At Emilcott, 2011 was a successful year where we were able to tackle new projects, serve our clients and continue to respond to current industry issues in the environmental, health and safety field. Though we have had many great memories from 2011, we would like to mention some of the things that stood out most in our business for 2011.

Hurricane Irene – the immense and powerful Atlantic hurricane that left a path of destruction and devastation was something that definitely stands out in 2011. We remember this event not only because of the wreckage caused by the storm, but also because of the after effects. The staff at Emilcott recognized the importance of addressing the legacy of water intrusion and the promise of mold after the storm and stressed to clients the importance of “timing” to address how to respond to this problem, as well as the importance of selecting the proper remediation technique along with an EHS mold expert and Emilcott’s mold remediation strategy. (Read more: Hurricane Irene Leaves a Legacy of Water Intrusion and the Promise of Mold)

Energy Sector – Emilcott has been thrilled to be able to participate in many different initiatives within the energy sector.  Regionally important to the growth of our economy, the ongoing infrastructure improvements have given us substantial health and safety support work. In EHSWire during 2011 we addressed many occupational hazards as Occupational Heat-related Illnesses where we went over the symptoms that workers may experience, as well as what should be done if someone does experience these symptoms. Besides dealing with working conditions such as heat, Emilcott also provided information on the truths about occupational slips, trips and falls which ended up costing American businesses $13.67 billion in workers compensation costs in 2008. Adhering to proper safety protocols and preventing injuries is something that benefits businesses and their workers. OSHA provides a Walking/Working Surfaces – Safety and Health Topic page which provides links to all the applicable standards.

With issues such as heat affecting the health of workers to preventing injuries on job sites, Emilcott has seen our fair share of mishaps. Being able to share our experiences and knowledge with others never gets old. From teaching someone the hazards about working near a crane, or things you should do when working in certain environments, Emilcott has always tried keeping people in the loop. We even have a 10-Hour Construction Industry Outreach Training Course based on the requirements established by OSHA which is a very hands-on and interactive class that we recommend to avoid a future work related issue. (Read more: Work Near a CRANE? Learn the Hazards!)

9/11 Tenth Anniversary – focused the changes that have occurred since 9/11/2001 such as the new precautions that have taken place on the American Chemical Security issue.   The DHS (the Department of Homeland Security) has been increasing their focus on utilities and chemical facilities which may become targets for terrorist activities and the DHS Chemical Facility Anti-Terrorism Standard (CFATS) now requires completing and submitting a Top Screen analysis to the DHS.

The James Zadroga Act, which was authorized to broaden, renew funding and extend benefits to Ground Zero workers whose death was a result of exposure, is of great significance and has put new emphasis on the importance of proper real-time environmental site monitoring. New technologies are available to protect site workers and the public from exposure to hazardous substances such as those from the collapse of the WTC towers. (Read more: 9/11 Tenth Anniversary Focuses on American Chemical Security)

Toxic Substance Control Act (TSCA) – was of major importance not only to Emilcott, but also to facilities who are manufacturers or importers of chemicals in amounts of 25,000 pounds or greater. With so many questions regarding TSCA and the changes, Emilcott decided to put on a free webinar along with posting a number of blogs that answered many of the concerns our clients had. Emilcott was able to use its expertise and help many clients with TSCA compliance questions and concerns regarding the developments of IUR reporting and reporting obligations in 2011 for the calendar year 2010. (Read more: August 2011 Update on the TSCA IUR-now-CDR Rule)

Though Emilcott has had many remarkable memories of 2011, we felt these 4 really left an impression on our business. Emilcott is privileged to know that we were able to assist our clients in many different businesses not only in 2011, but throughout our history. Emilcott looks forward to a productive 2012 and we are excited to see what this year has in store for us.

Do you have any environmental, health or safety concerns for 2012? If so, please share them with us below!

“343″ is a symbol of great sadness to members of the FDNY and their families as 343 is the number of FDNY firefighters who died on September 11, 2001. That staggering figure is remembered quite readily when recalling the events of that day and during the remembrances that have followed.  However, almost six years later, the lives of two additional NY firefighters were claimed during the demolition of the 9/11-damaged Deutsche Bank Building.

The 41-story Deutsche Bank Building stood adjacent to the World Trade Center and was severely damaged by falling debris and smoke when the Twin Towers collapsed. The damage to the skyscraper was so extensive that it had to be demolished. However, as the federal EPA requires, before it could be demolished, all asbestos-containing materials needed to be removed.

