There is no OSHA regulation stating how often general industrial hygiene testing should be done. However, it should be done every one to two years, depending on what chemicals or particulates are being generated. Most of the larger manufacturers follow this schedule so recent data are always available. Many clients of Environmental Safety Consultants have different areas tested each year, so that all areas are tested at least every two years. If manufacturing methods change, then the testing must be done at that time. Those method changes include the chemicals, stock materials, or procedures. Regulations can change, as well, lowering the permissible limits, which may warrant retesting if the most recent results were below the old limit but above the new one. Of course, noise is usually tested in the plant annually and the audiometric testing for the workers must be done annually.
Toxic mold is very misunderstood. Environmental Safety Consultants receives a lot of requests to do a mold inspection for “that black toxic mold”. That typically means they want to check for Stachybotrys chartarum. It also means that if we do not find that one, then there is nothing to worry about. That simply is not true. A lot of different types of mold can be toxic. Those include some common types such as Aspergillus, Penicillium, Curvularia, and, yes, even Cladosporium. The misunderstanding has come from all of the highly publicized information on Stachybotrys. When the potential health effects of mold are researched, it turns out that a lot of them can cause health problems for the wrong individual.
Environmental Safety Consultants has been serving Clearwater and St. Petersburg, Florida from its corporate offices in Bradenton, Florida since 1986. ESC has opened a new regional office in Clearwater to more efficiently serve its clients in St. Petersburg, Clearwater, and Tampa. The firm is licensed by the State in Engineering, Asbestos, Mold, and Radon. It is also accredited in Lead Based Paint, Visible Emissions, and Environmental Site Assessments, plus has a Certified Industrial Hygienist and a Professional Engineer on staff. Contact ESC today for all of your environmental permits and compliance, industrial hygiene, and occupational safety needs. We are here to serve you, the client!
Often laboratory results for bulk building material samples will show less than 1% asbestos. Almost as often, building owners or contractors will conclude they do not have to do anything about those materials. That is not necessarily true. These lab results mean that the lab technician saw asbestos fibers but that the concentration was less than 1%. Had the technician not seen any fibers, the results would have been none detected or non-detectable. The National Emissions Standards for Hazardous Air Pollutants (NESHAPs) regulation requires that these samples be point counted. The only other option is to assume they contain asbestos and comply with all applicable regulations. If the samples are point counted and the results are still below 1%, a NESHAPs notification is not required. NESHAPs is administered in Florida by the Florida Department of Environmental Protection (FDEP) and several counties under contract with the FDEP.
The fact that no notification is required has been misconstrued to mean no other requirements of any other agencies have to be met. That is not necessarily true. There are still requirements of the U.S. Occupational Safety & Health Administration (OSHA), U.S. Department of Transportation (DOT), Florida Statutes, landfills, and local government which may have to be met. OSHA has the less than 1% definition in its construction industry standard for asbestos abatement, but it also requires that disturbance of asbestos containing building materials not exceed OSHA’s Permissible Exposure Limit (PEL). Quite often when calculations are completed for the asbestos fiber concentration in air after disturbance of a building material with less than 1% asbestos, the PEL would be exceeded. In that case, OSHA’s abatement standard must be met.
In short, caution must be exercised in deciding the course of action for asbestos concentrations less than 1%. The potential worker exposure, contamination of buildings, and associated liabilities may be far greater than 1% of the building contract!
OSHA’s Hazard Communication Standard (HCS or Right-to-Know Rule) has been revised to align with requirements of the EU’s (European Union’s) Global Harmonization Standard (GHS). There are several deadlines from December 1, 2013 through June 1, 2016. The 2013 deadline was to train all employees on the new labels and Safety Data Sheets (SDS, formerly known as Material Safety Data Sheets or MSDS) that will be forthcoming with chemical products. There are nine hazard classifications and pictograms to universally communicate the hazards around the globe. The later deadlines concern revising your specific program and providing additional employee training for health or physical hazards.