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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Polychlorinated Biphenyls (PCBs) have historically been associated with use in dielectric fluids for transformers, light ballasts and other electrical devices. The use and disposal of this equipment has been strictly regulated under the Toxic Substances Control Act (TSCA), found in the federal code at 40 CFR 761.50. The Environmental Protection Agency (EPA) banned the use of PCBs in 1977 due to their ability to bio-accumulate in many species. The EPA considers high levels of PCBs to be “probable human carcinogens” and their use is reported to have adverse effects on the immune, reproductive and nervous systems. Today, the cleanup and disposal of PCB waste is regulated under the EPA Office of Solid Waste and Emergency Response.

PCBs have been identified in many lesser known uses – such as window caulk, masonry joint caulk, concrete expansion joints, grout and mastic. In many of these applications, Aroclor 1254 (the plasticizer of choice) was added at the job site to make the original product more pliable, durable and water-resistant. PCBs were used in concentrations ranging from 1% to 20% in these products and were widely used in buildings constructed or renovated between 1950 and 1978.

PCBs have been found not only in buildings but in applications ranging from airport runways to concrete water pipes and tanks. In addition, they are known to leach into porous materials such as concrete and masonry – causing these materials to become contaminated and treated as PCB remediation waste as well.

PCB Regulation…or Lack Thereof

Under TSCA, PCBs in products other than transformer oils are classified as “non-authorized” uses when the concentration exceeds 50 parts per million (ppm). In accordance with TSCA, these non-oil products must be removed and properly disposed. The removal must be performed in accordance with a risk-based disposal approval process – requiring a comprehensive program including Certified Industrial Hygienists, risk assessors and engineers.

The steps include a comprehensive building characterization and sampling plan, sample collection and     interpretation, sample documentation, risk assessment, abatement strategy development, and plan approval by EPA. Since the concentration of PCBs may vary widely even within the same building, extensive testing must be conducted to document the presence of PCBs throughout the building and the samples sent to accredited laboratories for analysis in accordance with a strict testing protocol.

Currently, there are no specific exemptions to regulations addressing PCBs for a building in use. Although the regulation requires removal, there is no duty to test to determine the presence or concentration of PCBs…no duty to report the findings to EPA…and no explicit duty to remove PCBs from a building that remains in use.

However, there are both civil and criminal penalties for misuse of PCBs. Civil penalties may range up to $32,500 per violation per day; and criminal penalties for willful and knowing violation can be as high as $25,000 per day and/or one year in prison. There is very limited enforcement of the regulation in many regions of the United States.

PCB Removal

The actual remediation process should be performed by experienced contractors. For removal of PCBs found on the exterior of a building, large tent-like enclosures, not unlike those used for asbestos abatement, are constructed around scaffolding. The enclosures are maintained under a pressure differential using HEPA-filtered devices. EPA recognizes a variety of removal techniques.

As the project progresses, additional testing of building materials must be performed to document that the PCBs have been removed to an acceptable level. For example, a limit of one ppm is permitted in construction materials that are PCB-contaminated; so it may be necessary to remove several rows of brick around a window to achieve this limit. Soils may need to be excavated and tested to get to a level of 20 ppm. And disposal of PCB-contaminated waste is strictly regulated – with very few landfills licensed to handle it. Needless to say, PCB remediation is an expensive, time-sensitive process that must be planned well in advance of building demolition or renovation. The process nearly always takes longer and costs considerably more than originally anticipated.

HETI…Helping to Deal with PCB Issues

Whether EPA continues to enforce this regulation remains to be seen. There have been efforts to re-visit the rule to consider limiting its application. Most recently, in 2010, EPA issued an Advanced Notice of Proposed Rulemaking concerning the reassessment of the use authorizations for PCBs. Despite holding a series of public meetings and collecting comments, EPA has not issued any proposed changes.

Nevertheless, the issues of PCBs will need to be addressed. Hydro-Environmental Technologies, Inc. (HETI) can assist building owners and managers, along with their insurance and legal advisors, manage the risk. Whether it’s PCBs, asbestos, lead-based paint, underground storage tanks, or another environmental issue associated with building management, renovation or demolition, HETI can help our clients assess and address those needs.

Managing the Risks

Nanotechnology – the manipulation of matter on a near-atomic scale to produce new structures, materials and devices – offers the promise of unprecedented scientific advancement for many sectors, such as medicine, consumer products, energy, materials, and manufacturing. Over the course of the next decade, nanotechnology could have a one trillion dollar impact on the global economy and employ two million workers – half of them residing in the United States.

This increasing use of nanomaterials in the global market brings new challenges to understanding, predicting and managing potential safety and health risks. Little is known about what effect these materials may have on human health; so until the results from research studies can fully elucidate the characteristics of nanoparticles that may pose a health risk, precautionary measures are warranted.

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Planning Is Key to Avoiding Expensive Mistakes

Commercial buildings have a defined life-cycle. At some point, most existing structures will be demolished for a new use, renovated as a part of an expansion or change, or occasionally damaged or destroyed by disaster (fire, earthquake, hurricane, tornado, flood, etc.).

As construction technology has advanced, building materials have changed and become more specialized. Engineered materials and steel have replaced wood, fluorescent lamps have replaced the light bulb, and a vast number of products – both man-made and naturally-occurring – have found uses in buildings to meet specific design needs. Many of these products were created to solve problems or satisfy needs; but often little thought was given to the impacts and problems that these “answers” may themselves create.

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