By August 18, 2007, demolition was well underway and the building now stood at only 26 stories tall.  Around 3:40 pm, a massive seven-alarm fire broke out as a result of a discarded cigarette in the asbestos decontamination unit on the 17^th floor.  The building had not been inspected by the Fire Department since March, when it should have been inspected every 15 days.  As a result, a crucial but inoperable fire standpipe forced firefighters to raise hoses up from the street to combat the flames.  Inside the building, three firefighters struggled to pull a hose through the deconstructed building. Only one of these men survived. The configuration of the asbestos abatement added to the difficulty of fighting a fire in an already structurally-compromised building.

The National Institute for Occupational Safety and Health (NIOSH), an institute within the Centers for Disease Control and Prevention (CDC), completed a description and evaluation of the incident as part of their fire fighter fatality investigation. Several items stand out from the asbestos abatement as contributors to the fire:

• White plastic sheeting was used to partition the floor area into separate zones.  All these partitions created maze-like conditions for the firefighters.
• Numerous zones were under negative pressure, as required for asbestos abatement, possibly drawing smoke and fire into localized areas.
• Stairwell doors were blocked by wooded hatch covers as part of the construction of the asbestos containments.
• Plastic sheeting, construction debris, and exposed lumber in partitions provided additional fuel.

These contributing conditions created by the asbestos abatement project have been recognized by several authorities, and in an effort to maximize safety, New York City enacted a number of new laws to ensure that asbestos abatement projects are conducted safely.  These laws impact the ways that asbestos projects are filed, approved and inspected, and involve new levels of cooperation among the agencies that oversee asbestos and construction safety:  the NYC Department of Environmental Protection (NYC DEP), the Department of Buildings (DOB) and the Fire Department (FDNY).  Most notably, the NYC DEP created the Asbestos -Technical Review Unit (A-TRU) to ensure that asbestos abatement is conducted safely and a new process for filing for asbestos permits called Asbestos Reporting and Tracking System (ARTS).

ARTS enables applicants to submit applications and/or receive approvals (or objections) electronically.  During the application process, applicants are asked questions to identify if

• the building’s fire protection systems (e.g., fire alarm or sprinkler system) will be turned off as a result of the abatement work,
• abatement work will result in blocked or compromised egress or whether any components of the fire protection system are going to be removed as part of the abatement
• abatement work entails removal of passive fire protection (e.g., fire resistance rated walls, sprayed on fireproofing, or smoke dampers)

If there is an impact to any of these fire protection items then a comprehensive Work Place Safety Plan must be developed for the project indicating abatement containment areas and systems, obstructed and temporary exits, tenant protection and a description of any measures that will be taken to mitigate compromised fire protection systems or means of egress. As a final item intended to promote life safety during abatement projects, the asbestos supervisor must inspect exits daily to ensure that there are no exterior blockages or impediments to exiting. If any blockages or impediments are identified, work must stop until the blockage has been removed.  Essentially, deconstruction and asbestos-abatement work cannot compromise the safety of workers and firefighters.

As Carrie Bettinger noted in a past EHSWire blog, “In our society and legal system it seems that, yes, someone (or many) has to tragically die before change and regulation are considered.” In this case, the tragedy was 343+2. Hopefully the A-TRU process and increased oversight from NYC DEP, DOB, and FDNY will prevent another similar tragedy from occurring.

Postscript:  The last of the Deutsche Bank tower criminal trials were completed in July, 2011. More information can be found at http://www.nytimes.com/2011/07/07/nyregion/final-defendant-is-acquitted-in-deutsche-bank-fire-trial.html.

It’s summertime again… time for barbeques, bathing suits, and sunscreen.  We all know we should protect ourselves from the sun damage to skin, eyes, and possible skin cancer.  I remember as a child the only available sun lotion was 2, 4, and 8, and it was considered healthy to get a little red.  A result of that latent exposure to the sun was Melanoma that killed my sister at age 47.

When asked about potential occupational “overexposure” to sunshine, I had to ask:

• Is there more to know about protecting workers from sun exposure?
• What are the regulations and occupational exposure recommendations for exposure to ultraviolet (UV) radiation?

Here are some answers ….

It is well established that UV light is the part of sunlight that causes “sunburn”.  UV light is a type of non-ionizing radiation with very high energy, which is why it can cause tissue damage.  So, it follows that one should protect themselves from overexposure to this commonplace yet risky energy source.

What do the government regulators and research institutions recommend?

The only reference in the Occupational Safety and Health Administration (OSHA) standards to UV radiation regards eye protection from UV radiation generated by welding arcs.  OSHA does have an informational webpage titled “Protecting Yourself in the Sun”.

The American Conference of Governmental Industrial Hygienists (ACGIH) has a recommended standard for employee exposure to UV radiation; however, this standard relies on measurement of the UV exposure and is intended for indoor/manmade sources of UV radiation.

