The goal of many safety professionals is to reduce risks in order to prevent injuries. So why is the “Zero Injury” metric a goal that seems attainable by some organizations and impossible to others?

How often do we see a “mature” safety program – one that is compliant with Occupational Safety & Health Administration (OSHA) regulations, consensus and industry standards – reach the point of diminishing returns with the typical incentives and milestone celebrations? It’s easy to blame that on the organization’s “safety culture” – that nebulous, non-measurable metric that is a critical part of every program.

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Update on ANSI/ASSE Standards

Falls are the leading cause of fatalities in construction, accounting for about one-third of all fatalities in that industry. The Bureau of Labor Statistics reported that there were 291 fatal falls to a lower level in construction in 2013, out of 828 total fatalities. According to the Occupational Safety & Health Administration (OSHA), the standards for fall protection “deal with both the human and equipment-related issues in protecting workers from fall hazards”.

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A new report from the Centers for Disease Control (CDC) provides an update on infections associated with potable (drinking) water in the United States. During 2011-2012, a total of 32 outbreaks were reported causing at least 431 infections and 14 deaths. Two-thirds of these outbreaks were caused by Legionella.   Additionally, CDC reported that non-potable water from cooling towers, showerheads and fountains was responsible for an even larger number of cases, of which nearly all were caused by Legionella.

More recently, an outbreak of Legionnaires’ Disease in New York City resulted in twelve deaths and more than two hundred illnesses. The outbreak has been tentatively linked to a cooling tower on the roof of a new boutique hotel. This resulted in an administrative order to test and clean all cooling towers in New York City. Additionally, this summer, the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) released a new standard, 188(2015), designed to prevent Legionellosis associated with building water systems.

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Assessing the Risk

Dust inhalation as a health issue has received increasing scrutiny at construction and environmental remediation sites. Historically, the focus has been on inhalation of respirable particulates by workers, especially since instrumentation is readily available to provide real-time worksite data for particulates in air. However, the focus is now broadening to include health risks associated with contaminants contained in the airborne dust, and on more sensitive nearby receptors such as residences where dust may travel and settle. Dust-related risks thus vary as a function of two variables: dust concentration and contaminant concentrations in the dust.

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One of the challenges in performing an assessment for mold in a water-damaged building has been the lack of a uniform standard approach. Every building has different construction, and damage may result from one or more causes or contributing factors. Water damage and fungal growth in a building may be localized or building-wide.

How does an indoor environmental professional design an appropriate study given these considerations? That was the task set before the American Standards and Testing Methods (ASTM) Committee D22.08. Previous committees had tackled the issue of indoor mold inside a building as a part of a Phase I Environmental Site Assessment (E2418 – “Standard Guide for Readily Observable Mold and Conditions  Conducive to Mold in Commercial Buildings”); but there had not been a standard guide for assessment of  fungal growth in buildings.

Let’s start out with a few scientific “givens” – mold is ubiquitous to the environment; it is naturally present in every indoor and outdoor environment; and it can thrive in any environment where there is available, sustained moisture, a suitable food source, favorable temperature and pH. So, it is easy to understand how attempting to derive a strategy valuable to all buildings would not be easy.

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Hazards and Control

“Hot work” is the term used to define activity that involves open flame or that produces heat and/or sparks that are capable of initiating fire or explosions. Examples of such work include welding, grinding, brazing, polishing, cutting, soldering, and using torches.

Hot work represents one of the most significant health and safety risks in industrial and commercial settings and is a main cause of fires and explosions. Most people inherently understand the danger fire represents. However, in many industrial/commercial settings, fires are even more dangerous given the likely presence of flammable gases and liquids, numerous employees and other people in close proximity to the hot work, high amounts of ordinary combustibles (such as paper, cardboard, wood, dust and plastics), and the size of the commercial/industrial building itself. In these settings, external contractors are likely to perform most of the hot work; and these contractors are often unfamiliar with specific site procedures – such as evacuation routes, muster points, and type/location of emergency equipment like fire extinguishers and emergency pull stations (alarm activation). For these reasons, a detailed Hot Work Policy/Procedure and effective, targeted training are required to maintain effective operational control over this significant safety and health hazard.

