Face Masks and COVID-19

Introduction

This paper is the second in a series on the pandemic disease, COVID-19. The first paper focused on safely reopening your business. The current paper will concern the issue of face masks. These are part of PPE or personal protective equipment which has become an everyday term since the pandemic began in this country last year. It is refreshing to be able to discuss PPE without the listener’s eyes glazing over! Of course, PPE can include gloves, suits, hearing protection, face shields, hard hats, steel toed boots, and more, but this paper concerns face masks for respiratory protection.

Face Masks Primer

The face masks used to protect people from breathing in SARS-CoV-2 (the novel corona virus which causes the disease COVID-19) have included surgical masks, N-95 masks, handkerchiefs, face shields, neck gaiters, and more. None of these actually filter out the virus (which is approximately 0.1 micron in diameter), but rather, they filter out respiratory droplets that are expelled when people exhale, talk, sing, laugh, cough, sneeze, etcetera. Of the masks above, N-95s offer the best protection. The N stands for non-oil proof, so they do not work in an oily environment – anywhere there is oil in the air, typically as a mist. The 95 means that they filter out 95% of particles 0.3 micron in diameter. The particles are made from dioctyl phthalate, a chemical used to test the respirators by manufacturers. If they pass the test, the manufacturers can deem them N-95 respirators after meeting other certification requirements of NIOSH (the National Institute of Occupational Safety & Health, which is a part of the CDC, the Center for Disease Control, (www.cdc.gov). Once they meet the certification requirements, they can display N-95 labels.

How to Wear the N-95

The N-95 face mask has two straps, a lower, and an upper strap. The easiest way to put it on is to put on the lower strap first, by putting it over your head and then lowering it so it rides along the back of your neck. The upper strap is then put over your head and rests on the crown in the back. Make sure the face piece seals snugly over your nose, down your face, around your mouth, and beneath your chin. Bend the part that goes over your nose so it fits closely over the bridge and down the sides. The goal is to seal the N-95 to your face so no air comes through cracks. That way, the air will be filtered when you inhale and exhale. Which brings up a point that exhalation valves do not filter air that you exhale. Thus, if you are infected, people around you may inhale your germs. Therefore, N-95s without exhalation valves are recommended.

What if you Can’t Get an N-95?

In that case, use a surgical mask. If one is not available, use a cloth filtering mask. The other types of masks are on down the list.

How often Can I Wear the Mask?

Whatever mask you wear, just remember that they are not designed to be worn over and over. They are designed to be thrown away after each use or disinfected if that is even possible. As with everything else, consult the manufacturer.

Tell Me More about Inhalation Exposure

And that is the topic of our next paper. We will discuss airborne exposure of the virus itself and exposure to respiratory droplets. Stay tuned!

So there is a discussion of face masks and protection from the SARS-CoV-2 which causes the disease COVID-19. If you need any assistance, ESC (www.escflorida.com) is here. We have a board Certified Industrial Hygienist (CIH) on staff and have been providing respiratory protection services to our clients for thirty years. We have the credentials and experience to help you with your respiratory protection needs. We are just a telephone call (800-226-1735) or an e mail away (escinc@verizon.net). Contact us today!

Environmental Engineering For Sewer Discharges Of Industrial Wastewater

Introduction

This paper is one in a continuing series concerning environmental engineering, which is one of the services provided by our environmental consulting firm, Environmental Safety Consultants, Inc. (ESC). It is critical to make sure that your facility’s sewer discharges of industrial wastewater is acceptable to the entity operating the receiving wastewater treatment (sewer) plant.

It is important that an environmental engineer evaluate the discharge, hopefully, before it begins. The discharge must be acceptable or pre-treated to be acceptable to the plant. This is required under the federal Clean Water Act mandated by the U.S. Environmental Protection Agency (EPA, www.epa.gov) and quite often is implemented via a local Sewer Use Ordinance, usually at the county level.

Why Worry?

The attitude may be, “Well, we are paying for the sewer discharge, so what does it matter?” Actually, it matters a whole lot. The discharge may knock out the microbiological organisms at the wastewater treatment plant so that it can no longer treat sanitary sewer water which it was designed to treat. It could cause an explosion, or it could pollute the surface water receiving the plant’s discharge. Alternatively, it could pollute the aquifer if the plant is discharging the effluent to groundwater (underground injection). The list goes on and on. But, one of the most compelling reasons is that you could be in violation of the Sewer Use Ordinance and subject to huge fines!

