While the core regulations under the National Emission Standards for Hazardous Air Pollutants (NESHAP) date back to the 1990s, NNPH’s recent push for compliance with AHERA-certified surveys is changing how local contractors and developers approach renovations and demolitions. Owners and contractors who aren’t aware of the stricter enforcement are being notified their demolition or building permit applications are now on hold pending the performance of those surveys by accredited AHERA Building Inspectors.

Background on Asbestos Regulations

Asbestos, a naturally occurring mineral once widely used in building materials for its durability and fire resistance, poses significant health risks when disturbed. Inhalation of its fibers can lead to serious conditions like asbestosis, lung cancer, and mesothelioma, prompting stringent regulations to protect public health.

At the federal level, the regulatory foundation lies in the NESHAP, part of the Clean Air Act administered by the U.S. Environmental Protection Agency (EPA). Originally promulgated in 1973, the standards underwent major revisions in 1990 to address demolition and renovation activities more comprehensively. These rules require thorough inspections for asbestos-containing materials (ACM) before any work that could disturb them, along with notifications to regulatory authorities to ensure safe handling and disposal.

Complementing NESHAP is the Asbestos Hazard Emergency Response Act (AHERA) of 1986, initially focused on schools but extending standards for inspector certification. AHERA mandates that surveys be conducted by accredited professionals trained in identifying and sampling ACM, using protocols that ensure accurate assessment and risk management.

Recent Changes in NNPH Heightened Enforcement

It’s important to note that these are not entirely new rules. The EPA NESHAP regulations have been in place since 1970. However, NNPH—serving Washoe County, including Reno and Sparks—has heightened enforcement, particularly requiring AHERA-accredited Building Inspectors for asbestos surveys as a prerequisite for building permits. This shift aligns with revisions to Section 040.110 of the District Board of Health Regulations Governing Air Quality Management, adopted on March 27, 2025, following public hearings and workshops.

The updates clarify requirements for sampling, notifications, and abatement, emphasizing the Acknowledgement of Asbestos Assessment (AAA) form submission before permit issuance. A key driver appears to be enhanced public health protections and alignment with EPA-delegated authority, as evidenced by NNPH’s September 12, 2025, workshop on renovation and demolition guidelines, which addressed common compliance questions. This enforcement wave follows earlier public comment periods in January 2025 and proposed revisions discussed in November 2024.

Impact on Local Construction and Building Projects

The updated requirements are noticeably affecting project timelines in Reno and Sparks. Building permits there that call for an AAA from NNPH now require a certified asbestos survey, potentially delaying project starts by weeks if not planned early. 

This underscores the immediate demand and why local firms are seeking specialized support from FACS due to the AHERA Building Inspector stipulation. Non-compliance risks fines that can far outweigh the investment. On the positive side, compliance fosters safer work environments and reduces potential liabilities.

How to Comply: Steps for Asbestos Surveys and Permits

Navigating these requirements starts with proactive planning. First, engage an AHERA-accredited Building Inspector to perform a thorough survey, following EPA and NNPH protocols for sampling and analysis of potential ACM. FACS inspectors are qualified to perform those surveys.

Submit the AAA application to NNPH via your online portal or email, including survey results, building plans, and lab reports. If friable asbestos-containing materials exceed regulatory thresholds (e.g., 260 linear feet or 160 square feet), a NESHAP Notification of Renovation or Demolition must follow, submitted at least 10 working days in advance with original signatures and payment.

For abatement, use licensed contractors adhering to wet methods, containment, and disposal standards outlined in Section 040.110. 

• Step 1: Hire Inspector – Engage AHERA-certified professional; required before permit application.
• Step 2: Conduct Survey – Inspect for asbestos using EPA-approved methods; timeline varies by building size; include lab analysis.
• Step 3: Submit AAA – Apply to NNPH with survey results and plans; required for permits in Reno/Sparks/Washoe.
• Step 4: NESHAP Notification – If ACM present, notify 10 days in advance; includes fees, original signature; mandatory for renovations/disturbances.
• Step 5: Abatement if Needed – Remove or manage ACM safely; by licensed contractors; follow containment protocols.

NNPH’s renewed focus on NESHAP through AHERA-certified surveys represents a much-needed step toward safeguarding community health, even as it introduces new layers to the permitting process. By understanding these requirements and partnering with experienced providers, stakeholders can minimize disruptions and ensure smooth project execution. FACS suggests you turn the hassle of compliance into an opportunity for safer, more efficient builds.

For more information or to schedule your survey now, call FACS at (888) 711-9998 or contact us online here: https://facs.com/contact-us.

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Robust EHS and EAP plans protect workers, shields the company from fines and lawsuits, and helps keep projects on schedule. Treat it as a living document tied directly to how you bid, schedule, and build — not as paperwork you file and forget. Employers should review applicable OSHA standards to determine which written plans are required for their operations.

