This change to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The Hazard Communication Standard used in the United States will be now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  The revised standard will make workers, transporters, distributers and emergency responders safer by using consistent, quality hazard information in the workplace:

• Replace confusing Material Safety Data Sheets (MSDS) with standard Safety Data Sheets (SDS) that contain a specified 16-section format.
• Use specific criteria to classify health and physical hazards for individual chemicals and mixtures.
• Provide labels that include multiple ways to communicate the hazards including harmonized signal words, standard pictograms and consistent, precautionary hazard statements
• Retrain employers by December 1, 2013 on the updated standard.

In addition to internal standardization, adopting GHS will help “reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.”

RGA is now offering a 2-hr GHS Awareness Webinar and will soon offer an 8-hr training on the new standard.  Register today for the GHS Awareness Webinar or sign up to receive our monthly training newsletter by email.

Ethel “Cookie” Kaufman, CSHS,  Senior Trainer  – Seattle, WA

Note: All quoted material is drawn directly from the OSHA website at http://www.osha.gov/dsg/hazcom/index.html

The point that I am leading to is that for years there has been a basic presumption, due to the language in regulation 40 CFR 763.86 (c.&d.) “If any homogeneous area of non-friable suspected ACBM is not assumed to be ACM, then an accredited inspector shall collect, in a manner sufficient to determine if the material is ACM or not ACM, bulk samples from the homogeneous area of non-friable ACBM that is not assumed to be ACM”. This applies for materials considered to be “miscellaneous” such as vinyl tile, sheet vinyl, mastic, cove base, and drywall. Generally, consultants have interpreted this to mean that only one sample of the material was required to be taken and analyzed to document that it does not contain asbestos.  At the end of this blog is the first confirmation that I have ever been able to get in writing from the Environmental Protection Agency clarifying the language in the regulation and stating that the regulatory requirement is that at least two samples of these materials must be taken and analyzed for a survey to meet the criteria in the regulations.  Naturally, this type of a survey will cost a lot more but it could also result in considerably less abatement costs! It is nice to see that persistence in pursuing issues like these eventually pay off, for better or for worse.

Click here to read the EPA’s clarification

Jerry McCaslin, Regional Business Development Manager  – Seattle, WA

By categorizing both the PCB products and the associated contaminated building materials the same type of debris removal and disposal costs can be significantly reduced while still retaining the existing environmental and health and safety protections.  

Under the proposed reinterpretation disposal of materials will be determined by whether the PCB bulk product (e.g. caulk or paint)is still attached to the building material: if the bulk product is still attached to the building material then both would be considered bulk product waste. If the bulk product has been removed and only the building material remains, then the building material would continue to be classified as remediation waste as under current regulations.

The comment period is from February 29, 2012 to March 30, 2012. You can submit your comments either through the EPA docket or to the email address: ORCRPCBs@epa.gov.

JoAnn Copperud, Chief Executive Officer  – Emeryville, CA

If asbestos containing material has been disturbed, take the following steps:

1.   Evacuate the area.
Immediately close off the area or room where the release occurred to prevent contaminating other areas. Do not attempt to clean up the asbestos containing material.

2.   Consult the Operation & Maintenance (O&M) Plan for Instructions.
The building’s O&M plan will identify the appropriately licensed consultant or personnel to contact following an asbestos fiber release.  He or she will classify the event and determine the correct response action.

An asbestos fiber release occurs when asbestos containing material is disturbed.  Common ways asbestos containing materials may be disturbed in the built environment include being broken, sanded, drilled, impacted by water or delamination.  Asbestos fiber releases fall into one of two categories: a major event or a minor event.  A minor event affects less than three (3) linear or square feet of asbestos containing material.  When more than three (3) feet of material is disturbed, the event is a major release. 

Minor release events typically do not pose significant health concerns for building occupants and are not reportable events.  Personnel with asbestos O&M training may clean up after a minor release under the supervision of a properly licensed person.

