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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What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

hazardous cleanup emergency

Being prepared for emergencies at your facility is vital, and having that plan communicated to your employees is even more critical.  OSHA references a couple of different plans in its regulations, one is the Emergency Action Plan and then OSHA’s HAZWOPER standard mentions requirements for an Emergency Response Plan.  So, what’s the difference between these two plans?

HAZWOPER emergency response team

Emergency Action Plans (EAP)

When reading the OSHA standards for Emergency Action Plans, it’s easy to be confused because they can be pretty complicated.

EAP requirements are found in 29 CFR 1910.38(a).  They are part of Exit Routes and Emergency Planning in Subpart E.  A number of OSHA standards require that you have an EAP, including the regulations related to Process Safety Management, Fixed Extinguishing System-General, Fire Detection Systems, Grain Handling, Ethylene Oxide, Methylenedianiline and 1,3-Butadiene.

In 29 CFR 1910.157, Portable Fire Extinguishers, there is mention of needing EAPs as an alternative to teaching your employees how to fight fires.  There are a bunch of if/then conditions, but OSHA really puts it plainly in their online eTools that the only way a company wouldn’t have to have an EAP is if you have an in-house fire brigade where every employee was trained and equipped to fight fires.  So basically, it doesn’t matter which regulations require EAPs, if you don’t have an in-house fire brigade where every employee is trained to fight a fire, you’re going to need an EAP.

So, Then What’s in an EAP?

This standard says that an EAP must be in writing, kept in the workplace, and available to employees for review.

At a minimum, EAPs need to include procedures for:

  • Reporting a fire or other emergency;
  • Emergency evacuation, including type and exit routes;
  • Employees who remain to operate in critical plant operations before they evacuate;
  • Accounting for all employees after evacuation;
  • Employees performing rescue or medical duties; and,
  • Name and job title of every employee who may be contacted by employees who need more information about the plan or their duties under the plan.

Employers with more than 10 employees are required to have an employee alarm system with a distinctive signal.

As an employer, you must train employees in the safe and orderly evacuation of other employees.  You must review the EAP with every employee covered by the plan when they are initially assigned to a job, when that employee’s responsibilities in the plan have changed, or whenever you make any changes to the plan.

If you have 10 or fewer employees you can communicate the plan orally to employees however, it’s a good practice to still have it in writing because when you get your 11th employee unless you’re super organized, it’s unlikely that will trigger a reminder to put your plan in writing.

HAZWOPER Emergency Response Plan

The OSHA HAZWOPER (Hazardous Waste Operations & Emergency Response) standard at 29 CFR 1910.120 goes into detail about Emergency Response Plans.

If you are going to have your employees respond to releases and spills, you are required to have an Emergency Response Plan.  This also applies to employees that are dispatched to an incident such as from a fire station, fire brigade, or emergency medical service. This plan describes what the employees are expected to do in an emergency response.

If your facility intends to evacuate everyone from the danger area when there’s a release and have someone else do the emergency response portion, then you just need an Emergency Action Plan.  Otherwise, if you are having employees respond, you need the Emergency Response Plan.

HAZWOPER emergency response

Emergency Response Plans need to include procedures/instructions for:

  • Pre-emergency planning and coordination with outside parties;
  • Personnel roles, lines of authority, training, and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up; and,
  • PPE and emergency equipment.

Emergency response organizations may use the local emergency response plan or the state emergency response plan or both, as part of their emergency response plan to avoid duplication. The HAZWOPER plan has also been adopted by EPA’s SARA regulations at 40 CFR 311 for state and local government employees in federal-OSHA states and their volunteers.

Other Emergency Response Plans Required

These are just two plans from a whole laundry list of emergency-related plans required by OSHA, EPA, DOT, and several other agencies.  Want to learn more?  Read our blog about all the other emergency plans required here.

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Fit Testing Questions Answered

Fit Testing Questions Answered

Once you conduct an evaluation to determine what type of respirator your workers will be required to use to protect them from the contaminants around them (that is, what type, Assigned Protection Factor (APF) needed, what filters and/or cartridges are required, etc.), there are three general steps that come next: a medical evaluation to ensure they’re medically capable of wearing one, fit testing to determine which size most comfortably and accurately fits, and training.  In this blog, we dive into the fit testing side.

Respirator fit testing is conducted on tight-fitting respirators to make sure the respirator gets a good seal on the employee’s face so that no contaminants will leak into the mask.  They may not always be the most comfortable or convenient things to wear, but fit testing finds a balance of comfort and protection at the same time.

Qualitative or Quantitative?  What’s the Difference?

Fit-testing methods are referred to as qualitative or quantitative.

In qualitative fit-testing, once the person being fit tested has his/her mask on, the tester introduces items such as saccharine, Bittrex, banana oil or irritant smoke near the mask to see if the person can smell or sense it.  This method relies on the worker’s ability to sense odor or irritants. NIOSH currently doesn’t recommend irritant smoke for fit-testing.  Qualitative fit testing is only for half-face, full-face and N95 filtering facepiece respirators that have an APF of 10.  An APF is the level of protection the respirator will provide if it’s functioning and wore correctly.  For example, an APF of 10 means the user can expect to inhale no more than one tenth of the contaminant present. Qualitative fit-testing is easy, fast and fairly inexpensive.  It’s considered to be only a pass or fail type of test.