How Will They Know?

The Sewer Authority can do sewer discharge tracing. They have access to lift stations and through inspection and testing, plus evaluating the facilities in the neighborhood, they can trace the discharge to your facility fairly easily. It is not that difficult. Believe me, we have seen it happen to more than one industrial facility.

What’s a Facility to Do?

First, read the Sewer Use Ordinance closely. It typically lists substances or certain properties of substances which are not allowed to be discharged. So if your effluent has any of those substances, you are dead in the water, right? Not necessarily so. Working in concert with your representatives, ESC’s environmental engineer may be able to come up with one or two of the following solutions:

Change the process generating the contaminant(s)
Chemical substitution – generating acceptable wastewater
Segregate the components and properly dispose of any hazardous wastes prior to discharge
Treat the wastewater before discharge – options include flocculation, primary & secondary settling, aeration, & filtration
Discuss alternatives with the Sewer Authority

In evaluating your wastewater and the treatment options the environmental engineer may very well need to conduct sampling and analysis of your wastewater before discharge; after treatment on a bench scale basis; after full implementation of treatment; and on a periodic basis depending on the Sewer Authority’s requirements and to monitor your treatment process.

So there is a discussion of the environmental engineering related to sewer discharges of industrial wastewater! If you need any assistance, ESC (www.escflorida.com) is here. We are a Florida licensed environmental consulting and Florida licensed environmental engineering firm with a P.E. on staff. We have the credentials and experience to help you with your industrial wastewater sewer discharge needs. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Environmental Engineering for NPDES Stormwater Pollution Prevention Plan (SWPPP)

Background

So far, we have provided several papers on or related to environmental engineering, which is provided stormwater pollution by environmental consulting firms like ours, Environmental Safety Consultants, Inc. (ESC). We provided information on environmental permits, then went into an overview of environmental engineering. Next, we addressed industrial wastewater and, finally, air emissions control provided by an air engineer. There was also a paper discussing Florida NPDES (National Pollutant Discharge Elimination System) Industrial Stormwater requirements. Now we will discuss the Stormwater Pollution Prevention Plan (SWPPP).

Stormwater Pollution Prevention Plan (SWPPP)

The current paper will discuss environmental engineering required for an SWPPP (Stormwater Pollution Prevention Plan). The regulatory requirements are provided by both the U.S. EPA (Environmental Protection Agency, www.epa.gov) and the FDEP (Florida Department of Environmental Protection, www.floridadep.gov). The requirements discussed herein primarily cover manufacturing and industrial facilities with SIC (Standard Industrial Classification) Codes 21 – 39 with specific exposure to stormwater.

Objective

The objective of the Stormwater Pollution Prevention Plan is self-evident from its name. That is, the SWPPP is prepared by an environmental engineer to prevent pollution of stormwater so it does not discharge and impact receiving waters. Why? Because if it does, it can impair the biological organisms and public health.

Components of Stormwater Pollution Prevention Plan

In preparing the SWPPP, the environmental engineer first identifies the facility and describes its operations, location, and receiving surface waters. Then, information and data are gathered in the following areas to assess the facility’s impact to stormwater:

Topography, runoff, & discharge point(s)
Material inventory, quantities, & exposure
Significant spills or leaks last three years
Non-stormwater discharges
Pollutant sources & specific parameters
Best Management Practices (BMPs) to control pollutants

Based on the results of the preceding, the environmental engineer discusses the findings with the client, then prepares the SWPPP and submits it for review. It is important that the client be able to implement and use the plan to reduce or eliminate pollutants in the facility’s stormwater runoff.

Implementation

The client’s management must endorse the SWPPP and sign it as documentation. A Pollution Prevention Team is formed and identified in the SWPPP. Team members and other personnel receive training. Resources are committed to attain the plan’s objective by implementing the BMPs selected. Visual monitoring of the stormwater discharge is required quarterly and laboratory analysis may be required during the second and fourth years of the five year permit. All records are kept in the SWPPP and, thus, it is a living document.

