EPA
United States
Environmental Protection
Agency
Office Of
The Administrator
(A101F)
171 R-92-011
April 1992
Radon Mitigation Employee
Health And Safety:
A Student Manual
Printed on Recycled Paper
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DISCLAIMER
This report was furnished to the U.S. Environmental Protection
Agency by the student identified on the cover page, under a National
Network for Environmental Management Studies fellowship.
The contents are essentially as received from the author. The
opinions, findings, and conclusions expressed are those of the author
and not necessarily those of the U.S. Environmental Protection
Agency. Mention, if any, of company, process, or product names is
not to be considered as an endorsement by the U.S. Environmental
Protection Agency.
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RADON MITIGATION EMPLOYEE
HEALTH AND SAFETY:
STUDENT MANUAL
Richard Torraco, William J. Angell, and Dyanne Drake
Midwest Universities Radon Consortium
University of Minnesota
July 23, 1991
This document was produced with the partial support of a U.S. Environmental Protection Agency (EPA)
National Environmental Education Management System (NEEMS) Fellowship awarded to Richard
Torraco Research Assistant with the Midwest Universities Radon Consortium (MURC) at the University
of Minnesota. This manual contains revisions made by William J. Angell, MURC Director, and Dyanne
Drake, MURC Research Assistant.
The mention of commercial products or services are for educational purposes and reader convenience
and does not imply endorsement nor does omission imply criticism.
MURC thanks the following reviewers for their constructive input: Bill Brodhead, Deborah Fugazzotto,
Harry Grafton, Larainne G. Koehler, Phillip C. Nyberg. Sheldon R. Weiner (OSHA), Thomas I. Bloom
(NIOSH), Ron Simon.
MURC is part of the Minnesota Building Research Center and Minnesota Extension Service. MURC is
an EPA sponsored Regional Radon Training Center established in accordance with U.S. Public Law
100-551.
U.S. Environ menta! Protection Agency
Region 5, Library (PI-12J
2J)
f
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Table of Contents
I. Overview and Introduction
II. Respiratory Hazards and Protection in Radon Mitigation Work
A. Need for Respiratory Protection and Limitations of Engineering Controls
B. Selecting the Proper Respirator
1. Disposable Paniculate Respirators
2. Organic Vapor Respirators
3. Combination Particulate/Organic Vapor Respirators
C. Conditions That May Prevent the Use of an Air-Purifying Respirator (APR)
D. Respirator Inspection Procedures
1. Disposable Paniculate Respirators
2. Organic Vapor Respirators
E. Conducting Positive and Negative Facefrt Checks Prior to Entering a Contaminated Area
1. Positive Pressure Facefit Check
2. Negative Pressure Facefit Check
F. Conducting Qualitative Respirator Fit-Testing
1. Saccharin Solution Aerosol Protocol for Disposable Paniculate Respirators
(a) Taste Threshold Screening
(b) Saccharin Solution Aerosol Fit Test Procedure
2. Isoamyl Acetate Protocol for Organic Vapor Respirators
(a) Odor Threshold Screening
(b) Isoamyl Acetate Fit Test Procedure
G. Cleaning, Maintenance, and Storage of Respirators
1. Cleaning and Sanitizing of Respirators
2. Maintenance and Storage of Respirators
H. When to Change Respirators or Respirator Filters and Cartridges
I. Physical Examination Requirements and Respirator Use
J. Documentation of Training and Instructions to Respirator Users
III. Monitoring Worker Radon Exposure
A. Need for Worker Exposure Monitoring
B. Units of Measurement
,,. C. Equilibrium Ratio
D. Calculating Worker Exposure to Radon and Radon Decay Products
1. Concept of Equilibrium Ratio
2. Equilibrium Ratio Calculation Exercises
3. General Relationship of Units of Radon Measurement (pCi/L) to Units of
RDP Measurement (WL)
4. Conversion Formula
5. Working Levels (WL) and Working Level Months (WLM)
6. Working Level Months Calculation Exercises
E. Current Guidelines for Occupational Exposure to Radon Decay Products
F. Procedure for Employee Monitoring
1. Importance of Respiratory Protection During Diagnostic Work
2. Following the EPA Guidelines and Protocols for Mitigation Work
3. General Employee Monitoring Considerations
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4. Monitoring Employee RDP Exposure Using ATDs
(a) ATDs
(b) E-PERMs
IV. Safe Mitigation Practices and Precautions
A. Radiation Protection (ALARA)
1. Ventilation
2. Logistics
3. Intrusive Activities
4. Sequence of Installation
5. Miscellaneous
B. Noise and Hearing Conservation
1. Noise is a Significant Health Hazard
2. The Characteristics of Sound
3. The Harmful Effects of Excessive Noise
(a) Auditory Effects of Noise
(b) Non-Auditory Effects of Noise
4. Methods of Noise Control
5. Hearing Protection
(a) Standard Hearing Protection Devices
(1) Earmuffs
(2) Earplugs
(b) Nonstandard Hearing Protection Devices
(1) Canal Caps (Superaural Hearing Protectors)
(2) Custom-molded Hearing Protection
6. EPA's "Noise Reduction Rating- (NRR) System
I n<£!?Ur.en!lr Estimatin9the Adequacy of Hearing Protector Attenuation
8. OSHAs Occupational Noise Exposure' Standard (29 CFR 1910 95)
C. Asbestos and Radon Mitigation Work
1. Current Uses of Asbestos
2. Health Hazards Associated with Asbestos
3. Occupational Exposure Limits for Asbestos
4. Precautions When Suspecting the Presence of Asbestos
Small-Scale Short-Duration Renovation and Maintenance Jobs Involving
Asbestos ( Exception- Provided by 29 CFR 1926.58, Appendix G)
6. Respiratory Protection for Asbestos Exposure
7. Additional Sources of Information on Asbestos
D. Electrical Safety
- 1. Electrical Hazards in Radon Mitigation Work
2. The Hearth Effects of Electrical Hazards
(a) Electric Shock
(b) Severity of the Shock
(c) Bums and Other Injuries
3. Correcting Electrical Hazards and Preventing Injuries
(a) Insulation
(b) Grounding
(c) Circuit Protection Devices
(d) Guarding
(e) Safe Work Practices
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E. Eye Safety
1. Selecting Safety Eyewear for Mitigation Work
(a) Safety Glasses
(b) Safety Goggles
(c) Face Shields
2. Wearing Contact Lenses On-The-Job
3. Supervision of a Workplace Eye Safety Program
V. Hazard Communication and Chemical Safety
A. What the Hazard Communication Standard Addresses
B. What is a Contractor Required To Do?
C. Material Safety Data Sheets (MSDSs)
D. Labeling of Hazardous Chemicals
E. Employee Training
F. Written Hazard Communication Program
VI. References
(to be listed)
VIII. Appendices
(copies of relevant OSHA standards and EPA guidance)
in
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I. OVERVIEW AND INTRODUCTION
Radon mitigation is focused upon reduction of occupant risks to environmental hazards. Thus, radon
mitigation contractors have the obligation to act safely at all times and to complete mitigation in a
manner that poses no hazard to workers or occupants.
This manual is intended to guide radon mitigation contractors and workers through training that reduces
exposure to ionizing radiation, particulates and organ vapors as well as excessive noise, electrical
hazards eye hazards, and chemical hazards. However, neither this manual nor related training will
address'all possible safety problems. Thus, the user of this manual is responsible for consulting with
applicable documents and manuals for equipment and supplies used, to establish appropnate health
and safety practices (e.g.: 29 CFR 1926; 29 CFR 1910; and 29 CFR 1910.1200-see appendices), to
determine the application of related regulations, and, if necessary to consult with an industnal hygienist
and other experts to develop a written company worker protection plan that may be required by
agencies and others.
This manual supplements but does not replace Occupational Safety and Health Administration (OSHA)
or other regulations. The students and instructors using this manual should obtain, read, understand,
and comply with companion OSHA and other regulatory standards including those cited in this manual
and subsequent revisions. Students are encouraged to seek further training including OSHA respirator
training.
This manual draft reflects the review of OSHA's Office of Standards Analysis and Promulgation but not
OSHA's Safety Standards Directorate (for electrical and eye safety). This additional review has been
requested by the U.S. Environmental Protection Agency's (EPA) Office of Air and Radiation and will be
incorporated in future drafts.
II. RESPIRATORY HAZARDS AND PROTECTION IN RADON MITIGATION WORK
A. The Need for Respiratory Protection and Limitations of Engineering Controls
A properly fitted, selected, and maintained respirator can provide significant protection against the
inhalation of radon decay products. Greater than 90% of RDPs can be effectively filtered from
breathable air provided the proper respirator is worn according to instructions.
However, the use of respirators In radon mitigation work Is no substitute for ventilating the
work space and other proper work practices. The first thing that you should do on entering the
basement or crawlspace—unless there Is friable asbestos containing material—Is to set up
ventilation equipment and pressurize the space with outdoor air to insure worker exposure Is as
low as reasonably achievable. Without adequate ventilation, radon and RDP levels can build up
without your realizing how much radon you may be breathing. The philosophy that "conditioning the
environment for the person, not the person for the environment" should be a guiding principal.
During an initial radon investigation, ventilation of the work area may be limited because pressure
and/or radon measurements need to be taken. However, when conducting subslab or wall pressure-
field diagnostics, vacuum cleaners should be discharged to the outside to prevent re-entrainment of soil
gas into occupied spaces. Vacuum cleaners should also be used to control dust from diagnostic and
mitigation activity. While investigating and taking measurements, it is particularly important to use
respiratory protection in the absence of adequate ventilation especially if the radon level is suspected
to be above 100 picoCuries per liter or 1 working level, whichever is tower. Personnel wearing
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respirators should be properly trained and medically qualified. Some employers require new
8xamination reP°rt- includin9 chest x-ray and pulmonary function, and
*
The classification of respirators includes: 1) air purifying respirators (APR) that work on the basis of a
negatrve pressure seal wrth the user's face, such as disposable paniculate and half-or full faced
a^S^SCUR'r^l^^681 3nd 2) SUpplied air respirators ** as self-contained breathing
apparatus (SCUBA). Selection of respirators should be guided by EPA Order 1440 3 found in the
append* of th,s manual. EPA Regional Offices may offer additional policy and guidance
tests and V™*M* physteals «•'• US-EPA
Although air-purifying respirators can provide significant protection against the inhalation of RDPs they
to^^**0??"* ^ inhalati°n °f rad0a Protectk)n from the inhalat»n of radon can onT
to achieved through the use of air line respirators (self-contained breathing apparatus) liis undear at
this time what the health effects are from high levels of radon with tow RDP wncentrations
B. Selecting the Proper Respirator
Radon mitigation work presents workers with at least two general types of inhalation hazards-particles
such as radon decay products, asbestos, mold, dust from concrete grinding and drillinq as wellS
vapors rom caulks, sealants, or paints that may be used in the couL of miti^atton wlrJ P
types of resonators are available which provkJe specif* protection for either ofbofh t^es of
ne^ed. tyP6S * r6Spirat0rS are common|y "sed by mitigators depending on the type of protection
1. Disposable Paniculate Respirators
If Af denCy fitterSl are National lnstitute for Occupational Safety and
M , Administration (NIOSH/MSHA) certified for use in atmospheres
^^n%*QS '"fJ3130" deCay Pr0duct (RDP) partides that account «>< the major ^ortion
of the rad.at»n dose recerved in most mitigation situations. However, as noted in Section E
nd thUS> Sh°Uld "* *» ^mrr^nded over other
(b) Examples: 3M #9970 High Efficiency Respirators; North #10030 Disposable Respirator.