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 APF over 10.  Full-face tight fitting respirators that are quantitatively tested have an APF of 50.  An APF of 50 means the user can expect to inhale no more than one fiftieth of the contaminant present.

​When Do I Need to Fit-Test Someone?

Employers are to ensure employees wearing tight-fitting facepiece respirators are fit-tested:

  1. Before use
  2. Whenever a different respiratory facepiece is used (size, model, make, style)
  3. Annually

Why is Fit-Testing Required Each Year?

A study published by NIOSH has affirmed the need for OSHA’s annual requirement for fit-testing for filtering facepiece respirators and other tight-fitting respirators.

In its study, NIOSH followed 229 subjects over three years’ time, making fit and physical characteristic measurements every 6 months. It was found that after one year, 10% of the subjects had changes in fit. In two years it was 20%, and in the third year, it was up to 26%. OSHA’s intended threshold for fit changes, when it made its rules in 1998, was 7% annually.

NIOSH also found that subjects who had lost 20 or more pounds had respirator fit changes. The greater the weight loss, the higher the chance that the respirator fit changed. Thus, NIOSH recommends those persons who lose 20 or more pounds get priority fit-test scheduling, even it is less than a year since their last fit-test.

In addition to weight loss and gain, other events such as dental changes, facial scarring and cosmetic surgery can affect respirator fit as well.

Note: NIOSH’s study can be found at: https://blogs.cdc.gov/niosh-science-blog/2016/01/05/fit-testing/

What Difference Does Respirator Brand Make in Fit Testing?

Different brands also fit differently, so a size a worker may wear in one mask may not be the same size in another brand.  If the person wears glasses, hearing protection or other items around their head during the job, they must wear them during the fit test.

What Facial Hair is Acceptable in a Fit-Test?

Beards and facial hair on men are back in style, but beards and respirators do not get along.  Certain kinds and lengths of facial hair including beards, sideburns, some mustaches, and even a day or two of stubble can interfere with the seal.  According to NIOSH, presence of facial hair under the seal causes 20 to 100 times more leakage.  Gases, vapors and particles will take the path of least resistance and will flow right through the hair into the mask and into the lungs.

Our Physician is Booked Now, Can I Go Ahead and Do the Fit Test Before I Get My Respirator Physical?

No!  Respirator physicals (medical evaluations) need to be done before the fit test to ensure the person getting tested is even medically qualified to wear one.  Wearing a respirator can put a strain on the heart and lungs and it is very important that an employee has been evaluated by a medical professional to prevent causing any damage to the employee.

How Often is Respirator Training Required?

Respiratory protection training is required ANNUALLY, that is, within 12 months.  Doing this training around the same time as the physical and the fit testing can help reinforce proper care techniques for the respirator.  This training should cover how to properly don (put on) and doff (take off) them, their limitations and capabilities, why a respirator is needed, how to use them in an emergency or when they malfunction, how to inspect and remove the seals, how to clean and store it properly, how to recognize medical signs and symptoms that may limit or prevent its effective use, and the general requirements of the respiratory protection standard.

Additional training shall be conducted if there are any changes in your workplace, changes in respirator that would make previous training obsolete and when a worker’s actions show additional training is required to ensure their safe use.

What Documentation Do I Need to Keep?

Once you’ve had someone fit tested, you need to ensure you maintain records of the fit test.  The documentation needs to include:

  • The name of the person tested,
  • Type of test conducted
  • Specific make, model, style and size of respirator tested
  • Date of the test
  • Pass/fail results for qualitative fit testing, or the fit factor and strip chart recording from a quantitative fit test
  • A written copy of your Respirator Protection Program

Where Can I Find the Requirements for Fit-Testing? 

OSHA governs the usage of respirators and sets forth its standards in 29 CFR 1910.134 for general industry, and for construction, standard 29 CFR 1926.103 references back to the general industry standard, saying its requirements are identical.  The specific protocols and instructions on how to conduct a fit test are in Appendix A of that standard.

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What is OSHA’s National Emphasis Program on Heat Hazards?

What is OSHA’s National Emphasis Program on Heat Hazards?

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Heat plays a large part in how we plan our day. We often put off work that creates heat or highly strenuous tasks to a time when the weather is more conducive to our needs. However, that cannot always be done. Sometimes a task must be done on a rigid schedule or is of an emergency nature so that work cannot be put off to a later, cooler, time of day. To that end, OSHA has developed a National Emphasis Program (NEP) to give some guidance to companies on how to work in the heat and keep employees safe.


What is OSHA’s NEP on Heat Hazards?

OSHA will conduct programmed (pre-planned) inspections in targeted high-risk industries on any day that the National Weather Service has announced a heat warning or advisory for the local area.

The NEP went effective on April 8, 2022 and will remain in effect for 3 years unless canceled or extended by a superseding directive.

The NEP establishes heat priority days when the heat index is expected to be 80 degrees Fahrenheit or higher. During these days OSHA will:

  • Initiate compliance assistance in the list of targeted high-risk industries; and,
  • Inspect any alleged heat-related fatality/catastrophe, complaint or referral regardless of whether the worksite is within the list of targeted high-risk industries.


What are the Targeted High-Risk Industries?