So there is a discussion of the preparation of an SWPPP by an environmental engineer! If you need any assistance, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental consulting and Florida licensed environmental engineering firm with a P.E. on staff. We have the credentials and experience to help you with your SWPPP. We are just a telephone call (800- 226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Environmental Engineering for Air Emissions

Background

In three previous papers we dealt with an overview of environmental engineering, industrial wastewater permits, and industrial wastewater environmental engineering. In this paper, we will discuss environmental engineering required to address air emissions to the outside environment. Environmental engineering for air emissions These emissions result from manufacturing and industrial operations. They may be from a point source such as a smoke stack or from a non-point source and are called fugitive emissions. The latter result from processes typically inside a building or in an outside designated area. Environmental engineering is required to determine the best reasonably achievable control technology to minimize the emissions to the environment outside of the facility. The environmental air engineer must be involved in the design, testing, and adjusting the controls. Applications for Title V Air permits and Federally Enforceable State Operating Permits (FESOPs) must be signed and sealed by a Florida licensed Professional Engineer (P.E.). A P.E. in Florida is only allowed to practice in areas that he or she has the required education, training, and experience. Thus, the P.E. must be an environmental engineer with air emissions knowledge and experience and is quite often called the Air Engineer and is usually with an Environmental Consulting firm such as ours, Environmental Safety Consultants, Inc.

Start with the Pollutants

To engineer the air emissions controls, you have to know the process generating the emissions. The environmental engineer must review the raw materials, the industrial or manufacturing process, the resultant air emissions, and the control options. Following are a few pollutants which may be of concern:

Particulate Matter (physical particles or dust)
Nitrogen Oxides
Sulfur Dioxide
Carbon Monoxide
Volatile Organic Compounds (VOCs)
Ozone
Lead

All of these except VOCs are criteria air pollutants established by the U.S. Environmental Protection Agency (EPA, https://www.epa.gov/criteria-air-pollutants). Each type of pollutant may require a different environmental engineering design to remove or reduce it before being emitted to the outside environment.

Clean It Up

The goal is to clean up the air so the pollutants are eliminated or below State standards prior to emission. These standards are thresholds for public health concerns. If the pollutants are below these criteria, there is not a public health concern, but there still may be a concern for unborn babies (pregnant women), children, the elderly, and individuals with certain lung conditions, such as emphysema, asthma, chronic obstructive pulmonary disease (COPD), etcetera.

Control Design

The control design is selected to address the pollutants. Following are a few examples:

Alternative raw materials
Industrial process modifications
Filters (cloth, baghouses)
Cyclones (gravitational)
Air scrubbers
Precipitators (electrostatic)
Equipment maintenance and cleaning

Role of the Environmental Air Engineer

First, the environmental engineer reviews the industrial process, including materials and chemicals, generating the air emissions. The engineer then evaluates several control design options and runs calculations to determine which one will work best and will be cost-effective. He or she then prepares the air permit application; submits it to FDEP and, if required, to the County; provides additional information requested by the FDEP and County; reviews the permit making sure that it meets good engineering practice and is manageable for the client; and, if requested, monitors the treatment process in light of the permit conditions.

So there is a discussion of air emissions environmental engineering and what the environmental engineer’s role is! If you need any assistance, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a P.E. on staff. We have the credentials and experience to help you with your industrial wastewater needs. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Environmental Engineering For Industrial Wastewater

Background

In two previous papers we dealt with an overview of environmental engineering and industrial wastewater permits. In this paper, we will discuss environmental engineering required to address ESC - Environmental Engineering for Industrial Waste Water industrial wastewater. This is the engineering required to treat the wastewater so it does not pollute the receiving surface water, or so it is within tolerable limits and virtually has no impact. Environmental engineering is required to determine the best reasonably achievable control technology to do so. The environmental engineer must be involved in the design, testing, and adjusting the treatment process. Florida NPDES Industrial Wastewater permit applications must be signed and sealed by a Florida licensed Professional Engineer (P.E.). A P.E. in Florida is only allowed to practice in areas that he or she has the required education, training, and experience. Thus, the P.E. must be an environmental engineer with industrial wastewater knowledge and experience.