(c) Indications for Use: To be used in environments where RDP's may be present (especially when
'S
against
2. Organic Vapor Respirators
(a)These respirators are NIOSH/MSHA certified for use in atmospheres with up to 1000 ppm of
ganc vapors from solvents, caulks, sealants, or paints (not for use with polyu re thane caulks
PpanSL=hl°am^ TheseK.elastomeric half-mask or, better, full-face respirators are fitted with '
replaceable cartrKiges which prov.de specific protection against organic vapors. Users should
determine that the respirator is appropriate for the specific compounds that will be encountered.
[!LESleS,:oM #5°01 S6ries Easi"Care ResPjrator: 3M #7000 series Easi-Air Respirator;
MSA Comfo II Respirator; as well as North, Survivair, Willson and other Models.
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(c) Indications for Use: To be used in environments where organic vapors may be present.
Organic vapors are released during the application of most paints, caulks, and sealants and during
the use of solvent based cleaning solutions. Organic vapor cartridge respirators do not provide
adequate protection against RDPs nor radon.
3. Combination Particulate Filter/Organic Vapor Respirators
(a) These are half-mask or, better, full-face respirators fitted with both organic vapor cartridges and
RDP paniculate filters. Because inhaled air is filtered through both types of purifying media,
respirators equipped in this way provide NIOSH/MSHA approved protection against radtonuclides,
RDP particulates, and organic vapors.
(b) Examples: 3M #5001 series Easi-Care Respirator fitted with 3M #2040 HEPA pre-filter; 3M
#7000 series Easi-Air Respirator fitted with #7251 organic vapor cartridge and #7255 radtonudide
paniculate filter; MSA Comfo II Respirator fitted with Type GMC-S filter/cartridge combination; and
similar North, Survivair, Willson, and other models.
(c) Indications for Use: To be used in environments where both RDPs and organic vapors may be
present. These organic vapor cartridge systems provide protection up to 1,000 ppm of organic
vapors. The combination fitter/cartridge systems do not provide protection from radon gas or
polyurethane compounds (xylene?).
C. Conditions That May Prevent the Use of an Air-Purifying Respirator
Several conditions can prevent the achievement of a proper fit and an adequate seal of the respirator
to the wearer's face. These conditions include:
* a growth of beard or sideburns
* a skull cap (protective headgear) that projects under the full-faced respiratory facepiece
* the temple pieces on glasses
* the absence of one or both dentures (upper or tower teeth)
* facial scars.
If any of these or other conditions prevent the proper fit of an air-purifying respirator, this type of
respirator cannot be worn. If respiratory protection is needed and the wearer is unable to achieve the
proper fit using an air-purifying respirator, several types of positive air powered respirators (PAPR) are
available which do not require the achievement of a face seal including hooded PAPRs. PAPRs are
much more expensive than other air purifying respirators.
D. Respirator Inspection Procedures
Respirators should be inspected by the wearer each time the respirator is worn or at least once a
month, whichever is more frequent. Attention should include the following guidelines:
1. Disposable Particulate Respirators
(a) Examine the foam face seal for any tears or deformities that might interfere with the achievement of
a proper face seal.
(b) If any portion of the respirator facepiece is wet, it should be set aside and allowed to dry in a clean,
uncontaminated place. Respirators which become saturated with water or other fluids should be
disposed of.
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(c) Inspect the metal nosepiece for creases or any deformity that might interfere with the achievement
QT a rooi T3O6 S63I.
(d) If the respirator has become contaminated or crushed, deformed, or damaged such that the fit or
face seal can no longer be achieved, dispose of the respirator and replace it with a new one.
2. Organic Vapor Respirators
(a) Check the facepiece for cracks, tears and dirt. Be certain the facepiece, especially the seal
area, is not distorted. The material must be pliabto-not stiff. »P»«aiiy me seal
(c) Examine that the heads straps are intact and have good elasticity.
sealed3™™ *" ^^ **"* ** *** °' "^^ °r fatiguing' Make sure the 9askets are
i! Hi2T,V!,the exhalation valve cover and examine the exhalation valve and valve seat for signs
of dirt, distortion, cracking, or tearing. Replace the exhalation valve cover.
E. Conducting Facefit Checks Prior to Entering a Contaminated Area
The techniques described here apply to facefit checks of half-mask and full-face cartridge resoirators
Disposable respirators cannot be fit checked and thus, should not be recommend* a7 iZSSSS*
superior respirators. Before wearing a respirator in a contaminated area, carefully follow
,nstruct*ns applicable to specif* respirator models provided by the ^
Positive Pressure Facefit Check
r^Lf^i °?a!lOVer thK e,xhalation «"«• and exhale gently. If the facepiece bulges slightly
and | no air leaks between the face and the facepiece are detected, a proper fit has been obSd
If a. leakage ,s detected, reposition the respirator on the face and/or readjust the tension ante
2T ST Sti. you CANNOT achieve a ^ lrt- D0
2. Negative Pressure Facefit Check
- ' no°Lthe f3'!"8 °f theKhands over tne OP6" area °f t^ cartridge cap (alternatively, surgical gloves
thp i™ Ter the.°P!nin9s>' inhale gently and hold your breath for five to ten seconds tt
he facepiece collapses sightly a proper fit has been obtained. If air leakage is detected reposttton
f !^SrPSro0T 'I6 faCe and/°r readjUSt the tensk)n of the elastic straPs l° elimjnate the leakage
If you CANNOT ach,eve a proper frt, DO NOT enter the contaminated area. See your supervisor
These facefit checks must be conducted by the respirator wearer prior to each entry into a
contaminated area. '
F. Conducting Qualitative Respirator Fit-Testing
Both of the following protocols involve two steps. First, it is determined if the individual can detect the
° 8?n °r,tfLe °d°r °f iS°amyl acetate and' » so- then jt is determined if the
^ °r Od°r NOTE"-the V3Wrty °f qualrtative f*-'estir* is
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1. Saccharin Solution Aerosol Protocol for Disposable Paniculate Respirators
performed without wearing a respirator, is intended to
determine whether the individual being tested can detect the taste of sacchann.
(1) Threshold screening as well as fit testing subjects shall wear an enclosure about the head and
shoulders that is approximately 12 inches in diameter by 14 inches tall with at least the front portion
clear and that allows free movements of the head when a respirator is worn.
(2) The test subject shall don the test enclosure. Throughout the threshold screening test, the test
subject shall breathe through his/her wide open mouth with tongue extended.
(3) Using a nebulizer the test conductor shall spray the solution into the enclosure.
(4) To produce the aerosol, the nebulizer bulb is firmly squeezed so that it collapses completely,
then released and allowed to fully expand.
(5) Ten squeezes are repeated rapidly and then the test subject is asked whether the saccharin
can be tasted.
(6) If the first response is negative, ten more squeezes are repeated rapidly and the test subject is
again asked whether the saccharin is tasted.
(7) If the second response is negative, ten more squeezes are repeated rapidly and the test
subject is again asked whether the saccharin is tasted.
(8) The test conductor will take note of the number of squeezes required to solicit a taste
response.
(9) If the saccharin is not tasted after 30 squeezes (step 10), the test subject may not perform the
saccharin fit test.
(10) If a taste response is elicited, the test subject shall be asked to take note of the taste for
reference in the fit test.
(b) Saccharin Solution Aerosol Fit Test Procedure
(1) The test subject may not eat, drink (except plain water), or chew gun for 15 minutes before
the test.
(2) The test subject shall don the enclosure while wearing the respirator selected. The respirator
shall be properly adjusted and equipped with a paniculate filter(s).
(3) As before, the test subject shall breathe through the open mouth with tongue extended.
(4) The nebulizer is inserted into the hole in the front of the enclosure and the fit test solution is
sprayed into the enclosure using the same number of squeezes required to elicit a taste response
in the screening test.
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"* ^ SUbJ6Ct Sha" be instmcted to ^om tne
OSitk)n' With°Ut ta'kin9' the *"*"* Sha" breathe
posrtton> the subject sha" breathe
!° Side" Standing in place- the «*l«a shall slowly turn his/her head
(f) Grimace. The test subject shall smile or frown
concenlration sha" *• replenished U5i^ one ha" lhe
" al any time du""9 «• « « *. taste
and a d
2. Isoamyl Acetate Protocol for Organic Vapor Respirators
(a) Odor Threshold Screening
The odor threshold screening test, performed without wearing a respirator is intended to
determine rf the individual tested can detect the odor of isoamyl ^
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(1) The screening test shall be conducted in a room separate from the room used for actual fit
testing. The two rooms shall be well ventilated but shall not be connected to the same
recirculating ventilation system.
(2) Two jars of similar appearance shall be prepared—one containing a cloth swab wetted with
0.5 cc of isoamyl acetate (IAA) solution and the other containing a cloth swab wetted with 0.5
cc of odor free water (e.g. distilled or spring water). Subjects will be requested to select the jar
with the banana oil smell to determine whether or not the individual tested can detect the odor
of isoamyl acetate.
(3) The odor test jar and blank jar containing water shall be labeled 1 and 2 for jar
identification.