OSHA’s NEP on heat hazards targets over 70 high-risk industries based on:

  • Bureau of Labor Statistics (BLS) on incidence rates of heat-related illnesses
  • Elevated numbers of fatalities or hospitalizations reported to OSHA
  • Highest number of heat-related General Duty Clause violations over the last 5 years

These include but are not limited to:

General Industries That are Likely to Have Heat-Related Hazards:

NAICS Code        NAICS Industry Sector Title

1121                      Cattle Ranching and Farming
1151                      Support Activities for Crop Production
2131                      Support Activities for Mining
3118                      Bakeries and Tortilla Manufacturing
3211                      Sawmills and Wood Preservation
3241                      Petroleum and Coal Products Manufacturing
3251                      Basic Chemical Manufacturing
3272                      Glass and Glass Product Manufacturing
3311                      Iron and Steel Mills and Ferroalloy Manufacturing
3314                      Nonferrous Metal (except Aluminum) Production and Processing
3315                      Foundries
3323                      Architectural and Structural Metals Manufacturing
3329                      Other Fabricated Metal Product Manufacturing
3361                      Motor Vehicle Manufacturing
3362                      Motor Vehicle Body and Trailer Manufacturing
3363                      Motor Vehicle Parts Manufacturing
3364                      Aerospace Product and Parts Manufacturing
3365                      Railroad Rolling Stock Manufacturing
3366                      Ship and Boat Building
3369                      Other Transportation Equipment Manufacturing
3371                      Household and Institutional Furniture and Kitchen Cabinet Manufacturing
4239                      Miscellaneous Durable Goods Merchant Wholesalers
4241                      Paper and Paper Product Merchant Wholesalers
4242                      Drugs and Druggists’ Sundries Merchant Wholesalers
4243                      Apparel, Piece Goods, and Notions Merchant Wholesalers
4244                      Grocery and Related Product Merchant Wholesalers
4245                      Farm Product Raw Material Merchant Wholesalers
4246                      Chemical and Allied Products Merchant Wholesalers
4247                      Petroleum and Petroleum Products Merchant Wholesalers
4248                      Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers
4249                      Miscellaneous Nondurable Goods Merchant Wholesalers
4413                      Automotive Parts, Accessories, and Tire Stores
4442                      Lawn and Garden Equipment and Supplies Stores
4881                      Support Activities for Air Transportation
4882                      Support Activities for Rail Transportation
4883                      Support Activities for Water Transportation
4884                      Support Activities for Road Transportation
4889                      Other Support Activities for Transportation
4921                      Couriers and Express Delivery Services
4922                      Local Messengers and Local Delivery
4931                      Warehousing and Storage
5311                      Lessors of Real Estate
5617                      Services to Buildings and Dwellings (includes landscaping services, tree removal and tree trimming services)
5621                      Waste Collection
5622                      Waste Treatment and Disposal
5629                      Remediation and Other Waste Management Services
6231                      Nursing Care Facilities (Skilled Nursing Facilities)
7211                      Traveler Accommodation
8111                      Automotive Repair and Maintenance
8113                      Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance
8114                      Personal and Household Goods Repair and Maintenance

Construction Industries That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

2361                      Residential Building Construction
2362                      Nonresidential Building Construction
2371                      Utility System Construction
2372                      Land Subdivision
2373                      Highway, Street, and Bridge Construction
2379                      Other Heavy and Civil Engineering Construction
2381                      Foundation, Structure, and Building Exterior Contractors
2382                      Building Equipment Contractors
2383                      Building Finishing Contractors
2389                      Other Specialty Trade Contractors

Industries not Included in General Industry or Construction That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

1112                      Vegetable and Melon Farming
1113                      Fruit and Tree Nut Farming
2213                      Water, Sewage and Other Systems (may be State or local jurisdiction)
4411                      Automobile Dealers
4412                      Other Motor Vehicle Dealers
4821                      Rail Transportation (may be Federal jurisdiction)
4885                      Freight Transportation Arrangement
4911                      Postal Service
5611                      Office Administrative Services
5612                      Facilities Support Services
5613                      Employment Services
5614                      Business Support Services
5616                      Investigation and Security Services
5619                      Other Support Services
6117                      Educational Support Services
7225                      Restaurants and Other Eating Places
8112                      Electronic and Precision Equipment Repair and Maintenance
9281                      National Security and International Affairs (includes Customs and Border Patrol, and Transportation Security Administration)


What Will the OSHA Auditors Be Inspecting When They Come to Your Facility?

During heat-related inspections, inspectors will:

  • Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illness(es). 
  • Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations did not occur. This may require the use of a Medical Access Order.
  • Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work.
  • Determine if the employer has a heat illness and injury program addressing heat exposure, considering the following:
    • Is there a written program?
    • How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
    • Was there unlimited cool water that was easily accessible to the employees?
    • Did the employer require additional breaks for hydration?
    • Were there scheduled rest breaks?
    • Was there access to a shaded or cool area?
    • Did the employer provide time for acclimatization of new and returning workers?
    • Was a “buddy” system in place on hot days?
    • Were administrative controls used (earlier start times, and employee/job rotation) to limit heat exposures?
    • Did the employer provide training on heat illness signs, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?
  • Document conditions relevant to heat-related hazards, including:
    • The heat index and additional weather data from that day, e.g., heat alerts from the NWS, data from the OSHA-NIOSH Heat Safety Tool App, saving a screenshot on a mobile phone or tablet. Additional information may be needed for indoor heat investigations.
    • Observe and document current conditions and those at the time the incident occurred (for unprogrammed inspections), including:
      • Observed wind speed
      • Relative humidity
      • Dry bulb temperature at the workplace and in the shaded rest area
      • Wet-bulb globe temperature at the workplace, (ensure the equipment has been properly calibrated prior to use)
      • Cloud cover (no clouds, 25%, 50%, 75%, 100%)
      • The existence of any heat advisories, warning or alerts the previous days
    • Identify activities relevant to heat-related hazards. These can include, but are not limited to:
      • Potential sources of heat-related illnesses (e.g., working in direct sunlight, a hot vehicle, or areas with hot air, near a gas engine, furnace, boiler or steam lines).
      • The use of heavy or bulky clothing or equipment, including personal protective equipment.
      • Estimate workload exertions by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy or very heavy work, considering both average workload and peak workload.
      • Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities.
    • OSHA believes a review of any potential heat-related hazards should be included in any programmed or unprogrammed inspection where radiant heat sources exist in indoor work areas or at outdoor work areas on heat priority days. OSHA advises inspectors to conduct compliance assistance and document it where heat-related hazards do not warrant issuing citations.
    • Inspectors can use the OSHA-NIOSH Heat Safety Tool App as a resource.

How Can You Prevent Heat Illness at Work?

Dangerous heat exposure can occur indoors or outdoors, in any season. Employers can keep workers safe by following these simple safety practices:

  • Follow the 20% Rule — on the 1st day, don’t allow employees to work more than 20% of a shift at full intensity in the heat. Increase their time by no more than 20% a day until they are used to working in the heat.
  • Provide cool drinking water – encourage workers to drink at least one cup every 20 minutes, even if they are not thirsty.
  • Rest breaks — allow workers time to recover from heat in a shady or cool location.
  • Dress for the heat — have workers wear a hat and light-colored, loose fitting, breathable clothing if possible.
  • Watch out for each other — encourage workers to monitor themselves and others for signs of heat illness.
  • Look for any signs of heat illness, including fainting, dizziness, nausea, and muscle spasms, and act quickly — when in doubt, call 911.
  • Offer training on the hazards of heat exposure and how to prevent illness.
  • Develop an Emergency Action Plan on what to do if a worker shows signs of heat-related illness.


Need Help in Getting Your Documentation in Order?

Do you need assistance in developing a formal heat illness and injury program compliant with this initiative? Do you need assistance in determining your potential heat exposures? iSi can help! 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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Health Hazard OSHA Regional Emphasis Program Looks at Industrial Hygiene-Related Issues

Health Hazard OSHA Regional Emphasis Program Looks at Industrial Hygiene-Related Issues

OSHA has issued a new regional emphasis program for its Region VII states (Kansas, Iowa, Missouri and Nebraska) that is targeting industries considered to be in the Top 50 for creating worker health hazards.  Called, “Top 50 Workplace – Health Hazard,” some of the other OSHA regions have similar emphasis programs, or more targeted programs.  Region VII didn’t have a mechanism to inspect for health hazards, so they created this one.

Effective and Enforcement Dates

It is effective October 1, 2021 through September 30, 2026.  Enforcement begins January 4, 2022.

What is This About?

This regional emphasis program is related to industrial hygiene.  Industrial hygiene deals with worker occupational health and tests the exposures workers have to potential health hazards. Besides protecting workers from safety injuries, OSHA’s goal is to protect workers from health hazards too.  Many health hazards are longer term issues that cannot be found by just looking at a company’s injury/illness data.

Exposures to certain substances may not cause health issues and cancer for a number of years.  For example, health issues from asbestos exposure may not arise for 15-50 years after exposure, formaldehyde 2-15 years, benzene 1-10 years, hexavalent chromium 20 years and nickel 13-24 years.

OSHA looked at inspection data from the past 3 years and ranked types of companies by the number of serious violations.  They narrowed that list to the Top 50 by NAICS code.  From there, they’re putting all the companies that fall within that list into a random picker to develop their first inspection list.  All of the companies on that list will be inspected before a new list is generated.  If all the companies on the list are not inspected within 3 years, then they’ll carry over to the new list.  OSHA will generate a new target list every 3 years at a minimum.

What Will Be Inspected?

By knowing what OSHA will be looking for, you’ll have an idea of what you need to do and the procedures to have in place in order to be ready.  Inspectors will ask to see your company’s:

  • Exposure monitoring* program;
  • Exposure monitoring records;
  • OSHA 300 logs to identify threshold hearing shifts, skin disorders, respiratory conditions, poisonings and other illnesses;
  • Safety and health programs for ventilation, occupational noise exposure, nonionizing radiation, hazardous materials from Subpart H, PPE, permit-required confined spaces, medical services and first aid, toxic and hazardous substances from Subpart Z and Hazcom; and,
  • Your programs for temporary employees. OSHA sees temps as more vulnerable to these types of hazards. And then,
  • After the records review, OSHA will conduct a comprehensive walk around of your facility and will be looking for areas where they can conduct occupational exposure sampling to run the tests themselves. That testing will occur as soon as possible. This includes wipe sampling, full-shift and short term monitoring and area sampling.  Note: If OSHA shows up for this type of inspection, make sure you do side-by-side sampling with them so that if there are any discrepancies, you’ll be able to point them out.