Start with the Pollutants

To engineer the treatment, you have to know the waste stream. The environmental engineer must become familiar with the industrial materials and processes generating the wastewater. Following are a few pollutants which may be of concern:

Heat (thermal)
Nutrients (phosphorus and nitrogen)
Biochemical Oxygen Demand (e.g., organic matter)
Heavy Metals
Volatile Organic Compounds (VOCs)
Radioactivity
Particulates resulting in Turbidity

Each type of pollutant may require a different environmental engineering design to remove or reduce it in the wastewater before discharge.

Clean It Up

The goal is to clean up the wastewater so the pollution is below State standards prior to discharge. Mixing zones can be approved where the concentration is above the standard at the point of discharge but is allowed to mix with the receiving water and must be below the State standards so many feet downstream. Approval of such mixing zones by the FDEP (Florida Department of Environmental Protection, www.floridadep.gov) is possible, but not likely. There has to be a very good reason why the State standard cannot be met at the point of discharge.

Treatment Design

The treatment design is selected to address the pollutants. Following are a few examples:

Cooling of heated (thermal) effluent
Primary and secondary settling of particulates in pond or tank
Aeration to encourage biota to degrade organic matter
Chemical additives to oxidize or coagulate select pollutants
Percolation to allow filtration in soil column
Filtration with various types of filters

Role of the Environmental Engineer

First, the environmental engineer reviews the industrial process, including materials and chemicals, generating the industrial wastewater. The engineer then evaluates several treatment design options and runs calculations to determine which one will work best and will be cost-effective. He or she then prepares the permit application; submits it to FDEP and, if required, to the County; provides additional information requested by the FDEP and County; reviews the permit making sure that it meets good engineering practice; and, if requested, monitors the treatment process in light of the permit conditions.

So there is a discussion of industrial wastewater environmental engineering and what the environmental engineer’s role is! If you need any assistance, Environmental Safety Consultants
(www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a P.E. on staff. We have the credentials and experience to help you with your industrial wastewater needs.

We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

What Is Environmental Engineering?

Term Defined

Quite often we are asked, “So what is environmental engineering? Do you pick up litter?” To which you probably know the answer to the second question is a definite “NO!!!”, but may not so definitely know the answer to the first question. According to Britannica (https://www.britannica.com), environmental engineering is “the development of processes and infrastructure for the supply of water, the disposal of waste, and the control of pollution of all kinds. These endeavours protect public health by preventing disease transmission, and they preserve the quality of the environment by averting the contamination and degradation of air, water, and land resources.”

According to Wikipedia (https://en.wikipedia.org), “Environmental engineering is a professional engineering discipline that takes from broad scientific topics like chemistry, biology, ecology, geology, hydraulics, hydrology, microbiology, and mathematics to create solutions that will protect and also improve the health of living organisms and improve the quality of the environment.” This definition is very similar to the one above. And both accurately define environmental engineering.

But Really, What is Environmental Engineering?

What is Environmental Engineering That is the million dollar question. But the history of the discipline will help answer it. For years and years, environmental engineering was known as sanitary engineering and was part of the civil engineering field. However, it came into its own being in the mid-1960’s with the recognition of pollution on our planet and the outcries to clean it up. Scientists and engineers came to the forefront to assist. Technical expertise was needed with water pollution, air pollution, and land pollution. Landmark federal laws were passed – the Clean Water Act (1972), the Clean Air Act (1970), and the Comprehensive Environmental Response, Compensation, & Liability Act (1980).Don’t worry, this is not a boring paper on detailed regulations! Those federal laws were only mentioned to identify the three main areas of environmental engineering and to demonstrate how loud the outcry was to clean up the environment. It is extremely impressive that the U.S. Congress passed these laws so quickly! And what they did was create the need for environmental regulations, permits, and agencies to accomplish the mission.

Agencies, you ask? Let’s start at the top – the U.S. Environmental Protection Agency (https://www.epa.gov) came out of Reorganization Plan No. 3 calling for the establishment of that agency. That was an executive order which President Richard M. Nixon signed on July 9, 1970. The EPA began operation on December 2, 1970. Wow, things seemed to move quickly fifty years ago!