(4) The following instruction shall be typed on a card a placed on the table in front of the two
test jars (i.e. 1 and 2): "The purpose of this test is to determine if you can smell banana oil at a
low concentration. The two jars in front of you contain clear liquids. One of these jars contains
a small amount of banana oil. Unscrew the lid of each bottle, one at a time, and sniff at the
mouth of the bottle. Indicate to the test conductor which bottle contains banana oil."
(5) If the test subject is unable to correctly identify the jar containing the odor test solution, the
IAA qualitative fit test shall not be performed.
(6) If the test subject correctly identifies the jar containing the odor test solution, the test
subject may proceed to respirator selection and fit testing.
(b) Isoamyl Acetate Fit Test Procedure
(1) Each respirator used for the fitting and fit testing shall be equipped with organic vapor
cartridges or offer protection against organic vapors.
(2) After selecting, donning, and properly adjusting a respirator, the test subject shall wear it to
the fit testing room. This room shall be separate from the room used for odor threshold
screening and respirator selection, and shall be well ventilated, as by an exhaust fan, lab hood,
or open window to prevent general room contamination.
(3) Using respirator fit-test ampules (e.g., North Safety Equipment #7002 or similar product),
hold the crushed swab 2 to 3 inches from where the respirator facepiece seals to the face and
using a circular motion, slowly move the swab around the entire perimeter of the respirator
seal.
(4) While performing this motion, the exercises previously identified in section F.1.(b)(5) shall
be performed by the test subject.
(5) If at any time during the test, the subject detects the banana like odor of IAA, the test has
failed. The subject shall quickly exit from the test area and leave the room to avoid olfactory
fatigue.
(6) If the test has failed, the subject shall return to the selection room and remove the
respirator, repeat the odor sensitivity test, select and put on another respirator, return to the
test area and again begin the procedure described in (1) through (4) above. The process
continues until a respirator that fits well has been tried. Should the odor sensitivity test be
failed, the subject shall wait about 5 minutes before retesting. Odor sensitivity will usually have
returned by this time.
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8
(7) i When a respirator is tried that passes the test, its efficiency shall be demonstrated for the
subject by having the subject break the face sea. and take a bLth before eTrt^tS area.
™,a™: *n=m M «« ~« , ^ ' COJK9I^^on build-up in the test area, used
Sained " * °°ntainer *** 96neral Ventilation of the test room sha» be
G. Cleaning, Maintenance, and Storage of Respirators
I^^esla^^'i^6"3"0?1 3nd St°rage °f resPirators are v^ important. They influence the
effectiveness and qualrty of resp.rator protect,on as well as the life-span of the respirator
1. Cleaning and Sanitizing of Respirators
''SS^
5£-^^=£=^^
excess" plain warm water and air drY in a non^ntaminated atmosphere. Do not use
respirator pieces. 9r ° aVOld poss>tie ovemeating and distortion of the
2. Maintenance and Storage of Respirators.
(a)
resPjrator is drV- the respirator should be inspected and any
"
H. When To Change Respirators or Respirator Filters and Cartridges
immediately.
1. If while wearing the respirator:
(a) you smell or taste contaminants
(b) you experience Difficulty breathing
(c) irritation occurs
(d) dizziness or other distress occurs
2.
r"ardinfl "mitalto"s °< ^Pi'""' » ««* may app,v ,o
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I. Physical Examination Requirements and Respirator Use
The OSHA standard on respiratory protection (29 CFR 1910.134) stipulates that "persons should not
be assigned to tasks requiring use of respirators unless it has been determined that they are physically
able to perform the work and use the equipment. A local physician shall determine what health and
physical conditions are pertinent. The respirator user's medical status should be reviewed periodically
(for instance, annually)."
J. Documentation of Training and Instructions to Respirator Users
Employer are strongly advised to maintain written records of all worker health and safety training
activities, including those pertaining to respiratory protection. An example of a training record is found
in the appendix of this manual.
III. MONITORING WORKER RAOON EXPOSURE
A. Need for Monitoring Worker Radon Exposure
Those involved in radon work—whether in radon measurement services, the investigation of buildings
with elevated radon levels, or the performance of radon mitigation—can be exposed to high levels of
radon and radon decay products (RDP's). Because these work-related exposure to radon are much
higher than the normal exposures of the occupants of problem buildings, it is imperative that measures
be taken to minimize occupational exposures to radon and to keep accurate records of all occasions
during which workers are exposed to radon and RDP's.
There is currently no single recommended method of monitoring radon mitigator workers for exposure
to radon and RDP's. A method of monitoring employee exposure to RDP's is given in Part F of this
section.
B. Units of Measurement
Health effects from radon exposure are due primarily to the radon decay products and the effect they
have on lung tissue. Radon decay products (RDP's; also known as radon daughters or radon progeny)
are measured in "Working Levels" (WL). This is a unit of measurement indicative of the energy
eventually released during the RDP decay process. A Working Level is any combination of radon
decay products in one liter of air that results in the release or emission of 1.3 x 105 or 130,000 mega
electron volts (MeV) of alpha particle energy.
Radon gas is commonly measured in picoCuries per liter (pCi/L). The picoCurie is a measure of
activity or rate of decay indicating 0.037 decays of radon per second (or 2.2 decays per minute). The
law of radioactive decay states that the rate of decay is proportional to the number of remaining
undecayed nuclei of atoms. Therefore, pCi/L represents the concentration of radon gas in the air (i.e.,
the number of nuclei of radon atoms in the air per volume of air).
Since radon's health effect—its dose to the lung tissue—is due mostly to the radon decay products, it
would appear that the chosen detection instrument should measure these decay products directly. In
practice, however, measurements of radon gas—rather than of RDP's—are often taken because there
are fewer variables in radon measurement, so there is greater certainty in representative results. For
instance, unlike that of RDP's, radon concentration is not affected by circulation or filtration devices.
Also, for time averaging measurements, radon gas measurements are generally more practical, easier,
and less expensive to make. Therefore, it is common practice to use instruments which measure
radon gas only and then make conversions to RDP exposure levels for estimating risk. Measurement
of radon defines the maximum concentration possible of RDP's.
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10
C. Equilibrium Ratio
(WL value! finn) = (1)
Radon Concentration 100
D. Calculating Worker Exposure to Radon and Radon Decay Products
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11
1. Concept of Equilibrium Ratio (ER)
(a) ER - (WL value) (100)
Radon Concentration
(b) Radon and RDP's are in "equilibrium" when maximum RDP's concentration reached.
(c) ER - 1 does not occur indoors (explain why);
ER ranges between 0 and 1; ER usually between 0.1 or 0.2 and 0.7.
(d) ER of 0.5 is commonly assumed as a conservative average.
2. ER Calculation Exercises
(a) Question: You are about to begin mitigation work in a building with a radon measurement
of 69 pCi/L and a working level measurement of 0.30. What is the equilibrium ratio?
Answer: ER = (WL) (100) - (0.30) (100) = 0.43
pCi/L 69
(b) Question: You are monitoring a basement crawlspace for radon and detect a level of 146 pCH..
Assuming an ER of 0.5, what is the estimated WL measurement in the crawlspace?
Answer: ER - (WL) (100) or 0.5 » WL (100) or WL » 0.5 x 146 - 0.73
pCi/L 146 100
3. General Relationship of Units of Radon Measurement (pCi/L) to Units of RDP's Measurement (WL)
(a) 4 pCi/L - 0.02 WL
200 pCi/L =. 1 WL
(b) Assumes an ER of 0.5
- ''(c) Employees are generally monitored for radon exposure and measurements are then converted
to RDP exposure level units (WL).
4. Conversion Formula WL - pCi/L x ER
100
pCi/L = WL_x_100
ER
5. Working Levels (WL) and Working Level Months (WLM)
(a) Occupational exposure to RDP's is measured in working level months (WLM)
(b) One WLM is the equivalent of exposure to 1 WL for 170 hours. (This assumes 170 working
hours per month).
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12
6. WLM Calculation Exercises
ln
1.1 OWL for 2 Hours
0.50 WL for 8 Hours
0.65 WL for 4 Hours
0.04 WL for 3 Hours
Answer: 0.053 WLM
For Example: 1.10 WL x 2 Hours divided by 170
0.50 WL x 8 Hours divided by 170
0.65 WL x 4 Hours divided by 170
0.04 WL x 3 Hours divided by 170
• 0.013 WLM
•• 0.024 WLM
0.015 WLM
0.001 WLM
TOTAL = 0.053 WLM
"*«
expose
180 pCi/L for 1 Hour
95 pCi/L for 6 Hours
37 pCi/L for 2 Hours
8 pCi/L for 2 Hours
RADON
LEVEL
WORKING
LEVEL
HOURS
OF
EXPOSURE
WORKING
LEVEL
MONTHS
(WLM)
(Answer: .0053 WLM + .017 WLM + .002 WLM + .0005 WLM = 0.025 WLM)
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13
E. Current Guidelines for Occupational Exposure to Radon Decay Products
Occupational exposure is measured by working level months (WLM). One WLM is the equivalent of
exposure to 1 working level for 170 hours; this assumes 170 working hours per month. The MSHA
standard for uranium mine workers and OSHA standard for occupational exposure is 4 WLM per year
(with 100pCi/L - 1WL). The Environmental Protection Agency (EPA) uses a guideline of 2 WLM per
year for employees and contractors working on radon projects (with 200 pCi/L - 1WL). Thus, the
MSHA, OSHA, and EPA standards and guidelines are in essential agreement in respect to radon (about
33 pCi/L average over 2040 hours or 12 working months).
F. Procedure for Employee Monitoring
1. Importance of Respiratory Protection During Diagnostic Testing
The ALARA (as tow as reasonably achievable) principle should be followed when considering work
practices and procedures during any radon related activity.
Diagnostics and/or follow-up radon-testing are more often performed in homes that are suspected of
having elevated radon concentrations. Testing devices should be deployed and retrieved spending a
minimum amount of time in the tower areas (basement, etc.) while still obtaining any needed
information (floor layout, HVAC description, etc.). Recording of data and any discussions with the
homeowner or others should be conducted in areas less likely to have elevated radon
concentrations.
Diagnostics by its very nature means attempting to locate and identify source points or areas.
Introducing ventilation may be impractical and self defeating during diagnostics but should be
considered in sites with very elevated ambient radon concentration. (Normally source points and
areas will be easier to identify in these sites). Any intrusive activities should be accompanied by the
use of a shop vac exhausted to the outside. Sub-slab communication tests should also be
performed with exhausts terminating in the outside air. All test holes should be covered over when
not being used and carefully sealed when the diagnostics are completed.