For instance, OSHA standards codified in 29 Code of Federal Regulations (CFR) 1910.120 call for the implementation of a written safety and health program for employees involved in hazardous waste operations. The program should identify, evaluate, and control safety and health hazards, and provide for emergency response for hazardous waste operations.

Your plan should do the following:

1. Spot the hazards
2. Size up the risk
3. Spell out the fix—with a plan for “what if?”

Below, we’ll walk you through the essential components of an effective EHS program and EAP (emergency action plan).

Hazard Identification and Risk Assessment

First, map the threats: chemical spills, falls from ladders, toxic fume exposure, and so on.

For every item on your list, ask two questions:

“What could go wrong?” and “How bad and how likely is it?”

Plot the answers on a simple risk matrix; red boxes get priority. Then consider the hierarchy of controls:

1. Eliminate (e.g. stop using the hazardous material)
2. Substitute (e.g. switch to a less hazardous material)
3. Engineer (e.g. install a local exhaust ventilation system)
4. Administrative (e.g. provide additional training to employees)
5. PPE (e.g. use respirators — note that this is the last line of defense, not the first)

Update the matrix whenever the scope changes. Don’t file and forget your plan. Refer to it often.

Emergency Preparedness and Response

Establish procedures and plans for responding to emergency situations that may occur.

A lean, field-tested Emergency Action Plan covers:

• Alarms and Talk-Back: Horns, radios, bilingual instructions.
• Evacuation Routes: Two clear paths, marked in daylight and dark.
• Critical Shutdown: Who turns offthe generator or secures the crane?
• Spill and Fire Gear: Extinguishers, absorbents, and trained hands within 50 ft.
• Medical: First-aid kits and someone certified, reachable in three minutes.

Run drills quarterly; log who attended and what went sideways. Paper plans don’t save lives, but muscle memory does.

Training and Education

OSHA’s rule of thumb: “Train in a language and vocabulary workers understand.” A better rule: “Train until they can teach the next person.”

Mix it up with different presentations:

• Hands-on demos (how to react to a chemical spill)
• Toolbox talks (ten minutes at daybreak; one topic only)
• Short e-modules (for refresher quizzes)
• Competency checks (a signature alone won’t prevent a disaster)

Track it all. Self-designed spreadsheet, computer learning management system (LMS), documentation posted on the jobsite — just be able to show an inspector a real record.

Occupational Health and Safety Controls

Identify potential occupational health hazards and implement appropriate controls to mitigate risks. These could include falls, electrocution, respiratory hazards, heat stress, noise exposure, confined spaces, and more.

Ask yourself: “Does the control eliminate the root risk or do we normally just use PPE?” Aim high on the hierarchy.

Environmental Management

A clean job site is cheaper, safer, and simply looks better to passersby. Identify and manage environmental impacts associated with the workplace or site, including air and water quality, waste management, and energy conservation.

• Dust and Diesel: Water trucks, silt fencing, Tier 4 engines, idle-off rules.
• Stormwater: SWPPP (Stormwater Pollution Prevention Plan) in place, wattles checked after every rain, logs signed.
• Waste: Separate hazardous (solvents, lead wipe) from non-hazardous materials; label drums; ship within 90 days.
• Energy: LED light towers, battery scissor lifts, power-down policies.

A tidy site gives you bragging rights and shows the world you care.

Regulatory Compliance

Federal OSHA is only the front door. List applicable local and state laws, regulations, and standards related to environmental health and safety for the project.

You’ll likely juggle:

• EPA: air permits, NPDES stormwater, RCRA waste rules
• DOT: 49 CFR hazmat if you haul diesel or acetylene
• State and Local: State OSHA extras such as fire-marshal hot-work permits, city noise curfews, and more.

Build a compliance matrix: law → activity → person in charge → proof. Digital binders beat a milk crate full of coffee-stained printouts.

Incident Reporting and Investigation

Establish a system for reporting and investigating incidents and near misses to identify the root cause and prevent future occurrences. Near-miss today, ambulance tomorrow — that’s the progression often seen.

• Report all mishaps and “near misses” within 24 hours.
• Investigate with the “Five Whys” or a fishbone diagram — don’t list “worker error” as your go-to description.
• Correct errors, whether human or equipment.
• Share the lesson in the next toolbox talk.

Digital apps make reporting painless. Transparency breeds trust; cover-ups breed repeats.

Auditing, Monitoring and Continuous Improvement

Schedule regular monitoring and auditing of the EHS plan to identify areas for improvement and ensure ongoing compliance. Safety is a loop, not a line.