Once the EPA began publishing regulations to clean up the environment, they worked in cooperation with states to form departments or to use existing departments to implement the regulations. And so state environmental departments formed to clean up the environment across each state. Pollution control departments and divisions were formed at county and city levels.

Existing health departments were tapped. Funding came down from EPA and it was often tied to the construction of wastewater treatment plants which are a huge expense that no county or city can afford on its own. If the states did not enforce the mandated environmental regulations, EPA would cut funding. And that meant jobs, worsening pollution, and outcries from the public. So there were incentives to comply.

Birth of the Environmental Engineer

Formerly known as civil or sanitary engineers, environmental engineers came to the forefront to assist the various governmental entities and the private sector with implementation of and compliance with the environmental regulations.

Environmental scientists and engineers began working together both in the government and private sectors. Their job? Ultimately, their job was to clean up the environment through the design of processes, equipment, and testing in the areas of water, air, and land. And they are still at it today!

Further Assistance

If you need any help, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a Florida licensed Professional Engineer and Environmental Scientists on staff. We have been completing environmental engineering and science projects since 1986. We have the credentials and experience to help you complete your Environmental Site Assessment project.

We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

My Bank Let Me Out Of A Phase I Environmental Site Assessment!

I Don’t have to Worry

The buyer is elated – “No Phase I! Celebrate!” Really? Are you sure that’s a good thing? The buyer’s response is quite often something to the effect of: “It must not be a concern if the bank isn’t concerned.” To which we usually respond “Not necessarily!”

See, quite often the bank is not concerned, because if the loan recipient goes bankrupt trying to pay for a cleanup on down the road, the bank may just write off the loan as bad debt. They are not liable for the cleanup and that came from the 1996 Amendments to CERCLA (Comprehensive Environmental Response, Compensation, & Liability Act, known as Superfund, (www.epa.gov). That gave banks a “safe harbor” from becoming a Potentially Responsible Party (PRP). Thus, the banks cannot be held responsible for a cleanup just because they loaned money on the property. Of course, they have to be very careful in their involvement with the property and cannot actively manage it.

Suddenly, it doesn’t look like such a great favor the bank did for the buyer. And perhaps, the buyer had selective hearing at the time. A savvy banker may say “Officially we are not requiring a Phase I, but we do recommend you do one, for your own protection.” And, regretfully, the buyer only heard the first part of the banker’s statement.

It’s Part of Your Due Diligence

Bank Doesn't Require Phase I ESA Forget the bank! As the buyer, you exercise your due diligence to check out other aspects of the property – title, back taxes, infringements, rights-of-way, utilities, building systems, structural integrity of the building, and probably many more things. But you don’t want to know if there is a solvent plume under the building? Something like that can sicken occupants from what is known as vapor intrusion. But, you say, “The building is in great condition and in good repair, that vapor intrusion situation is highly unlikely.” On the contraire, it is highly likely. There are always cracks, crevices, and breaches that vapors can follow into the building. And how about that expensive addition you are going to make? It may get much more expensive or become impossible when you attempt to deal with the contamination beneath the building.

They Can’t Make Me Clean it Up!

You are striking out again. They can make you clean it up. In some cases, they can allow you to leave the contamination in place but they can also require a restrictive covenant be placed on your deed. Getting to that point can be expensive because they can require a Phase II Environmental Assessment, that is, testing of the soil and groundwater at numerous depths and locations to define the plume’s degree of contamination, horizontal extent, and lateral extent. Once the covenant is on the deed, it restricts your use and future buyers’ uses of the property. It can suddenly become very hard to sell the property.

Savvy Buyers Do Phase I’s

That is what we have seen over the past twenty years. The Phase I Assessment is an important part of their due diligence, regardless of the bank not requiring it. As a matter of fact, we have quite a few clients who start with the Phase I because if it shows contamination or a strong potential for contamination, they cut their losses, spend no more on due diligence, and move on to the next property.

Conclusion

You should seriously consider if you want to omit a Phase I Site Assessment. You may save a couple thousand dollars up front but it could turn into losses in the hundreds of thousands of dollars in the future.

Further Assistance

If you need any help, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a Florida licensed Professional Engineer and certified Environmental Assessors on staff. We have been completing Environmental Assessments since they first started being done in 1988. We have the credentials and experience to help you complete your Environmental Site Assessment project.

