annual environmental job development all-grantee...
TRANSCRIPT
Bruce Lippy, Ph.D., CIH, CSP
Director of Safety Research, CPWR, The
Center for Construction Research and
Training
301-495-8527
Annual Environmental Job Development All-Grantee
Meeting, September 18, 2013
The broad sections to this presentation
1. What are the general health hazards at
Brownfields?
2. How can we assess hazards on our
specific sites?
3. How should we control the hazards?
How are they different
from those on NPL sites?
What are the general hazards at brownfields sites?
Photo courtesy
eLCOSH,
CPWR
OSHA addresses Brownfields H&S on its website
OSHA’s website cites a 1999 EPA Brownfields Case Study Report • Petroleum hydrocarbons
• Lead
• Construction debris containing lead paint
and asbestos-containing materials
• PCBs
• Wood treated with creosote,
cadmium/chromium/arsenic
• Industrial chemicals
• Diesel fuel
• Any of the safety hazards in construction
Lots of OSHA standards may apply!
What about this site?
Does OSHA's HAZWOPER standard (29 CFR 1910.120 or 1926.65) apply to work done at brownfield sites?
Clean-up operations that fall within the
scope of the standard may include
operations where hazardous
substances are removed, contained,
stabilized, or processed in order to
make the site safer for people.
Who is responsible for safety and health oversight at a brownfield site?
Photo courtesy Wikimedia
Health and Safety Coordinator
enforcing the HASP
Asbestos is a major Brownfields hazard. Why was it used?
• Excellent insulator • Acoustical insulation qualities • Water resistance • High tensile strength • Non-conductivity • High chemical resistance • Ability to be woven • Nearly indestructible • Commonly found • Inexpensive
U.S. production and imports have steadily dropped
NIOSH Current Intelligence Bulletin 62, 2011
Carcinogenic Christmas Decorations! Raybestos-Manhattan Corporation (1940):
“It is a safe snow for holiday decorations.”
9”x 9” floor tiles are nearly always asbestos-containing
The 1’x1’ ceiling tiles often contain asbestos
1’x 1’ acoustic tile on ceiling above
drop ceiling of 2’x 4’ ceiling tile
The mastic “hockey pucks” for 1x1 tiles often contain asbestos
Thermal system insulation with asbestos poses a serious exposure issue during renovation
Aircell is ALWAYS asbestos-containing
• pipe
insulation • looks like
corrugated cardboard
• gray color • friable
Fire doors may contain asbestos. No cutting, drilling, sanding or abrading
Can’t tell a fire door contains
asbestos by age or label!
Transite pipe is hard cement with asbestos mixed in
Damaged ACM floor tile is common in Brownfield buildings
Photo courtesy NASA Goddard
2%Chrysotile asbestos
The EPA asbestos bans can help you determine the presence
• 1972 - Sprayed-on insulation and
fireproofing
• 1975 - Molded and wet applied asbestos
• 1976 - Asbestos pipe insulation
• 1978 - Acoustical and decorative
applications
• 1989 - Proposal to phase out all asbestos
usage in three stages by 1997
• 1991 - Phase 2 and 3 cancelled by US
Circuit Court of Appeals
Where can you find it?
Lead is another major health hazard on Brownfields
EPA has a free course on The Renovation, Repair and Maintenance Rule (40 CFR Part 745) Training Manual Overview
• Eight modules • Hands-on exercises, 11
Skill Sets
The EPA course has important appendices for trainers
1. EPA’s Renovation, Repair, and
Maintenance Program Final Rule (40
CFR Part 745)
2. U.S. HUD Requirements
3. Renovate Right: Important Lead
Hazard Information for Families, Child
Care Providers and Schools
4. Small Entity Compliance Guide to
Renovate Right
5. Steps to LEAD SAFE Renovation,
Repair, and Painting
6. Hands-on Exercises
How widespread is lead-based paint in housing?
Year House Was Built Percent of Houses with
Lead Based Paint
Before 1940 86 percent
1940-1959 66 percent
1960-1978 25 percent
All Housing 35 percent
Feb 09 5-26
Traditional Renovations Create Airborne Leaded Dust
0
100
200
300
400
500
600
Hand Sanding Power Sanding Interior Demolition
Traditional Work Practices
Mic
rog
ram
s/M
ete
r3
*
* OSHA Permissible Exposure Limit (PEL)
= 50 µg/m3
Prohibited Practices
• Open-flame burning or
torching.
