This presentation discusses facility surface dust contamination from lead soldering operations. While airborne exposures may be below limits, lead dust can deposit on surfaces throughout buildings at levels orders of magnitude higher than standards. This can create liability risks during property transfers and health risks for maintenance workers and sensitive groups. Sampling data from four facilities show widespread contamination on surfaces far from soldering areas, even over a decade after operations. Cleanup is possible but contamination may remain above guidelines after initial cleaning. Courts have found companies liable for lead contamination left on purchased properties.
Combustible Dust, (or Explosive Dust), cleaning, is a required preventative good housekeeping and maintenance program, in manufacturing and production facilities. This minimizes safety hazards, potential flash fires, and catastrophic dust explosions, in addition to maintaining Indoor Air Quality. Combustible dust is fine particulate dust, which is generated from products such as wood, metals, grains, agricultural, chemicals, plastics, paper, and carbonaceous products. The manufacturing and production facilities equipment and machinery, pulverize, mill, grind, crush, macerate, and cut the bulk product. In return, dust is generated, and accumulates on all equipment and facility structure surfaces. The fine powder dust, which is suspended on the higher, inaccessible and unnoticeable surfaces, is the most problematic. Yet the most hazardous, especially when a primary upset or explosion generates a sonic pressure wave that suspends these particles into the path of a flame front (reaction front), which causes a devastating secondary dust explosion.
In addition to the fire and explosion hazards of dust, the industrial hygiene aspect of fine particles can impact and affect, the facility workers health, leading to illnesses, and injuries. "The Bureau of Labor Statistics reports that 6.1 percent of private-sector employees suffered 5.7 million workplace injuries and illnesses in 2000. Forty-six percent of those injury cases required days away from work for recuperation or restricted work activity.
J. Paul Leigh of the Stanford Medical Center notes that businesses spend $170.9 billion a year on costs associated with occupational injuries and illnesses—expenditures that come straight out of company profits. Injuries and illnesses increase workers’ compensation and retraining costs, absenteeism, and production faults. They also decrease productivity, morale, and ultimately, profits.
Fortunately, statistics from injury and illness reports filed with OSHA show that workplaces that establish safety and health management systems reduce their injury and illness costs by 20 to 40 percent. "In today’s competitive business environment," says OSHA Administrator John L. Henshaw, "the black-and-blue of workplace injuries can be the difference between operating in the black and running in the red." Reference 1 (http://www.osha.gov/Publications/JSHQ/fall2002html/safety_health.htm)
High ceiling and surface cleaning, Air Conveyance Cleaning, Dust collector cleaning, Conveyor Belt cleaning, Silo tank cleaning, Lab Fume Hood cleaning, and dust control vacuuming, are some of the services, that may be required to clean the combustible dust. These services help prevent airborne dust and particulates, from accumulating, in the manufacturing and production facilities. These services may also help promote equipment longevity, may decrease utility costs for operating equipment, may increase the brightness of lighting, may stabilize insurance rates, and may allow a greater Return On Investment on manufacturing equipment.
Combustible Dust cleaning should be performed by a certified and trained cleaning company. The certified training should be similar to the N.A.D.C.A., I.A.Q.A., O.S.H.A., and I.I.C.R.C. cleaning standards. Additionally, the certified cleaning contractor, should have the proper Industrial and Commercial cleaning equipment. Most importantly is an industrial, explosion-proof, dust collecting H.E.P.A. vacuum, as the main piece of equipment. Broom sweeping and compressed air, is not a viable means of cleaning combustible dust, by the NFPA 654 Combustible Dust Standard. The act of broom sweeping, and compressed air, actually stirs up dust and particulate into the air, which may create more issues with sensitive equipment that provide ignition sources, and possible dust explosions. High reach equipment, such as High reach platforms,
Scissor Lifts, Articulate Booms, Scaffolding, Fiberglas extension ladders, and Fi
Combustible Dust, (or Explosive Dust), cleaning, is a required preventative good housekeeping and maintenance program, in manufacturing and production facilities. This minimizes safety hazards, potential flash fires, and catastrophic dust explosions, in addition to maintaining Indoor Air Quality. Combustible dust is fine particulate dust, which is generated from products such as wood, metals, grains, agricultural, chemicals, plastics, paper, and carbonaceous products. The manufacturing and production facilities equipment and machinery, pulverize, mill, grind, crush, macerate, and cut the bulk product. In return, dust is generated, and accumulates on all equipment and facility structure surfaces. The fine powder dust, which is suspended on the higher, inaccessible and unnoticeable surfaces, is the most problematic. Yet the most hazardous, especially when a primary upset or explosion generates a sonic pressure wave that suspends these particles into the path of a flame front (reaction front), which causes a devastating secondary dust explosion.