We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today! We are your Phase I Environmental Assessment Company.

Skip The Phase I Environmental Site Assessment

I Just Want to Do a Phase II Environmental Site Assessment

We have that telephone call quite often. The caller usually says, “Look, just give me an estimate for a Phase II Environmental Site Assessment. I don’t want to do a Phase I.” To which we respond, “Okay, so you have already had a Phase I done?” “No, but I know it was a gas station.” At which point we explain how skipping the Phase I risks omitting information and data which could affect the type of testing you do in the Phase II.

Due Diligence

We further explain that in so doing, the caller may not be exercising due diligence in determining if the site is or could be contaminated from usage of the itself or properties in the vicinity. Why the concern about due diligence? Well, if due diligence is exercised via a Phase I and, if required, a Phase II, and contamination is found later on, Superfund (CERCLA, Comprehensive Environmental Response, Compensation, & Liability Act, www.epa.gov) is supposed to cover the cleanup. Considering cleanups can start at less than $50,000 and run into the millions, that is nothing to take lightly.

What Could be Omitted on the Site Itself?

Environmental Site Assessment Let’s use the gas station example. A gas station today is not necessarily a gas station yesterday. In the 1950’s to mid-1970’s, a gas station was normally a full service station, not the convenience store that sells gasoline and diesel fuel today. Not only did they sell fuel from underground storage tanks, but they quite often dumped used oil, chlorinated carburetor cleaner, and other petroleum based wastes into a used underground storage tank. And, yes, those tanks leaked just like the fuel tanks. At the end of the day, they often hosed down the floor of the repair shop and squeegeed it out the door onto the pavement, grass, dirt, road, and storm drains. Oh, by the way, they also had hydraulic oil tanks underground for the lifts, which also leaked.

A lot of the details on the site usage would be missed by jumping to a Phase II. The operations above raise the need to include used oil, solvents, hydraulic oil, and heavy metals from the used oil in the Phase II. But guess what? Prior to it becoming a service station in 1960, it was part of a former celery field for 30 years where every pesticide available was used. And that is an even bigger omission. One would not necessarily have discovered that by skipping the Phase II.

How about the Vicinity?

Well, it turns out, there was a perchloroethylene (perc) contaminated dry cleaner right across the street. But it is clear across the street, who cares? You should because that contamination could have migrated to your site and you could end up bearing the cleanup cost. And by the way, the ASTM E 1527 -13 Standard E-27 for Phase I’s (www.astm.org) considers that an adjacent property – the road offers no separation. Oh, and right down the street was a paint and body shop which was less than meticulous in handling and disposing solvents and paints. Matter of fact, the groundwater plume from that operation is now at the edge of your site.

Conclusion

So that should be enough information for you to decide that skipping a Phase I is not a good idea. If you do, the consequences may be more than you can stand – emotionally and financially!

Further Assistance

If you need any help, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a CIH on staff. We have the credentials and experience to help you complete your industrial hygiene project.

We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Industrial Hygiene Testing Results

Industrial Hygiene Blogs So Far

This is the ninth in a series of blogs on industrial hygiene (IH). Our last blog covered the selection of an industrial hygiene testing firm. The current blog will address what to do with the industrial hygiene testing results.

The Report

Most likely, if you selected a reputable firm with experience and a Certified Industrial Hygienist on staff, you will end up with a thorough report. The objective and scope of work will be stated and the methods will be identified. Details of the testing event will be provided. Then, the results will be presented and evaluated. They will be compared to regulatory limits of the U.S. Occupational Safety & Health Administration (OSHA, www.osha.gov) and recommended limits of organizations such as the American Conference of Governmental Industrial Hygienists (ACGIH, www.acgih.org) and the National Institute for Occupational Safety & Health (NIOSH, www.cdc.gov).

Oftentimes, we are asked why limits beyond OSHA’s are included. The reason is that in many cases, OSHA’s limits are 40 years old. They have not been able to keep up with new information and data, because most of their moves are challenged in court. We are talking worker protection here and minimizing your company’s liabilities. The other limits such as ACGIH’s Threshold Limit Values® (TLVs®) and NIOSH’s Recommended Exposure Limits (RELs) are more current and can be considered industry standards. Our legal friends tell us that you can be held accountable to industry standards in a court of law. Therefore, you want to take these recommended limits seriously.