The National Institute of Occupational Safety and Health (NIOSH) Workplace Safety and Health Topics  webpage, UV Radiation, is devoted to providing information to workers and employers regarding the risks, health hazards, and recommended control methods for reducing the risks of sunburn and skin cancer from sun exposure.  NIOSH recommends the following for protection from occupational exposure to UV radiation:

• Wear sunscreen with a minimum of SPF 15.
  • SPF refers to the amount of time that persons will be protected from a burn. An SPF of 15 will allow a person to stay out in the sun 15 times longer than they normally would be able to stay without burning. The SPF rating applies to skin reddening and protection against UVB exposure.
  • SPF does not refer to protection against UVA. Products containing Mexoryl, Parsol 1789, titanium dioxide, zinc oxide, or avobenzone block UVA rays.
  • Sunscreen performance is affected by wind, humidity, perspiration, and proper application.
• Old sunscreens should be thrown away because they lose their potency after 1-2 years.
• Sunscreens should be liberally applied (a minimum of 1 ounce) at least 20 minutes before sun exposure.
  • Special attention should be given to covering the ears, scalp, lips, neck, tops of feet, and backs of hands.
• Sunscreens should be reapplied at least every 2 hours and each time a person gets out of the water or perspires heavily.
  • Some sunscreens may also lose efficacy when applied with insect repellents, necessitating more frequent application when the two products are used together.
• Follow the application directions on the sunscreen bottle.
• Another effective way to prevent sunburn is by wearing appropriate clothing.
  • Dark clothing with a tight weave is more protective than light-colored, loosely woven clothing.
  • High-SPF clothing has been developed to provide more protection for those with photosensitive skin or a history of skin cancer.
• Workers should also wear wide-brimmed hats and sunglasses with almost 100% UV protection and with side panels to prevent excessive sun exposure to the eyes.

The International Commission on Non-Ionizing Radiation Protection (ICNIRP) and World Health Organization (WHO) published a recommendation paper “Protecting Workers from Ultraviolet Radiation, 14/2007”.  This document addresses both natural and manmade UV sources.  It provides an interesting risk matrix based on latitude, work conditions, work environment and clothing and makes recommendations for additional protection based on the combination of these factors. The book is comprehensive and full of interesting facts for anyone interested in diving in.  For example, dark sunglasses without the dark side shields (or wrap-around design) will allow a substantial amount of UV exposure to the eyes.  This is because when wearing sunglasses the pupil and eyelids open proportionally to the darkness of the sunglass then the light exposure comes in from the sides!

Occupational health programs for outdoor workers at risk from UV exposure include the classic industrial hygiene elements:

Engineering Controls

• Shade structures for work areas

Administrative Controls

• Training for supervisors and workers about the risks from UV exposure and appropriate protection measures with procedures for sun avoidance
• Recognizing individual susceptibilities to offer additional protective measures when needed.
• Adjustment of work hours to avoid midday sun.

Personal Protective Equipment (PPE)

• Clothing and hats
• Sunscreens
• Eye protection

Medical Surveillance

• Identify individuals having a high risk of skin cancer
• Conduct periodic medical surveillance with examination of both the eye and skin

Program Assessment

• User acceptance of PPE
• Evaluation of the quantity of sunscreens used

What’s the Take Away?

In general, the recommendations for protecting outdoor workers from natural UV exposure may sound very familiar:

1. Avoid sun exposure during midday – 10 am–4 pm, especially in tropical latitudes
2. Use sunscreen with at least a SPF 15 and apply liberally with reapplication every 2 hours
3. Wear a hat (with wide brim and neck flap) and long sleeves if exposed for long periods
4. Wear UVA/UVB-rated sunglasses with side shield or wrap around design
5. Seek shade
6. Clouds may  not reduce the potential for UV exposure

Have a healthy and safe summer.

By John Defillippo, CHMP

Do you have hazardous chemicals in your workplace? If you think the answer is no, are you sure?

OSHA defines a hazardous chemical as one that presents either a physical or a health hazard. Many common and readily available products such as paints, cleaners, and other materials found in the workplace meet this definition. In fact, last year OSHA issued over 6,300 violations to companies that failed to comply with this standard. As we noted in a previous blog, non-compliance with the Hazard Communication standard was the third-largest source of OSHA violations in 2009 and 2010!

If you are an employer, you have a legal obligation to provide a workplace that is free of recognized hazards and to communicate any hazards present to those in the workplace.  In 1985, OSHA established the Hazard Communication Standard (1910.1200) to ensure, in part, that all workers have the “right-to-know” about the hazardous chemicals in their workplace.