Respirator use should be considered (only if following an approved respirator plan) when performing
inspections on suspected elevated radon sources such as crawl spaces, sumps, floor drain, etc.
Workers performing diagnostics should participate in employee monitoring programs similar to
workers who install mitigation systems.
This manual does not consider the issue of "respirator credit", which is to say, if respirators are
property worn by workers, the workers' exposure to radon and its decay products may be
significantly less than the levels reflected in measurement of indoor environment. Students should
be alert to future decisions concerning credit for a proper respirator program. Ignoring the respirator
credit issue results in a conservative occupational exposure practice.
2. Guidelines and Protocols for Mitigation Work to Minimize Radiation Exposure
The ALARA (as tow as reasonably achievable) principle should be followed when considering work
procedures and practices during any radon related work (see section IV-A).
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14
3. General Employee Monitoring Considerations
small and unobtrusive
measure radon, not RDP's (see section B)
convenient and easy to use
light weight
measure integrated radon concentrates over long period-typica.lv 3 months to a
™H»« MM expit^roVrnr^rny±r hr^nse time-
„
4. Monitonng Employee RDP Exposure:
(a) *_„«., „„,*«,, S(WUK1 OQ monitored with his/her own ATD nr F PFDU ^^i
should be documented on his/her P t-PERM and measurement results
s/ner own Personal Radon Exposure Record (see Figure 1)
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15
Students should be alert to future EPA or other guidance concerning employee occupational and
background monitoring.
(c) Each ATD or E-PERM should be clearly labeled with the initial deployment date and its location
(i.e., either the name of the employee to wear the monitor or the location of background
radiation monitoring).
(d) In accordance with current EPA protocols for screening measurements, minimum ATD
( deptoyment time is 720 hours (i.e., 90 eight-hour working days). At the end of the exposure
monitoring period, representative background radiation measurements corresponding to each
Syee's^ersonal ATD are subtracted from employee ATD measurements to est.mate actual
work-related exposure. E-PERM users should follow manufacturers recommendations and
future EPA guidance.
(e) Radon mitigation contractors should consult with monitor suppliers concerning storage,
deployment, collection, shipping, and quality assurance/quality control involving employee
monitoring.
(f) Radon measurement results from the lab must be converted from pCiA. to WL's and entered on
each employee's Personal Radon Exposure Record (see Figure One).
IV. SAFE MITIGATION PRACTICES AND PRECAUTIONS
A. Radiation Protection (ALARA)
The ALARA (as tow as reasonably achievable) principle should be followed when considering work
procedures and practices during any radon related work.
1. Ventilation
Ventilation of work spaces suspected of having elevated radon levels should begin immediately
upon arrival at the work site (ventilation should be initiated prior to commencing work whenever
possible particularty in elevated radon environments). This should be initiated even as radon or
decay particle monitoring is being set up. The amount of ventilation required will be dependerrt
upon a number of factors including: existing radon concentrations, size (air volume) of the work
space and other pertinent factors (presence of friable ACM-like material; ability to temper the
- " outside ambient air when it is very hot, cold, or damp; etc.). Ventilation should normally be
performed in a positive mode to maximize its effectiveness. Where ventilation of outside air is not
feasible or sufficient to reduce radon concentrations, interior circulation of air should be considered
to reduce decay product concentration (plate out). Using an tonization filtration system (e.g. No-
Rad Radon Removal System should oe considered in appropriate situations. Respirator should be
worn (only if following an approved respirator plan) when the measures do not sufficiently reduce
radon and/or decay product concentrations.
2. Logistics
Whenever possible, radon mitigation tasks should be performed in areas with low radon
concentrations (outside, garage, first floor, breezeway, etc.). This would include both work activities,
discussions with homeowners, and break and lunch periods. Radon concentrations within the mam
work areas (basement, crawl spaces) should determine to what degree this practice is followed.
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16
3. Intrusive Activity
Any intrusive activity (drilling floor and/or wall holes, cracks grinding, etc.) should include the use of
a shop vac devce exhausting to the outskJe area. This will help to minimize ai n^^JSc?
are a hazard in of ^themselves and more so when attached to radon decay products ^es
«r ^, ?9 ft? tl°0ntrol SUb-Slab radon Concentrations when drilling arxl/or wring to
(exten( 0* '" """P areas ™ also **»* from hi
r «r
r nf 7h S exten(£? M0* '" """P areas ™* also **»* from this procedure) he niet
hose of the shop vac should remain within 6 inches of the hole being drilled. This w II direcTmost
t±n h!thVa **% S';b*SOil rad°n and radon decay Products to the^skJe air. Care shcSd ™
taken by the worker to avorf breathing in the area between the ftoor hote and thelnle? oJ the shop
4. Sequence of Installation
5. Miscellaneous
ex^re^31™ SitUati°nS "^ requil0 SPe°ia' arran9ements °r procedures to minimize worker
team approach in
B. Noise and Hearing Conservation
1 . Noise is a Significant Health Hazard
Environmental experts and sound specialists consider noise to be the most widesoread an
m nm S" aecs Urban' ^
present in rwmes and is pervasive throughout business and industry At work a noisv office' can
a?rr°innhH5R° dedbelS (dB): 3 ** fact0ry can avera9e 85 dB= a P*« shop 95 dB a constrSS
00da ^ S^P' 11° dB: 3 ^^ faCt0ry' 118 dB: a ''mberingPSrte,12/d^ a et
C°StS the Unrted States about 4 bi«ion do.lars a
•mpact on health can be skjniffcant. toss of hearing occurs very stowiy TSft^ Mh
are'nsKJk>us- not ^dden or dramatic, and doiittle to attract attentton
norri « Sr18 a
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17
Yet the good news is that hearing toss caused by work-related exposure to noise is preventable
The inforrnatton and guidelines provided in this section can assist in the preservation of hearing for
workers exposed to noise whether in the course of mitigation work or elsewhere.
2. The Characteristics of Sound
Sound is nothing more than the reaction felt by a listener when minute cyclic changes in barometric
pressure occur. The action of sound waves move a sound from where it is produced to the ear,
where hearing takes place.
Sound waves are made up of molecules of air bumping into each other, transferring energy outward
from a source, such as a dap of thunder or the chirping of a bird. This source disrupts the
barometric pressure around it, and causes the air molecules to bump into each other, away from it,
much like when a ripple is created in water if a pebble is dropped into it.
The following terms are key concepts that are important for the understanding of noise as a
significant health hazard.
Intensity Intensity is described in decibels (1/10 of a "Bel") - in honor of Alexander
Graham Bell. A reference must be specified or there is no meaning to
decibel.
Decibel {dB) Sound is measured in terms of sound levels which are expressed in
decibels. Zero on the decibel scale is regarded as the lowest sound level
that the healthy unimpaired human ear can detect (a sound level of 20
micronewtons per square meter). Decibels are logarithmic and not linear
units like miles or pounds. Rather, they are representative points on a
sharply rising curve. Thus, while 10 dB is 10 times more intense than one
dB, 20 dB is 100 times more intense than 1 dB (10 x 10), 30 dB is 1,000
times more intense than 1 dB (10 x 10 x 10) and so on. One hundred dB,
therefore, is 10 billion times as intense as 1 dB (that is, represents 10
billion times as much acoustic energy) as one decibel.
Sound Pressure Level- is ... (ADD)... and rt is sound pressure level that is measured by sound
level meters.
Pure Tone Pure tone does not normally occur in nature. It is made by humans. It is
the fundamental component and in its pure form is a sinusoidal oscillation
of barometric pressure. The number of oscillations per second is the
"frequency" of a pure tone and is identified as Hertz (Hz) - the greater the
number, the higher the frequency. "Pitch" is the term used to sensation of
frequency.
Hearing threshold is the degree of toudness at which you first begin to hear a sound.
Attenuation Attenuation is the reduction in sound pressure level (dBA) obtained by
distance, barriers, hearing protection, audio booth walls, etc. High
frequencies (Hz) are attenuated, or reduced more rapidly than tow
frequencies.
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Hgun»1
PERSONAL RADON EXPOSURE RECORD
Name:
Social Security #:
Job Site Radon Working
Date or Number Level Level
(PCM.) (WL)
/200-
Hoursol
Exposure
(HR)
X
Working
Level Months
(WLM)
/170-
I
>
Cumulative
Exposure1
(WLM)
Momh(s):
rear:
Type/
Model of Serial
Monitor1 Number
Supervisor's
Initials
/200-
/170-
/17Q -
/200-
/170-
J20Q-
/170-
/200-
/17Q -
/200-
/170-
/200-
/170-
/20Q.
/170-
/2QO-
/170-
1 Bw«d upon an annual racommanded hMhh and utoly hnH of 2 wocUng laval month* (WLM).
S. lndka» fx lypa ot monrtor
t. Charooal Cantalaf
i Alpha Trmek Defector
3 E-PERMS
4. Condnooua Monitor (Typa):
5. CMMr(S|MC«y
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19
3. The Harmful Effects of Excessive Noise
Excessive noise can damage parts of the human hearing (auditory) system-primarily the inner ear-
SS^eEHi the gradual loss of hearing. Excessive noise also has harmful effects on hearth ,n
additton to rts effect on hearing (i.e., prolonged noise exposure causes headaches and other adverse
eymptorra) ^)thThe auditory and non-auditory effects of excess noise exposure are bnefly reviewed m
this section.
(a) Auditory Effects of Noise
When exposed to intense sound waves for an extended period of time, temporary damage to hearing
can occur. For example, after a loud concert or a long period in a noisy nightclub we expenence
ringing in the ears or "tinnitus". This is a temporary symptom due to damage to the heanng organ
within the inner ear (the cochlea) that resolves after several hours away from noise in a quiet
environment.
Another symptom of excessive noise exposure is a gradual dullness of sound as if both ears were
partially blocked that occurs due to exposure to intense noise. This condition is also temporaryas
hearing returns to the usual clarity after its allowed to "rest" from the intense noise for several hours.
Pain can also occur as a result of sudden, very intense noise, as those of us who've experienced pain
due to jet take off, explosions, and artillery fire can attest. Depending on the duration of the noise the
pain can be followed by a period of tinnitus, yet both symptoms resolve after a period of time away from
the noise exposure.
Permanent hearing toss may occur as a result of exposure to toud noises for extended periods of time.
The hearing toss associated with exposure to work-related noise is commonly referred to as acoustic
trauma" This type of hearing loss is the result of nerve or hair cell destruction in the hearing organ and
is irreversible. No form of medical care or surgery can repair the damage to hearing caused by
overexpose re to noise.
