United States
           Environmental Protection
             Office Of
             The Administrator
171 R-92-011
April 1992
Radon Mitigation Employee
Health And Safety:
A Student Manual
                                        Printed on Recycled Paper


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.

                      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
U.S. Environ menta! Protection Agency
Region 5, Library (PI-12J

                                       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

        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

     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)


  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

  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.


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

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


  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.

      (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.

     (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

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
    (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.

                                   "* ^ 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 ^

    (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

    (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

    (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

    (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.

          (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


         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.
                                resPjrator is drV- the respirator should be inspected and any

H.  When To Change Respirators or Respirator Filters and Cartridges

  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

                            r"ardinfl "mitalto"s °< ^Pi'""' » ««* may app,v ,o

 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.


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

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.


   C.  Equilibrium Ratio

                                        (WL value! finn)   = (1)
                                      Radon Concentration    100
D. Calculating Worker Exposure to Radon and Radon Decay Products


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
                         pCi/L = WL_x_100

 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).

6.  WLM Calculation Exercises
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
     180 pCi/L for 1 Hour
     95 pCi/L for 6 Hours
     37 pCi/L for 2 Hours
     8 pCi/L for 2 Hours
   (Answer: .0053 WLM + .017 WLM + .002 WLM + .0005 WLM = 0.025 WLM)


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

      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).

  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)


         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

      (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).


 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.


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

   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 {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

     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


                                                                       PERSONAL RADON EXPOSURE RECORD
Social Security #:
Job Site Radon Working
Date or Number Level Level
(PCM.) (WL)


Level Months
Model of Serial
Monitor1 Number


                                                                            /17Q -
/17Q -
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


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

   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

    (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

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

     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


          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




             TABLE 1.
EPA "Noise Reduction Ratings" (NRR)
 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.


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


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

   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:


        -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


   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

       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.

 1 Milliampere

 5 Milliamperes
                                          TABLE 2

                         Effects of Electric Current in the Human Body


                                   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


       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

       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


     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

    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


   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

(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:

          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


          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!).

           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


    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


   (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


   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.

   *  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

   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

        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
  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
    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.


 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.

    *  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.

    (to be listed)

    (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


 Project Site/Location:_

 Full Name
Training conducted by:_

Conducted by:_
                                                                            Soc. Sec. No.