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Showing posts with label plattsburgh respirator training. Show all posts
Showing posts with label plattsburgh respirator training. Show all posts

Thursday, January 04, 2018

OSHA's Silica Standard - What's All The Fuss About? Part One

Happy New Year!  May your New Year be healthy, profitable, & peaceful!  This blog post we will talk about the silica regulation and what the fuss is all about.  We've heard from some of our clients that they are concerned that the regulation is like the asbestos regulation.  Well in reality the regulation is more like the lead regulation than the asbestos regulation.  The big drop in the permissible exposure limit makes it similar to the asbestos regulation in that visible dust exposures may result in violations, but that's where it ends for similarity.  Table 1 of the silica standard is similar to the 1926.62 (d) (2) of the lead standard which is Protection of Employees During Assessment of Exposure.  Where based on a certain task (i.e., scrapping lead paint) the employer must comply with all parts of the standard, including the use of respirators.  Table 1 in a sense has a similar requirements.
Spraying Water to Keep Dust Levels Down Will Become Common Place
The Occupational Safety and Health Administration (OSHA) released the final rule for respirable crystalline silica 1926.1153 on March 25, 2016 with compliance dates more than one year past the publication date.  Giving the various industries regulated by the standard plenty of time to comply.  In fact, the construction industry was the first industry required to comply by June 23, 2017, however, the current administration delayed the standard until September 23, 2017 giving the construction industry additional time to comply.  In addition, OSHA's silica website is quite robust with guidance documents in helping the industry comply.  With all this time to comply, including challenges to the standard that the courts eliminated, and equipment manufacturers having time to review Table 1 of the standard, complying with the standard is pretty straightforward if you are performing any of 18 tasks in Table 1.

Table 1 tasks involve exposures to respirable crystalline silica when the following tools are used on concrete, brick, block, stone, mortar, and other materials that contain crystalline silica:
  • Stationary masonry saws;
  • Handheld power saws;
  • Handheld power saws for cutting fiber-cement board;
  • Walk-behind saws;
  • Drivable saws;
  • Rig-mounted core saws or drills;
  • Handheld and stand-mounted drills (including impact and rotary hammer drills);
  • Dowel drilling rigs;
  • Vehicle-mounted drilling rigs;
  • Jackhammers and handheld powered chipping tools;
  • Handheld grinders for mortar removal (i.e., tuckpointing);
  • Handheld grinders for uses other than mortar removal;
  • Walk-behind milling machines and floor grinders;
  • Small drivable milling machines;
  • Large drivable milling machines;
  • Crushing machines; and
  • Heavy equipment and utility vehicles when used to abrade or fracture silica containing materials (i.e., hoe-ramming or rock ripping) or used during demolition activities; and 
  • Heavy equipment and utility vehicles when used for tasks such as grading and excavating.
Doing tasks in this manner, we hope will be a thing of the past!
If your work involves Table 1 tasks then determine how long your workers do those tasks and follow the requirements.  If the requirements require a respirator then you may want to reduce the time period a worker does a task so a respirator is not required.  This would be considered an administrative control under hierarchy of controls and perfectly acceptable.  Once you have determined the tasks, the controls, and time periods, the next step is to write your exposure control plan.  The exposure control plan details the tasks, controls, and time periods/respirator requirements and designating a competent person to ensure the exposure control plan is enforced.  The final step is to train the workers and the competent person on the exposure control plan so everyone understands and knows what is required under the plan.

Wearing A Respirator, Adds Significant Costs for Silica Projects

If your exposure control plan requires respirator, then you must meet the requirements of the respirator standard 1910.134, see our blog post regarding the directive which tells you how this standard would be enforced.  This standard would require a medical evaluation of workers to ensure they can wear a respirator, annual respirator fit testing, and annual training on the use of the respirator.  Respirator standard would also require a written program and the designation of a competent person to administer the written program.  In addition, the silica standard would require you provide a medical exam, specifically for silica, if workers use respirators for 30 days or more in a calendar year.  This medical would be required every 3 years.  The medical must include:
  •  medical & work history; 
  • chest x-ray;
  • pulmonary function test; 
  • physical exam focused on the respiratory system; and
  • testing for latent tuberculosis infection.  
After all of the above, the final steps in compliance is maintaining the records, in accordance with 1910.1020, and updating the plans on an annual basis.  1910.1020 standard requires that exposure records be maintained for 30 years from the date of creation and medical records be maintained for duration of employment plus 30 years. 
More Projects Will Look Something Like This
Based on the above information, we think it is pretty obvious that you want to eliminate tasks that involve the use of respirators or reduce the amount time a worker does a task that might require a respirator.  Doing so eliminates the need for the silica medical exam and all the requirements under the respirator standard.  The long term costs involved with meeting the requirements for using a respirator (silica medical exam & respirator standard requirements), we think would outweigh the cost of improving equipment used by workers to meet the requirements of Table 1 for each of the tasks.  We have added some silica courses to our schedule to help you comply with the new standard.  Visit our website for more information.  Happy New Year and Be Safe!  

