Safety hazards such as falls get a lot of attention in construction. But far more construction workers die each year from exposure to chemical hazards (such as asbestos, silica and lead) than from safety hazards.
It’s difficult for the Occupational Safety and Health Administration (OSHA) to enforce chemical hazard standards in construction. First, construction work changes day to day, and OSHA could arrive after the task or operation causing chemical exposure is already complete. Assessing chemical hazards also requires air monitoring. As a result, only about five percent of OSHA construction inspections are for health hazards, and those mostly focus on the few comprehensive health standards in construction (asbestos, lead and hazardous waste).
A Better Way to Address Health Hazards in Construction
OSHA recently revised its hazard communication standard to improve and standardize chemical safety information. As part of the revision, chemical manufacturers will soon be required to update their safety data sheets (SDSs) and send them to employers who will be required to pass that information on to employees.
So the question becomes “Once you identify hazardous chemicals, what should you do about them?” There’s a new approach to address and control chemical hazards in construction that answers just this question. It’s been developed by a subgroup of the American National Standards Institute (ANSI) A10 committee. Over the last several years, members of the LHSFNA’s Occupational Safety and Health Division have been integrally involved in drafting and finalizing the standard. Set to gain final approval in early 2015, the standard will be known as the ANSI A10.49-2015 standard on Control of Chemical Health Hazards in Construction and Demolition Operations.
The standard provides users with a step-by-step framework to determine whether chemicals are of low, medium or high toxicity. It then examines key factors to sort the exposure potential into low, medium or high categories. The toxicity and exposure information is then combined to determine whether a chemical hazard control plan is needed, and if so, whether a basic, intermediate or advanced plan is called for to control the potential risks.
Low-hazard/low-toxicity chemicals can be handled with simple precautions (i.e., following the label). But more toxic and higher exposure chemicals require increasingly sophisticated exposure control plans – referred to in this standard as Job Health Hazard Analysis (JHHA) plans. Simple plans can be written by the contractor, intermediate plans by a “chemical hazard competent person” and advanced plans by a “qualified person” such as a certified industrial hygienist (CIH). The flowchart below (reprinted from the standard) shows how the process works.
Steps needed to evaluate chemical use tasks and incorporate resulting information into an appropriate JHHA plan. (Note: Step 2 involves looking at task-generated exposures from chemicals already on site using a similar process.)
By tailoring the approach to the level of risk, the standard only requires professional help (i.e., a qualified person) for the most hazardous situations. Many construction companies do not have full-time industrial hygienists on staff and often have to call in consultants to do such work. For this reason, the standard also calls for the use of a “chemical hazard competent person.” An appendix in the standard lays out the recommended qualifications and training needed to be a chemical hazard competent person. Other appendices include numerous tables that contractors can and should use to help estimate exposures. These tables were developed based on industrial hygiene principles, yet are simple enough for non-hygienists to use.
The standard contains a similar flowchart and process for chemicals found on the job. This includes chemicals identified in the process of renovation or demolition work that were not brought on site by the contractor. In this case, the process to assess the hazards is more difficult as these substances will not have SDSs.
The approach outlined above was developed with the goal of limiting the need for exposure monitoring. Exposures can vary from day to day, meaning monitoring on one day may provide limited information on how to make decisions for the next one. By not mandating monitoring, the standard recognizes that eight-hour average exposures will be less useful in protecting workers and instead looks at exposures and controls by task. However, contractors can always choose to be more conservative than the standard requires. For example, they could prioritize monitoring for all cases combining high exposure potential with highly toxic products, or they could still make use of a CIH to ensure they are not overexposing workers.
For too long health has taken a backseat to safety in construction, but the A10.49 standard provides a practical approach that is tailored to the industry. This new standard will hopefully focus more contractors on the health hazards their workers face and stimulate efforts to control them. Health culture belongs alongside safety culture as an element in any successful construction safety and health program. In the long run, construction workers and the industry should see a more productive workforce that stays healthier longer, then enjoys a healthy retirement.
Copies of the standard will be available shortly from the American Society of Safety Engineers (ASSE) at www.asse.org/departments/standards.
[Scott Schneider is the LHSFNA’s Director of Occupational Safety and Health.]