However such hearing tosses usually are only partial. That is, excessive noise exposure does not
result in simultaneous toss of hearing at all sound frequencies. Hearing toss is first evident in the
reduction of the ability to hear high frequency sounds.
The most common levels of work-related noise exposures are well betow the pain threshold for noise.
Pain is experienced at noise levels of 135-140 dBA and above. There is a wide range of noise levels
" and frequencies to which long-time exposure may cause a slowly developing impairment of heanng
The part of the inner ear that may be damaged depends on the frequency components of the noise field
that are present at the levels of exposure. Individual susceptibility of the exposed worker may also be a
factor Noise-induced permanent hearing loss is first evident in a reduction in the ability to hear high
frequency sounds. As the exposure continues, the reduction progresses to the tower frequency sounds
in the speech range. Exposure to noise that will produce this stow damage may sometimes be
accompanied by other signs, such as a sensation of tingljng or ringing in the ear (tinnitus) when one
moves out of the noise field. Current evidence indicates that any permanent effect on the hearing
organ is unlikely unless it is preceded by a temporary threshold shift of the hearing level. This shift can
be detected by an appropriate program of hearing testing, and this information can serve to warn
overexposed personnel that there is a risk of permanent damage to hearing.
There is a gradual loss in hearing sensitivity that takes place as people grow older. This decrease in
hearing sensitivity accompanying the aging process is known as presbycusls. Hearing tosses due to
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20
(b) Non-Auditory Effects of Noise
hormones into the blood. Even stomach chane L a"°u* endocnne 9'ands pour additional
^^
f •»«•"«<- .0 «
factor in the rate o. occurrence oHhesVdisease »4«b™ ' ™V ^ ^ 3 Ool**u«n9
4. Methods of Noise Control
IS
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21
(im?
souncz
MEDIUM
RECEIVE*
A,
3,
Figure 2. The 3 stages of the noise transmission pathway.
* use of noise dampers, acoustic insulation, mufflers, pads, carpet, etc..
* use of sound barriers, walls, shields, and other separations between the employee and
the noise source.
Some of these noise reduction methods are not practical for radon mitigation work. Another point of
intervention is to control noise at the receiver (Point C in Figure 2) using various types of heanng protection.
This is the most practical method of noise control for mitigation work.
5. Hearing Protection
From an employee health and safety standpoint, the wearing of hearing protection to reduce the harmful
effects of noise is the last measure to be used after steps to minimize exposure time and steps to reduce
noise at the source have been exhausted. Administrative control of noise (i.e., rotating employees out of
noisy environments) and engineering controls (i.e., damping or insulating noisy tools and equipment) are
the noise control interventions of choice for preventing noise-induced hearing toss. When these measures
are impractical or ineffective in bringing noise down below harmful levels, various types of heanng
protection devices are available for protection against the harmful effects of noise. The types of heanng
' protection in common use are briefly described as follows.
(a) Standard Hearing Protection Devices
(1) Earmuffs
Earmuff devices cover the external ear to provide an acoustic barrier. The attenuation provided by
earmuffs varies widely due to differences in earmurf size, shape, seal materials, shell mass, and type of
suspension. Head size and shape also influence the attenuation characteristics of these protectors.
The type of cushion used between the shell and the head has a great deal to do with attenuation
efficiency. Liquid-filled cushions give better noise suppression than foam rubber types.
Of these two types, foam-filled earmuffs are lighter, less expensive, and provide a tower level of noise
attenuation efficiency than liquid-filled earmuffs. Both types have adjustable headbands that
accommodate various head sizes. It is important that the earmuffs be adjusted and properly seated
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around , he ears (or torn corrfor, and optimum r»ise anenua,»n. Examples o. foanv.iw ear™«s
•Bilsom "Universal I"
'Howard Leight "QM24"
Examples of liquid-filled earmuffs include-
•Bilsom "Viking"
'Howard Leight "QM27"
'Howard Leight Thunder 29"
(2) Earplugs
PremokJed Earplugs
•EAR -UrtraFif KM.
•American Optical "Hear Guard"
•North "Corn-Fit"
•Howard Leight "Air Soft"
•Bilsom "Per-Fit"
Formafc^ Earplugs
, types are des^ned lor ««*- u-
•EAR Disposable Earplugs
•Bilsom "Ultra Sort"
'North "DeciDamp"
•Howard Leight "Quiet"
(b) Nonstandard Hearing Protection Devices
(1) Canal Caps (Superaural Hearing Protectors)
•American Optical "Sound Out"
•Howard Leight "QB2"
•EAR "Caps"
(2) Custom-molded Hearing Protection
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23
a small portion of it in the ear canal. As the material sets, it takes the shape of the individual's ear
and external ear canal. These special, custom-fit devices are only available from hearing specialists
(i.e. certified audiotogists and otolaryngotogists--ear, nose, throat physicians).
6. EPA's "Noise Reduction Rating" (NRR) System
EPA has established a numerical system to measure the relative noise reducing capability of hearing
protectors. Each model and brand of hearing protector is given a value or noise reduction rating (NRR)
according to its noise reducing capability. According to EPA regulation, the NRR of a hearing protection
device must be shown on the outside of the hearing protector package.
The following table lists selected types of hearing protectors and their corresponding NRR's.
General Category
CANAL CAPS
EARPLUGS
(Formable)
EARPLUGS
(Premolded)
EARMUFFS
TABLE 1.
EPA "Noise Reduction Ratings" (NRR)
for
Selected Types of Hearing Protection
Manufacturer & Model Examples
American Optical "Sound Out"
Howard Leight "QB2"
Bilsom "Ultra Soft"
Howard Leight "Quiet"
American Optical "Hear Guard"
(Corded and Uncorded)
Howard Leight "Air Sort"
Howard Leight "QM24"
Bilsom "Universal I"
Howard Leight "Thunder 29"
Bilsom "Viking"
Noise Reduction Rating
17 decibels
25 decibels
26 decibels
26 decibels
24 decibels
27 decibels
24 decibels
24 decibels
29 decibels
29 decibels
7. Procedure for Estimating the Adequacy of Hearing Protector Attenuation
The OSHA noise standard offers several methods of estimating the adequacy of hearing protector noise
attenuation. The methods assume that there is a way to determine what noise level exists in the work
environment. Noise level surveys can be accomplished using a sound level meter, which can be purchased
or rented, or by contracting the services of an industrial hygiene consultant.
Estimates of the adequacy of hearing protector attenuation use the NRR values given each brand and
model of hearing protector. Estimating the adequacy of hearing protector attenuation involves a two-step
process. First, determine the workplace noise level using a sound level meter or through the services of an
industrial hygiene consultant (and, if applicable, obtain the employee's 8-hour time-weighted-average (TWA)
noise exposure). Second, subtract the NRR of the hearing protector selected from the workplace noise
level or the employee's 8-hour TWA noise exposure. The resulting level is an estimate of the noise level to
which the employee is exposed under the hearing protector.
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24
8. OSHA's "Occupational Noise Exposure" Standard (29 CFR 1910.95)
In the early 1980's the Occupational Safety and Health Administration (OSHA) issued and later amended a
comprehens^e health standard covering occupattonal noise exposure In an attempt to reduc^ he h^
inadence of no,se-,nduced hearing loss in business and industry. The standard, "CXxupatkSa I NoS
Exposure" (29 CFR 1910.95), requires a comprehensive "hearing conservation pr^ to insure he
nsure e
protection of employees from workplace noise overexposure. According to the standard "The emotover
shall adrnmister a continuing, effective hearing conservation program, as described in (the standard)
W, oreHV6r .t!mpl°yee n°iSe 6XP°sures ^ual or exce«i an 8-hour time-wekjhted average sound leve (TWA)
of 85 deabels measured on the A scale (slow response) or, equivalently, a dose of fifty percent."
thT'ST5 f'6 T^iS'J0 XT** With the Provisions of thjs standard if employees are exposed at or above
the acton lever of 85 deabels as an 8-hour time-weighted average-the minimum noise teveT a? which
1 *** whfch triggers the protective «***»• °f the ^
. whfch triggers the protective «***»•
program. It is likely that workers doing residential radon mitigation projects may not be
is str e™ ,„
'-
• Aud,«, exP°sures are at or a^ve the 85 decibel "action level";
piSTJr; S ^- ( 6anng aCUrty tests) for a" emPtoyees whose exposures equal or
exceed an 8-hour time-weighted average of 85 decibels-
'
H nt1-10" aVai'able t0 emPtoyees at no cost to them and ensuring that
the hearing protection is worn by exposed employees
S^ver"3' he3rin9 C0nservation trainiR9 to employees exposed at or above the
Maintaining accurate written records of workplace noise levels, employee audiometric
test results, and employee training records. -uuwmeinc
B. Asbestos and Radon Mitigation Work
1 . Products Containing Asbestos
f°Und in a wide varie* of
f'Slon maens. an9S: ra6 'inin9S f°r rai'road Cars and airP|anes: and i
Pipe Pr0ducts used for water suPP'y and sewage piping
°r e'eCtriC WireS' fire Pr°tection material' chemfca|Pt£2;
- C0mponents' reskjential an^ industrial building materials.
1 paints- coa^s- arxi seaiams:
— n P^ts, f.ers for beverages,
fire-protective ciothing- eiectrk:ai
° ra«°™«?*™ w°rk in: pipe, duct, furnace, boi.er and e.ectric
^^^^
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25
2. Health Hazards Associated with Asbestos
Exposure to asbestos may increase the risk of these serious diseases:
a. Asbestosis—a chronic lung ailment that can produce shortness of breath, permanent lung damage,
and increased risk of dangerous lung infections.
b. Lung cancer
c. Mesotheltoma—a relatively rare cancer of the thin membranes lining the chest and abdomen.
d. Certain other cancers such as cancers of the larynx, stomach, colon and rectum, and esophagus.
While asbestos exposure itself can increase the risk of developing lung cancer, asbestos and cigarette
smoking together may increase lung cancer risk over the already high risk due to smoking alone.
Cigarette smokers, en the average, are 10 times as likely to develop lung cancer as nonsmokers.
Smokers who are also heavily exposed to asbestos has been shown to be up to 90 times more likely
to develop lung cancer than nonexposed individuals who do not smoke.
There is evidence that quitting smoking will reduce risk among asbestos-exposed workers, perhaps by
as much as half or more. Workers who were exposed to asbestos on the job at any time during their
lives or who suspect they may have been exposed should not smoke.
