we can.


Learn more about the sustainability services iSi can help you with here
.

iSi's Sustainability Services

iSi can help you get several internal and external sustainability tasks accomplished, including all of the ISO standards listed and more.  Check out where we may be able to help you by visiting our Sustainability page.

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Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

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Let iSi help you determine what to do about ototoxic chemicals and noise exposures at your facility!

The effects of chemical exposures in the workplace has been highly documented.  Chemicals can affect you when you breathe them in, ingest them, inject them or absorb them through your skin.  However, did you know that chemicals can cause hearing loss too?

What is Ototoxicity?

Chemicals which can contribute to hearing loss are called “ototoxicants” and the hearing loss itself is considered to be “ototoxicity.”  Ototoxic chemicals reach the inner ear, connected pathways and nerve fibers through the blood stream or through the ear’s hair cells.  Hearing losses can range from sound distortion to the inability to detect two sounds with similar frequencies to inabilities to detect time gaps between sounds or localize sound.

The problem increases when there is a noise exposure combined with the exposure to an ototoxicant.  Ototoxic chemicals make a bigger impact on noise exposure, especially impulse noise.  Ototoxic chemicals plus noise becomes worse than just the noise alone or the chemical alone.   The noise levels do not even need to be above OSHA’s Permissible Exposure Limit (PEL) standards.  It’s the combination of the two which causes the greatest damage.

Which Chemicals Are Considered Ototoxic?

  • Pharmaceuticals: aspirin, some antibiotics, NSAIDs, loop diuretics
  • Tobacco smoke
  • Solvents, degreasers and paints containing toluene, p-xylene, styrene, ethylbenzene, methylstyrene, trichlorethylene, carbon disulfide, n-propylbenzene or n-hexane
  • Carbon monoxide
  • Hydrogen cyanide
  • Nitriles: 3-butenenitrile, cis-2-pentenenitrile, acrylonitrile, cis-crotononitrile and 3,3’-iminodipropionitrile
  • Metals and compounds: mercury, lead, organic tin and germanium dioxide
  • Pesticides: pyrethroids, hexachlorobenzene, insecticides or organophosphates
  • Some limited research has also speculated arsenic, cadmium, halogenated hydrocarbons, bromates, alkylic compounds and manganese may also affect ototoxicity

Which Industries or Operations May be Affected?

  • Manufacturing
  • Construction
  • Printing
  • Painting
  • Fueling vehicles and aircrafts
  • Firefighting
  • Weapons firing (Military)
  • Pesticide spraying

How Do You Test for Otoxicity?

Determining whether you have the potential for this condition is primary.  First, conduct a risk assessment to determine if your operations could be affected. 

Check the Toxological Information section of the chemical’s Safety Data Sheet (SDS Section 11) to see if the chemical is considered a neurotoxicant.  If there is nothing listed in this section, often other clues can be found in the SDS such as general toxicity, nephrotoxicity or if the chemical produces reactive free radicals.

From there, exposure limits and thresholds are dependent on different factors such as the chemical itself, exposure routes, concentration, duration, noise exposure and individual risk factors such as age.  Workplace sampling will be able to help you quantify your exposures. 

Audiogram tests can show early onset of hearing impairments and threshold shifts.   However, they cannot tell you the difference between whether the impairment is noise-related or ototoxic-related.  If you have complaints of hearing loss, investigate whether ototoxicity could be a factor.

The American Conference of Governmental Industrial Hygienists (ACGIH) recommends periodic audiograms for those who have noise exposures combined with carbon monoxide, hydrogen cyanide lead and solvent mixtures.  When there’s not a noise exposure, ACGIH still recommends audiograms be used when workers have the potential to be exposed to ethylbenzene, styrene, toluene or xylene.

PPE and Training Requirements

Make sure you reduce the effects of ototoxic chemicals in your workplace either through controls such as isolation, limiting exposures, or eliminating unnecessary tasks, or through the use of PPE.  Conduct your PPE assessment per OSHA rules.  You may need to include proper hearing protection, as well as PPE which can prevent inhalation (respirators), or absorption through the skin (chemical gloves, arm sleeves, aprons).

If you have a potential for ototoxic chemical exposure, this also needs to be included in your Hazard Communication (HAZCOM) training. 

