Industrial Hygiene Sampling for Welders

Safety, industrial hygiene, OSHA compliance, training

By Rachel Morgan, MPH, ASP
EHS Specialist at Palmetto EHS

Welding is a necessary process used in many general industry and construction operations, however the welding process can expose welders to various metal fumes. The fumes generated contain metals such as aluminum, beryllium, cadmium, chromium, cobalt, copper, iron, lead, manganese, nickel, silver, tin, and zinc among others. Exposure to welding metal fumes can cause a variety of health effects. Acute exposure is often associated with nausea and irritation of the eyes, noise and throat, while chronic exposure is often associated with health effects such as lung and urinary tract cancer. Metal fume fever may also occur and cause symptoms such as fever, chills, achy muscles, nausea, headaches, and vomiting.

The potential exposure to welding metal fumes is dependent on a variety of factors, which include the type of welding being performed (MIG, stick, TIG, etc.), the ventilation controls in use (local exhaust ventilation, dilution ventilation, etc.), the air circulation/location of the welding (indoors, outdoors, confined space, etc.), the work practices of the welder, engineering controls used, the composition of the welding rods and the metals being worked on, etc. One way to determine if your controls and work practices are working properly and that your employees are not being exposed above the occupational exposure limits, is to conduct industrial hygiene sampling. The sampling will let you know if your workers are being exposed to welding metal fumes above or below the Permissible Exposure Limits established by OSHA for each applicable metal. Based on the results, you can then determine if additional controls are necessary.

If you have not performed any industrial hygiene sampling for welding metal fumes, or if you’ve made changes and need to update your sampling, contact us.

Respiratory Protection Reminders

Respirator Fit TestingBy Rachel Morgan, MPH, ASP
EHS Specialist at Palmetto EHS

Nearly five million employees are required to wear respirators due to occupational exposure to airborne contaminates according to OSHA estimates. Respirators do one of two things to protect those wearing them – they can filter out contaminates in the air or they can supply clean/uncontaminated air from another source. Tight fitting respirators require fit testing prior to their use in the workplace, and annually thereafter, in order to verify that the respirator has a sufficient and acceptable fit to the face of the employee. Employees wearing tight fitting respirators must  be clean shaven and have no facial hair that interferes with the seal of the respirator. In order to ensure that employees can properly use a respirator, OSHA also requires annual respiratory protection training. OSHA’s Respiratory Protection Standard, 29 CFR 1910.134, details exactly what must be covered in the annual training. Another OSHA requirement prior to allowing or requiring employees to wear respirators in the workplace is a medical evaluation. This requirement is to be sure that your employees can medically wear a respirator before you put them in one. It is important to keep in mind that breathing while wearing a respirator is more difficult than without one and can put a larger physiological burden on the body. Lastly, a written respiratory protection program is required of employers with employees required to wear respirators (some elements are required for employers with employees voluntarily wearing respirators as well). The OSHA Respiratory Protection Standard also details what must be included in the written program. 

While engineering and work practice controls or substitution of materials are the ideal and preferred way of dealing with airborne contaminates in the workplace, sometimes it is not feasible or possible to reduce exposures below the occupational exposure limits and respirators must be used.

If you are in need of fit testing, medical evaluations, or respiratory protection training or written program, contact us.

Proposed Rule Changes for Beryllium in Construction and Shipyard Industries

OSHA will not be enforcing the new beryllium standards for those covered by the construction and shipyard sectors at this time. They have proposed to retract some of the provisions contained within the final rule for these two sectors. The proposal does, however, keep the lower permissible exposure limit (PEL) and short term exposure limit (STEL), 0.2  µg/m3 and 2.0 µg/m3, respectively, for beryllium in the construction and shipyard industries. OSHA proposes to keep the lowered exposure limits due to the risk of chronic beryllium disease and lung cancer for those exposed to beryllium. According to OSHA, beryllium exposure in the construction and shipyard sectors is fairly restricted to abrasive blasting (construction and shipyard) and welding (shipyard), therefore standards already in effect, such as the respiratory protection standard, ventilation and protection in welding, cutting, and heating in shipyards standard, etc., may provide enough protection for those exposed to beryllium. Comments from the public on the new proposed rule will be taken by OSHA until August 28, 2017.

The final rule on the beryllium standard for general industry became effective on May 20, 2017, and will not be affected by OSHA’s proposed changes to the beryllium standard for those covered by the construction and shipyard standards. If you need industrial hygiene sampling to be in compliance with the general industry rule, contact us.

For more information on the proposed rule, see https://www.federalregister.gov/documents/2017/06/27/2017-12871/occupational-exposure-to-beryllium-and-beryllium-compounds-in-construction-and-shipyard-sectors.