The law requires major release events be reported to the appropriate regulatory agencies.  A major release may also pose a health risk to building occupants.  Only licensed asbestos abatement contractors can clean up a major release and post-abatement air clearance sampling is required before allowing occupants back into the affected areas of the building.

Tedd Kattchee, CAC, CDPH Lead
Project Manager  – Emeryville, CA

As of October of 2011 EPA has added the requirement for contractors to build “vertical containment or equivalent extra precautions during exterior projects”…if the renovation work is “performed within 10 feet of the property line.   The amendment goes on to state that vertical containment is a vertical barrier consisting of plastic sheeting or other impermeable material . . . or an equivalent system of containing the area.” 

One of the benefits of using vertical containment permits renovators to contain an area that is “closer to the renovation activity than the minimum floor (6’) or ground (10’) . . . specified by the RRP rule. . .”    This gives the renovator more flexibility in designing effective containment strategies that might include ‘equivalent…precautions” such as minimizing dust flow via the use of wetting/encapsulating products such as one discussed that is a gel-like agent used to ‘encapsulate painted materials to allow for sanding without dust release.   As per the folks at the Department of Commerce, this type of product would be an acceptable alternate solution, when used as directed.

Vertical containment allows contractors to power wash by enclosing all sides and the top of the area being washed.  The Department of Commerce interprets the phrase ‘other impermeable material’ to include tightly woven landscape fabric.  According to some tests they ran, the high-grade, tightly-oven material allows for water to flow through freely, but not the lead paint chips that come from the activity or pressure/power washing.  I would like to add that while Department of Commerce is accepting the use of both the gel-like product use and the landscape/weed-protection fabric, Region 10 of the EPA was not present for comment. 

Finally, it was comforting to hear that the Department of Commerce is checking the Craigslist Ads in Washington State against the list of licensed RRP firms in the state.  They intend initially to call those non-certified firms and let them know about the requirement, before following through with additional enforcement as needed.

Ethel “Cookie” Kaufman, CSHS,  Senior Trainer  – Seattle, WA

Permissible Exposure Limits (PELs) are promulgated by OSHA and by state agencies (in state plan states).  The PELs are legally enforceable, but most have not changed since they were first promulgated in the 1970s.  The regulatory process has to address factors such as health effects, economic and technical issues, and ability to determine compliance.  As a result, the update process is slow and PELs in general have not kept up with the times.

Two organizations in the US provide occupational exposure level (OEL) recommendations that are not legally enforceable, but are based on updated scientific research and studies.  The National Institute of Occupational Safety & Health (NIOSH) (a department of the CDC) publishes Recommended Exposure Limits (RELs).  “NIOSH…REL[s] [are] based on risk evaluations using human or animal health effects data, and on an assessment of what levels can be feasibly achieved by engineering controls and measured by analytical techniques.”  NIOSH continually conducts research and updates RELs accordingly.

The American Conference of Governmental Industrial Hygienists, (ACGIH) publishes annual Threshold Limit Values (TLVs).  This member-based professional organization advances knowledge on occupational and environmental health.  TLVs are based on peer reviewed scientific literature and provide exposure levels at which no adverse health effect would be observed in a typical worker.  TLVs are health based and do not consider economics or technical feasibility.

After a little research and a bit of discussion with my client I was able to show him that his contaminant levels were below the PEL, REL, and TLV, and that even though there were traces present, they would not adversely affect his employees. 

 Eric Hartman, CIH, Operations Manager  – Seattle, WA

According to data collected by the U.S. Department of Labor, Bureau of Labor Statistics, Census of Fatal Occupational Injuries program, fatal injuries in confined spaces averaged 92 fatalities per year between 1998 and 2000. Inadequate ventilation contributes to the most common confined space hazards such as when 1) deadly gases are trapped inside or along the bottom of a trench; 2) lack of air movement in and out of the space creates an atmosphere much different than the ambient air; 3) oxygen deficiency occurs  due to the presence of other gases or chemical reactions; 4) conditions worsen due to work activities like welding, cutting, use of bonding agents, cleaning w/ solvents, use of other chemicals, or the use of gas-powered equipment; 5) inhalation biohazards are present such as animal fecal material, sewage, or decaying plant matter (mold).

