Safety Wars
Safety Meeting 5 Construction Site Industrial Hygiene
July 7, 2021
A short discussion, and of course a story on 29CFR1926.55 Gases, Vapors, Fumes, Dusts and Mists in Construction
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We are not like some of those other safety groups that charge money or are subject to the whims of sensors And group administrators visit safety nights at safety nights dot com. That safety nights and nights is spelled with a. K. Today on safety wars gases, vapours, fumes, dusts, mists in construction. We had a situation recently in one of my projects, a construction contractor was using a different product than what was usual. And I asked him if he had any industrial hygiene monitoring data on it. And my experience, the product that he was using required respirators. He said no and the most, the strongest terms everything on f He said there's no requirement for any monitoring or a sampling. And why would we do it anyway? We're doing it outside, therefore it's safe. I innocently asked him who the designated competent person or the industrial hygienist was. And according to the regulations, he said he was, that's all got back to my client. My client got a little bit annoyed with me. They said, well, jim, what does the regulations say? So today's safety meeting is because of that situation on construction sites. Companies must comply with The construction regulation 29 CFR 1926.55 Gases. Vapours, fumes, doesn't miss. The regulation is actually real short and it's real simple. Actually, employers must limit employees exposure to any substance listed in the regulation. We're talking permissible exposure limits, threshold limit values, whatever is listed in this particular regulation. Plus, there are other regulations that apply, for example, the Lead Standard Spasticity Regulations and the OSHA standards, things of that nature. So if you're dealing with a substance with a C in front of it, meaning a ceiling limit, that means that you cannot exceed the list of concentration for 15 minutes or more preferably, you would use a real time monitoring instrument that's calibrated for that contaminant. That's not possible. You gotta go with a 15 minute time weighted average exposure, meaning some type of air sampling where you're going to collect an air sample on a filter or other sample media, like a charcoal tube, Silica Gel tube, anything like that. It's all uh done very scientifically and according to what an analytical method put out by OSHA or nash or other applicable method, depending on where you're universes and you take that and you send it out to a laboratory for analysis. If you're dealing with an eight hour time weighted average exposure meaning of permissible exposure limit for OSHA or something else. If OSHA doesn't regulate that, you need to have some type of a breathing zone air sample. So that's the same thing as with what we just discussed a sample as we collected and sent out somewhere for analysis. And what else you have to do. You have to protect your employees through the hierarchy of controls. You're trying to engineer the hazard out, eliminate the hazard, preferably, that's number one. Engineer it out. Then, going through, trying to substitute the one substance for a less hazardous substance, some type of an administrative control and lastly, some type of personal protective equipment on some sort. Usually with the pls, you're always dealing with a respirator of some sort. And if you're going to be issuing respirators, you have to go and comply with the respirators Standard in 29 CFR 1910 1 34 what else do you need for this regulation? You need to have some type of confident industrial hygienists. That's what a small i industrial hygienists or some other technically qualified person. In our case here, the foreman, uh, that was designated as this content industrial hygienists probably wasn't confident there are several exemptions in this regulation that are covered in other regulations, like asbestos and a couple of other chemicals. So what was our resolution? We had an assessment done And it turned out that they did need respirators for this activity, which I pointed out to begin with, even though they were outside. So either this guy was trying to cover for, they knew it was dangerous. So hey, we'll just sell the employees. Hey, you're outside. Don't worry about it. Or he just didn't know or maybe he was being lied to by his management. But here is what the thing is this job went out for bid. That means an estimator has to go out and I take into account employees safety. In this case, the estimator did not. And I suspect that he realized that he needed to supply respirators because magically all these respirators appeared. But he was hoping that someone on my end would not say anything and that's not like me. I'm probably going to say something and be polite about it um about doing this. What's the moral of this story? You're a safety person. Got to go through the safety data sheets, compare them to the regulatory requirements and this regulation and other regulations. There might even be a local regulations dealing with this chemical or any number of chemicals that you need to comply with. You need to reduce the liability for your company. But more importantly, you got to protect the worker, creating a better, safer workplace for everyone. What's the most effective thing that unnecessary here? What was our biggest tool? Is one having a backbone being assertive but not being a jerk with. If you're a contractor trying to get the assessments done prior to going on to a job site, you need to account for it in your bids and just don't hope that you're going to have that safety person or someone who's on paper, a safety person who really isn't failing to do their job, but you're counting on persons not doing their job. Don't be that person not doing their job. And the other thing is this, if you need an audit done, give us a call call, drop us a line gym at safety words dot com. That's my email address for safety wars. This is jim proposal. The views and opinions expressed on this podcast are those of the host and its guests and do not necessarily reflect the official policy or physician of the company. Examples of analysis discussed within this podcast are only examples. It should not be utilized in the real world as the only solution available as they are based only on very limited and dated open source information, assumptions made within this analysis are not reflective of the position of the company. No part of this podcast may be reproduced, stored in a retrieval system or transmitted in any form or by any means mechanical, electronic recording or otherwise, without the prior written permission of the creator of the podcast, jay Allen.