Essentially, employees have a Right-to-Know about any hazardous substances that they may come into contact with at work and how to protect themselves from adverse affects. Employees, for their part, have a responsibility to follow directions and work safely by using products for their intended purpose and in accordance with the manufacturer’s instructions to reduce risk and chance of exposure. This is where the Hazard Communication Standard “kicks in”, as all workplace information about hazardous substances needs to be in a Written Hazard Communication Program.  This “HazCom” program must contain

• A list of all hazardous chemicals in the workplace and a Material Safety Data Sheets (MSDS) for each chemical (or product) on that list
• All employees must have access to that list and the MSDS’s during their work shift
• Methods to communicate hazards of these chemicals to employees, on-site contractors and visitors such as signs and labels
• Records showing that all employees have been properly trained to understand the hazards, read the MSDSs and understand labeling and signs.

In addition to the federal OSHA requirements for labeling, the State of New Jersey has specific labeling requirements for all vessels, piping and containers that contain hazardous chemicals.

So, do you have hazardous chemicals in your workplace? Are you rethinking your answer?

If you have products that arrive with an MSDS, and you have not implemented a written HazCom Program, you’ll need to get a program in place to be OSHA compliant. If you have been following the standard, consider the following:

• Are you keeping up with its requirements?
• When was the last time your HazCom Program was reviewed?
• Is your hazardous chemical list and MSDS collection up-to-date?
• Do you know what OSHA considers “Hazardous”?
• Is every hazardous chemical container labeled properly – even the transfer containers?
• Are ALL your employees trained about the workings of your HazCom program and the hazards of each chemical in their workplace?

Now do you know the answer? Or, do you have more questions?

If you are confused or intimidated, don’t worry.  A great resource is the Institute of Hazardous Materials Managers which certifies individuals as Hazardous Materials Managers (CHMM) and Hazardous Materials Practitioners (CHMP). These trained professionals must demonstrate various levels of knowledge, expertise, and excellence in the management of hazardous materials. And, there are EHS (Environmental, Health and Safety) experts like Emilcott everywhere – their job is to help companies stay in compliance with state and federal regulations while protecting employees. No matter what resource you find, just ask if they are experienced in developing Hazardous Communication programs. Not only will workers stay health and safety, you’ll see added benefits like prevention of property damage, reduced insurance claims and costs, and, of course, your company will not be cited for OSHA’s third most-common violation!

Have you found any chemicals in your workplace that you didn’t know are hazardous? Does your “right-to-know” increase your job comfort level or concern you? And, have you carefully reviewed the company HazCom plan so that you understand “what to do if…”?

Slips, trips, and falls aren’t at the top of anyone’s “most glamorous” EHS topics list.  Many people perceive slips, trips, and falls as minor incidents resulting solely from either carelessness or clumsiness. In fact, losing your footing is the basis for basic comedic art (ever watch “The Three Stooges” or “America’s Funniest Home Videos”?)  

Quite the opposite — slips, trips, and falls are a very costly and serious worker safety issue. In 2008, these incidents cost American businesses a staggering $13.67 billion in direct workers compensation costs. That’s more than any other cause and more than the combined cost of the third through sixth ranked causes. 

Injury, Illness and Death Facts You Should Know

Slips, Trips, and Falls….

• Result in back injuries, strains, sprains, bruises, broken bones, concussions, and even death!
• Cause 15% of all accidental deaths, and are second only to motor vehicles as a cause of fatalities.
• Were the fourth leading cause of fatal work injuries in 2008 (13.4%, or 700 out of 5,214 fatalities).
• Rank as the second leading cause of disabling occupational injury.
• Are the third leading cause of all occupational injuries/illnesses (21.8%) and injuries/illnesses resulting in days away from work (21.4%).

How can slips, trips, and falls be prevented?

As with most safety hazards, slip, trip, and fall hazards can be minimized with a combination of good work practices, proper use of appropriate equipment, proper facility and equipment maintenance, and worker training. OSHA’s Walking/Working Surfaces – Safety and Health Topic page provides links to all the applicable standards. Some basic preventive practices include:

• Good housekeeping
  • Keep floors clean, dry, and sanitary
  • Clean up spills promptly
  • Keep aisles and walkways free of obstructions and clutter
• Footwear
  • Fit properly
  • Require slip-resistant foot in areas prone to wet or slippery conditions
• Fall prevention and protection
  • Provide appropriate fall arrest systems
• Facilities and equipment
  • Walking and working surfaces
    • Floor surfaces should not be slippery or uneven
    • Install non-slip flooring in areas prone to wet or slippery conditions
    • Maintain floors in good condition
    • Equip elevated working surfaces and stairways with guardrails
    • Protect floor holes such as drains with grates or covers
    • Promptly remove ice and snow from walkways, parking lots, etc.
    • Adequate lighting
    • Ladders
      • Provide properly rated ladders
      • Maintain ladders in good condition
• Training
  • Provide worker training for
    • Slip, trip, and fall hazards
    • Ladder use
    • Personal fall arrest systems

Don’t Slip Up on Safety!