 If confined spaces are present in a facility, OSHA generally requires the employer to 1) Develop and oversee a Confined Space Entry program; 2) identify all confined spaces within the facility; 3) ensure that employees are trained and properly equipped to safely enter.  RGA project managers and trainers are available to assist clients developing an OCHA compliant program to assess and/or minimize employee exposure to confined space hazards.

Marlin Bryant, CAC, CDPH Lead, CIEC, REA-I
Project Manager  – Emeryville, CA

Study Highlights

 This study is the first of its kind.  Researchers investigated the effects low lead blood levels have on adults, children and prenatal fetuses.  Based on the study results:

• Children with less than 5 ug Lead per deciliter blood have decreased academic achievement, increased incidences of ADHD and increased behavior problems.  However, there is limited evidence that a prenatal fetus with less than 5ug Lead per deciliter blood has a decrease cognitive function 
   
• Less than 10ug Lead per deciliter blood reportedly correlates to psychological effects, decreased hearing, decreased cognitive function and other neurological effects in adults. At this same level, adults may also experience increased blood pressure, increased hypertension and cardiovascular-related mortality.

 Click here to read the full report.  
 

What can we do about it?

It is simple to limit Lead exposure.  Construction and maintenance workers use safe work practices to limit lead exposure.  These work practices include working wet, cleaning up, using a HEPA vacuum and using the right respirator.

Industrial hygiene consultants assess potential tenant and worker exposure issues.  Industrial Hygienists can write and help your company implement a proactive worker health and safety program.  RGA also provides lead awareness and lead renovator training for your staff.  Lead awareness and a few simple steps will help protect you, your works and their families.

Ethel “Cookie” Kaufman, Trainer  – Seattle, WA
Andre Zwanenburg, Trainer  – Seattle, WA

 Glass fibers are ubiquitous in many building materials and as a result, are typically present in quantifiable concentrations in most building environments. Glass fibers have been known to be an irritant for quite some time and are classified as a nuisance dust in occupational regulations.

The best way to test for the presence of glass fibers is to take surface tapelifts. Commonly air monitoring is found to be an ineffective method of sampling as it actively disrupts the deposition of the particulate and makes it hard to quantify how much is present. Tapelifts also make it possible for other particulate to be collected that might indicate the origin of the glass fibers (ceiling tile, office cubicle partition, etc.)

At RGA, we have a dedicated laboratory that is qualified to analyze tapelift samples for the presence of glass fibers as well as other particulate. Contact us for pricing and sampling guidelines today.

  Matthew Quarterman, Lab Analyst – Seattle, WA

It is estimated that about 1.5 million workers are currently exposed to nanoparticles in the workplace, and that by 2015 the number has been estimated to be approximately 3.5 million. There are some uncertainties about the potential health risks associated with exposure. The most common route of exposure to airborne particles is inhalation in the workplace.

 Research suggests that some nanomaterials behave similar to an asbestos exposure. Furthermore nanoparticles can be deposited in the lungs, can enter into the brain via nasal passages and even enter the body through skin and the resulting health affects are numerous. Due to these potential health risks, it is important to provide workers a safe work environment to minimize potential exposures and provided adequate personal protective equipment (PPE) and proper engineering controls.

There are currently no national or international standards to measure nanomaterials in the workplace. However, traditional industrial hygiene sampling methods (personal sampling) to assess a workers personal exposure and direct-read instrumentation is available to evaluate engineering controls and work practices.

RGA has qualified and certified professionals (Certified Industrial Hygienists, Professional Engineers, Geologists, Certified Asbestos Consultants, and Certified Lead Professionals) that have the expertise to assist businesses in evaluating workplace exposures.

Steve Rosas, Operations Manager – Irvine, CA