In addition to the fire and explosion hazards of dust, the industrial hygiene aspect of fine particles can impact and affect, the facility workers health, leading to illnesses, and injuries. "The Bureau of Labor Statistics reports that 6.1 percent of private-sector employees suffered 5.7 million workplace injuries and illnesses in 2000. Forty-six percent of those injury cases required days away from work for recuperation or restricted work activity.
J. Paul Leigh of the Stanford Medical Center notes that businesses spend $170.9 billion a year on costs associated with occupational injuries and illnesses—expenditures that come straight out of company profits. Injuries and illnesses increase workers’ compensation and retraining costs, absenteeism, and production faults. They also decrease productivity, morale, and ultimately, profits.
Fortunately, statistics from injury and illness reports filed with OSHA show that workplaces that establish safety and health management systems reduce their injury and illness costs by 20 to 40 percent. "In today’s competitive business environment," says OSHA Administrator John L. Henshaw, "the black-and-blue of workplace injuries can be the difference between operating in the black and running in the red." Reference 1 (http://www.osha.gov/Publications/JSHQ/fall2002html/safety_health.htm)
High ceiling and surface cleaning, Air Conveyance Cleaning, Dust collector cleaning, Conveyor Belt cleaning, Silo tank cleaning, Lab Fume Hood cleaning, and dust control vacuuming, are some of the services, that may be required to clean the combustible dust. These services help prevent airborne dust and particulates, from accumulating, in the manufacturing and production facilities. These services may also help promote equipment longevity, may decrease utility costs for operating equipment, may increase the brightness of lighting, may stabilize insurance rates, and may allow a greater Return On Investment on manufacturing equipment.
Combustible Dust cleaning should be performed by a certified and trained cleaning company. The certified training should be similar to the N.A.D.C.A., I.A.Q.A., O.S.H.A., and I.I.C.R.C. cleaning standards. Additionally, the certified cleaning contractor, should have the proper Industrial and Commercial cleaning equipment. Most importantly is an industrial, explosion-proof, dust collecting H.E.P.A. vacuum, as the main piece of equipment. Broom sweeping and compressed air, is not a viable means of cleaning combustible dust, by the NFPA 654 Combustible Dust Standard. The act of broom sweeping, and compressed air, actually stirs up dust and particulate into the air, which may create more issues with sensitive equipment that provide ignition sources, and possible dust explosions. High reach equipment, such as High reach platforms,
Scissor Lifts, Articulate Booms, Scaffolding, Fiberglas extension ladders, and Fi
Quick and effective cleaning is the need of the hour for rapid industrial development and for creating an echo-friendly atmosphere. This is mainly influenced by the process of automation and the selection of cleaning chemicals/methods.
Rhinox Double Press Fittings are manufactured by utilizing unique and modern machinery which tends to eliminate welding, threading and solution joining system.
Green Building And Indoor Air Quality Jpl 6 14 09guest23a287b
MicroShield Environmental Services provides a presentation reviewing their approach to Indoor Air Quality and Green Building.
Presentation by John P. Lapotaire, CIEC
for Lake and Sumnter County Home Builders Association.
Indoor air quality (IAQ) is a term which refers to the air quality within and around buildings and structures, especially as it relates to the health and comfort of building occupants.
August 2015 ComplianceSigns Connection Workplace Safety NewsletterComplianceSigns, LLC
Top Safety News for August 2015, including:
• OSHA delays Confined Spaces in Construction enforcement to October
• Guidance issued on Hazcom enforcement
• OSHA Fines total $2.9 million in July
• NIOSH offers easy, effective way to reduce silica dust exposure
• Safety Tip: Reduce arc flash hazards
Quick and effective cleaning is the need of the hour for rapid industrial development and for creating an echo-friendly atmosphere. This is mainly influenced by the process of automation and the selection of cleaning chemicals/methods.
Rhinox Double Press Fittings are manufactured by utilizing unique and modern machinery which tends to eliminate welding, threading and solution joining system.
Green Building And Indoor Air Quality Jpl 6 14 09guest23a287b
MicroShield Environmental Services provides a presentation reviewing their approach to Indoor Air Quality and Green Building.
