Should We Be Wearing Better Masks? The Best Face Covering Is The One That Is Worn Properly & Used!

We recently read two articles in The Atlantic called "Why Are Americans Still - Still! - Wearing Cloth Masks?" and "Why Aren't We Wearing Better Masks?" and another in Scientific American called "Why We Need to Upgrade Our Face Masks - and Where to Get Them".  All three articles discuss why Americans are still wearing cloth face-coverings now that N95 respirators (or the KN95 respirators, these respirators are made in China and are not approved by the National Institute of Occupational Safety and Health (NIOSH)) are more readily available (The NIOSH Science Blog discusses the roles NIOSH, Occupational Safety and Health Administration (OSHA) and the Food and Drug Administration (FDA) play regarding respiratory protection).  The articles mention a new study not peer-reviewed yet from Bangladesh which claims that wearing surgical masks decrease COVID-19 symptoms and antibodies by 11.2 percent, while cloth masks only led to a 5 percent decrease.  It proceeds to give several reasons why we continue to use face-coverings from public-health agencies not prioritizing surgical masks and N95 respirators to price to supporting one's sports team.  Two of the articles describe how face-coverings are far better than nothing and also saying how cloth masks are more eco-friendly (The Covid Crisis Is Now a Garbage Crisis, Too) giving face-coverings a backhanded credit for helping when nothing else was available.  The articles, in my opinion, even support the notion that we should be buying KN95 respirators even though they are not approved by NIOSH.  If anything shouldn't we be buying American-made N95 respirators so we can increase the demand and hence increase the supply of masks that are made here?  This was the subject of a New York Times article "Can't Find an N95 Mask? This Company Has 30 Million That It Can't Sell" and the Washington Post article "In the early days of the pandemic, the U.S. government turned down an offer to manufacture millions of N95 masks in America."

Two suppliers of N95 respirators

Let us first say as a person, who believes in the use of respirators and their importance in protecting individuals from exposure to hazardous substances (see all our posts regarding 9/11), we agree that N95 respirators or surgical masks would protect people better from SARS-CoV-2 than cloth face-coverings if worn correctly.  However, we would need to be able to provide each person N95 respirators (in their size either small, medium, or large) or surgical masks, make sure they had a sufficient supply to meet their needs, make sure the N95 respirator fits each person, make sure they understand how to wear the N95 respirator or surgical masks correctly, and finally, they are provided a means of disposal for the respirators or the surgical masks.  As you can imagine that would be a significant cost to the government (or tax-payers) and would require a significant undertaking to make sure every American would be protected by using N95 respirators or surgical masks.  Meanwhile, the biggest issue is whether we are talking N95 respirators, surgical masks, or face coverings they must be worn correctly to protect you, and remember facial hair reduces the effectiveness of all these face coverings.  See the chart below for various ways of improperly using face coverings.  The Centers for Disease Control and Prevention (CDC) website "Types of Masks and Respirators" was updated as of September 23, 2021, and provides information on types of masks and when to wear them and now includes a section on considerations for children.

Both these articles treat surgical masks and N95 respirators as simple items to wear and that anyone can wear them.  However, this is not a fact as we mentioned above N95 respirators require medical clearance, fit testing, and training all mandated by OSHA for individuals that are required to wear them.  As for surgical masks, we have to remember the ones that are typically sold to the public aren't actually surgical masks.  Surgical masks are cleared by the FDA, see the chart below for the difference between the N95 respirators and surgical masks.  Note that surgical masks do not provide the wearer with a reliable level of protection from inhaling smaller airborne particles.  This is for FDA-cleared surgical masks, which means the ones the public purchases probably aren't reliable either considering they are not cleared by FDA.

Surgical Masks vs N95 respirators

However, the use of cloth face-coverings has been shown to reduce the emission of virus-laden droplets (source control) and help reduce inhalation of these droplets.  The CDC website "Use of Cloth Masks to Control the Spread of SARS-CoV-2" which was last updated on May 7, 2021, provides some significant research on how the use of cloth face-coverings block the transmission of respiratory droplets with some face-coverings performing on par with surgical masks as barriers for source control.  In the section "Human Studies of Masking and SARS-CoV-2 Transmission" data regarding the "real-world" effectiveness of community masking is limited to observational and epidemiological studies with many of these showing significant levels of protection from wearing face coverings.  An example of one of these was "A study of an outbreak aboard the USS Theodore Roosevelt, an environment notable for congregate living quarters and close working environments, found that use of face coverings on-board was associated with a 70% reduced risk of transmission.