*Exposure monitoring includes sampling for your employees’ exposure to various health hazards found in your facility.  This could be chemicals and substances such as asbestos, heavy metals, and formaldehyde, solvents and paints, hazardous dusts, welding fumes, noise, vibration, temperature, ventilation and particulates.

Remember that there is a number of OSHA emphasis programs already set in place. If your company is the target of one of them they can happen any time OSHA is already onsite for something else.  In the directive for this health hazard emphasis, they mention that if you fall under multiple emphasis areas, they’ll stack them and do them all at once in one comprehensive inspection.  In Region VII, there’s already a regional noise and respiratory hazards emphasis program.  Also in this region there’s a powered industrial truck emphasis so just having a forklift onsite could start the ball rolling on an inspection.

OSHA’s Goals – The Inspections’ Report Card

Knowing OSHA’s goals with these inspections can give you additional insight into what their inspectors will be looking for.  Each regional office is required to file a report on their efforts with this emphasis, and in it, they’ll be looking to prove their worth on these efforts, and how their staff helped improve overall workplace health.  Some of the data goals include:

  • Total number of health hazards abated;
  • Total number of overexposures identified;
  • Total number of personal air monitoring samples conducted (full shift, short-term, area samples);
  • Total number of wipe samples taken;
  • Total number of noise samples conducted;
  • Total number of workers removed from health hazards;
  • Total number of workers found overexposed to each substance found in 1910.1000-1910.1029; and,
  • Total number of safety hazards abated/workers removed from safety hazards (that they found at the same time they were there doing the health inspection).

The Top 50

This is the list of the Top 50 NAICS code industries who will be inspected.

What’s Next?

Is your company on this list and what do you need to do in order to be ready if your name is drawn?

iSi can help you get ready with program development, exposure monitoring plans and strategies, onsite exposure monitoring and onsite representation during the inspection.  Learn more about industrial hygiene here, or contact us today!

 

Is Your Company on the List?

We can help with the needed IH monitoring plan, onsite sampling and other assistance.  Contact us today!

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

Email  |  LinkedIn

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

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

Need Help?

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.

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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.

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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.

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Bleach Safety

Bleach Safety

With the spread of COVID-19, businesses and households are looking for ways to clean and sanitize surfaces, and bleach is one of those cleaners that experts have deemed acceptable.  Before you begin, please review these bleach safety tips to ensure you and your workers are protected:​

Uses for Bleach

Bleach can disinfect which means it is effective at killing most bacteria, fungus and viruses but the surface needs to be clean of dirt and grime beforehand. If needed clean the surface with soap and water before disinfecting.

Cleaning refers to the removal of dirt and impurities, including germs, from surfaces. Cleaning alone does not kill germs. But by removing the germs, it decreases their number and therefore any risk of spreading infection.

Disinfecting works by using chemicals to kill germs on surfaces. This process does not necessarily clean dirty surfaces or remove germs. But killing germs remaining on a surface after cleaning further reduces any risk of spreading infection.

The Centers for Disease Control & Prevention (CDC) recommends the following concentrations for disinfection of hard surfaces:

  • 5 tablespoons (1/3rd cup) bleach per gallon of water
  • 4 teaspoons bleach per quart of water

Remember to always add bleach to water and not water to bleach.

Personal Protective Equipment 

Bleach is a corrosive, meaning it will burn skin, so it needs to be kept off skin and out of eyes. So always wear the following when mixing and using bleach.

  • Nitrile gloves
  • Safety glasses or chemical goggles
  • Long sleeves
  • Pants
  • Covered shoes

Always wash your hands with soap and water after working with any chemical but especially before eating, drinking or smoking.

First Aid

  • Eyes: Hold the eye open and rinse slowly and gently with water for 15 to 20 minutes, or for the time the manufacturer recommends. Remove contact lenses, if present, and continue rinsing the eye. Call a poison control center, emergency services, or a doctor.
  • Skin: Remove the contaminated clothing. Rinse the skin immediately with plenty of water for 15 to 20 minutes, or for the time the manufacturer recommends.
  • Inhaled/breathed in: Move the person to fresh air. If breathing is affected, call a poison control center, emergency services, or doctor.
  • Swallowed: Call a poison control center, emergency services, or doctor. Do not try to get the person to vomit unless told to do so specifically by a medical professional. Do not give anything by mouth to an unconscious person.

When providing first aid or when helping another person, be careful not to come into contact with the bleach yourself. Use protective clothing when necessary.

Hazards of Mixing Bleach

Don’t mix bleach with ammonia, acids, or other cleaners. Mixing bleach with common cleaning products can cause serious injuries. Be sure to always read the product label before using a cleaning product.

iSi works with companies to help them with safety and industrial hygiene issues.  Contact us if you have questions about industrial cleaning issues, using bleach or any other industrial disinfectant.

dont combine these bleach products

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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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!

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

A new bill introduced in the U.S. House of Representatives would require OSHA to establish heat exposure rules for both indoor and outdoor workplaces.

Called the Asuncion Valdivia Heat Illness and Fatality Prevention Act, it would require OSHA to issue a formal heat protection standard.  The bill was introduced on July 10 by U.S. House Representatives Judy Chu and Raul Grijalva, with 27 co-sponsors.  The Act is named for a farm worker who died from heat exposure.  Chu led the effort to get a similar law passed in the state of California.