Does This Affect You?

Do you have the potential for ototoxicity in your workplace?  iSi can help you make that determination, conduct your risk assessment, and/or quantify your exposures through sampling.  Contact us today!

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

As a former corporate environmental, health and safety manager, Ryan has a vast experience in working with both environmental and safety compliance issues in multiple states.  His specialties include national and international dangerous goods transportation, hazardous waste, environmental compliance, industrial hygiene and safety compliance. He is also an ISO 14001 Lead Auditor.

Email 

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Update:  2020 Final Rule Adds to and Clarifies OSHA Beryllium Standard

Update: 2020 Final Rule Adds to and Clarifies OSHA Beryllium Standard

Need Help?

iSi can do the sampling, write your plan, and help with any other part of this new requirement!

OSHA’s beryllium exposure standard for general industry, construction and maritime has been in place since May 2018, with various enforcement dates for different requirements.  Included below are the major highlights of the standard as well as 2020 Final Rule updates due to become effective on September 14, 2020.

There are a number of requirements for companies with potential beryllium exposures. Do these apply to your company?

What is Beryllium?

Beryllium is a lightweight but strong metal used in aerospace, telecommunications, information technology, defense, medical, and nuclear industries. It can be found in various items such as brake systems, missile parts, guidance systems, welding, alloys in dental crowns and bridges, laser devices, heat shields, computer parts, x-rays, golf clubs, bicycles and more. Exposure to beryllium comes through inhalation and through contact.

What’s Required in OSHA’s Beryllium Exposure Standard?

Exposure Assessments and Limits

If your workers are expected to be exposed to beryllium, you must conduct an exposure assessment using performance or scheduled monitoring methods. There are standards for exposures:

  • Permissible exposure limit (PEL) to 0.2 micrograms per cubic meter, averaged over 8 hours;
  • A short-term exposure limit (STEL) of 2.0 micrograms per cubic meter over a 15 minute sampling period; and,
  • An action level of 0.1 micrograms per cubic meter, calculated as an 8-hour time weighted average.

NEW (2020)   The definitions of a confirmed positive case (including a clarification of time requirements for abnormal or borderline test results) have been updated.  

Written Exposure Control Plan

If workers will be exposed to beryllium, companies must prepare a written exposure control plan. It doesn’t matter if you’re over the above limits – if you have the potential exposure, you need a written plan. The plan must include a list of operations and job titles affected, procedures for minimizing cross contamination and keeping surfaces clean, required engineering controls/practices to be used, respiratory protection methods, required personal protective equipment (PPE), and procedures for handling contaminated PPE, clothing and respirators. The plan must be reviewed annually, updated as required, and available for employee review.

PPE

Companies must provide respiratory protection where exposure cannot be controlled and personal protective equipment separate from street clothing must be provided to limit skin contact.   For protective clothing, change rooms and showers are to be provided and used. These rooms and showers must be in place by March 11, 2019.  There are specific rules for PPE

NEW (2020)   OSHA did not intend for beryllium-related PPE to be worn in areas outside of beryllium work areas.  Thus, it’s important for employers to determine what their beryllium work areas are, that is, where is there a potential for dermal contact and airborne impact and then act accordingly with PPE.  Employees who could reasonably be expected to have airborne exposure to and/or skin contact with soluble beryllium, beryllium solutions, or visible beryllium dust, fumes, or mists in concentrations of 0.1 percent by weight or more would be the ones affected.  OSHA also didn’t intend for PPE to be changed out after each individual work task and didn’t intended that residue be completely eliminated before entering eating and drinking areas, it needs to be “as free as practicable.”  They’ve made some word changes to clarify this.

Beryllium Work Areas

Engineering and work practice controls such as ventilation changes or enclosure must be developed to prevent excessive beryllium from becoming airborne. Engineering controls are due by March 10, 2020. In the meantime, beryllium work areas must be marked and have limited access. In construction, a competent person must be designated to mark these areas.

NEW (2020)   Some minor changes have been made in the Housekeeping section for disposal, recycling and reuse.  The rule’s requirements for disposal, recycling, and reuse do not apply to intra-plant transfers; more detail has been given as to what constitutes an appropriate enclosure; materials bound for disposal can be cleaned; and some minor wording changes have been made to this section and other sections to make them easier to understand. 