Bruising, twisting or breaking a bone makes your work life and personal life extra challenging – it’s worth it to take a few minutes to prevent the accident from ever happening. On TV and in the movies, slips and other footing mishaps are carefully orchestrated with hidden padding, stunt doubles, some great camera tricks, and, of course, an endless supply of retakes. When you’re working on the job, there’s only one chance! 

Using the tips listed above, take a look around your workplace to see if it meets the criteria to prevent slips, trips and falls.  Don’t forget to look at your own feet to see that you are properly dressed for the environment and job duties. If you see a situation that is unsafe or could potentially be a slip, trip and fall hot spot, make sure you point it out to your coworkers and safety officer so that a permanent solution can be found.

Has it happened to you?

Have you experienced a slip, trip or fall on the job?  Could it have been prevented? What was the outcome for you and your company?

Paula Kaufmann, CIH

We have some news on this year’s TSCA IUR Form U submission.  Well, it really isn’t information about the requirements – but we do know that this year’s Form U submission period will not be June 1 to September 30.  It will most likely be later this year.  So, we all can move that task to another segment of the calendar year!

More Information

On May 11, 2011, the EPA issued a Federal Register Notice amending the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) regulations by delaying  the June 1 to September 30 submission period for the 2011 Form U reports.  The notice indicated that this delay will not alter the timing of subsequent submission periods (e.g., the submission period from June 1, 2016 to September 30, 2016).  This is an interesting statement as one of the changes included in the proposed IUR Rule is a change of the reporting period cycle to every four (4) years from the current five (5) year cycle.

The EPA is delaying the submission period because the proposed IUR modifications rule has not yet been finalized. EPA expects to have the final version of the changes to the IUR reporting requirements in the near future. The revised 2011 submission period will be announced with the publication of the final IUR modification rule. 

How does this delay what the EPA rule refers to as a “suspension” affect what needs to be done for the 2010 reporting period?  It seems that the EPA will mandate a new submission period but it is not clear when this will be during 2011.

• We are assuming that the reporting period will remain as the 2010 calendar year. 
• Our next assumption, or guess, is that the Form U submission period will shift to September 1 to December 31, but that will require that the final rule on the IUR modifications be published very soon.

“Food” for Thought…

As recently as March 4, 2011, representatives from the American Petroleum Institute (API) met with the EPA presenting concerns about several aspects of the proposed IUR modifications rule.  One topic the API presented was that when the last set of revisions of the IUR was finalized in 2003 with the next reporting period was extended by one year shifting from 2004 to 2005 with Form U submission in 2006.  During 2004 and 2005, the EPA held many workshops and issued clarification and guidance documents.

And, for now, we wait for the Final Rule and hope that the data we have all collected for the 2010 reporting period will be adequate.  Emilcott’s recommendations for what to do while we wait are in my January blog:  “TSCA IUR Update – What Are the Changes?”. Essentially, we are advising our clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Here are a couple of items to keep on your radar:

• Be sure your list of manufactured chemicals is complete.  Your list should be based on all chemical processes and imported materials received at the site and not just on the products.
• When calculating individual substance volumes – include imported mixtures with those manufactured at the site aggregating all mixtures containing that substance. 

…And, Emilcott will continue to keep you posted!

What to do if you need help or have questions?

If you need assistance related to the TSCA New Chemicals regulatory requirements or the potential changes due to the Inventory Update Reporting Rule, Emilcott can guide you through the reporting.  We can also help you navigate the maze of reporting a potential Form U violation from prior filing years to the EPA (See http://www.emilcott.com/services/svcenvcompliance.asp). 

As more information becomes available from the EPA regarding the IUR and as testing of the electronic tool begins, Emilcott will keep you up-to-date via EHSWire and our “Regulatory Updates” Newsletter.  

Please give me a call at 1-800-886-3645 or write a comment below if you have any questions or additional information to contribute.

Through my membership with the New Jersey American Industrial Hygiene Association (NJ-AIHA), I had the opportunity to make a presentation at the New Jersey Clean Air Council’s (NJCAC) annual meeting on April 13^th.   This particular meeting sounded intriguing as it would be focusing on a topic of great interest to me – a technical dialogue on how to measure and identify the effect of air pollution (and other environmental stressors) on the cumulative health issues of the public. The meeting aimed to bring professionals from varying disciplines to discuss technical approaches, academic research and general opinions on how to reduce this pollution and therefore improve the health of the affected populations.  

The meeting lasted a full day with contributing presentations from a dozen or so professionals. There were 15 NJCAC Board members at the meeting and 50+ attendees comprised of 11 presenters, NJDEP staff, and members of the public.  As a presenter, we were each given about 20 minutes to make our points regarding specific urban populations that have inordinately higher exposure to air contaminants as compared to people living and working in “cleaner” urban, suburban and rural areas of the state.  The majority of the presentations concluded that there are neighborhoods where pollution levels are chronically and significantly high.  Presented evidence also linked higher incidences of illnesses and disease with these cumulative exposures to contaminants and other environmental (and social) stressors.  