The Bill and Standard Requirements

The current bill would require a federal standard as strict as any state law.  As a result, requirements would include:

  • Set exposure limits and limitations on how long workers can be exposed to heat.
  • Written heat-illness prevention programs including:
    • Engineering controls such as local exhaust ventilation, shielding from radiant surfaces, insulation of hot surface, evaporative coolers, fans and mist coolers, updating air conditioning systems, natural ventilation;
    • Administrative controls such as rotating work schedules, scheduling work earlier or later in the day, and work rest schedules;
    • PPE such as water-cooled garments, air cooled garments, reflective clothing, cooling vests; and,
    • Emergency response plans.
  • Workers would have paid breaks in cool spaces and access to water.
  • Employees would be allowed to acclimatize to the heat.
  • Employers would be required to train workers in heat-stress symptoms and responding to them.

If passed, the new OSHA heat standard would need to be in place within 2 years.  If the for some reason the standard wasn’t finalized by then, an interim standard would need to be created for finalization in another 2 years.

How Does OSHA Handle Heat Now?

Currently heat-related injuries and illnesses are cited under the General Duty Clause.  In June, a Georgia company was cited $21,311 for a worker who was hospitalized with heat exhaustion.  In January it cited the U.S. Postal Service $149,664 for a worker who died from a heat-related episode.  Many states and OSHA state-plan states have also developed their own rules.

House Committee Testimony – Let the Debate Begin

The bill has been introduced the House Committee on Education and Labor.  In a hearing of that committee on July 11, in addition to the testimony of Chu and Grijalva, other supporters ranging from an occupational health and safety professor, an organizer with a warehouse advocacy center, an occupational medical doctor, and a representative of the United Farm Workers of America gave testimony in support of the bill.   

However, a labor representative from California Farm Bureau federation, a safety and health representative of Associated General Contractors and other House committee members had some questions about the standard.

Congressman Ben Cline said that while it’s certainly a serious and important issue, he questioned if the bill was taking a one-size fits all solution.  He questioned if it would be overly burdensome to apply a federal standard to all areas of the country when there are different levels of heat and different levels of heat-related illness between states.  Cline said that a one-size fits all approach becomes much more complicated when it’s applied to different industries where the workplace may change from one place to another, such as in truck driving.  He also pointed out that in 2012, OSHA had considered a heat illness standard.  However, the effort was cancelled because OSHA found having one overall standard for this issue had many complications and opportunities for ineffectiveness.

Congressman Bradley Byrne questioned if it was possible to make a federal regulation flexible enough to both be effective and fit different workplaces, workers, and scenarios. He said that anything developed needs to have many stakeholders involved, from OSHA to employers to employees.  If the regulations are too onerous, employees may not want to do what they need to do to comply.  To get everyone involved, it will take time to develop, and the 2-year timeline for a federal regulation is incredibly short compared to the 15 years it took the state of California to bring together stakeholders to develop a similar but state regulation.  Byrne pointed out that OSHA already has a mechanism to enforce heat standards, and also cited the 2012 OSHA decision to cancel heat regulations in favor of enforcement and education. He said he’d like to hear from OSHA as they’re the ones who will be forced to implement such a standard in only 2 years, considering they had tried before and then had decided against it.  Byrne said Congress needs to be very careful when passing laws like this because of the unintended consequences that can come out of it. 

Watch the house committee meeting below:

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iSi can help you with workplace safety issues, programs & training — 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!

Which Industries Are Affected by OSHA’s Beryllium Standard?

Which Industries Are Affected by OSHA’s Beryllium Standard?

OSHA started enforcing certain provisions of its new beryllium standard starting May 11, 2018.  Is your company affected by this new standard?

Beryllium is a lightweight but strong metal and exposures to beryllium occurs through inhalation or contact when making products containing beryllium.  Which industries are affected by beryllium and what products contain beryllium?  See the list below:

  • Aerospace (aircraft braking systems, engines, satellites, space telescope)
  • Automotive (anti- lock brake systems, ignitions)
  • Ceramic manufacturing (rocket covers, semiconductor chips)
  • Defense (components for  nuclear weapons, missile parts, guidance systems, optical systems)
  • Dental labs (alloys in crowns, bridges, and dental plates)
  • Electronics (x- rays, computer parts, telecommunication parts, automotive parts)
  • Energy (microwave devices, relays)
  • Medicine (laser devices, electro-medical devices, X-ray windows)
  • Nuclear energy (heat shields, reactors)
  • Sporting goods (golf clubs, bicycles)
  • Telecommunications (optical systems, wireless base stations)

(Source: OSHA’s beryllium information site)

If your company produces any of these products, you need to determine your exposure levels and follow guidelines set forth by the new beryllium standard.  Learn more about what these guidelines are in our previous blog post “Beryllium: What You Need to Know About OSHA’s Newest Exposure Standard”.

Need Help?

iSi can help determine if the regulation applies to you and help you comply with the standard!

Let iSi help you pull together your beryllium compliance program!

OSHA’s Silica Rule for General Industry

OSHA’s Silica Rule for General Industry

The OSHA silica rule for general industry/maritime is more geared toward proving silica exposures are occurring below certain levels and thus there is more of a sampling focus.