Medical Monitoring

Companies with beryllium exposures must offer medical exams to affected workers. If a worker has a beryllium-related disease, companies must offer additional workplace accommodations for the worker to protect themself from additional exposure.

NEW (2020)   OSHA has made clarifications regarding the specific timing on when employers are to have employees who may have been exposed to beryllium in an emergency get medical exams taken, depending on when their last exam was or if they’ve ever had one.  In another update, because exams at Chronic Beryllium Disease (CBD) Diagnostic Centers may take more than 30 days, OSHA has allowed for the initial consultations to be done within 30 days (including virtual/phone consultations) and then full evaluations within a reasonable time.  The employer must also be sure the employee is offered any tests deemed sufficient by the examining physician at the CBD testing center, and if not offered there, they should be allowed to be performed at a separate location mutually agreed upon by employer and employee. 

Worker Training 

Affected workers must be trained in the hazards of beryllium. This must be done separately from Hazard Communication training and be specific to beryllium.

NEW (2020)  Just as PPE pertains to those in beryllium areas, so does training.  Those are employees working in beryllium work areas and any other employees who may not be working directly with a beryllium-generating process, but who may reasonably be expected to have airborne exposure to and/or skin contact in concentrations of 0.1 percent by weight or more.

Recordkeeping 

NEW (2020)   In recordkeeping requirements throughout the standard, all references to collecting social security numbers have been removed.

Other 2020 Changes

  • Dermal and Airborne Contact, but Not Everybody:  Just like PPE and training have been clarified it’s only for those working in or could be reasonably affected by beryllium, medical monitoring, wash facilities and change rooms are also subject just to those persons who could be exposed.  References to dermal contact have been updated to also encompass airborne contact, but this change also helps narrow the requirements so that they don’t have to be in place for everyone in the facility.
  • Check out the complete 2020 final rule revisions and explanations in the Federal Register HERE.

Does This Apply to You?  We Can Help You Find Out

Are your workers exposed to beryllium? What are your exposures, which work areas of your company are affected, and do you have the necessary protections in place?   Let iSi conduct your monitoring to check. We can also help you with plans, PPE recommendations and training. Contact us today!

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

Keith brings over 20 years of industrial hygiene and safety experience to iSi and its clients. An industrial hygienist, Keith jokes that he "sucks air for a living."  He specializes in workplace exposure testing and sampling strategies, safety compliance, ergonomics and training in a variety of topics in both the industrial hygiene and safety field.

Email  |  LinkedIn

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Industrial Hygiene in Construction: Focus Four Health Hazards

Industrial Hygiene in Construction: Focus Four Health Hazards

Recently the American Industrial Hygiene Association (AIHA) published results of its study of construction occupations and workers across 32 states regarding construction worker health.

For several years, there has been an OSHA Focus Four emphasis on physical safety (Falls, Electrocutions, Struck-By and Caught-In-Between).  However, at construction worksites, the focus on industrial hygiene in construction and worker health has consistently lagged behind. Besides Focus Four and equipment and tool safety, companies focus on zero injuries.  Health hazard exposures are just as common and can be harder to see because some may not arise until they become chronic.

As a result, AIHA has published a guidance document on a new Focus Four for Construction HEALTH Hazards including:

  1. Manual Material Handling
  2. Noise
  3. Air Contaminants
  4. High Temperatures


Manual Material Handling

Manual material handling is strenuous work that can cause overexertion. Repeated work day after day, vibration from tools and equipment or awkward positioning can cause musculoskeletal disorders (MSDs) such as back strains and sprains; arm and hand injuries; elbow and shoulder issues; and knee disorders. There are not many medical remedies for MSDs other than pain killers which can lead to opioid addictions.  Disabilities and early retirement can also arise.  MSDs are not cheap from a worker’s compensation perspective, taking 50% of all worker’s comp costs in construction.

AIHA says reducing these hazards will not only lower your costs, but help you retain your most experienced workers, help attract new employees, keep employees productive as they age and increase roles for women in the trades.