Control Options

So, let’s say your report shows that the airborne concentrations of certain chemicals in your plant exceed the regulatory or recommended limits. What are your options to control the situation? OSHA would prefer that you use administrative controls or engineering controls INDUSTRIAL HYGIENE TESTING RESULTS first and as a last resort personal protective equipment (PPE). Why is PPE considered a last resort? Because it is the last line of defense. If it fails, your workers may be ex-posed to hazardous airborne concentrations. Therefore, OSHA prefers that the hazard be eliminated or reduced to a level that is either nonhazardous or is as low as reasonably achievable.

Here are a few examples of controls. Administrative controls may involve substitution of chemicals with less hazardous chemicals, or shift rotation to minimize the time of exposure, or changing the task so the worker is less exposed, or training employees properly. Engineering controls could include exhaust ventilation, automated dispensing of chemicals, general ventilation, and more. Of course PPE includes respirators, safety glasses, welding curtains, protective clothing, gloves, and on and on.

What Next?

Assemble the appropriate players and evaluate the different control options. The cost, effectiveness, and likelihood to be used are real factors for serious consideration. Once a selection is made and the controls are implemented, decide when to retest. After all, you probably won’t know whether the controls are effective without data.

So that concludes our blog on what to do with the results from completing industrial hygiene testing. And we have now covered a lot of ground in the field of industrial hygiene.

We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Industrial Hygiene Testing Firm Selection

Industrial Hygiene Blogs So Far

This is the eighth in a series of blogs on industrial hygiene (IH). Our last blog covered the design of industrial hygiene testing. The current blog will address how to select an industrial hygiene firm to do the testing.

Selection Players

Most likely, you will need other players besides yourself to select the firm to do the industrial hygiene testing. It often takes representatives from Safety, Facilities, Maintenance, Operations, and Purchasing. Each of these players has a different interest and plays a different role in the project. They have interests in worker protection, compliance, production efficiency, and expenditure of money and man hours. They must communicate on the project. A meeting may be necessary.

Testing Objective

INDUSTRIAL HYGIENE TESTING FIRM SELECTION Assuming that you are in charge of Safety, you need to control the selection and must make sure that the players understand the objective. You want to be clear and concise. For example, you may advise the players that our objective is to determine if our painters applying the primer and finish coats are being overexposed to methylene chloride. They spray the paints off and on for a total of six hours during their eight hour shift five days a week. We have exhaust ventilation in the paint spray booths and they wear full facepiece air purifying respirators equipped with organic vapor filters piggybacked with particulate filters. Assuming the respirators have the proper protection factor, what are they exposed to if the respirator fails or they do not don it properly? We want to know what the airborne methylene chloride concentration is on an eight hour time weighted average (TWA) basis and on a fifteen to thirty minute short-term basis. Does it exceed the limits of OSHA (www.osha.gov) or ACGIH (www.acgih.org)? If so, we need to reduce their exposure.

Selection Criteria

Again, you will need to take the lead in suggesting the criteria to select the industrial hygiene testing firm. You may specify that the firm has on staff a Certified Industrial Hygienist (CIH), ten years of experience, a quick response time, and a reasonable turnaround time. Other players will have their criteria.

Purchasing may want to check the firm out on Dun & Bradstreet to make sure they are financially sound.

Request Estimate

Once the criteria have been established, request an estimate from one or two firms. Define the objective, operation, paints, and shift. The industrial hygiene firm may or may not want to visit your plant before submitting the estimate.

Specify all of your company’s criteria and conditions in completing the work. Let the firm(s) know up front what the expectations and schedule are.

Review Estimate

You need to review the estimate first and request revisions if necessary. Once it meets all the requirements, the other players need to review either it or your recommendation. Reach a decision and award the job, then get it done.

So that concludes our recommended procedure to select an industrial hygiene firm to complete your testing. In our next blog in this series, we will discuss what to do with the results.

In the meantime, if you need any help, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a CIH on staff. We have the credentials and experience to help you complete your industrial hygiene project.

We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!