• Heat gun above 1100º F.
• Power sanding, power
grinding, power planing,
needle guns, abrasive
blasting and
sandblasting, without
HEPA vacuum
attachment.
The broad sections to this presentation
1. What are the general hazards on
Brownfields?
2.How can we assess hazards
on our specific sites?
Anyone here old enough to
remember a Packard?
How do we determine the risks this abandoned Packard factory poses?
Abandoned Packard factory, Detroit.
Courtesy Wikimedia
Risk is a function of
Severity of possible
harm
Probability of the occurrence
of that harm
Is risk different than hazard?
• Risk is different from hazard
• Hazards can be controlled so there is
negligible risk
• Most used definition: Risk is the
product of the severity of the hazard
and the probability of the hazard
Is a live grenade always a hazard?
Is it always a risk?
Perceived severity of consequences has a strong influence on behavior
This is the most basic risk matrix
High A M U U
Med to High A M U U
Low to Med A A M U
Low A A M M
Low Low to
Medium
Medium to
High
High
Pro
ba
bil
ity
Severity A = acceptable
M = marginal
U = Unacceptable
Apply the matrix to this operation
Confirmed real by
NASA
Who’s more uneasy flying than driving? Show of hands
• The likelihood of dying on a jet flight is 1 in 8,000,000
• This is flying around the clock for more than 438 years before a fatal crash (FAA, 1998)
• Odds of dying in car cash: 1/88 (NSC, 2011)
Group exercise: Put the following in order of greatest lifetime risk of death
Heart disease
Cancer
Assault by firearms
Natural heat Floods
Bitten or struck by dog
Answer to group exercise (National Safety Council “Injury Facts 2011”)
Order Cause Lifetime Odds
1 Heart disease 1 in 6
2 Cancer 1 in 7
3 Motor vehicle accidents 1 in 88
4 Falls 1 in 171
5 Assault by firearms 1 in 306
6 Natural heat 1 in 12,517
7 Contact with hornets, wasps and bees 1 in 71,623
8 Legal execution 1 in 96,691
9 Bitten or struck by dog 1 in 120,864
10 Floods 1 in 175,803
Lifetime odds of death for selected causes, U.S., 2007
Can we eliminate all risk?
Photo courtesy Louise Docker and Wikimedia
Job Hazard Analysis is the most used tool because of its applicability
• Can JHAs can be performed for all
your jobs?
• Who should perform JHAs?
(Supervisors? Safety pros?)
• Any role for workers?
Breaking every job or activity down to each step is critical
Step Potential
Hazard
Control
How do I identify workplace hazards? (OSHA)
A JHA is detective work
• What can go wrong?
• What are the consequences?
• What are other contributing factors?
• How likely is it that the hazard will occur?
Now let’s do a JHA for using a electrical cut-off saw on concrete floor
Step Potential
Hazard
Control
Now let’s do a What-If Analysis
What-If? Result Controls - in
place or needed
Rules for each group:
1.Start each question with “What if…?”
2.Everyone in the group should pitch an idea
3.Do not criticize the question, just work it
Our job is to remove all of the old tires from this abandoned steel plant, without disturbing any drums
The broad sections to this presentation
1. What are the general hazards on
Brownfields?
2. How can we assess hazards on our
specific sites?
3.How should we control the
hazards?
The hierarchy of controls has underpinned industrial hygiene control efforts for a long time
Elimination
Substitution
Modification
Containment
Ventilation
Work Practices
PPE
More reliance
on workers
Why is PPE at the bottom?
Class I, II and III asbestos work must be in regulated areas
What are the engineering controls during abatement?
Feb 09 5-49
Specialized tools for lead abatement can protect workers
• Large jobs may require special
considerations to get the job done,
like: • Power sanders, grinders and planers,
needle guns, and abrasive and sand
blasters, each with required HEPA-filtered
capture attachments.
• Pneumatic and battery powered tools to
protect against shock hazards.