Noise

Exposures to noise can create either temporary or permanent hearing loss and other problems like tinnitus (ringing in the ears), sleep disturbance, impairment of balance, hypertension and cardiovascular disease. AIHA says a rule of thumb to use is that if you need to raise your voice to talk with someone an arm’s length away, the noise level will be over your 85 decibel limit. There are also many apps for your phone that can give an approximate noise level reading. Just remember these are not calibrated and can be off by several decibels. Those exposures at 85 decibels will cause damage over time, but construction tools and activities at 130-140 decibels will cause instant damage.

AIHA says hearing loss is the most common workplace illness in the U.S., and there is no cure for hearing loss or tinnitus.

Make sure you know what your noise exposures measurements are , know how to properly select and use hearing protection, communicate noise hazards, conduct hearing tests annually, train employees and include information about noise off the job. Better yet, find ways wherever possible to reduce noise exposures.


Air Contaminants

Air contaminants can include dusts, metal fumes, gases, vapors, solvents, and exhaust.    Odors are not always present, and those who “get used to the smell” may not know their overexposures to it.  For some contaminants, the fact that you can smell them means you’re already overexposed.

Contaminants can be inhaled or absorbed. Inhalation causes damage to the nose, throat and lungs causing damage and potential for asthma, breathing difficulties, lung scarring, COPD and lung cancer.  Absorption can cause blood, nervous system and organ damage.

This is another health hazard that may not be seen right away, but can arise later in an employee’s life, affecting quality of life.

This hazard can be reduced by pre-planning, determining:

  • Hazards of material to be used – what does the SDS say?
  • Amount used?
  • Duration used?
  • How will it be dispersed?
  • Confinement/enclosures used?
  • Controls used?
  • Ventilation and exhaust planned?
  • What PPE is needed?
  • Are respirators needed and do you have a proper respiratory protection program in place?
  • What are the occupational exposure limits allowed?

AIHA cautions that just because a task will be done for a short amount of time doesn’t lessen the hazard.


High Temperatures

Construction workers are susceptible to heat exposures due to the nature and location of their work.  Often things like PPE will add to the potential for problems.

Heat exposures play with the body’s ability to think clearly and act normally, so the worker may not speak up. That’s why it’s important for all workers, supervisors and foremen to be aware of the signs and symptoms of heat-related illnesses.

Proper training and planning ahead will help prevent major issues.  Make sure you look at things like:

  • Heat index
  • Experience and acclimation of worker (new or temp workers?)
  • How much work will be in direct sun?
  • Confined spaces
  • Additional heat sources (radiant heat/welding)
  • Physical workload
  • PPE to be used
  • Insulation and heat shields
  • Ventilation
  • Work schedules
  • Hydration, shade and break areas


In Closing

Although this article focuses on the construction worker, there is a lot that general industry workplaces can learn from this information too.

For more information about the Focus Four Health Hazards, check out the AIHA guidance document.

iSi’s team of industrial hygienists can help you with these issues and take care of the workplace and employee sampling that’s needed in several of these hazards.  Contact us today with your questions or to get a price quote.

Worker & Area Sampling

Let iSi’s industrial hygiene team help you determine what your workplace exposures are. Contact us today!

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

Tami has been with iSi for over 24 years.  During this time, she has enjoyed helping promote regulations compliance awareness and education through her involvement with iSi Training and through leadership roles with industry conferences and professional organizations.

Email  |  LinkedIn

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EPA Adds 1-BP to Clean Air Act Hazardous Air Pollutants List

EPA Adds 1-BP to Clean Air Act Hazardous Air Pollutants List

EPA has added 1-bromopropane (1-BP), aka n-propyl bromide, to its list of hazardous air pollutants under the Clean Air Act.  This is the first time since 1990 that EPA has added a chemical to the list from a petition request.

The CAS number for 1-BP is 106-94-5.

How is 1-BP Used?

1-BP is found in products for the following applications:

  • Adhesive sprays
  • Solvent sprays for asphalt production, aircraft maintenance, and synthetic fiber manufacturing
  • Vapor and immersion degreasers for cleaning plastics, metals, electronic components and optical components
  • Dry cleaning
  • Spot removers
  • Coin cleaners
  • Paintable mold release products
  • Automotive refrigerant flushes
  • Lubricants

Which EPA Compliance Obligations Will This Affect?

Since the change is part of the Clean Air Act, you will need to take note that this will affect the following EPA reports and permits:

You should also now start tracking the quantities purchased and used to help you with these reports.