Presentation by John P. Lapotaire, CIEC
for Lake and Sumnter County Home Builders Association.
Indoor air quality (IAQ) is a term which refers to the air quality within and around buildings and structures, especially as it relates to the health and comfort of building occupants.
August 2015 ComplianceSigns Connection Workplace Safety NewsletterComplianceSigns, LLC
Top Safety News for August 2015, including:
• OSHA delays Confined Spaces in Construction enforcement to October
• Guidance issued on Hazcom enforcement
• OSHA Fines total $2.9 million in July
• NIOSH offers easy, effective way to reduce silica dust exposure
• Safety Tip: Reduce arc flash hazards
Every time a combustible dust accident happens, you can make two assumptions. Firstly, preventing the accident could have been done with a combustible dust safety program. Secondly, the accident, or one just like it, probably happened before. Maybe at a different company or in another place, but some things stay the same. With combustible dust accidents, history does repeat itself.
An automated cleaning process that continuously protects against combustible ...Milling and Grain magazine
Explosions from combustible dust have plagued the milling and grain industry throughout its history. In just grain handling alone, OSHA, the Occupational Safety and Health Administration, reports that over the last 35 years there have been over 500 explosions across the US, which have killed more than 180 people and injured more than 675.
Combustible Dust: More than just Industrial HousekeepingNilfiskVacuums
This presentation explains industrial explosions caused by combustible dust. It answers the questions:
What is Combustible Dust?
Who’s at Risk?
It offers instruction for proper maintenance and industrial housekeeping practices. It provides combustible dust resources. It also provides an explanation of industrial vacuums and explosion-proof vacuums for improved worker safety.
Choosing the Right Industrial Vacuum
Construction Worker’s Death in Manhole Leads to $136K Pena.docxmaxinesmith73660
Construction Worker’s Death in Manhole Leads to $136K
Penalty
Aug 09, 2010
OSHA has cited Matula & Matula Construction Inc. of Lake Jackson, Texas, for
workplace safety and health violations following the death of an employee who was
working inside a sanitary sewer manhole. Proposed penalties total $136,000.
"This company exposed its workers to hazardous atmospheres while they were
working in sanitary sewers," said Mark Briggs, OSHA's director for its Houston South
Area Office in Texas. "It is critical that procedures for safe confined space entry are
utilized each time a worker enters a confined space."
OSHA issued citations alleging two willful, three serious, and two repeat violations
following an investigation that began Feb. 8, when a worker who was pumping grout
into the sewer line on the Highway 332 Utility Relocation Project in Lake Jackson was
overcome by hydrogen sulfide.
The willful violations are for failing to implement confined space entry procedures,
including testing, ventilation and rescue, and to train employees on the hazards of
working in a confined space. OSHA issues a willful citation when an employer
exhibits plain indifference to or intentional disregard for employee safety and health.
Serious violations include failing to train employees about the danger of working with
hazardous chemicals in the workplace, and to inspect, properly maintain, and repair
damaged ladders. A serious violation is one in which there is substantial probability
that death or serious physical harm could result from a hazard about which the
employer knew or should have known.
The repeat violations are for failing to make a reasonable estimate of employee
exposure to hazardous chemicals such as hydrogen sulfide and carbon monoxide, and
to properly erect a ladder for use in accessing the sanitary sewer manhole. OSHA
issues repeat violations when an employer previously has been cited for the same or
substantially similar violations in the past three years, and those citations have become
a final order.
The company has 15 business days from receipt of the citations to comply, request an
informal conference with OSHA's area director in Houston, or contest the citations and
penalties before the independent Occupational Safety and Health Review Commission.
Copyright 2010 1105 Media Inc. See our Privacy Policy.
Page 1 of 1Construction Worker’s Death in Manhole Leads to $136K Penalty -- Occu...
1/29/2013http://ohsonline.com/Articles/2010/08/09/Manhole-Death-in-Texas.aspx?sc...
1
EHST 3060/61:
Environmental Issues in
Construction
To identify specific chemical hazards in
construction
To discuss the adverse health effects of these
chemical hazards
To enumerate the tasks involved with
exposure to chemical hazards
To discuss the OSHA standards associated
with chemical hazards in construction
Asbestos
Lead
Crystalline Silica
Carbon monoxide
Solvents
Physical
Chem.