Note the circled area of the package (which means they are not surgical masks). 

It is our opinion, one of the main reasons face-coverings are better is because they are easier to use, easier to breathe through, light-weight, and because of these things more likely to be used and used correctly.  Wearing the face-covering correctly and using the face covering is what is helping reduce transmission of SARS-CoV-2.  So follow the CDC guidelines on when to use face-coverings and let's stop the spread!

Related Articles:

Filtering Facepiece Respirator or a Dust Mask or N95 Respirator versus a Surgical Mask

Governor Cuomo Announces Schools Can Open. Can They or Should They?

September 5 is N95 Day - Whaaaaat??

Future Environment Designs Wishes You a Happy Labor Day Weekend!

Future Environment Designs (FEDTC) wishes everyone a Happy Labor Day weekend!  In a year that seems to continue to challenge all of us, it is worthwhile to remember that this weekend and Monday in particular we are celebrating the contributions of the labor movement to the development and achievements of the United States of America (USA).  

Labor Movement in the 21st Century

The labor movement is a major part of American history that describes the history of organized labor, USA labor law, and the more general history of working people.  According to Wikipedia, "the nature and power of organized labor are the outcomes of historical tensions among counter-acting forces involving workplace rights, wages, working hours, political expression, labor laws, and other working conditions."  As commentator E. J. Dionne has noted, the union movement has traditionally espoused a set of values - solidarity being the most important, the sense that each should look out for the interests of all.

The Fire that Sparked the Labor Movement

Future Environment Designs hopes as we enjoy this weekend, we remember the importance of the labor movement and even more importantly we remember solidarity, the sense that each of us should look out for the interests of all!

Current Asbestos & Mold Hard Cards Required for Asbestos & Mold Projects! Fast Track Variances on Pause and New Asbestos Attachments for New York City DEP!

New York State Department of Labor (NYSDOL) as of July 31, 2021, is requiring current asbestos and mold hard cards for asbestos and mold projects.  Their latest automatic response email claims to be turning around asbestos hard cards in five (5) weeks and licenses in three (3) weeks.  That same NYSDOL email says they are turning around mold licenses in three (3) weeks.  So it seems the NYSDOL's license and certification unit is back to normal.  On the other hand, the New York City Department of Environmental Protection (NYCDEP) is allowing workers whose hard card expired on March 15, 2020, or later to continue to work using their existing card until August 31, 2021.  See NYCDEP's Extension of Asbestos Certification Deadline website for more information.  In addition, NYCDEP has reinstated the examinations for asbestos as of April 21, 2021. 

Asbestos Company License and Worker (hard card) Certificate

In our blogpost in February 2021, we discussed that NYSDOL's Engineering Services Unit (ESU) came out with 10 Fast Track Variances and that this was a pilot program.  On Thursday, July 22, 2021, the Professional Abatement Contractors of New York (PACNY) were notified by NYSDOL's ESU that they were shutting down the Fast Track Variance Program.  The following is quoted from the NYSDOL email to PACNY:

"As the results of an increasing number of questions concerning relief granted by some Fast Track Variances (FTVs), ESU has decided to temporarily stop the FTV program.  ESU will go back and review each FTV to ensure that the relief granted, and conditions listed in the FTV are consistent with ICR 56 and appliable Federal requirements.  ESU will also try to better define when and how each FTV can be utilized. There seems to be some confusion about how some FTV’s are to be used.  When ESU completes its review of an FTV, we will reissue that FTV for use moving forward.  It is ESU’s hope that this review will not take long. In the meantime, site-specific variances should be applied for as usual via email to me and cc: Edward.Smith@labor.ny.gov"

So it seems if you want an FTV, you will have to apply and wait the time it takes to approve site-specific variances (anywhere from 3-6 weeks).