What is the Hazard?

1-BP can be inhaled as a vapor or mists of spray and can also be absorbed through skin contact.   It is colorless with a sweet odor.  It can cause irritation of the eyes, nose and throat, and can damage the nervous system.  Women of childbearing age are cautioned that prolonged exposure can cause developmental and reproductive effects.  Extreme cases can cause kidney and liver issues as well as neurological issues such as dizziness, loss of consciousness, slurred speech, confusion, twitching and difficulty walking.  

Some people have experienced symptoms with use as little as 2 days, but most cases have effects after long-term exposure.

Make Sure You Know Your Exposures

If your company is using products with 1-BP, please make sure you are conducting industrial hygiene sampling of your employees and their usage of 1-BP to identify what their exposures are.  The American Conference of Governmental Industrial Hygienist’s (ACGIH) threshold limit value for 1-BP is a very low 0.1 ppm, so any exposures over that will require respiratory protection.

iSi has conducted 1-BP sampling for two of our clients within the past year.  Each were using vapor degreasers with 1-BP in them.  Exposures measured at 3.74 ppm for one company and 49.5 ppm for another.  These were very well above the recommended 0.1 ppm and each company needed to change protocols to get the exposures down.

PPE and Administrative Controls

Besides respiratory protection when limits are over the thresholds, both EPA and OSHA recommend usage of chemical protective gloves/clothing and eye protection when handling 1-BP. 

OSHA has specific recommendations for eliminating the hazard altogether through isolation, ventilation and other engineering controls.  Some administrative controls they recommend include reducing both the time and number of workers exposed to the chemical, purchasing and storing the least amount possible and keeping containers closed between use.

Because of the hazard, there are other products now on the market that can be used for the same functions that do not have 1-BP in them.

Get 1-BP fact sheets on the EPA website here and on the OSHA website here to learn more.

Questions?

If your company is using 1-BP and you have questions on how it will affect your compliance reporting and tracking obligations, we can help!  Email us or contact us by phone.

1-BP Assistance

If you need help determining how this new rule will affect your air reporting, or if you need 1-BP exposure sampling to see where you stand, contact us today!

Questions?

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How UV Lighting Can be Used as a Disinfectant for Your Facility

How UV Lighting Can be Used as a Disinfectant for Your Facility

UV Light for Your HVAC

iSi can now provide disinfecting UV lighting for your HVAC system. UV light installations kill protein encased viruses, bacteria and mold.

UV lighting can be used as another tool in your safety and environmental arsenal to make your workplace safer and healthier.  But how does it work?

What is UVGI?

Ultraviolet Germicidal Irradiation, or UVGI, is a technology that goes back to the 1930’s with studies showing that ultraviolet light has the ability to kill or inactivate airborne microorganisms. These studies showed that an optimal wavelength of 265 nanometers (nm) was able to provide the largest reduction in airborne microorganisms. This was found to be very close to the wavelength produced by low-pressure mercury vapor lamps (254 nm).

Ultraviolet light can be broken down into 4 different bands:

  • UV-V: 10-200 nm
  • UV-C: 200-280 nm
  • UV-B: 280-315 nm
  • UV-A: 315-400 nm

The sun emits the full spectrum of ultraviolet light but only UV-A & UV-B make it to the surface.  The others are filtered out by the Earth’s atmosphere.  The UV-C band is the most effective at attacking the harmful microorganisms, so it needs to be generated artificially.

UV light spectrum

How does UVGI work?

UV-C wavelengths are readily absorbed by the DNA and RNA of microorganisms such as germs and mold.  When absorbed, UV damages their DNA or RNA structure, preventing the microorganism from replicating. The magnitude of their reduction is affected by their resistance to UVGI, the quantity of UV energy delivered, and the type specific microorganism being irradiated.

UV light

Wall-mounted UV light system.

Disinfecting light is delivered in two common methods. The first is by placing light units, either with or without fans, near the top of a room close to the air vents in order to clean the air as it circulates the room.

The second method is to place the unit directly into the heating and air conditioning (HVAC) system. This second method places the light in a location where the room occupants are not directly exposed to the light, and if placed correctly, can have an added advantage of cleaning the HVAC coils and drip pan to improve the efficiency of the HVAC system.

iSi light frame

UV light for HVAC system.