Exposure Sampling

Employers must conduct exposure monitoring for silica if the potential for exposure could be at or above an action level of 25 µm3 (micrograms per cubic meter of air), averaged over an 8-hour day.  The maximum limit, also known as the permissible exposure limit (PEL) is 50 µm3, averaged over an 8-hour day (the old PEL was 100 µm3). If your workers’ exposures are above the PEL, your company must take measures to protect workers from exposure.

Affected employees must be notified, in writing, of assessment results and what’s being done to control exposures.  If results are above the action level but below the PEL, sampling will need to occur every 6 months until exposures are below the action level for 2 consecutive measurements.  If results are above the PEL, sampling will need to occur every 3 months until exposures are below the action level for 2 consecutive measurements.

Unless the potential for silica exposure is 0%, if there’s even a slight potential for silica exposures, it’s best to conduct the sampling to know exactly what your exposure levels are for documentation purposes. Documentation of your exposure assessment is very important for your recordkeeping files and shows due diligence with the standard.

Anytime a process or change occurs in the facility, monitoring must be conducted again.

Other Requirements

  • Dust Controls — Dust controls need to be used to protect workers from exposures above the PEL. In most cases, wet methods and ventilation can be used to aid in this.  Again, your exposure sampling will be able to tell you how well your dust controls are working.
  • Respirators — When dust controls don’t keep exposures below the PEL, respirators are required.
  • Medical Exams — Medical exams including chest X-rays and lung function tests must be offered to workers exposed at or above the action level (25 µm3) for 30 or more days per year. These must be offered every 3 years.
  • Warning Signs — Warning signs must be posted at entrances to areas where exposures above the PEL may occur.

Compliance Deadlines

Employers must comply with all requirements of the standard by June 23, 2018 with some exceptions for medical surveillance and hydraulic fracturing.

Medical surveillance for those exposed above the PEL (50 µm3) for 30 or more days must be offered to employees starting June 23, 2018.  Medical surveillance for those exposed above the action level (25 µm3) for 30 or more days starting June 23, 2020.

Hydraulic fracturing operations in the oil and gas industry must implement their engineering controls to limit exposures to the new PEL by June 23, 2021.  Significant efforts are currently being made to develop effective dust control technologies specifically for this industry.  Many of these are in development and have demonstrated promise.  Although some are commercially available, many are still in development and those available now have not been widely implemented yet.  The potential effectiveness of these controls is why OSHA has given some extra time for this industry for development and implementation.

Now What?  How Can iSi Help You With This Standard?

iSi is here to help your company comply with this new standard. We can assist with:

  • Compliance Determinations, Audits and Checklists – Helping you determine if this standard applies to you, evaluating your site for exposure potential, determining areas needing warning signs or restricted access, and making a compliance checklist for you
  • Exposure Sampling – Sampling your facility or construction sites for exposure levels, arranging for lab analysis of samples, preparing documentation for recordkeeping, and preparing your written employee notices
  • Written Program Development – Preparing your exposure control plan or respiratory protection program
  • Training – Silica training and respiratory protection training
  • Respirator Fit-Testing – Annual respirator fit-testing (after your medical surveillance is complete)
  • Answering Questions – Our safety and industrial hygiene experts on-staff can help you with any other questions you may have.

Contact us today with questions or pricing requests.

h

Resources

Here are some helpful resources for silica in general industry:

 

 

 

 

Need assistance in sorting out these silica changes?  Let us help!

OSHA’s Silica Rule for General Industry

OSHA’s Silica Rule for Construction

Webinar

Watch our webinar to determine how these regulations apply to your company.

Construction requirements are more geared toward methods of controlling exposures and silica exposure sampling.

Table 1

The construction standard has a table of common construction tasks and the instructions on how to control dust for each.  This is referred to as Table 1.  As long as your company is following the actions required of Table 1, your company will not be required to conduct sampling and won’t be subject to the PEL requirement. Please note that some of the instructions in Table 1 require workers to wear respirators.  If your workers currently do not wear respirators, use of respirators will trigger the need to comply with 29 CFR 1910.134 for use of respirators.  This would include developing a written respiratory protection program, annual respirator physicals, annual respirator training and annual respirator fit-testing. Contact us here for a copy of Table 1

What if You Don’t Want to Follow Table 1?  More on Silica Exposure Sampling

Employers who choose not to follow the guidance of Table 1 will then be subject to the requirements of the action level and the PEL.  This triggers the additional sampling and monitoring requirements that the general industry standard requires. Employers will need to conduct exposure monitoring for silica if the potential for exposure could be at or above an action level of 25 µm3 (micrograms per cubic meter of air), averaged over an 8-hour day.  The PEL is 50 µm3, averaged over an 8-hour day (the old PEL for construction was 250 µm3).

Affected employees must be notified in writing of assessment results and if it’s above the PEL, the notification will need to include what’s being done to control exposures.  If results are above the action level but below the PEL, sampling will need to occur every 6 months until exposures are below the action level for 2 consecutive measurements.  If results are above the PEL, sampling will need to occur every 3 months until exposures are below the action level for 2 consecutive measurements. Unless the potential for silica exposure is 0%, if there’s even a slight potential for silica exposures, it’s best to conduct the sampling to know exactly what your exposure levels are for documentation purposes.