Silica Enforcement Delayed for those in Construction 

rachel photo-website

By Rachel Morgan, MPH, ASP
EHS Specialist at Palmetto EHS

The enforcement date for OSHA’s new Crystalline Silica in Construction Standard has been delayed from June 23, 2017 until September 23, 2017. The delay in enforcement is in order to give OSHA more time for the “development of additional guidance materials” as well as to give them “the opportunity to conduct additional outreach to the regulated community and to provide additional time to train compliance officers.” OSHA has released Fact Sheets about the new respirable crystalline silica rule for both construction and general industry employers, however at this time a Small Entity Compliance Guide has only been released for those covered by the construction standard. Sometime in the spring of 2017, they are expected to also release a Small Entity Compliance Guide for those covered under the general industry and maritime standards. Although enforcement of the written Silica Exposure Control Plans for those in construction will not commence until September 23, 2017, it is advisable that those covered by the new rule begin the development and implementation of Exposure Control Plans now. If you need help writing your Exposure Control Plan or sampling for respirable crystalline silica, contact us.

For more information about the delay of enforcement, see https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=31082 , and for more information from OSHA about the new silica rule, see https://www.osha.gov/silica/.

Beryllium Rule Effective Date Delayed

In February, we posted an article about OSHA’s final rule on beryllium in the workplace and noted that the the effective date of the final rule had been pushed back from March 10, 2017 to March 21, 2017. That effective date has now been postponed to May 20, 2017. The delays in the effective date of the final beryllium rule are due to the “Regulatory Freeze Pending Review” memorandum and is intended to give OSHA more time to review, evaluate, and asses the rule. Although the effective date of the beryllium rule has been pushed back, the compliance dates within the rule will not change, and most of the rule becomes enforceable on March 12, 2018. Contact us if you need help becoming compliant with the final beryllium rule.

OSHA Issues Final Rule on Walking-Working Surfaces and Fall Protection Standards

rachel photo-websiteBy Rachel Morgan, MPH, ASP
EHS Specialist with Palmetto EHS

The update to the Walking-Working Surfaces and Personal Fall Protection Systems Standards is expected to prevent 29 deaths each year and is meant to help employers performing both construction and general industry activities, as it aligns some of the general industry requirements for fall protection with those already in place for construction. Workers will be better protected under the new rule because it incorporates consensus standards, best practices in the industry, as well as advances in technology to update and clarify the standards, as well as add requirements for employee training and inspections. The new rule allows employers more flexibility in their selection of fall protection, it requires that exposed workers be trained on fall hazards, existing fixed ladders (over 24 feet) must be equipped with a cage, well, personal fall arrest system, or ladder safety system, among other requirements. While the effective date of the final rule was January 17, 2017, a few of the requirements have staggered effective dates. Most of the staggered effective dates range from 6 months to two years, however the requirement for replacing cages and wells on all fixed ladders (over 24 feet) that have personal fall arrest systems or ladder safety systems does not become effective for another 20 years. For more information and to see all of the requirements included in the final rule, see https://www.osha.gov/walking-working-surfaces.

OSHA Top 10 Violations for Fiscal Year 2016

OSHA’s Top Ten Violations for Fiscal Year 2016

These are the top ten OSHA violations for fiscal year 2016, which covers all violations cited by Federal OSHA from October 1, 2015 to September 30, 2016.

  1. Fall Protection in Construction (1926.501) (1st in 2014 and 2015)
  2. Hazard Communication (1910.1200) (2nd in 2014 and 2015)
  3. Scaffolding in Construction (1926.451) (3rd n 2014 and 2015)
  4. Respiratory Protection (1019.134) (4th in 2014 and 2015)
  5. Lockout/Tagout (1910. 147) (5th in 2014 and 2015)
  6. Powered Industrial Trucks (1910.178) (6th in 2014 and 2015)
  7. Ladders in Construction (1926.1053) (8th in 2014, 7th in 2015)
  8. Machine Guarding (1910.212) (9th in 2014 and 2015)
  9. Electrical – Wiring Methods (1910.305) (7th in 2014, 8th in 2015)
  10. Electrical – General Requirements (1910.303) (10th in 2014 and 2015)

If your company needs help addressing issues related to these highly cited violations, contact us.

Do Your Employees Have Exposure to Hexavalent Chromium?

Safety, industrial hygiene, OSHA compliance, training

By Rachel Morgan, MPH, ASP

Hexavalent chromium is a form of chromium that is present in many industrial operations and can cause a variety of illnesses. Welding on stainless steel is one of the main sources of hexavalent chromium exposure in the workplace. Other sources of exposure include smelting of ferro-chromium ore and chrome plating with chromic acid. Hexavalent chromium is a carcinogen and has the potential to cause lung cancer, respiratory tract irritation, and damage to the skin and eyes. Wheezing and shortness of breath are sometimes found in workers who become allergic to hexavalent chromium over time as well.