Bob Martin, the NJDEP Commissioner, gave an introductory presentation outlining current and future regulatory initiatives for reducing air pollution in New Jersey. One plan is to ban older diesel equipment in areas that do not have effective emission controls.  Joe Suchecki, a representative of the Engine Manufacturers Association, correspondingly, presented convincing evidence that new diesel technology does not create air pollution problems.  The trick now is to get all the older diesel equipment off all the roads and construction sites replaced by either new equipment or equipment retrofitted to control air emissions.

Ana Baptista, PhD, gave an excellent presentation on the high levels of pollution in the Newark Ironbound district and the resulting links to disease in the residential population resulting from cumulative exposure to these contaminants.  Dr. Robert Laumbach gave a similar presentation about future research that he is leading to test people who live in the Ironbound in an attempt to prove this link of air pollution exposure to increased illness and disease.

My own presentation discussed Emilcott’s experience measuring local air pollution (particulates and vapors) and other environmental parameters (noise, wind speed and direction) using the Greenlight Environmental Monitoring System which collects, in real-time, data for particulates (at multiple particle size ranges) and vapors, coupled with data of wind speed and direction, to identify emission sources and measure their impact on local air pollution.  We have found that “what is measured, improves”, and by using this sophisticated and integrated air monitoring approach, identified emission sources can be controlled to make immediate and sustainable improvements to the local air quality. 

Overall, excellent information was presented, reinforcing the fact that the air quality in much of New Jersey is not very good and, in certain areas (usually in disadvantaged urban neighborhoods), it is extremely poor.    And, residents living in zones with the worst air pollution also show some link to increased disease and illness.     

I left the NJCAC annual meeting knowing that solid academic work was underway to prove that high levels of air pollution causes disease.  What was missing was evidence that effective, short-term actions are being taken, to reduce the levels of pollution and contaminant exposure in these areas to improve overall health for the resident population.

By Don Hoeschele, MS, CHMM

In an age where we are reliant on modern technology as a part of our job, it is difficult to imagine not being able to use your cell phone or access the Internet because of topography.  As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”?  Specifically, I had to meet OSHA’s requirements for communication:  29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”.  

For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help?  In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it!

On this particular project, numerous construction crews were working at different, extremely remote locations with a distance of several miles between each work crew. While the power line tower construction and electric line-stringing companies included requirements for an eventual end-to-end 2-way radio system, the system was not available for at least the first year of the project. And, since cell phones and the average two-way radio systems were not able to be consistently or reliably available to meet the communication needs required for this project, I needed to find an alternative. 

After digging around and countless meetings, calls, and trips to all kinds of communications companies, we settled on a resourceful, cost-conscious and effective method of communicating between the crews, safety personnel, surveyors and managers. The end result was a creative mix of new technologies:

• Cell phone signal boosters in each vehicle in the field
• GPS SPOT locator units for each  crew
• New technology satellite phones for work crews heading into the most remote locations.  

The vendor that built these systems also owned many of the frequencies needed for an end-to-end two-way radio system that would reach across the 275-mile project location.

Of course, the system’s effectiveness had to be proven – we were relying on it! So, I spent hours deep in the mountains field testing the equipment in some of the most remote project locations I have ever seen. Luckily, I was helped by some of the project team members who had spent a great deal of time in this area. Experience also helps communication!

This project had unusual difficulties – a big, remote, mountainous and unpopulated area – that could have thwarted OSHA’s communication requirements.  At any time, it would have been easy to throw in the towel, cross our fingers or perhaps put together a patched-together system and hope it worked.  However, with some tenacious ingenuity and a confidence that a reliable health and safety communication system could be found, we were able to overcome the almost overwhelming challenges and put an effective field communication system into place.

Have you been faced with challenges to provide adequate communication systems for your employees?  What has made a job site seem almost impossible to conquer? What did you do to overcome those challenges?

Dale Wilson, CIH, LEED AP

We all know what Green Buildings are, right? There are various permutations but generally, to be green, the structure is designed, built, maintained and sustained in an environmentally responsible and resource-efficient manner. The end-all objective is to reduce impact of the “built package and system” on both the environment and mankind by

• Using energy, water, and other resources efficiently
• Protecting occupant health
• Improving employee productivity
• Reducing pollution and waste

As a LEED AP-certified professional who specializes in Indoor Environmental issues with a focus on fire and life safety, I was very interested in recent articles that are creating awareness of some critical health and safety problems inherent to the green building movement that 1) use innovative, locally-produced products, and 2) implement new design, construction, and operation approaches intended to reduce energy usage and be environmentally sound.