Asbestos Inspector Initial Class

Meanwhile, NYCDEP Asbestos Program has issued two new attachments (NYCDEP's version of FTVs).  They include Attachment CS which is the "Requirements for the Abatement of In-Place ACM with or without ACM Debris in Crawl Spaces/Cellars with Concrete (Non-Soil) Floors Under Modified Containment (without plastic on the walls)" and Attachment CRS which is the "Requirements for the Abatement of Contaminated Soil with or without ACM Debris and/or Inplace Removal of ACM in Crawl Spaces/Cellars with Soil Floors Under Modified Containment (without plastic on the walls)".  Both of these attachments can be found on our website under our resources page under FED Training CD-Dropbox Folder.  In addition, we recently heard the NYCDEP was issuing violations for improper labeling of cassettes and sampling pumps not properly labeled.  It certainly seems NYCDEP has not changed its tactics of issuing fines for nonsense items versus making sure the actual work is being done correctly.  If you are a reader of this blog make sure you get credit for being a reader and enter the discount code FEDTCBLOG15 to get a 15% discount on our published course prices.

Future Environment Designs wins the 8th Annual Pro/Am PACNY Fishing Tournament

On the morning of July 7, 2021, Future Environment Designs participated in the 8th Annual Professional Abatement Contractors of New York (PACNY) Fishing Pro-Am Tournament.  The tournament was based out of the Lake Breeze Marina, Kent, New York, and on Lake Ontario.  It was an iffy day with a thunderstorm passing through just before the tournament started and the lake was a bit rough with 2-4 foot waves.  There were 17 boats in this year's tournament (a nice turnout considering the recent easing of Covid restrictions).  They were:

The lake was a little rough which made for some interesting fishing.

1. AAC Contracting - Free Spirit 
2. Cornerstone Training Institute (CTI) - Sunrise II 
3. CTI - Legacy
4. CTI - Trolling Tails
5. Lozier - Screaming Reels 
6. US Ecology - Reflection
7. US Ecology - Shotgun
8. Metro - Rusty Lure
9. Dival - Reel Excitement
10. Abscope - Troutman
11. Sienna - Get Hooked
12. ECG - Richmond 4
13. Future Environment Designs - Catchin Hell
14. Sessler - Intimidator
15. Aramsco - Mister
16. First On-Site Restoration - 3 Dogs
17. HSE - Bite Me 

Future Environment Design's fishing team consisted of Ms. Sheryl Esposito, Mr. Matthew Desch, Ms. Veronica Hansen Garcia, and Mr. Angelo Garcia, III.  This was the first year that Future Environment Design's team was more than two people.  We were thrilled to have Sheryl and Matt with us this year.  Most of you have met Sheryl and Matt at the annual PACNY Conference at Turning Stone Casino in Verona, NY.  Sheryl is usually womaning our booth at the Conference.  Unlike other Tournament years, because of the rough lake, we went straight out and did not do a shotgun start.  Because of the rough water, Captain Tom Murray of the Catch 'N' Hell boat decided to go far out and work our way back.  Which was a good decision considering how it turned out.  It definitely was our day considering our first catch was the one that won big fish for the day!

The winner weighing in at 25.66 lbs.

We had the good fortune to catch enough Salmon & Trout to last us the entire year and fill our freezer (including sharing with Sheryl and Matt)!  By the time we had to decide whether to go in or keep fishing, we had caught sufficient fish to decide to call it an early day at 11 AM (based on the weather that was a good decision).  Our second and third salmon catches brought us the Trophy and the prize money for the Tournament:

Future Environment Designs and the Catch 'N' Hell Team

We are so proud to finally have our name added to the Trophy and that it only took 8 years to win the trophy.  This was the second time, we've caught the big fish the first time was the Second Annual Tournament.  The buffet (back again now that Covid restrictions have eased) at the Black North Inn was delicious roast beef with weck bread and horseradish.  A great big THANK YOU to Darren Yehl of CTI for organizing this Tournament!  Between our daughter's wedding, training beginning to return to normal, and this fishing tournament the summer has been a blessing but is going too quickly.  This year is the 6-year anniversary of Article 32 NYS's Mold Law and most everyone's license will be expiring between September and January 2022.  Look forward to seeing all of you soon and regaling you with my fishing adventures!