Inclean_NovDec2014_Coatings as Solutions for the Remediation Pro Nov-Dec 2014
Leadpresentation98
1. FACILITY SURFACE DUST TALK
My presentation today is about facility surface dust (lead dust) from
soldering operations. This presentation does not deal with classic industrial
hygiene situations. Situations where employees are dealing directly with
hazardous chemicals, in this case, lead. My co-author, Mr. Dana Dickson
and I independently discovered this phenomenon of lead dust deposits with
its real and potential implications, and would like to share this information
with you.
ISSUES:
The general issue regarding lead dust deposits does not appear to be one of a
major health risk for building occupants. The issues are however important
and consist of the following:
• Potential property transfer liability
• Potential health risk for building maintenance personnel
• Potential health risk for susceptible populations
• Risk of lead exposure to building occupants
Potential Property Transfer Liability
When building are purchased, the buyer wants to minimize liability. If
soldering operations deposit lead on surfaces, especially in excess of some
guideline (e.g. HUD) then the possibility of transfer liability is real.
Building Maintenance Personnel
Surface lead concentration levels we have found (independently) in
ductwork and on ventilation equipment surfaces and filters have been orders
of magnitude higher (milligrams per square foot vs. micrograms per square
foot) than HUD standards. This was true for both HVAC systems and local
exhaust systems. It is possible that maintenance personnel could have lead
exposure in a previously contaminated building. In a building currently
using lead, maintenance personnel could also be exposed to lead dust many
hundreds of feet away from the soldering operations.
Potential Health Risk for Susceptible Populations
An example of a worst case scenario would be if a contaminated facility
were converted into a day care center, health facility or school.
2. Risk of Unnecessary Lead Exposure to Building Occupants
If the contamination is there then the potential risk of exposure is greater.
To eliminate the chance for exposure, either eliminate the contamination or
eliminate contact with contaminated surfaces. This is a principle of
industrial hygiene.
While I’m on the subject of IH principles let’s discuss some of our classic
rules…. (Slide 3)
Mr. McDermott states that, if exposures are less than acceptable levels, you
have basically done your job. The first sentence in this slide (Slide 4) also
states one of our basic IH principles – No (significant) worker exposure
implies no hazard further away. Does this rule of thumb work most of the
time? – yes, but not necessarily when it comes to lead fume and surface
contamination issues. Why doesn’t it work with lead and contamination
issues?
FAN VOLUME VS IH SAMPLE VOLUME:
First, when you think about it, personal sampling volumes for lead are small
in comparison to HVAC air volumes. We would sample 960 liters of air (34
cubic feet of air) for an 8-hour sample at 2 lpm. Think about the hundreds
and even thousands of cubic feet of air per minute going through general
ventilation systems. Think for a moment – if the lead fume has any
tendency for settling on surfaces, how little the air concentration would have
to be to have significant surface contamination given months and years of air
circulation in the facility.
FATE OF FUME:
What surprised me on my first experience with lead surface dust was the fact
that the airborne lead fume not captured by the local exhaust would settle on
surfaces. We know that lead fume is very small and I thought that even if a
minute amount of lead fume escaped the local exhaust and circulated in the
general ventilation most of the fume would leave the building. Measurable
concentrations of lead are deposited on surfaces throughout the building.
SURFACE LEAD STANDARDS
Let us discuss some surface lead standards. HUD Standards (Housing
Urban Development Standards) are 100 ug/ft2 for floor and carpet, 500 ug/ft2
for window sills and 800 ug/ft2 for window wells. NIOSH in a 1994 case
3. study article in Applied Occupational Hygiene proposed 46 micrograms per
square foot as their level of concern. NIOSH also stated they considered this
level to be too conservative after analyzing their data. There are no
published regulatory or consensus standards for industrial surface lead
contamination.
Over the past few years hygienists in our area, have considered 200-300
ug/ft2 of lead as non-hazardous surface concentration. This criteria is
loosely based on the HUD standards. The criteria also considers the
characteristics of the population at risk and what has been found to be a
feasible cleanup level.
This slide is a wave solder machine. The machine uses a wave of molten
solder to solder multiple components onto a printed circuit board. This slide
shows hand soldering. We all know that personal airborne lead exposure
from hand soldering is minimal. However, we have found evidence that if
given enough time, hand soldering can contaminate facility surfaces with
lead.
SAMPLING DATA:
Facility A – Wave Solder
Facility A is a printed circuit board manufacturing and assembly operation.