Adopt a systematic approach:

• Weekly superintendent walk-throughs
• Monthly management scorecard review
• Quarterly third-party audit
• Annual top-to-bottom program rewrite

Making the Plan a Living Document

A rock-solid EHS plan is:

1. Site-specific — names the trench by location, not an abstract “excavation area.”
2. Accessible — QR code on every foreman’s phone, hard copy in appropriate languages on the wall.
3. Dynamic — updates when the crane is relocated or the paint formula changes.
4. Integrated — safety decisions drive scheduling, procurement, and quality.

Revamp your plan when regulations or situations change, but keep safety in sight.

Where FACS Fits In

Crafting a plan that satisfies regulators and the real world can take you way too long, and you can miss way too much. Our team of industrial hygienists and environmental scientists has done the heavy lifting on hundreds of sites.

FACS employs experienced industry leaders that can assist in developing a site specific EHS plan customized to your project: No cookie-cutter PDFs — each plan is hand-built for your specific needs.

Let’s put a custom EHS plan to work for you. Call FACS at (888) 711-9998 or contact us online here.

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In 2024 alone, more than a quarter of California’s inspected engineered-stone shops were hit with stop-work orders, and fines reached five-figure territory for “routine” violations. Now the emergency rule that triggered those shutdowns is permanent—no sunset clause, no grace period, no excuses.

If you manage bids, schedules, or safety talks, you should adjust your work to the new permanent standard under the Title 8 CCR §5204 regulation.

Who Does the New Silica Standard Affect?

Worker protection from respirable crystalline silica is a serious requirement of Cal/OSHA safety standards. Section 5204 covers all general-industry operations where workers may be exposed to respirable crystalline silica and work with artificial stone (composite, engineered, or “quartz” materials) or natural stone > 10 percent silica by weight.

Exceptions:

• Construction (§1532.3), agriculture (§3436), and sorptive-clay processing remain under their own rules.
• Objective-data exemptions below the 25 µg/m³ action level still apply—but not to “High-Exposure Trigger Tasks” (HETTs), meaning any cutting, grinding, drilling, polishing, or cleanup that disturbs artificial stone (> 0.1 % silica) or high-silica natural stone.

What Got Tougher in the Permanent Silica Standard

Regulated Areas:

ETS (2023): Required for high-exposure trigger tasks; provisional signage allowed.

Permanent Rule (2025): Signage text locked in—must warn of “permanent lung damage that may lead to death,” displayed in both English and Spanish.

Engineering Controls

ETS (2023): Running water “where feasible.”

Permanent Rule (2025): Continuous water flow or full submersion mandated; employer must document that flow rate is adequate for dust suppression.

Respiratory Protection

ETS (2023): Loose-fit PAPR allowed if exposure < Action Level.

Permanent Rule (2025): Tight-fit PAPR with HEPA/N-R-P 100 filters is the default; downgrade only after semi-annual sampling shows exposure < Action Level.

Medical Surveillance

ETS (2023): Baseline exam plus annual follow-up.

Permanent Rule (2025): Baseline, then every three years; immediate follow-ups required for high-exposure workers (HETT or > PEL results).

Silicosis Reporting

ETS (2023): “Prompt” reporting language.

Permanent Rule (2025): 24-hour deadline to notify Cal/OSHA and CDPH of any confirmed case.

Dry sweeping/air blow-off—banned outright.

Employee rotation—no longer an acceptable exposure control.

Eight Core Silica Exposure Duties for Employers

1. Written Exposure-Control Plan – List all materials/tasks by silica content. Include air-monitoring records and engineering-control schematics.
2. Exposure Assessment & Air Monitoring – Initial sampling plus 12-month repeat cycle; HETT work may trigger 6-month or 3-month cycles.
3. Engineering Controls – Continuous-water tools, submerged cutting, water-jet, or local exhaust with HEPA filtration.
4. Regulated-Area Management – Barricades or tape, plus bilingual danger signage.
5. Respiratory-Protection Program – PAPR (HEPA/N100/R100/P100) minimum; fit-testing per §5144.
6. Housekeeping Rules – Wet cleanup or HEPA vac only; no dry sweeping, no compressed-air blow-off.
7. Medical Surveillance & Medical Removal Protection – Baseline exam, chest imaging as needed, and 3-year cycle; wage retention up to 6 months if removal required.
8. 24-Hour Silicosis/Cancer Reporting & Recordkeeping – Confirmed cases reported within 24 hours; all sampling & medical records kept 30 years.

Penalties and Shut-Down Risk

Cal/OSHA’s 2025 penalty schedule caps a serious citation at $25,000 and a willful/repeat at $162,851. The minimum penalty for willful violations is $11,632.

But the real hammer is the Order Prohibiting Use (OPU). Inspectors spotting dry cutting or missing water-feed can tape off your saw on the spot. In 2024, more than a quarter of inspected shops were shut down until they fixed violations.