Controlling Risk and the Permit System

To effectively control hot work risks, the first question to ask is whether the hot work can be avoided entirely. For example, instead of using a torch to cut, can shears be used? Instead of welding or radial saw cutting, can bolts or mechanical cutting be used? Can the hot work be performed off-site? If hot work cannot be avoided and must be conducted on-site, can these activities be performed in areas specifically designed for such work?

If hot work must be performed on-site, effective hazard control is especially important. All  individuals utilizing hot work equipment should be trained on its proper use, the site-specific Hot Work Policy/Program, emergency action plan(s), fire-extinguisher use, and alarm activation procedures. Other training may be required depending on the type of work being performed and site-specific policies and hazards.

Using a permit system is a good way to not only maintain operational control, but also to inform management and people in the immediate area that hot work is taking place. Permits should contain instructions for performing hot work; the date, time, location and type of hot work being performed; names of individuals involved and their specific roles; date and time of permit expiration; and any other pertinent site-specific requirements. Many examples of hot work permits exist on OSHA’s website (www.osha.gov) and on the Internet. Continue Reading →

What Are They, Who Needs One, And By When

This issue of HETI Horizons provides an overview of the Spill Prevention, Control, and Countermeasure (SPCC) Rule – including its applicability, requirements and implications. It is a federal regulation that impacts more than 400,000 facilities of all types nationwide, and there are potentially serious consequences, fines and penalties for noncompliance. Affected facilities were required to implement the SPCC Rule by November 10, 2011, but a high percentage of them remain unaware of requirements under the Rule and the risk exposures of being non-compliant.

It should be noted that this overview is not all-inclusive and does not cover state and local requirements that may impose additional or differing requirements to those in the federal SPCC Rule. Additionally, there are a number of other federal, state, and local codes and regulations that also apply to facilities subject to the SPCC Rule.

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History and Update

ASTM first issued guidance for performing due diligence environmental site assessments (ESAs), or Phase I’s, in 1993. The stated intent was (and remains) to assist the user with qualifying for certain “limited liability protections” (LLPs)  available under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The ASTM practice has undergone periodic revisions, and serves a common reference and protocol for the purpose of identifying, before acquisition or occupation of a property, if a release of oil and hazardous material (OHM) to the environment is present. ASTM “standard practice” E1527 defines information sources and records to be reviewed, outlines certain information to be obtained from governmental authorities and persons associated with the property, and performance of limited visual and physical inspection of the property. However, it is important to note that the use of the ASTM practice has always been voluntary and is not required to qualify for CERCLA LLPs.

The ESA process also plays a critical role in business decision-making and risk management – having been incorporated by banking, insurance and other financial services institutions into their internal due diligence processes. Thus, the Phase I has become an accepted industry practice for environmental risk evaluation.

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One of the current cutting-edge advances in home energy conservation is the use of spray polyurethane foam insulation. Although the chemistry has been around since the 1940s, the past ten years have seen the application expand in commercial buildings and high-end homes. Spray foam is applied to the structural elements of a house – often on the attic roof deck, on foundation footings, and within exterior wall cavities – to provide insulation, act as a vapor barrier, and reduce noise transmission. While most applications are for newly constructed buildings, spray foam may also be used to retrofit older buildings and homes.

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Claims involving structural fires pose many unique challenges. The origin of visible soot and char, as well as the extent of damage and need for specialized remediation techniques, means that claim professionals, among others, be informed on the most current consensus standards. HETI Horizons is pleased to publish this article, prepared by the Indoor Air Quality Association (IAQA) and the Indoor Environmental Standards Organization (IESO), on a new standard to evaluate HVAC systems following a structure fire.

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