Monday, April 13, 2015

NIH Still Active in Gulf Region Five Years After Oil Spill

NIH Still Active in Gulf Region Five Years After Oil Spill - as we've written in the past, the increase use of respirators during disasters is a necessary step to prevent worker exposure to contaminants that make them sick immediately or in the future.  Respirator use during disasters continues to be optional when it should be mandatory.  Disasters typically involve exposures to asbestos, silica, lead, poly-chlorinated biphenyls (PCBs), etc.  The only way to protect yourself from many of these contaminants is through the use of properly fitted air-purifying respirators.

English: Respirator
English: Respirator (Photo credit: Wikipedia)
A properly fitted air purifying respirator will protect workers for most disaster and demolition exposure issues.  Providing workers with this type of respirator requires that you meet the Occupational Safety and Health Administration's (OSHA) 1910.134 respirator standard.  The standard is not that difficult to comply with.  It does require a plan for respirator use (selecting the type of respirator that will protect workers), medical evaluation for employees using respirators (to ensure they can wear the respirator), fit testing (to ensure the employee wears the correct size and it fits), and training the worker (so they know how to wear a respirator and its limitations).  There are other requirements but these are minimal compared to the four main requirements listed above.

Thursday, October 16, 2014

Future Environment Designs Participates in the North Country Honor Flight’s First Annual Golf Tournament

Written by: Kimberly Granmoe, Executive Assistant

On Sunday, July 20, Future Environment Design (FED) participated in the North Country Honor Flight (NCHF) Golf Tournament held at the North Country Golf Course in Rouses Point, NY.   It was a beautiful day for the tournament, blue skies with temperatures in the low 80’s.  What a great turnout for the organization’s first fundraising tournament.  Approximately 168 golfers registered to participate in the golf tournament intended to raise money for the mission of the North Country Honor Flight.   The North Country Honor Flight, part of the Honor Flight Network, is a local non-profit organization created solely to honor America's Veterans for all their sacrifices.  Their mission is to transport America's Veterans to Washington, D.C. to visit those memorials dedicated to honor their service and sacrifices.


Future Environment Design's Golf Team

Future Environments Designs was represented by Kimberly Granmoe, Executive Assistant, and Sheryl Esposito, Marketing Assistant.  They teamed up with Troy Granmoe, Kimberly’s husband, and Justin, Kimberly's & Troy's son.  The golf tournament was a best ball-scramble and our team shot an overall score of 76, placing midway among the 35+ teams.
   
Kimberly & Sheryl at the 11th Hole
In addition, to sponsoring a team,  Future Environment Designs also sponsored the 11th hole flag.  Kimberly Granmoe, when she's not assisting Angelo Garcia, III, volunteers as an event coordinator for the NCHF.  As Event Coordinator, Kimberly coordinates flags to be flown over the Pentagon on the day the Veterans are visiting the WWII Memorial in Washington, DC.  The flag is then presented to each Veteran in a flag case together with Certification that the flag was flown in recognition of the Veterans Honor Flight visit to the WWII Memorial and in recognition of the Veterans service to our Nation.

Kimberly with Mr. Morgan Mickalsen, WWII Vet

Upon completion of the tournament, all participants enjoyed a turkey dinner, with all the trimmings, which was followed by an auction consisting of over a 100 items donated from local area businesses.  The Golf Tournament generated  over $27,000 for the NCHF.  The NCHF together with the Honor Flight Network will continue to do whatever it takes to fulfill the dreams of our Veterans and help our heroes travel absolutely free.   It is our way of paying a small tribute to those who gave so much.  Currently, top priority is given to America's most senior heroes — survivors of World War II and any veteran with a terminal illness who wishes to visit THEIR memorial.  Since America felt it was important to build a memorial to the service and the ultimate sacrifice of her veterans, the Honor Flight Network believes it's equally important that they actually get to visit and experience THEIR memorial.

If you know of any WWII Veterans interested in taking a trip of a life time or you are interested in volunteering or donating, please contact the organization at North Country Honor Flight, PO Box 2644, Plattsburgh, NY  12901 or email northcountryhonorflight@westelcom.com.



Friday, September 05, 2014

September 5 is N95 Day - Whaaaaaat??