3. Occupational Exposure Limits for Asbestos
As a results of the serious health risks associated with asbestos, regulatory control over occupational
and environmental exposure to asbestos has become increasingly stringent. OSHA's health standard for
occupational exposure to asbestos currently limits workers to an airborne asbestos concentration of no
more than 0.2 fibers per cubic centimeter (cc) of air as the average 8-hour workday exposure (8-hour
Time-Weighted-Average). In addition, no employee may be exposed to a concentration in excess of 1.0
fiber per cc of air as averaged over a sampling period of thirty (30) minutes. (This is a so-called short
term "excursion limit". Generally the most toxic substances are given these exposure restrictions by
OSHA).
NOTE - State standards may vary from OSHA standards.
4. Precautions When Suspecting the Presence of Asbestos
Asbestos bonded in finished products is not a risk to health, as long as the product is not damaged or
disturbed (for example, by sawing or drilling) in such as way as to release fibers into the air. Since the
fibers are nearly indestructible, a risk exists if they are set free. Once the asbestos particles enter the
lungs, they may remain for prolonged periods.
, 'If you discover a substance that might be asbestos during the course of performing mitigation work (e.g.,
in floors, walls, insulating materials) and the substance is far enough removed from the immediate area
of the mitigation work, no health risk likely exists as long as the substance is left undisturbed and does
not become friable or airborne.
If the substance suspected to be asbestos is directly in the way of work to be done or close enough to
the work that you can not assure that it would be left undisturbed (i.e., drilling needs to be done through
asbestos-containing materials), leave the substance atone and notify the homeowner and your
supervisor of the suspected presence of-asbestos. Asbestos which may be disturbed during radon
mitigation should be taken care of by a qualified asbestos remediation contractor.
The OSHA standard on asbestos was amended in 1986 and requires that asbestos control or removal
projects be undertaken only by personnel who have special training and competence in performing such
work. Radon mitigation contractors should be aware that revised rules concerning the OSHA standard
are anticipated in 1992 (see proposed rules in July 20, 1990 Federal Register). The proposal rules:
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26
-lower the permissible exposure limit to 0.1 f/cc.
-clarify the definition of small-scale, short-duration operations
"225^ R?HtiVe £6SSUre enctosures are r^ired, except in small-scale jobs, roofing and tile
removal, in all demolition, renovation and removal work ^
a" C0nstmctk3n ope"""™ including small-scale short-
(10) ^ ^ t0 >— -""*"• e™n or ~ except
5. Small-Scate, Short-Duration Renovation and Maintenance Jobs Involving Asbestos
( Exception" Provided by 29 CFR 1926.58. Appendix G)
The 1986 amended OSHA standard (but not the 1990 proposed rules) has specrfically exempted
6. Respiratory Protection For Asbestos Exposure
In accordance with the respirator selection criteria of the OSHA asbestos standard the air
.
7. Additional Sources of Information on Asbestos
^^
C. Electrical Safety
1. Electrical Hazards in Radon Mitigation Work
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27
condition. Cracked or peeling electric cord insulation and frayed, overstressed extension cords can
result in an ignition source or exposed wire and the potential for accident or injury. Use of extension
cords of a lighter gauge and tower voltage handling capacity than the electrical equipment or power tools
they serve results in overloading and the possibility of electrical fires.
When the radon mitigation work involves drilling or cutting through slabs and wall partitions, care must
be taken to avoid contact between electrical wiring running beneath slabs and walls and the power tool
used to make the penetrations. When working outside the building, such as when installing the roof cap
on the ventilation system, care must also be taken in positioning an aluminum ladder if one is used to
access the roof. Serious and possibly fatal electric shock can occur when metal ladders become
energized through contact with the power line to the building.
Another potential electrical hazard exists when initially hooking up the ventilation system fan to an
electrical circuit for its power supply. Electrical fires, property damage, and possible worker injury can
occur if the wiring is done improperly. Radon mrtigators should comply with focal electrical codes.
2. The Health Effects of Electrical Hazards
(a) Electric Shock
Shock is the most common health effect associated with electrical hazards. Electricity travels in
closed circuits, and its normal route is through a conductor. Shock occurs when the body becomes
a part of the electric circuit. The current must enter the body at one point and leave at another.
Shock normally occurs in one of three ways. The person must come in contact with both wires of
the electric circuit; one wire of an energized circuit and the ground; or a metallic part that has
become "hot" by being in contact with an energized wire, while the person is also in contact with the
ground.
The metal parts of electric tools and machines may become "hot" if there is a break in the insulation
of the tool or machine wiring. The worker using these tools and machines is made less vulnerable
to electric shock when a tow-resistance path from the metallic case of the tool or machine to the
ground is established. This is done through the use of an equipment grounding conductor—a tow-
resistance wire that causes the unwanted current to pass directly to the ground, thereby greatly
reducing the amount of current passing through the body of the person in contact with the tool or
machine. If the equipment grounding conductor has been properly installed, it has a tow resistance
to ground, and the worker is being protected.
(b) Severity of the Shock
The severity of the shock received when a person becomes a part of an electric circuit is affected by
three primary factors: the amount of current ftowing through the body (measured in amperes); the
path of the current through the body; and the length of time the body is in the circuit. Other factors
which may affect the severity of shock are the frequency of the current, the phase of the heart cycle
when shock occurs, and the general health of the person prior to shock. Table 2 shows the effects
of electric current at various amperage levels in the human body.
The effects from electric shock depend upon the type of circuit, its voltage, resistance, amperage,
pathway through the body, and duration of the contact. Effects can range from a barely perceptible
tingle to immediate cardiac arrest. Although there are no absolute limits or even known values that
show the exact injury from any given amperage, the table shows the general relationship between
the degree of injury and amount of amperage for a 60-cycle hand-to-foot path of one second's
duration of shock.
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1 Milliampere
5 Milliamperes
TABLE 2
Effects of Electric Current in the Human Body
Reaction
Perception level. Just a faint tingle.
Slight shock fett; not painful but disturbing. Average individual can
let go. However, strong involuntary reactions to shocks in this
range can lead to injuries.
6-25 Milliamperes (women)
9-30 Milliamperes (men)
50-150 Milliamperes
1 ,000-4.300 Milliamperes
1 0,000-Milliamperes
Painful shock, muscular control is tost
This is called the freezing current or "let-go" range.
Extreme pain, respiratory arrest, severe muscular contractions If
he extensor muscles are excited by the shock, the person may be
thrown away from the circuit.
Individual cannot let go. Death is possible.
Ventricular fibril.atk>n (The rhythmic pumping action of the heart
ceases.) Muscular contraction and nerve damage occur Death is
most likely.
Cardiac arrest, severe burns and probable death.
CUrrem °f 9°° milliamPeres aPPlied for .03 seconds in fusing ibnSn The so
(c) Bums and Other Injuries
^^
Arc or flash bums, on the other hand, are the result of high temperatures near the body and are
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produced by an electric arc or explosion. They should also be attended to promptly.
Finally, thermal contact burns are those normally experienced when the skin comes in contact with
hot surfaces of overheated electric conductors, conduits, or other energized equipment. Additionally,
clothing may be ignited in an electrical accident and a thermal bum will result. All three types of
bums may be produced simultaneously.
Electric shock can also cause injuries of an indirect or secondary nature in which involuntary muscle
reaction from the electric shock can cause bruises, bone fractures, and even death resulting from
collisions or falls. In some cases, injuries caused by electric shock can be a contributory cause of
delayed fatalities.
In addition to shock and bum hazards, electricity poses other dangers. For example, when a short
circuit occurs, hazards are created from the resulting arcs. If high current is involved, these arcs
can cause injury or start a fire. Extremely high-energy arcs can damage equipment, causing
fragmented metal to fly in all directions. Even tow-energy arcs can cause violent explosions in
atmospheres that contain flammable gases, vapors, or combustible dusts.
3. Correcting Electrical Hazards and Preventing Injuries
Electrical accidents appear to be caused by a combination of three possible factors - unsafe equipment
and/or installation, workplaces made unsafe by the environment, and unsafe work practices. There are
various ways of protecting people from the hazards caused by electricity. These include: insulation,
guarding, grounding, mechanical devices, and safe work practices.
(a) Insulation
One way to safeguard individuals from electrically energized wires and parts is through insulation.
An insulator is any material with high resistance to electric current. Insulators - such as glass, mica,
rubber, and plastic - are put on conductors to prevent shock, fires, and short circuits. Before
employees prepare to work with electric equipment, it is always a good idea for them to check the
insulation before making a connection to a power source to be sure there are no exposed wires.
The insulation of flexible cords, such as extension cords, is particularly vulnerable to damage.
The National Electrical Code (NEC) generally requires that circuit conductors, the material through
which current flows, be insulated to prevent people from coming into accidental contact with the
current. Also, the insulation should be suitable for the voltage and existing conditions, such as
temperature, moisture, oil, gasoline, or corrosive fumes.
Conductors and cables are marked by the manufacturer to show the maximum voltage and
American Wire Gage size, the type letter of the insulation, and the manufacturer's name or
trademark.
Insulation is often color coded. In general, insulated wires used as equipment grounding conductors
are either continuous green or green with yellow stripes. The grounded conductors that complete a
circuit are generally covered with continuous white or natural gray-colored insulation. The
ungrounded conductors, or "hot wires," may be any color other than green, white, or gray. They are
often colored black or red.
Most large capacity power tools, such as the heavy-duty drills and saws needed for renovation and
mitigation projects/provide the user protection from electric shock through "double insulation."
Double insulated tools with metal housings have an internal layer of protecting insulation completely
isolating the electrical components from the outer metal housing. This is in addition to the functional
insulation found in conventional tools. Preferably, theses tools contain a nonconductive handle, an
insulated armature shaft, and a completely insulated motor. Brushes, commutators, and built-in
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switches are designed and used under the concept of reinforces insulation. This means that in
addition to the functional insulation, a reinforced or protecting insulation is also incorporated into the
This extra or reinforced insulation is physically separated from the functional insulation and is
arranged so that deteriorating influences such as temperature, contaminants, and wear will not affect
both insulations at the same time. Unless subject to immersion or extensive moisture which might
nullify the double insulation, a double insulated or all-insulated tool does not require separate ground
connections; the third wire or ground wire is not needed.