Documentation of your exposure assessment is very important for your recordkeeping files and shows due diligence with the standard. Anyone above the PEL and not using Table 1 must take measures to protect workers from exposure.  Dust controls need to be used to protect workers from exposures above the PEL. When dust controls don’t work, respirators are required.

Other Requirements for Construction

  • Medical Exams — Medical exams that include chest X-rays and lung function tests must be offered to workers who are required by the standard to wear respirators for 30 or more days per year. These exams must be offered every 3 years.
  • Competent Person — Your company will need to designate a competent person to implement the your written exposure control plan.
  • Restricted Access — Procedures for how your company will restrict access to work areas where high exposures may occur must be included in your written exposure control plan.

Compliance Deadlines

Employers must comply with all requirements of the standard by September 23, 2017.  If your company chooses to use exposure sampling and laboratory analysis, then the compliance deadline for laboratory evaluation of exposure samples is June 23, 2018.

Now What?  How Can iSi Help You With This Standard?

iSi is here to help your company comply with this new standard. We can assist with:

  • Compliance Determinations, Audits and Checklists – Helping you determine if this standard applies to you, evaluating your site for exposure potential, determining areas needing warning signs or restricted access, and making a compliance checklist for you
  • Exposure Sampling – Sampling your facility or construction sites for exposure levels, arranging for lab analysis of samples, preparing documentation for recordkeeping, and preparing your written employee notices
  • Written Program Development – Preparing your exposure control plan or respiratory protection program
  • Training – Silica training and respiratory protection training
  • Respirator Fit-Testing – Annual respirator fit-testing (after your medical surveillance is complete)
  • Answering Questions – Our safety and industrial hygiene experts on-staff can help you with any other questions you may have.

Contact us today with questions or pricing requests.

Webinar

Attend our webinar to determine how these regulations apply to your organization.

Construction requirements are more geared toward methods of controlling exposures and silica exposure sampling.

Table 1

The construction standard has a table of common construction tasks and the instructions on how to control dust for each.  This is referred to as Table 1.  As long as your company is following the actions required of Table 1, your company will not be required to conduct sampling and won’t be subject to the PEL requirement. Please note that some of the instructions in Table 1 require workers to wear respirators.  If your workers currently do not wear respirators, use of respirators will trigger the need to comply with 29 CFR 1910.134 for use of respirators.  This would include developing a written respiratory protection program, annual respirator physicals, annual respirator training and annual respirator fit-testing. Contact us here for a copy of Table 1

What if You Don’t Want to Follow Table 1?  More on Silica Exposure Sampling

Employers who choose not to follow the guidance of Table 1 will then be subject to the requirements of the action level and the PEL.  This triggers the additional sampling and monitoring requirements that the general industry standard requires. Employers will need to conduct exposure monitoring for silica if the potential for exposure could be at or above an action level of 25 µm3 (micrograms per cubic meter of air), averaged over an 8-hour day.  The PEL is 50 µm3, averaged over an 8-hour day (the old PEL for construction was 250 µm3).

Affected employees must be notified in writing of assessment results and if it’s above the PEL, the notification will need to include what’s being done to control exposures.  If results are above the action level but below the PEL, sampling will need to occur every 6 months until exposures are below the action level for 2 consecutive measurements.  If results are above the PEL, sampling will need to occur every 3 months until exposures are below the action level for 2 consecutive measurements. Unless the potential for silica exposure is 0%, if there’s even a slight potential for silica exposures, it’s best to conduct the sampling to know exactly what your exposure levels are for documentation purposes.

Documentation of your exposure assessment is very important for your recordkeeping files and shows due diligence with the standard. Anyone above the PEL and not using Table 1 must take measures to protect workers from exposure.  Dust controls need to be used to protect workers from exposures above the PEL. When dust controls don’t work, respirators are required.

Other Requirements for Construction

  • Medical Exams — Medical exams that include chest X-rays and lung function tests must be offered to workers who are required by the standard to wear respirators for 30 or more days per year. These exams must be offered every 3 years.
  • Competent Person — Your company will need to designate a competent person to implement the your written exposure control plan.
  • Restricted Access — Procedures for how your company will restrict access to work areas where high exposures may occur must be included in your written exposure control plan.

Compliance Deadlines

Employers must comply with all requirements of the standard by September 23, 2017.  If your company chooses to use exposure sampling and laboratory analysis, then the compliance deadline for laboratory evaluation of exposure samples is June 23, 2018.

Now What?  How Can iSi Help You With This Standard?

iSi is here to help your company comply with this new standard. We can assist with:

  • Compliance Determinations, Audits and Checklists – Helping you determine if this standard applies to you, evaluating your site for exposure potential, determining areas needing warning signs or restricted access, and making a compliance checklist for you
  • Exposure Sampling – Sampling your facility or construction sites for exposure levels, arranging for lab analysis of samples, preparing documentation for recordkeeping, and preparing your written employee notices
  • Written Program Development – Preparing your exposure control plan or respiratory protection program
  • Training – Silica training and respiratory protection training
  • Respirator Fit-Testing – Annual respirator fit-testing (after your medical surveillance is complete)
  • Answering Questions – Our safety and industrial hygiene experts on-staff can help you with any other questions you may have.

Contact us today with questions or pricing requests.

Need help sorting out these new silica requirements? Let iSi help!

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