The design and placement of these different systems are governed by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) which has published many documents on the subject.

UV Safety Considerations

UV-C band light is a safer band than the UV-A and UV-B that we deal with in nature. We have always been taught to apply sunscreen and wear sunglasses to protect ourselves from the burns we receive when outside. Due to the shorter wavelengths UV-C will only penetrate the outer skin layers and along the surface of the eye. It will not give you the severe sun burn the longer wavelengths will. It will cause a reddening and slight irritation of the skin and an painful itching sensation that will last a few days in the eye so slight protection is required if you are directly exposed to the light from these units.

UV Lighting for Your HVAC Units

iSi is now providing the second method UV germicidal lighting, the one for your HVAC system.  Our units are customized to your specific HVAC system and area to be disinfected.  Learn more about this service and get a quote here.

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

As a former corporate environmental, health and safety manager, Ryan has a vast experience in working with both environmental and safety compliance issues in multiple states.  His specialties include national and international dangerous goods transportation, hazardous waste, environmental compliance, industrial hygiene and safety compliance. He is also an ISO 14001 Lead Auditor.

Email 

Questions?

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Return to Work Building Issues: Stagnant Water

Return to Work Building Issues: Stagnant Water

Legionnaires, Heavy Metals Among the Hazards That Could Affect Your Building’s Water System Safety

As we all prepare to return to work, we may find additional hazards lurking in our buildings if they have been closed up or have had limited occupancy due to stay at home orders. Building water systems that have been sitting stagnant can have depleted disinfectant levels. This leads to increased bacteria and biofilm levels inside the system. It can also show increased levels of corrosion products such as iron, lead and copper depending on what your pipes are made from.

Water System Safety:  Environmental and Safety Hazards of Stagnant Water

As water sits unused in pipes, the disinfectant normally found in water (typically chlorine, but check with your water service to see what they are using) depletes to a point where a biofilm forms inside the pipe. This biofilm then grows and when the system is turned on water droplets can become airborne and inhaled causing many illnesses that can affect the lungs such as Legionnaires’ disease. Water that has sat in pipes also increases the amount of corrosion products from the piping itself and can lead to increased levels of metals in the water, depending on what your plumbing is made from. These increased levels can be ingested from various sources within a company such as drinking fountains, ice machines, plumbed coffee systems, water softeners, improperly maintained water heaters, on demand water heaters and dishwashers.

Water System Safety:  Have a Plan to Deal With the Stagnant Water dirty water in faucet

Before buildings are reopened, a plan should be established to flush out the contaminates in your building’s entire water system. This flush should go all the way back to the main line from the municipality. You may need the assistance of a plumber or water engineer to properly determine the size and length of the pipes so the proper volume of the water system can be calculated.

Once known, the volume will then determine the length of time the system will need to flow. In some cases, this could require over an hour of water flow. Be sure to pay special attention to any dead spaces in both the hot and cold-water systems. Remember, this water can be contaminated with bacteria that may cause respiratory issues and the hot water may be hot enough to cause burns so be sure to include proper safety equipment in the plan if doing large scale flushing.

Water System Safety:  Clearance Testing

Once the system has been flushed, testing can be done on the water to determine if it meets the standards established by the Environmental Protection Agency (EPA) for Primary Drinking Water. Those standards can be found at https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations. If you are interested in the USEPA’s Lead and Copper Rule a Quick Reference Guide can be found at https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt.

If you need assistance in determining the safety of your buildings water system, please contact iSi.

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

Keith brings over 20 years of industrial hygiene and safety experience to iSi and its clients. An industrial hygienist, Keith jokes that he "sucks air for a living."  He specializes in workplace exposure testing and sampling strategies, safety compliance, ergonomics and training in a variety of topics in both the industrial hygiene and safety field.

Email  |  LinkedIn

Questions?

Does this apply to your company?  Do you have questions?  Contact us!

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The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

With all things COVID-19 impacting our businesses, researching immediate actions to understand their impacts is critical. Some companies may feel the pressure and immediate need to “clean” everything. However, it’s important to know which cleaning compounds work in what situations, the impact to the materials they’ll be cleaning, their composition, the application methods required by the label and the potential hazards they may cause those workers applying them and working around them.