Green Building Fire Safety

In Megan Grennille’s recent EHSWire article about the seminal Triangle Fire, it noted that building and fire code rules caught up with the high rise construction only after the tragedy of 146 worker deaths highlighted the challenges of safety and rescue in the case of a fire. The same situation recently occurred in Bakersfield where a green-constructed Target store highlighted some new concerns for health and safety for emergency responders:

“The fire at the Bakersfield Target started, firefighters learned, at the photovoltaic array [solar] on the building’s roof. Even after the firefighters disconnected the electrical mains, they discovered that the solar panels were still energized, presenting a safety challenge in addition to the fire.”

This brings to light how the integration of green building practices on a seemingly typical commercial building can present new hazards that must be identified to protect building occupants and emergency responders.  Fire fighters responding to an alarm may cut electrical power from the supply grid, but what is the procedure if there is an active solar array or an integrated wind turbine generating power as a part of the building?  Other “new” electrical and fire hazards facing unprepared emergency responders include the unknown level of fire resistance of recycled/green building materials, how to control fire spread on green vegetative roofs, and how to control smoke in wide, open atrium areas.

“owners of green buildings might have to be aware that the green designs can present previously unconsidered challenges that arise as a direct result of construction choices. …Because codes — even a decade after green design concepts hit the mainstream — still largely deal with traditional building designs and materials, facility managers have to know how to address the intersection of green design and current codes.”

The bottom line is that “green concepts should be reviewed as part of a fire-protection and life-safety analysis”, because buildings, green or not, must meet building and fire code standards to protect the health and safety of both the occupants and emergency responders.

Moisture and Mold Management in Green Buildings

Another potential hazard of green buildings is the management of moisture within the building and how selection of a green design and materials may be inappropriate if the location and weather are not considered:  “the design-and-construction community must not assume that if one builds green, then one will be building regionally correct or even lower risk buildings”.

A recent article, Hidden Risks of Green Buildings, was written from an insurance underwriter’s perspective and centered on the management of moisture.  The article mentioned the trend of using carbohydrate-based building products instead of petroleum-based building products.  That is where my eyes widened! Any indoor quality consultant knows the formula:  moisture + food source = perfect habitat for mold growth.  Carbohydrate-based building products are food for mold!

Moisture comes from many sources in a building: bulk water from a rook, window, or facade leak; water pipe break; HVAC condensate overflow; condensation on cold surfaces; or vapor (relative humidity) in the air.  Additional humidity can be added to the air by introducing humid outdoor air that has not been properly dehumidified or from other sources such as showers, locker rooms, steam rooms, gyms, kitchen facilities, human respiration (particularly if more people are occupying the space than the original design).  (More information on these moisture-related potential problems including the risk of LEED “flush-outs” can be found here.)

Moisture meeting carbohydrate-based building materials over time certainly does look like the potential beginning of The Perfect Storm, because, in reality, carbohydrate-based building materials, even treated with the best biocide, would only be “mold resistant” not “mold proof”.  Given food, water, and time… mold will grow.  So as a professional IEQ consultant who has seen it all when it comes to mold contamination, I sincerely believe the article’s foreshadowing that “the design community would be advised to prioritize the lessons…already learned from the waterproofing, humidity control, and building forensics community”.  When using potential mold “food” within a building, moisture control is ever more critical to the air quality of the building as well as the building material’s life cycle.

Are you interested in green construction? Have you thought of the potential hazards that can be created when using new technologies, new materials and tightening up the envelope?

John Sloan's cartoon "The Real Triangle" published two days after the fire

by Megan Grennille

As the Project Coordinator at Emilcott, I often see our EHS staff’s recommendations for health and safety improvements at our clients’ worksites. These companies want to create a safer workplace for their employees — it makes good business sense, and it’s just the “right” thing to do!  It is hard to imagine that, historically, employee health and safety practices used to be very different in the U.S.

March 25, 2011 marks the centennial of the Triangle Shirtwaist Company fire — just 45 minutes from the Emilcott office in Morristown.  It was the type of workplace that women my own age worked… I could have been trapped in the shop!  That realization makes me think how lucky I am — and how far workers’ rights have come in the U.S.  I am familiar with the Occupational Safety and Health Act (“OSHA”), and its mandate that every one of us has the right to a workplace free of recognized hazards.  So, where did all this policy begin…?

The Triangle Shirtwaist Company

The owners of the Triangle Shirtwaist Company in Greenwich Village ran what was considered to be a large garment factory.  This factory took up the top three floors (8, 9 and 10) of the ten-story Asch Building in lower Manhattan near Washington Square.  The employees used sewing machines to manufacture shirtwaists, a type of blouse with a high neck.  Like others of this vintage, the shop was designed to maximize output while squeezing in as many workers as possible.  Most of the workers were female and recent immigrants and everyone worked long workdays under extremely poor conditions. 