The condition of the insulation and casing of power cords, extension cords, and drop lights should
be inspected regularty. Flexible cords from power tools, fans, blowers, radon monitors and
diagnostic equipment, and other electrically-powered equipment should be periodically checked for
cracked or peeled insulation and frayed, overstressed plug connection points.
(b) Grounding
Grounding is another method of protecting employees from electric shock; however, it is normally a
secondary protective measure. The term "ground" refers to a conductive body, usually the earth
The term also means a conductive connection, whether intentional or accidental, by which an
electric circuit or equipment is connected to earth or ground plane.
By "grounding" a tool or electrical system, a low-resistance path to the earth is intentionally created
When properly done, this path offers sufficiently low resistance and has sufficient current-carrying
capacity to prevent the buildup of voltages that may result in a personnel hazard. This does not
guarantee that no one will receive a shock, be injured, or be killed. It will, however substantially
reduce the possibility of such accidents - especially when used in combination with the other safetv
measures discussed in this booklet. 7
There are two kinds of grounds required by the NEC. One of these is called the "service or system
ground." In this instance, one wire - called "the neutral conductor" or "grounded conductor - is
grounded. In an ordinary low-voltage circuit, the white (or gray) wire is grounded at the generator or
transformer and again at the service entrance of the building. This type of ground is primarily
designed to protect machines, tools, and insulation against damage.
To offer enhanced protection to the workers themselves, an additional ground, called the "equipment
ground, must be furnished by providing another path from the tool or machine through which the
current can flow to the ground. This additional ground safe-guards the electric equipment operator
in the event that a malfunction causes the metal frame of the tool to become accidentally energized
The resulting heavy surge of current will then activate the circuit protection devices and open the
circuft.
Grounding of portable electric tools and the use of proper ground-fault interrupters (GFIs) provide
he most convenient way of safeguarding the operator. If there is any defect or short circuit inside
he tool, the current is drained from the metal frame through a ground wire and does not pass
through the operator's body; or, where a ground fault interrupter is used, the current is shut off
before a senous shock can occur. All electric power tools should be effectively grounded except the
double insulated and cordless types. Correctly grounded tools are as safe as double insulated or
low voltage tools, especially when used with a proper ground fault interruption. The continuity of the
ground should be checked so there will not be a false sense of security.
(c) Circuit Protection Devices
Circuit protection devices are designed to automatically limit or shut off the flow of electricity in the
event of a ground-fault, overload, or short circuit in the wiring system. Fuses, circuit breakers, and
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ground-fault interrupters are three well-known examples of such devices.
Fuses and circuit-breakers are over-current devices that are placed in circuits to monitor the amount
of current that the circuit will carry. They automatically open or break the circuit when the amount of
current ftow becomes excessive and unsafe. Fuses are designed to melt when too much current
flows through them. Circuit breakers, on the other hand, are designed to trip open the circuit by
electro-mechanical means.
Fuses and circuit breakers are intended primarily for the protection of conductors and equipment.
They prevent overheating of wires and components that might otherwise create hazards for
operators. They also open the circuit under certain hazardous ground-fault conditions.
The ground-fault interrupter or GFI is designed to shut off electric power within as little as 1/40 of a
second. It works by comparing the amount of current going to an electric device against the amount
of current returning from the device along the circuit conductors. A GFI should be used in high-risk
areas such as wet basements, bathrooms, laundries, kitchens, and garages as well as construction
sites.
(d) Guarding
Live parts of electric equipment operating at 50 volts or more must be guarded against accidental
contact. Guarding of live parts may be accomplished by:
* location in a room, vault, or similar enclosure accessible only to qualified persons;
* use of permanent, substantial partitions or screens to exclude unqualified persons;
* location on a suitable balcony, gallery, or platform elevated and arranged to exclude
unqualified persons; or
* elevation of 8 feet or more above the floor.
When working outside a building, such as when installing the roof cap on a ventilation system, care
must be taken in positioning an aluminum ladder if one is used to access the roof or other elevated
area. Avoid contact between metal ladders and the power line to the building.
(e) Safe Work Practices
Mitigators and others working with electric equipment need to use safe work practices. These
include: de-energizing electric equipment before inspecting or making repairs, using electric tools
that are in good repair, using good judgment when working near energized lines, and using
appropriate protective equipment.
De-energizing Electrical Equipment. The accidental or unexpected sudden starting of electrical
equipment can cause severe injury or death. Before ANY inspections or repairs are made - even on
the so-called tow-voltage circuits - the current should be turned off at the switch box and the switch
padlocked in the OFF position. At the same time, the switch or controls of the machine or other
equipment being locked out of service should be securely tagged to show which equipment or
circuits are being worked on.
Tools. To maximize safety, mitigators should always use tools that work property. Tools should be
inspected frequently, and those found questionable, removed from service and properly tagged.
Tools and other equipment should be regularly maintained. Inadequate maintenance can cause
equipment to deteriorate, resulting in an unsafe condition.
Good Judgment. Perhaps the single most successful defense against electrical accidents is the
continuous exercising of good judgment or common sense. All employees should be thoroughly
familiar with the safety procedures for the mitigation job being done. When work is performed
around energized lines, for example, some basic procedures are:
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1. Have the line de-energized
y usln9
4. Keep a safe distance from energized lines
D. Eye Safety
in addition to safety eye wear, an eye wash kit should be available at all mitigation job sites.
1. Selecting Safety Eyewear for Mitigation Work
(a) Safety Glasses
(b) Safety Goggles
^^
lens. These goggles are designed to give ,he eyes IromaUnd side prSnS spS
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or flying material. Safety goggles are also available with flexible plastic frames. Flexible types of
goggles are preferred by many because of their light weight, and convenience, however, they
generally have a shorter wear-life than the more sturdier frame and glass lens type.
Oversize safety goggles are available that fit over prescription glasses. These provide a high
level of eye protection and can be worn by prescription glass wearers who donl normally need
safety eyewear, such as visitors to a job site undergoing mitigation work.
To prevent fogging of the inner surface of the goggles, vents are provided which are shielded
so that foreign material, especially liquid chemicals, cannot penetrate the goggles if splashed
on the outside.
(c) Face Shields
Face shields are available in a wide variety of types to protect the face and neck from flying
particles, sprays of hazardous liquids, and from hot solutions. As a general rule, face shields
should be worn over baste eye protection, such as safety glasses. Three baste styles of face
shields include headgear without crown protectors, with crown protectors, and with crown and
chin protectors.
The materials used in face shields should combine mechanical strength, light weight,
nonirritation to skin, and the capability of withstanding frequent cleanings. Only optical grade
(clear or tinted) plastic, which is free from flaws or distortions, should be used for the windows.
Again, face shields are not recommended as a baste type of eye protection against the impact
of foreign material. Although they do provide protection for the face, they must be used in
combination with safety eyewear for adequate eye protection.
2. Wearing Contact Lenses On-The-Job
Contact lenses should never be considered as a substitute for protective equipment for the eyes.
However, some workers, of necessity, must wear contact lenses to perform their jobs. Those that
do must consequently exercise extra care. When the work environment entails exposure to
chemical vapors, fumes, or splashes; intense heat, metal chips or fragments, or an atmosphere with
a high paniculate concentration, contact lens use should be restricted. Workers have had their
eyesight permanently impaired and have even been blinded by corrosive chemicals or small
particles getting between the contact lens and the eye.
Depending on the nature of the foreign body hazard, safety glasses or safety goggles must be worn
over contact lenses to provide the necessary level of protection.
3. Supervision of a Workplace Eye Safety Program
The selection and ready availability of eye protection for employees is the straight- forward
portion of a workplace eye safety program. Employee compliance with the wearing of prescribed
personal protective equipment, including safety eyewear, is uneven at best. The issue of insuring
that employees actually wear their safety eyewear very often represents the most challenging part
of an eye safety program.
Reasons given for non-compliance with the wearing of personal protective equipment include
employees feeling that the equipment is uncomfortable or seems to interfere with work, a tow
awareness level on the part of employees of the extent of the safety hazard present, temporary
unavailability of equipment ("I forgot it" or "I left it in the truck"), and other reasons (or excuses!).
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A workolace eye safety program based en protective equipment cannot be effective unless the eye
protection is worn and compliance with this is enforced. During radon mitigation jobs when drilling
sawing, applying solvents to plastic pipe, or other structural alterations are being done 100 percent
compliance with the wearing of eye protection must be insisted upon. Safety glasses serve no
purpose folded in a worker's pocket, especially if a serious eye injury could have been prevented
by wearing them. ^
The applicable OSHA health and safety standard, "Eye and Face Protection" (29 CFR 1910 133)
states that: .'
"protective eye and face equipment shall be required where there is a reasonable
probability of injury that can be prevented by such equipment. In such cases,
employers shall make conveniently available a type of protector suitable for trie work to
be performed, and employees shall use such protectors. No unprotected person shall
knowingly be subjected to a hazardous environmental condition. Suitable eye
protectors shall be provided where machines or operations present the hazard of frying
objects, glare, liquids, injurious radiation, or a combination of these hazards."
In addition to a humanistic obligation to provide employees with a safe working environment the
above passage from OSHA standards provides employers with additional incentive to promote eye
safety: failure to provide employees with proper eye protection is against federal health and safety
regulations.
VI. HAZARD COMMUNICATION AND CHEMICAL SAFETY
The Occupational Safety and Health Administration (OSHA) has issued a regulation which affects every
contractor in the construction industry entitled the Hazard Communication Standard (29 CFR 1926 59)
Called "HazCom" for short, it requires all contractors to educate their employees about the hazardous
chemicals they are exposed to in the workplace and the methods necessary to protect themselves
Chemical exposure may cause or contribute to many serious health effects such as heart ailments, kidney
and lung damage, sterility, cancer, bums, and rashes. Some chemicals may also be safety hazards and
have the potential to cause fires, explosions, and other serious accidents. The basic goal of the standard is
to ensure that employers and employees know about chemical hazards and how to protect themselves
This knowledge, in turn, should help to reduce the incidence of chemical source illnesses and injuries.
Many contractors mistakenly believe that they donl use hazardous chemicals in the course of mitigation
work. But hazardous chemicals are found in many commonly used products such as caulks sealants and
paint. Contractors also may be very unused to complying with a "performance-oriented" regulation such as
,HazCom. Unlike other OSHA standards which generally require contractors comply with specific provisions
o ensure a safe workplace, HazCom establishes certain performance goals and allows employees the
flexibility to develop a program appropriate for the specific workplace.