The Occupational Safety and Health Administration (OSHA) has both an Action Level (2.5 µg/m3) and a Permissible Exposure Limit (5.0 µg/m3) for hexavalent chromium. If initial monitoring of workers indicates that that they are exposed above the Action Level, employers are required to begin sampling every six months, however if workers are exposed above the Permissible Exposure Limit, employers are then required to sample every three months. If controls are put in place and resampling indicates that exposure has dropped below the Action Level, then the sampling can be discontinued if the results are confirmed by a second sampling event taking place a minimum of seven days later.

Any time conditions change in the workplace, such as a change in materials, equipment, ventilation, other control methods, processes, etc., the employer is required to perform sampling if they have any reason to believe that employee exposure is above the Action Level. In addition to the sampling requirements, OSHA’s Hexavalent Chromium standard also stipulates various other requirements, such as housekeeping, medical surveillance, hygiene areas, PPE, etc., when employees are exposed above OSHA limits.

If you are in need of initial sampling, periodic sampling, or sampling because you’ve implemented controls, contact us and we’ll be happy to help.

Emergency Preparedness

By Rachel Morgan, MPH, ASP, EHS Specialist at Palmetto EHS

While we all hope to never have to act upon our emergency action plans, there will be times when it will be unavoidable. In October of 2015, South Carolinians had to deal with the “1000 Year Flood,” and last week, in the midst of hurricane season, Hurricane Matthew. Preparing for an emergency, such as a hurricane, prior to the event saves lives, and is one of the many reasons why OSHA requires employers to have emergency action plans.

Although the training requirements vary based on the processes at the workplace, the materials on site, the number of employees, etc., one of the vital components of the emergency action plan includes training of employees on evacuation plans, shutdown procedures, alarms, reporting procedures, etc. In addition to this type of training, employers should also be conducting drills (at least annually) so that what to do in the case of an emergency is not a question for employees. Remember the saying “proper preparation prevents poor performance?” That applies here as well – if your employees have been prepared for what to do in the case of an emergency, their performance will result in fewer injuries and less confusion during and after the evacuation and/or incident. Following a drill is the best time to evaluate the efficacy of the drill and the emergency action plan, and to make the appropriate changes needed.

OSHA’s “Evacuation Plans and Procedures eTool” outlines the minimum requirements of the emergency action plan and include the following:

  • Means of reporting fires and other emergencies
  • Evacuation procedures and emergency escape route assignments
  • Procedures for employees who remain to operate critical plant operations before they evacuate
  • Accounting for all employees after an emergency evacuation has been completed
  • Rescue and medical duties for employees performing them
  • Names or job titles of persons who can be contacted.

For more information on hurricane specific information, visit https://www.osha.gov/dts/weather/hurricane/index.html and contact us if you need help developing an emergency action plan of your own.

Respiratory Protection: Are You in Compliance?

Respirator Fit TestingBy Rachel Morgan, ASP
EHS Specialist at Palmetto EHS

Respiratory protection in general industry was the 4th most frequently cited OSHA standard by Federal OSHA in fiscal year 2015. With 5 million workers estimated to be wearing respirators, we thought it would be a good time to talk about achieving or remaining in compliance with OSHA’s Respiratory Protection Standard.

To begin, employers must have a written Respiratory Protection Program in place for employees using voluntary or required respirators (the written program is not required if employees are wearing dust masks voluntarily).

Employers must also ensure that employees are medically able to wear the respirator through a medical evaluation using a medical questionnaire that includes all of the information contained in Appendix C of OSHA’s Respiratory Protection Standard.

After employees have been medically cleared to wear the respirator, they must then be fit tested for all tight fitting facepiece respirators. It is also important, and required by OSHA, that the fit test be conducted with the same make, model, style, and size of the respirator that the employee will be using in the workplace. The fit testing can be performed quantitatively or qualitatively.

Once these steps have been completed, the employer must ensure that the respirators are being maintained appropriately, which includes cleaning and disinfecting, storage, inspection, and repair of the respirators.

Employees wearing respirators must also go through training about the respirators and their use. OSHA’s Respiratory Protection Standard outlines the topics that employees must be able to demonstrate knowledge about after going through training. The fit testing and training aspects are annual requirements required by OSHA.

If it has been more than a year since your employees were fit tested and trained, or if you need medical evaluations or help developing a written Respiratory Protection Program, contact us and we’ll help you get into compliance.

For more information on specifics regarding respiratory protection, please visit https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12716.