• Specialized planning and containment.
There are engineering controls for reducing dust through ventilation…
Check out CPWR’s
Construction
Solutions
…and through water
Respiratory protection is at the bottom of the hierarchy
53
Why? What can possibly go wrong with respirators?
Is there an OSHA standard for respirators?
• Yes! • General Industry 29 CFR 1910.134
• Construction: 29 CFR 1926.103
• Respirator regulation may be
contaminant specific: • Asbestos
• Lead
What is required in a written respiratory protection program?
• Selection
• Medical evaluation
• Fit testing
• Proper procedures for routine and
emergency use
• Proper inspection, cleaning,
maintenance, and storing
• Training
• Program evaluation
Respirators can be divided based on facial coverage
• Full-face • Half-face
Which offers more protection?
A key difference is the pressure inside the mask when inhaling
• Negative pressure • Positive pressure
Which offers more protection?
For Brownfields asbestos and lead work, air purifying respirators (APRs) are generally acceptable
When would they not be acceptable?
North Full-face Respirator
Courtesy North Corporation
Powered air purifying respirators are the next step up
PAPRs with tight fitting facepiece PAPR with loose
fitting hood
PAPR with loose
fitting facepiece
for welding
Air purifying respirators filter out dusts AND vapors
Must have the correct
color-coded cartridge and
it must be NIOSH-
approved
Most useful cartridges for asbestos and lead
Color Type Protection against
Magenta,
purple
High Efficiency
Particulate Air (HEPA)
Dust particles, asbestos
fibers, lead particles,
bacteria
Black
Organic vapor Solvents
Yellow
Organic vapor/Acid gas Cleaning agents
NIOSHs categories of particulate filters are based on oil mist degradation
• Not resistant N
• Resistant R
• Protective against P
Particulate filters are further classified base on efficiency
• 95 percent, designated 95
• 99 percent, designated 99
• 99.97 percent, designated 100 (HEPA filter)
This gives 9 categories of particulate respirators. What does OSHA allow for asbestos?
N R P 100 100 100
99 99 99
95 95 95 1926.1101(h)(3)(i)(B) Provide HEPA filters for powered and non-powered
air-purifying respirators.
What is the most penetrating particle size?
Particle diameter
Effic
iency
Courtesy Roland
Berry-Ann, NIOSH 4-65
Same filtration principle in negative air machines
OSHA requires that workers pass a fit test before wearing a respirator
PortaCount Quantitative Fit Testing System
Courtesy TSI, Inc.
Quantitative Qualitative
Allegro Complete Smoke Fit Test Kit Photo
Courtesy Gempler’s
Both are acceptable. Which is better?
User seal checks must be performed before each use
IUOE National
Training Fund
304.253.8674 •
www.iuoeiettc.org
Negative pressure check Positive pressure check
IUOE National
Training Fund
304.253.8674 •
www.iuoeiettc.org
Taking care of your gear
• Cleaning
• Storage
• Maintenance
Is this a good maintenance
and storage of respirators?
IUOE National
Training Fund
304.253.8674 •
www.iuoeiettc.org
Cleaning is important and easy
Clean in accordance with manufacturers
recommendations; Usually warm water and
mild soap
OSHA does not allow filtering facepiece respirators for asbestos work • 1926.1101(h)(3)(i)(A)
• Employers must not select or use filtering
facepiece respirators for use against
asbestos fibers.
Protecting yourself during lead-paint abatement
• Workers should wear: • Disposable painter’s hat
• Disposable coveralls • Repair tears with duct tape
• Dispose of in plastic bag
• Disposable N-100, R-100 or P-100 respirator
• Wash face and hands frequently and at
the end of each shift • Washing helps to reduce hand-to-mouth
ingestion of leaded dust
• OSHA may require more protection
depending on what work is done
OSHA’s lead in construction standard requires employer to:
• Provide employees with a full facepiece
respirator instead of a half mask respirator
for protection against lead aerosols that
may cause eye or skin irritation at the use
concentrations.
• Provide HEPA filters for powered and non-
powered air-purifying respirators.
1926.62(f)(3)(i)(B)
Thanks for your time!
410-916-0359
Questions or comments?