Records show that on March 25, 1911 a fire erupted on the top floors of the Asch Building killing 146 people in less than twenty minutes.  How did this tragedy happen?

• The fire began on the 8^th floor just as workers were ready to leave for the day.
  • Many of the workers sewing on the 8^th and 10^th floors escaped (they either saw the fire or were warned about the fire)
  • Workers on the ninth floor were not as lucky; the fire below them became an inferno before they were alerted to it.  
• Building exits quickly became almost non-existent:
  • The two stairwells in the building were steep and narrow.
  • One exit was locked because the Triangle Company tried to discourage employees from leaving the workplace and stealing. 
  • The fire escape buckled from the combination of heat and weight of the people and fell to the ground.
  • Two elevators also failed due to the heat from the fire and weight of people jumping into the elevator shaft to flee the fire
  • Workers trapped inside the building leapt from the top floors with nowhere to go as all of the escape routes were failing. 
• Although the Manhattan fire department responded, one of the largest hook and ladder trucks was only able to reach the sixth floor of the burning building.

In a nutshell, no warning system, no fire extinguishing system, no emergency exit plan, and, clearly no compliance with NFPA 101!

Given the tragic high death rate, it seems as though everything that could have gone wrong did go wrong.  But in 1911 high rise buildings were relatively new with unforeseen dangers.  In fact, the owners of the Triangle Shirtwaist Company claimed they were not responsible because building regulations were inadequate at the time.  (Their legal argument about the locked exit door was that the lock’s key was tied to the lock with the string).  And, there were no smoke detectors, occupancy limits, sprinkler systems, or planned evacuation routes affixed to the wall.  Today, we take these measures for granted.  Just think of how fire extinguishers could have changed the outcome of this disaster if they had been in place on the eighth floor. 

A Turning Point for Workplace Safety

These lives were not lost in vain! This seminal industrial accident became a catalyst to initiate reform in the safety and welfare of factory workers in New York and the rest of the country.  It also marked a turning point in the fight for workers’ rights in America as only a small percentage of workers were unionized at the time.  

Immediately, workers and the public began calling for change to address occupational safety issues!  Just one day after the fire a protest was held at the Women’s Trade Union League.  Within one week the Committee on Safety was established in New York City.  On June 30, 1911 the New York State Factory Investigating Commission was formed to report factory conditions.  Frances Perkins, who witnessed the fire from the ground, eventually became the U.S. Secretary of Labor under Franklin Roosevelt and helped bring in many new labor laws during her time in office. 

Where Are We Today?

American workers are now protected by a safety net designed and enforced by OSHA and other federal and state labor laws, but workplace accidents still occur.  In 2009, 4,340 fatal work injuries were recorded in the United States (3.3 deaths for every 100,000 full-time workers).   After 100 years of reform, they are on a smaller scale — fewer injuries and the incidents that usually do not make national headlines unless, again, there is a dramatic loss of life such as mining accidents.

A US Senate resolution just passed on March 17 designating the week of March 21–25 as “100th Anniversary of the Triangle Shirtwaist Factory Fire Remembrance Week.” The Asch Building, now referred to as the Brown Building, is located at 29 Washington Place and is occupied by New York University. Designated a National Historic Landmark, the anniversary of the Triangle fire has been marked by an annual memorial ceremony in front of the building by the New York City Fire Department and the ILGWU (now UNITE). 

Sweatshops exist in many countries where worker protection is less important than economic growth.  Driven by cost, much of the clothing sold in America is made in sweatshops overseas.   Just last year a fire broke out in a garment factory in Bangladesh.  Similar to the Triangle Shirtwaist Factory Fire, it was on the upper floors of a building and some exits were locked.  The fire killed at least 25 people and injured many more, most of which were women and girls.  The Triangle Shirtwaist 100^th Commemoration Ceremony will be a timely and powerful reminder of steps we’ve taken to improve worker health, and what remains left to do.

To learn more about the Triangle Shirtwaist Fire and 2011 commemoration events, visit these links:

• Centennial Commemoration Information
• NYU Open House Exhibit
• Cornell University Historical Document and Timeline
• What the Triangle Shirtwaist fire means for workers now
• Dramatic Oratorio by Tony-nominated composer Elizabeth Swados:”Triangle: From the Fire” (audio file)
• Senate Resolution 106: Recognizing the 100th anniversary of the Triangle Shirtwaist Company fire in New York City on March 25, 1911, and designating the week of March 21, 2011, through March 25, 2011, as the “100th Anniversary of the Triangle Shirtwaist Factory Fire Remembrance Week”.