Happy 4th of July!

Future Environment Designs, Inc. would like to wish all our clients and friends a very Happy 4th of July!  We hope your celebration is a joyful one, a safe one, and one that remembers the importance of leaving this country better off for our children and our children's children!  We would like to remember the words Theodore Roosevelt said regarding the USA:

Blessed Be America!

Future Environment Designs Celebrates the New Normal with New Pricing!

We are now fully open that the Centers for Disease Control (CDC) has decided that fully vaccinated people can resume normal activities and New York State has announced that 70% of New Yorkers have received the first dose.  We have updated our pandemic policy to meet the new requirements.  When you attend training with us please provide proof that you have been vaccinated so we can allow everyone to not wear face coverings.  We strongly recommend the use of the New York State Excelsior Pass System.  The system creates a wallet on your smartphone to allow you to present proof that you've been vaccinated.  If you are not vaccinated, you can either attend a virtual training course or attend an in-person course as long as you wear a face-covering (as per CDC recommendations).

To celebrate the new normal or the return to normal we have decided to adjust our pricing to be more in line with the New York State market, in addition, readers of this blog can now claim a discount on our new prices.  When registering for your class just enter the code FEDTCBLOG15 to get a 15% discount on our published course price.  Remember we still provide our best discounts to our loyal customers (25%).  As part of the online (virtual) requirements, we were required to create class interactions and a way to administer the exam.  Since these have been successful in the virtual classes, we will continue to allow students to take the exam at our Learning Management System (Administrate LMS portal) and will continue using Poll Everywhere to spark conversations in our classes.  To be able to do that you should bring an electronic device (laptop, iPad, smartphone, etc.) to our classes.  We will still have paper exams for those who want to take the exam the old-fashioned way or we don't have internet access.

We've been very busy creating eLearning courses.  We've just finished creating a Lead in Construction Awareness Course and will be completing a Mold in Construction Awareness Course, soon.  We can bundle these courses together with our Asbestos Awareness Course to create an entry-level certificate course (ALM) Asbestos, Lead, and Mold in Construction Awareness or add our Silica in Construction course to create another entry-level certificate course (SLAM) Silica, Lead, Asbestos, and Mold in Construction Awareness.  The ALM certificate course costs $65 and the SLAM certificate course costs $75.  These are significant savings from taking the courses separately.  Please contact us at 1-800-969-3888 to set these courses up for your staff.

Finally, those of you who have attended our classes for years have met Alyssa, my daughter, and remember her cute way of saying wetter-water.  Well, we're happy to announce that Alyssa got married in May to a wonderful woman Sarah Jednak.  We are so happy to have Sarah officially join the family.  We look forward to seeing everyone soon!

Is There an Appropriate End Date for Asbestos Use?

When we first became an asbestos consultant over 39 years ago, we remember people telling us that buildings will remove all their asbestos materials in 5 years, 10 years, or 15 years depending on who we talked to.  Well, asbestos is still in buildings and this article is about why there are many years still left in this industry.  In the construction industry, there are some who think that a certain year was the end of asbestos use in building materials.  Over the years we have reviewed many asbestos inspection reports or property transfer reports (phase I environmental audits) reporting that since a building or a part of a building was built after 1980 there are no asbestos-containing materials.  The companies making this statement assume that the federal government banned all asbestos-containing materials in 1980.  In New York State, the Department of Labor (NYSDOL), which regulates asbestos abatement, uses the year 1974 in the regulations for determining which buildings require the assumption of building materials that contain asbestos.  While the federal government, under the Occupational Safety and Health Administration (OSHA) regulation 1926.1101 (k) (1), requires building owners to presume surfacing materials, and thermal system insulations, installed prior to 1980, to contain asbestos.  To refute this presumption these materials must be sampled.  Regarding asphalt and vinyl flooring materials installed no later than 1980 must also be considered asbestos-containing or sampled to refute the designation.  In addition, the regulation also requires if the employers/building owners have actual knowledge, or should have known through the exercise of due diligence, that other materials are asbestos-containing they too must be treated as such.  Owners are required to handle these building materials as asbestos-containing materials (ACM) until a certified asbestos inspector takes samples of the materials, in accordance with the Environmental Protection Agency's (EPA's) Asbestos Hazard Emergency Response Act (AHERA), and the samples verify the materials do not contain asbestos (which usually means multiple samples of the building material have to been taken and all samples must have results that no asbestos is in the building material).  However, are 1974 or 1980 appropriate dates to use in making a determination whether building materials can contain asbestos?  We think not!