According to the National Institute of Occupational Safety and Health (NIOSH) today September 5 is N95 Day.  NIOSH says, "N95 Day is a time to recognize the importance of respiratory protection in the workplace and familiarize yourself with the resources available to help you make educated decisions when selecting and wearing a respirator."  To celebrate, NIOSH will be providing N95 filtering facepiece respirator information through social media channels such as a Twitter chat, a webinar, and new infographics.  For more information visit there website at:  http://www.cdc.gov/niosh/npptl/N95Day.html.


Interesting thing to us is why celebrate the N95 filtering facepiece respirators?  Filtering facepiece respirators have their place in protecting workers from respiratory hazards, however, that place is very limited.  This type of respirator cannot and should not be used for respirable dusts like asbestos or lead.  Nor should it be used for vapors or mists or gases.  As the picture above from Ground Zero - 9/11 World Trade Center rescue, recovery and cleanup shows, knowing which respirator to wear was one of the problems for the workers who worked there.  The picture shows workers wearing filtering facepiece respirators and half mask air purifying respirators.  Considering the contaminants (asbestos, mercury, PCBs, to name a few) at the site, filtering facepiece respirators should not have been a choice at all.  This is probably the main reason to have an N95 day is to make sure people understand the limitations of this type of respirator.  But why limit it to filtering facepiece respirators, we should be celebrating all respirators!  So for our part we say Happy Respirator Day!

Thursday, August 28, 2014

OSHA Releases New Respiratory Protection Directive

The Occupational Safety and Health Administration (OSHA) issued directive number CPL 02-00-158 "Inspection Procedures for the Respiratory Protection Standard".  This new directive gives instructions to OSHA compliance safety officers and area directors on interpretations and enforcement policies for enforcing the respirator standard 1910.134.  This directive cancels and supersedes the previous directive CPL 02-00-120 dated September 25, 1998.  Directives are used by OSHA to ensure the standards are enforced uniformly across the country.  These directives are useful resources in that they inform the industry, and employers how OSHA intends on enforcing the respirator standard.


Changes to this revision include: updated definitions section to include definitions for assigned protection factors (APF) and maximum use concentrations (MUC); greater clarification on voluntary respirator use, and a better explanation of a compliant respirator program and provides additional acceptable methods to assess respiratory hazards; updates the directive with information related to the revised Hazard Communication standard (1910.1200); and provides guidance on evaluating the need for respiratory protection for chemicals used in workplaces by referring to employer's Hazard Communication program wherein chemical manufacturers communicated the need for respiratory protection.

Muster einer Atemluft-Einwegmaske
Muster einer Atemluft-Einwegmaske (Photo credit: Wikipedia)
According to this directive if employers require employees to wear respirators for the protection against TB they must be in compliance with the respirator standard 1910.134.  Probably the most interesting portions of the directive are the modifications to voluntary use of respirators.  According to the directive, it was the intent of the standard that the employer would not be required to incur any costs associated with voluntary use of filtering  facepiece respirators (dust masks) other than providing a copy of Appendix D of the standard to each user.  OSHA is concerned that voluntary use may cause an employee's health being jeopardized by the wearing of a respirator, or the wearing of a dirty respirator that can cause dermatitis or ingestion of a hazardous chemical, and the sharing of a respirator that leads to transmittal of disease.

Voluntary use of filtering facepiece respirators is one of the most misunderstood sections of the respirator standard.  Some points from the directive: NIOSH-approved filtering facepieces are strongly recommended but are not required; voluntary use does not require the employer to have a written program; and merely posting Appendix D is not considered adequate.

The directive is a useful resource to give employers an indication of how OSHA will enforce the respirator standard and it is a useful tool to help avoid citations or to fight violations.  

Monday, June 03, 2013

Future Environment Designs Will Be Exhibiting at Plattsburgh Business Expo

We are looking forward to our annual exhibit at the 25th Annual Business Expo on this Thursday, June 6, 2013 at the Plattsburgh State University Field House.  Join us from 10 AM to 5 PM and we can discuss the various training courses we provide in the area.  We hope to see you there!  In addition, if you "Like" the North Country Chamber on Facebook you can get Free Admission.  Follow the link below:


25th Annual Business Expo - June 6thBusiness Expo
Don't miss the largest networking event of the year!
180 Businesses will showcase their products and services this Thursday, June 6th at the SUNY Field House. Join us from 10 - 5 to learn what area businesses can do for, enter to win hundreds of prizes, and make new business contacts. 
Admission is $5. Or, Like the North Country Chamber on Facebook TODAY for Free Admission.    The VIP List will be printed tomorrow - so be sure to Like us Today and you will be on the list for free admission. Click for more info
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Saturday, April 20, 2013

NY Times Article Criticizing OSHA, Doesn't Criticize It Enough!