In addition to worker exposure, a radon mitigation contractor should consider potential occupant exposure
to such hazards as vapor released from caulks, sealants, and solvents. The contractor should advise the
client of these hazards and their protective options such as ventilation.
A. What the Hazard Communication Standard Addresses
The Hazard Communication Standard establishes uniform requirements to assure that the hazards of all
chemicals imported into, produced, or used in U.S. workplaces are evaluated, and that the resultant
hazard information and associated protective measures are transmitted to employers and potentially
exposed employees.
Chemical manufacturers and importers must convey the hazard information they leam from their
evaluations to downstream employers by means of labels on containers and material safety data sheets
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(MSDSs). In addition, all employers must have a hazard communication program to get this information
to their employees through labels on containers, MSDS's, and training.
This program ensures that all employers receive the information they need to inform and train their
employees property and to design and put in place employee protection programs. It also provides
necessary hazard information to employees, so they can participate in, and support, the protective
measures in place at their workplaces.
B. What is a Contractor Required To Do?
All employees who may be exposed to hazardous chemicals will need to be trained in the dangers
associated with those chemicals and the protective measures they need to take. There are four major
elements of compliance required by the Hazard Communication Standard:
1. Material Safety Data Sheets (MSDSs)
2. Labels
3. Employee Training
4. A Written Hazard Communication Program
The following sections will describe these elements of HazCom and provide examples of each.
C. Material Safety Data Sheets (MSDSs)
The Material Safety data Sheet (MSDS) is a detailed information bulletin prepared by the manufacturer
or importer of a chemical that describes the physical and chemical properties, physical and health
hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures,
and control measures. Information on an MSDS aids in the selection of safe products and helps
prepare employers and employees to respond effectively to daily exposure situations as well as to
emergency situations.
The MSDS's are a comprehensive source of information for all types of employers. There may be
information on the MSDS that is not useful to you or not important to the safety and health in your
particular operation. Concentrate on the information that is applicable to your situation. Generally,
hazard information and protective measures should be the focus of concern.
The first thing to do is to make sure you have an MSDS for every hazardous substance you use. It is
the responsibility of suppliers/distributors to provide MSDSs with the products they are selling. You
should have been receiving MSDSs with every shipment of hazardous substances.
Nonetheless, you still may have trouble getting the MSDSs from suppliers who are unaware of their
,, responsibilities. If you donl receive an MSDS with a shipment, it's your responsibility to request one.
If a product is tagged or labeled with any key words such as "danger, "caution", "flammable", "warning",
etc., that is a signal to you to get an MSDS from the supplier. Put any requests to a supplier for an
MSDS in writing.
To simplify this process, you may want to designate one employee to coordinate your compliance
efforts. That person should set up a system to collect all incoming MSDSs and set up an easily
understood filing and retrieval system. Without an organized system, you could easily be overwhelmed
with paper. The MSDSs will vary in length from two to twenty pages, depending on the make-up of the
substance. These documents should give you a complete breakdown on the hazards associated with
the products you are using and will be a key to effective employee training.
If your supplier tends to be a retail outlet, such as a hardware store or a building products supplier, be
aware that retailers only have to supply MSDSs to customers who have commercial accounts. For all
other customers, the retailer must supply the address and telephone number of the manufacturer from
which an MSDS can be obtained. It will be wise to automatically ask for MSDSs with your purchases if
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you have a commercial account or the address and telephone number if you don't have an account.
Once you have an MSDS on a product, though, it's not necessary to get one with every shipment of that
product. You only need to obtain another one if the chemical make-up of the product changes.
All employers having difficulty obtaining MSDSs from product suppliers and/or manufacturers are
advised to contact their local OSHA office for assistance.
Once MSDSs for products have been obtained, they should be made available to employees at each
job she. This is most easily done by maintaining a binder of all MSDSs in trucks or trailers at each work
location. All employees must be informed of the locations of MSDSs and give access to them upon
request. As MSDSs are intended as standardized sources of health and safety information on
chemicals used in the workplace, and must be made readily available to employees while they are in
the workplace.
SUMMARY OF REQUIRED ACTIVITIES: MSDSs
* Request MSDSs for hazardous substances from suppliers/manufacturers
* Maintain MSDSs at each job site within easy access of employees
* Inform employees about what MSDSs are and where they are located
* Although not a requirement of the standards, review each MSDS to be sure it is clear and
understandable to employees
D. Labeling of Hazardous Chemicals
The most immediate source of safety information for both the prevention of and response to accidents
with hazardous substances are the labels on product containers. In case of a mishap at the job site
involving a hazardous substance, the label is the most immediate source of information on a product's
dangers and emergency response, with the MSDS serving as a backup.
Employers must ensure that all containers of hazardous substances in the workplace are labeled with
the name of the substance, the appropn'ate hazard warning, and the name and address of its
manufacturer. The labels must be in English, legible, prominently displayed, easily understandable, and
not defaced. For any hazardous substance containers not so labeled, the employer must ensure that a
label or labeling information is obtained from the chemical manufacturer or other responsible party.
Although the label on a hazardous substance is a brief summary of the information provided on the
substance's MSDS, labels and MSDSs are not substitutes for one another. Each substance must be in
a property labeled container and have a corresponding MSDS. However, you can use one to check the
other. If a product has a warning label, but no MSDS or vice versa, you will need to request either the
label or MSDS from the supplier.
Portable containers into which hazardous substances have been transferred from their original
containers must also be property labeled with the name of the substance, the appropriate hazard
warning, and its manufacturers name and address. For example, if a coating or sealant is transferred
from its original drum into smaller containers which are not labeled, then the smaller containers must be
labeled with the hazard warning from the drum. The only exception to this requirement is when the
person making the transfer is going to use all of the substance in the course of the present task at
hand. In such cases of immediate use of the substance, no labeling is required on the portable
container.
As for MSDSs, employees must be trained about this system for product labelling and the importance of
heeding product instructions and warnings. Employers are required to provide instruction for employees
on the meaning of warnings and the interpretation of warning symbols and hazard rating systems if used
on labels. If an accident with a hazardous substance occurs, its container will be the first thing sought
for information on the product. Products must be properly labelled, and labels must be clear and
understandable.
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SUMMARY OF REQUIRED ACTIVITIES: LABELS
Ensure that all containers of hazardous substances are appropriately labeled
* If not, obtain labels or labeling information from product suppliers
Instruct employees on the meaning of the terminology and symbols used in warning labels
E. Employee Training
Even though you may use several types of potentially hazardous substances (i.e., caulks sealants paints
etc.) at many different job sites, training all employees on these hazards need not be a monumental
project. Once MSDSs and a labeling system is in place, training is largely a process of transmittina this
information to employees.
Employers or their designated representatives must convey to employees the potential health risks and
precautions associated with hazardous substances used on-the-job. This means employees should be
trained in the following areas:
1 . How to recognize hazards at work;
2. What the harmful physical and health effects are from hazardous substances sued on-the-job-
3. How employees can protect themselves from these hazards;
4. And what actions to take in the event of a hazardous substance emergency.
All employees potentially exposed to hazardous substances must be trained in these areas. In deciding
who should receive this training, the term "potentially exposed" is to be interpreted broadly Not only
should training include employees actually exposed to hazardous substances during their routine job
duties but also employees who may be exposed through unexpected releases of hazardous substances or
in accident or emergency situations. In this sense, office personnel who routinely come to job sites in the
course of their work could potentially become exposed to hazardous substances and should receive
trsinin
Training must be provided at the time employees are initially assigned to work and whenever a new
hazardous substance is introduced into the workplace. Even though an employee may already have
received training on a substance from another employer in the past, the training should be given to the
employee because (s)he is now your employee and your responsibility. It may be best to offer HazCom
training nght after employees have completed their tax and immigration forms. In this way several
administrative and training tasks related to employment can be "signed-off" on by the employee at once.
nc^nn^S0"8^13513^88 iSn1 a °ne"time occurrence. A number of employees pass through the
construction industry and new hazardous substances are introduced into the workplace periodically Each
cft^PofYhe ^ nt^-intrDdUC8d naZ3rd indicates the need tor trainin9' Training ™* be done for each
category of hazard rather than each chemical and thus, additional training is not required when new
?* T1 th? PreSlm the S3me hazard< " more than one co^racting company is working on the
'nf0rmatlon on hazardous substances for the employees of all participating contractor must
fUS? COmPanies; Trainina- on new hazardous substances need not repeat training in other
received And addrttonal trainir* is TOt necessa* when you substrtute
SUMMARY OF REQUIRED ACTIVITIES: EMPLOYEE TRAINING
Plan the training with information from the MSDSs and labels of all hazardous substances used on-the-
Select an employee or outside contractor to conduct the training-
. ^.VkJe traif!!ng t0 emPtoyees in cogent areas listed above during normal work hours-
Document all training provided to each employee.
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F. Written Hazard Communication Program
The final part of putting together a program for complying with HazCom is preparing the Written Hazard
Communication Program. Basically, this written program is a description of all the activities described in
the three preceding sections that are being done to comply with HazCom. It should begin with a current
list of all hazardous substances used on-the-job and include descriptions of systems you have developed
for hazard substance labeling, MSDSs, and employee training.
Once completed, the written program must be available to employees and employee representatives if they
request to see it. It is also one of the first things OSHA requests to see, should you undergo an OSHA
inspection. Since a copy of the written program must be maintained at each job site, it is advisable to keep
a written program with product MSDSs in a trailer or truck at each work location, as copies of MSDSs must
also be readily available to employees.
SUMMARY OF REQUIRED ACTIVITIES: WRITTEN HAZCOM PROGRAM
* Prepare a list of all hazardous substances used on-the-job;
* Outline all steps taken to comply with HazCom requirements for labels, MSDSs, and employee training;
* Make the written program available to employees, employee representatives, and OSHA upon request.
VI. REFERENCES
(to be listed)
VII. APPENDICES
(copies of relevant OSHA standards)
A. 29 CFR 1926, Occupational Safety and Health Standards
B. 29 CFR 1910, Construction Health and Safety Standards
C. 29 CFR 1910.1200, Right to Know
D. EPA order 1440.3
E. Health and Safety Training Record
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E. HEALTH AND SAFETY TRAINING RECORD
Project:
Client:
Project Site/Location:_
Date:
Full Name
Training conducted by:_
Remarks:
Conducted by:_
Organization
Soc. Sec. No.
Signature:
IBMXMURC+OWNBKP
COMPLETE.TOR
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