Terrazo?

The Ban and Attempts to Ban Asbestos

The federal agency with the responsibility for banning asbestos is the EPA.  This agency, under the National Emissions Standards for Hazardous Air Pollutants (NESHAPS), banned the use of asbestos for sprayed-on application of fireproofing and insulating in 1973 and for decorating purposes in 1978.  In 1975 EPA’s NESHAPS regulation also banned the installation of pre-formed (molded) asbestos block insulation on boilers and hot water tanks and the wet-applied and pre-formed (molded) asbestos pipe insulation.  Since two of these bans did not go into effect until after 1974, the New York State end of use date is not appropriate and the construction industry should not use it to determine buildings that contain asbestos.  In 1985 EPA published "Guidance for Controlling Asbestos-Containing Materials in Buildings" which has become known as the "Purple Book".  The Purple Book in Appendix A has a list titled "Asbestos-Containing Materials in Buildings".  This list shows a large number of asbestos-containing materials that were still being used in 1981.  Based on this information, it seems 1980 is not an appropriate end date for asbestos use, including asphalt and vinyl flooring materials.  Under a separate regulation, the Toxic Substances Control Act (TSCA), EPA tried to ban and phase out the use of asbestos in 1989.  In 1991 the “Asbestos Ban and Phaseout Rule,” as the rule became known as, was vacated and remanded by the U.S. Fifth Circuit Court of Appeals.  In 1993 EPA stated that corrugated paper, roll board, commercial paper, specialty paper, flooring felt, and new uses of asbestos were still subject to the ban.  Vacating the “Asbestos Ban and Phaseout Rule” meant that a number of building materials could contain asbestos such as asbestos-cement corrugated sheet, asbestos-cement flat sheet, asbestos clothing, pipeline wrap, roofing felt, vinyl-asbestos floor tile, asbestos-cement shingle, millboard, asbestos-cement pipe, automatic transmission components, clutch facings, friction materials, disc brake pads, drum brake linings, brake blocks, gaskets, ceiling tiles, non-roofing coatings, and roof coatings are not banned and could still be used in buildings.  The recent attempt to ban asbestos was made under the amended TSCA regulation.  In 2016, President Barak Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act that amended TSCA and made needed improvements to the law including requiring risk-based chemical assessments.  In 2019 EPA published a final rule called the Significant New Use Rule (SNUR).  The SNUR requires manufacturers and importers to receive EPA approval before starting or resuming manufacturing and importing or processing of asbestos.  Materials subject to this law include adhesives; sealants; roof coatings; arc chutes; beater-add gaskets; extruded sealant tape; and other tapes; filler for acetylene cylinders; high-grade electrical paper; billboard; missile liner; packings; pipeline wrap; reinforced plastics; roofing felt; separators in fuel cells and batteries; vinyl-asbestos floor tile; cement products; woven products; and any other building material.  It is obvious that this law does not ban asbestos nor does it really answer the question of how much asbestos is in commerce currently.  