Most businesses are considering decontamination strategies where it makes sense. In some cases, this might be at the janitorial level, and in other cases, it might be more of an industrial solution involving the production floor, manufacturing processes and even potential products that need to be disinfected/sanitized.

EPA-Approved Products

Some definitions to understand:

Cleaning is the removal of dirts, soils and impurities from the surface.

Sanitizing is meant to reduce, not kill, the occurrence and growth of bacteria, viruses and fungi (typically reduces bacteria on a surface by 99.9%).

Disinfecting a surface will “kill” the microscopic organisms as claimed on the label of a particular product. … The minimum level of effectiveness in a modern-day disinfectant is 100 percent kill greater-than 6-log reduction of an organism.

Both sanitizers and disinfectants are regulated by EPA. In order to substantiate their claims, testing is required to prove their function, and this would be the EPA certification. There are several pre-defined criteria that pertain to how they perform, at what concentration and conditions, what “bugs” they kill, how fast they work, etc. EPA registrations take time, often years. Companies can subregister under an existing formulation. That means they are using an already certified formula.

How Will What You Are Cleaning Be Affected?

All cleaners do not work with all materials. With the desire to decontaminate everything, one important item to consider is what you are actually “cleaning.” There are numerous products that are EPA-certified, and some will be on the acidic side. Others (most commonly) will be on the alkaline side, and even a few will be neutral. Their contents may include: hydrogen peroxide, quaternary amines, surfactants, acids, bases, etc.

Recently iSi evaluated a solution for disinfecting aluminum surfaces. With softer metals such as aluminum and copper, the possibility of corrosion or discoloration is much higher with certain disinfectants.

Most of your harder metals (steel, stainless, alloys) are unlikely to be affected.

These soft metal materials can be found in food processing plants, automotive, aerospace and other industries. Thus, it is important to know ahead of time what the results of using the cleaner will be.

Also, please make sure you’re applying the disinfectant per the product’s label and directions. Do not vary from those directions.  Variances in application methods from what the label says may alter the effectiveness of the disinfectant, cause damage to materials, and may make you non-compliant with regulatory guidelines.

How Will the Person Doing the Disinfecting Be Affected?

Make sure you know exactly what’s in the cleaners to be used. Most importantly, get their Safety Data Sheets (SDSs) and really read them and analyze them.

  • How will its usage affect the person who will be applying it?
  • What kind of personal protective equipment will be needed?
  • Do you have that personal protective equipment on hand? With national shortages, do you even have a way to get ahold of it?
  • How will it affect the atmosphere and air quality of the areas it will be used in?
  • What does the overall tone of it say about the type of person and qualifications needed to apply it? Is it really something you’d be comfortable having janitorial staff work with, or does it need to be someone with a greater level of hazardous materials training?
  • Do you have the staff on hand (right now) to take care of this?
  • What is your overall risk?

Unfortunately some SDSs can be vague, confusing, and can even contradict themselves. So please be very careful and make sure you have a firm grasp on what you’re dealing with.

We Can Help Take Care of It

iSi has been pulled into some research gathering for current clients, and also has been providing onsite personnel for others. We have people on-staff to help you with researching and figuring out your requirements. We deal with confusing and contradicting SDSs every day and have the proper staff of safety and chemistry personnel on hand to work through them. We also have an entire team of hazardous materials and safety trained and experienced industrial cleaning technicians ready to support you.

Give us a call, email us, or send us a message through social media and we will get back with you to see how we can help.

Need Help?

Do you need help with understanding the ramifications of a disinfectant?  We can help!

Questions?

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OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

Respiratory Protection Assistance

iSi conducts both quantitative and qualitative fit-testing and can help you determine what your facility’s needs are for respiratory protection.  Contact us today!

OSHA has added two new fit testing protocols for quantitative respirator fit-testing.  The two new protocols are actually modifications of the current ambient aerosol CNC protocols for full-facepiece, half-mask elastomeric, and filtering facepiece respirators.  These modifications cut in half the number of steps required, also making them faster to conduct.

There are two types of manufacturers of quantitative fit-testing machines which are most popular, the Portacount by TSI and a controlled negative pressure (CNP) machine by Occupational Health Dynamics, or OHD.   The changes in the protocols affect TSI’s PortaCount-type machines.