As you can see air samples in the immediate work place are less than the
PEL of 50 ug/M3. Blood tests of the maintenance personnel that clean and
maintain the wave solder machine have blood lead results less than the
OSHA standard and less than the state health department standard.
However look at facility A’s surface lead concentration data:
Operator workstation and assembly workstations are relatively clean,
because the surfaces are cleaned regularly as per OSHA mandate. The
surfaces away from the operator are however much more contaminated.
FACILITY B
Facility B is a warehouse/office facility that last had hand and wave
soldering operations more than 11 years ago. While the majority of samples
were less than 200 ug/sq. ft., three samples were 800-999 ug/sq.ft, and three
samples were found to have milligram per sq. ft. concentrations.
4. FACILITY C
Facility C is a wave soldering and hand soldering facility in which
approximately 50% of the first floor of the two story building was engaged
in the lead operation. The building was undergoing ownership transfer and
we were asked to do a 30 sample surface testing survey on the remaining
ventilation systems. Most of the sample results were in milligram/sq. ft.
concentrations. These data include samples from general and local exhaust
systems. Carpet close to the wave soldering operation did not pass TCLP.
The lead not captured by local exhaust was recirculated through a ceiling
plenum, and as a result, the plenum surfaces.(eg: ceiling panels electrical
fixtures etc.) were all thought to be contaminated. Before we could sample
other surfaces, we were told not to continue sampling. It was interesting to
note that while we were taking our lead samples the upper floor was being
remodeled. The interesting item of note is that the wave soldering operation
on the first floor used to be on the second floor for many years.
FACILITY D
Facility D is a large facility in which hand soldering and sand blasting is
done. The two samples in the 200-499ug. range were in the electronics
repair shop, while the higher sample was in the radiator shop. Sandblasting
of lead painted casting had be done in the facility, but not in either of these
areas. Although the sample number is small these data imply that hand
soldering, can contaminate facility surfaces.
DISCUSSION
We have seen four facilities with various levels of lead contamination. Now
lets look at some pre-clean/post-clean data to see if our claim of surface lead
contamination less that 200-300 ug/sq.ft. can be attained . As you can see in
the case of the Facility A HVAC system most of the postclean surfaces had
wipe sample results of less than 100 ug/sq.ft. Two samples were found to be
over 200ug/sq.ft. after the “initial” cleaning. The areas were re-cleaned and
passed the 200 ug/sq.ft. criteria.
There has been a legal case that has looked at lead contamination liability.
5. The BCW Associates Ltd. and Knoll International Inc. vs. Occidental
Chemical Corp and Firestone Tire and Rubber Company.
September 29,1988
U.S. District Court for the Eastern District of Pennsylvania
Civil Action No. 86-5947
The plaintiffs sought to recover costs related to cleanup of lead dust from a
warehouse in Pottstown, Pennsylvania pursuant to the CERCLA act of 1980.
The court determined the plaintiff knew it had purchased a dusty warehouse
(as is) but had no suspicion that the dust (which was mostly zinc oxide) had
lead sulfate contamination. The zinc oxide was originally used to make
white sidewall tires. The plaintiff upon discovering the lead sulfate provided
employees with PPE and also stated that the dust was contaminating
furniture that it was manufacturing.
The plaintiffs sought to receive compensation for:
Sampling and testing
Personal protective equipment
Cleanup and removal of contamination
Legal fees
The court said that if the defendant had acted responsibly and carefully
collected all the dust generated by the tire grinding operation and disposed
of it in an appropriate facility and if the dust had been released into the
environment Firestone would be liable under CERCLA.
The court went on to say that the defendant could not circumvent the
liability by allowing the lead to remain in the warehouse, and then released
into the environment.
In its defense the defendant contended that the plaintiffs were motivated not
by CERCLA liability in initiating clean up, but by product liability, quality
control and employee health. The court said that the defendant confused
causation with motivation.
The facts in this case are different than the facts surrounding soldering dust
contamination. The plaintiff claimed that the furniture it was making was
contaminated, and thus contaminating the environment. Nevertheless, this
case appears relevant.
6. I have discussed data on lead contaminated surfaces in facilities and some
implications of the contamination. Are there things we could do to minimize
lead accumulation and associated liability?
YES.
The industrial hygiene principles of substitution, other engineering and
administrative controls, and education are applicable to the control of this
potential hazard.
Keith/leadpresentation98.doc