Electrical wire insulation

Asbestos Used Still Today

Is there an appropriate end date for asbestos use in buildings?  Some headlines indicate the answer to this question is no.  These headlines indicate that some current building materials are contaminated with asbestos or still contain asbestos sufficiently enough for the materials to be considered asbestos-containing materials.  For example, the Asbestos Disease Awareness Organization (ADAO) reported in November 2007 that they sampled a number of current building materials and determined that DAP’s “33” window glazing and “crack shot” spackling paste and Gardner’s leak stopper roof patch all contained asbestos.  DAP’s “33” window glazing was purchased at Home Depot and Lowes for the purpose of the study and contained 2.6% tremolite, and 0.13% chrysotile asbestos (2.73% total asbestos).  DAP’s “crack shot” spackling paste was also purchased at Home Depot and Lowes and contained 0.98% tremolite, and 0.066% chrysotile asbestos (1.05% total asbestos).  Gardner’s “leak stopper roof patch,” along with other products by Gardner, is listed with the National Institute of Health as known asbestos-containing material on the open market and contained 11% chrysotile asbestos.  It is important to remember that the definition of asbestos-containing materials is any material that contains greater than 1% of asbestos in the material.  Though this does not apply to the OSHA asbestos regulation which is more concerned about how much asbestos gets in the air from a material that contains any asbestos.  In addition, the New York Times reported on July 20, 2001, that W. R. Grace & Company’s Monokote (probably #5) fireproofing spray product (used in the late 1980s) was contaminated with tremolite asbestos.  The Seattle Post-Intelligencer reported on February 8, 2005, that seven of W. R. Grace & Company’s current or former executives were indicted on federal charges that they knowingly put their workers and the public in danger through exposure to vermiculite ore contaminated with tremolite asbestos from its mine in Libby, Montana.  In 1990 W. R. Grace & Company closed the mine but the ore was used as attic and wall insulation, wallboard, and fireproofing into the early 1990s.  The asbestos content in these materials can be as high as 2%.  In research conducted by EPA on vermiculite attic insulation in 2001 and 2002, found homeowners that use their attics could be exposed to airborne asbestos fibers above the OSHA permissible exposure limit (0.1 fibers/cubic centimeters).

asbestos woven products

The Liability of Ignorance

Since there is no total ban on the use of asbestos in building materials, it means that 1974 or 1980 are not appropriate cut off dates on the use of asbestos in building materials.  This means all buildings or facilities no matter when they were constructed should be inspected for asbestos-containing materials.  EPA's NESHAP regulation 40 CFR 61.145 Standard for demolition and renovation requires buildings/facilities to be thoroughly inspected before the renovation or demolition, no matter what date the building was built.  It also means that the construction industry should be very careful when working on buildings after these dates because it is possible that if an asbestos inspection or survey was done it may have not been done properly.  From our experience, we've seen inspectors not sample roofing materials, joint compound, sheetrock, textured paint, siding shingles, and window caulking just to name a few building materials that should be sampled.  Building owners, banks, facility managers, architects, engineers, general contractors, and subcontractors should not think that because the EPA regulation requires an inspection, and if the inspection is not done correctly that there is no chance for a violation or liability.  OSHA requires that employers inform their workers of all the potential hazards at a project (job) site.  Should materials that were not inspected turn out to be asbestos-containing or even if the sample result is 1% or trace asbestos and the exposure exceeds the permissible exposure limit (0.1 fibers per cubic centimeter based on an eight hour time-weighted average) or the excursion limit (1.0 fibers per cubic centimeter over thirty minutes) the employer would be in violation of the OSHA asbestos regulation.  No matter the construction date of the building.  The building owner could then face third-party litigation from the workers if they develop a disease (mesothelioma being the most significant because of its direct tie to asbestos exposure) from such an exposure.  In addition, the AHERA regulation which applies to public and private schools (kindergarten to 12th grade)  requires that architects that design new schools or renovations of existing schools certify that the building materials used do not contain asbestos.  Utilizing safety data sheets (SDS), which are required for most building products, to certify the products would not be sufficient considering that DAP’s SDS (discussed above) did not mention the asbestos contamination in the product and the NESHAPS regulation requires building materials to be sampled for the content of asbestos.  Meaning the only way to certify the products to limit liability would be to have suspected materials sampled and analyzed for asbestos.  It is very important for building owners, banks, facility managers, architects, engineers, general contractors, sub-contractors, asbestos inspectors, and phase I environmental auditors to realize that although the asbestos regulations refer to dates before 1980, inspections are advisable and required under the EPA's NESHAPS & OSHA's asbestos regulations since the installation of asbestos-containing materials into buildings can continue to this day.

Fire Door