On March 30, 2013, the New York Times wrote the article "As OSHA Emphasizes Safety, Long Term Health Risks Fester."  You can click on the title of the article to read the article if by chance you have not read it or saw it.  As many of you know I am a sharp critic of the Occupational Safety and Health Administration (OSHA) and their inability to protect worker health at Ground Zero, at the BP Oil Spill, Katrina, etc, etc, etc!  Here is another sad case of OSHA failing to do their job and claiming there is nothing they can do!  Are they kidding us!  Lets see the facts in this case:

  • The culprit in this chemical exposure story is a chemical known as n-propyl bromide, or nPB.  “Medical researchers, government officials and even chemical companies that once manufactured nPB have warned for over a decade that it causes neurological damage and infertility when inhaled at low levels over long periods…”  So we know that exposure to this chemical is hazardous (fact!).

  • 3D diagram of n-propyl bromide molecule. Prepa...
    3D diagram of n-propyl bromide molecule. Prepared with Discovery Studio Visualizer 1.7 and GIMP 2.2 (Photo credit: Wikipedia)
  • Did we have an exposure?  “For about five years, Ms. Sheri Farley, 45, stood alongside about a dozen other workers, spray gun in hand, gluing together foam cushions for chairs and couches sold under brand names like Broyhill, Ralph Lauren, and Thomasville.  Fumes from the glue formed a yellowish fog inside the plant, and Ms. Farley’s doctors say that breathing them in eventually ate away at her nerve endings, resulting in what she and her co-workers call “dead foot”."  That sounds like an exposure to us (fact!).
  • What did the employer do to protect the workers?  “Even as worker after worker fell ill, records from the Occupational Safety and Health Administration show that managers at Royale Comfort Seating, where Ms. Farley was employed, repeatedly exposed gluers to nPB levels that exceeded levels federal officials considered safe, failed to provide respirators and turned off fans meant to vent fumes."  So the employer knew the dangers and didn't protect the workers (fact!).
  • What's a willfull violation?  According to OSHA, a willfull violation is a violation that the employer intentionally and knowingly commits or a violation that the employer commits with plain indifference to the law.  OSHA may propose penalties of a maximum of $70,000 for each willfull violation (fact!).
So if you buy into this argument that OSHA is powerless to act.  Then why did violations only total, as per the article, "less than $20,000 in OSHA fines related to glue fumes."  That is a travesty!  OSHA needs to wake up and do its job.  

What does the Director of OSHA have to say about this?  “I’m the first to admit this is broken,” said David Michaels, the OSHA director, referring to the agency’s record on dealing with workplace health threats.  “Meanwhile, tens of thousands of people end up on the gurney.”  You're the director and that's your answer.  Get your act together and fix the problem.  You know there's a problem and you're not fixing it.  You should be fired!  You've been the OSHA Director for what four years and we must admit you've done a lot of good.  However, at the same time this issue of protecting worker health has continued to fester and you know its broken and you haven't fixed it.  If you were on Donald Trump's Apprentice program, you would've been fired.


Let's look at the issue that the business claims they can't afford to protect workers.  Based on the article it says Royale "which employs about 100 workers and had around $7.5 million in sales in 2011",  in addition, Royale has also "paid nearly a half-million dollars - in court settlements, required upgrades....".  Where did these business owners get their education on running a business?  Here are some statistics from the article that makes you wonder about business owners and support a need for OSHA to do a better job of protecting worker's health:

  • "Chronic ailments caused by toxic workplace air - black lung, stonecutter's disease, asbestosis, grinder's rot, pneumoconiosis, - incapacitate more than 200,000 workers in the United States annually.  More than 40,000 Americans die prematurely each year from exposure to toxic substances at work - 10 times as many as those who die from refinery explosions, mine collapses and other accidents that grab most of the news media attention."
  • Occupational illnesses and injuries like Ms. Farley's cost the American economy roughly $250 billion per year because of medical expenses and lost productivity, according to government data analyzed by J. Paul Leigh, an economist at the University of California, Davis, more than the cost of diabetes or chronic obstructive pulmonary disease.  Roughly 40 percent of medical expenses from workplace hazards, or about $27 billion a year, is paid by public programs like Medicare and Medicaid."
In our opinion, it would be more effective to have a respiratory protection program using respirators and proper filters.  The probable cost of a respiratory protection program for 100 workers would be around $40,000.  It seems to us it would be cheaper to provide the workers with respirators than to pay for court settlements, worker's compensation insurance costs, disability insurance costs, etc.  It is way past time we started recognizing the need to push respirator use to handle situations that either the political will, financial will, or just plain indifference is not protecting workers.
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That Time of Year! Conferences, Posting Requirements, and OSHA Violations Increased!

It's that time of year again. We're between conferences.  February 15-16, 2024 was the Professional Abatement Contractors of New Yor...