 Quantitative Fit Testing vs. Qualitative Fit Testing

Qualitative fit-testing uses items such as saccharine or irritant smoke to determine protection.  It relies on the person being tested’s ability to sense odor or irritants.  Qualitative fit testing is only for half-face and N95 filtering facepiece respirators that have an APF of 10.

Quantitative respirator fit-testing uses a machine to measure pressure loss inside the mask or to count quantities of particles to calculate a fit factor. 

Quantitative testing is considered more accurate than qualitative fit-testing.  Quantitative fit-testing must be conducted for respirators requiring an Assigned Protection Factor (APF) over 10.  Full-face tight fitting respirators have an APF of 50 and thus need to be quantitatively fit-tested.

The New Protocols

OSHA based their new protocols on the results of three different studies.  After consideration and comment, 4 of the 8 exercises were removed or changed. 

These include the grimace exercise, normal breathing, and deep breathing.  The grimace exercise was often found to shift the fit of the mask while the breathing exercises were considered exercises that rarely affected fit factor.  For full facepiece and half-mask respirators, talking was eliminated in favor of jogging-in-place, a new exercise.   

Additional changes were made to the number of sets and the duration.   OSHA anticipates 5 minutes can be shaved from each fit-test with the new protocols.

PortaCount Upgrades Needed

If you have PortaCount Models 8030, 8038, 8040 or 8048, you will need a software upgrade that you can download from the TSI website.  You can also have the update uploaded when you send in your machine for its annual service.  PortaCount Model 8020 or 8028 users will only be able to use the original 8-step protocols.   If you have a machine manufactured by another company which uses the same protocols, you will need to check with your manufacturer if the machine you’re using requires an update.

Link to the New Protocols

For more information about the specific protocols, visit the revised Appendix A of the standard.

iSi can help you determine your facility’s respirator needs then provide the personnel to help accomplish tasks — Contact us today!

Snakes as an Indoor Air Quality Issue: iSi’s Memorable Projects

Snakes as an Indoor Air Quality Issue: iSi’s Memorable Projects

At iSi we get the opportunity to come across all types of industrial hygiene and indoor air quality projects.  One of our most memorable ones involved something that isn’t typically thought of as a indoor air quality problem:  snakes!

In Chapman, Kansas, employees at a 1930s office building were complaining about an unpleasant odor in the building. The employees suspected that the odor was coming from snakes that were nesting in and around the building.

chapman snakesIn the spring and fall over the past several years, employees frequently caught snakes in the building. The snakes often poked their heads out from the ductwork and slid over toes at work stations. The snakes were confirmed to be black racers, which produce a distinctive odor when they are disturbed or active. Some settling asphalt near the building provided a place for the snakes to den, and some snakes found paths which allowed them to enter the building. With winter approaching, the snakes had no reason to leave once inside the building.

iSi’s Industrial Hygienist, Constance Timmons, met with a local wildlife biologist from Kansas State University to do a walkthrough evaluation of the building to gather background information. With the indoor air quality information that they gathered, Constance and the wildlife biologist determined that the odor was in fact due to snakes.

Although the odor was not a health hazard, iSi recommended ways to prevent the snakes from re-entering the building in the spring such as using snake traps; a drift fence between the building and the field, consisting of silt about an inch deep; and using pea gravel as a filler around the building because it does not support tunnels.

Indoor air quality project and snakesFor ongoing snake control, iSi recommended placing glue traps along the inside walls of the building, making sure that the traps are not adjacent to standing pipes. A snake is able to wrap around the pipe and leverage itself off the trap. Also, turning up the heat in the building may increase the capture of snakes on the glue traps because they are not able to hibernate when they are so warm. Building personnel were advised that, if they chose to relocate the snakes, to release them at least two miles from the building during any season but winter. Racers have a home range of 25-50 acres, and would find their way back if not released far enough away.

In the 2 days after our visit, the employees were able to catch over 23 snakes!

Do You Have An Indoor Air Quality Issue?

If you’ve got an indoor air quality issue, we feel like we’ve seen it all! Let us diagnose the problem and find the solutions.

What indoor air quality or workplace exposure issue can we help you with? Contact us today!

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