A Practical Roadmap to §5204 Compliance

Gap Analysis

• Map tasks where employees may be exposed against §5204 requirements
• Flag dry processes and inadequate water-feed tools.

Engineering Upgrades

• Budget for new wet saws, water-recycling systems, or downdraft HEPA tables.
• Verify flow rates meet manufacturer specs for dust suppression.

Engage a Qualified Person

• Exposure monitoring may have to be conducted by a third-party “qualified person,” such as a Certified Industrial Hygienist (CIH).

Finalize Written Exposure Control Plan & Training

• Implement exposure control plan
• Conduct bilingual, task-specific training; refresh annually.

Medical Program Contract

• Partner with an occupational clinic familiar with silicosis diagnostics and Cal/OSHA’s 24-hour reporting portal.

Frequently Asked Questions

“We’re below the Action Level—do we still need regulated areas?”
Yes, for any HETT. The regulated-area requirement is task-based, not exposure-based.

“Can I just rotate employees?”
No. Rotation is explicitly prohibited as an exposure control.

“Is a loose-fitting PAPR ever okay?”
Only if semi-annual sampling proves exposures < 25 µg/m³, and even then you need written justification and medical clearance.

The Bottom Line for California Employers Concerning Respirable Crystalline Silica Exposure

The engineered-stone sector is the immediate target, but any operation that liberates respirable crystalline silica is now under the microscope. Waiting for federal OSHA to act won’t help; California has already moved the goalposts.

However, the journey does not end with the enactment of stricter regulations; it continues with diligent compliance, robust enforcement, and the unwavering commitment of all stakeholders to safeguard the well-being of workers and communities.

The law is complex, but that isn’t a valid reason to ignore it. A good first step is to evaluate your high-exposure tasks. For help understanding the requirements and making sure your business is in compliance.

To speak with a FACS lead plan expert, call (888) 711-9998.

The post Silica Exposure and Cal/OSHA’s Silica Emergency Rule appeared first on Forensic Analytical Consulting Services.

The Science of Heat Stress

When a job generates heat load (stress) faster than the body can dump that heat (strain), the internal thermostat misfires. Think of an engine with a plugged exhaust pipe—pressure climbs until the engine fails.

Three components tip the scale:

1. Environment: air temperature, humidity, radiant heat, and air velocity (or lack of it).
2. Workload: metabolic heat created by the body as it works to perform its duties
3. Worker factors: hydration level, fitness, age, medications, alcohol use, acclimatization, and the insulating power of PPE.

At equilibrium, metabolic heat roughly equals heat lost through sweating, evaporation, and air movement. Tip any of the above components far enough and the body’s core temperature rises quickly, setting the stage for heat illness. Heavy exertion in mid-90s Fahrenheit air can dehydrate a laborer by two liters an hour—about a half-gallon. Losing that much fluid for three hours straight and your endurance and judgment unravel long before thirst sets in.

The Heat-Illness Ladder—Catch It Early

Heat Rash is the early warning light—red, prickly clusters in sweaty skin folds. Left unchecked it can infect, but more importantly it signals that body cooling is already lagging behind. Keep skin dry, swap out saturated shirts, dust with drying powders; skip greasy ointments that trap heat.

Heat Cramps —painful muscle spasms in the calves, thighs, even the abdomen. They strike workers who flush out sodium faster than they replace it. Treatment is simple: sheltered rest plus slow sips of a water or sports drink rich in electrolytes.

Heat Syncope is a fancy word for fainting. Blood pools in the legs when a worker stands motionless or bolts upright after stooping. Dehydration and poor acclimatization amplify the drop in blood pressure. Lay the person down in shade, elevate feet, loosen gear, and hydrate gradually.

Heat Exhaustion is the cliff edge. The employee sweats heavily, feels dizzy, irritable, nauseated; skin is cool and clammy but the body’s core temp climbs. Move them to an air-conditioned trailer or at least a shaded area, remove heavy PPE, apply cool wet towels to head and neck, and keep a buddy present until vitals stabilize or EMTs arrive.

Heat Stroke is the cliff. Sweating shuts down, skin turns hot and dry, core temperature rockets past 106 °F, and the central nervous system glitches—confusion, seizures, even coma. Every minute without active cooling risks permanent disability or death. Call 911, flood clothing with cool water, fan aggressively, pack ice at neck, armpits, and groin, and stay with the worker until medics take over.

Measuring the Invisible—Numbers that Drive Decisions

Using a standard thermometer to review heat risk is not the answer, that’s guessing, not managing. You need a method that captures humidity, air speed, and radiant load.

• Heat Index merges dry-bulb temperature with relative humidity to predict “feels-like” heat. It’s perfect for a lunch-room poster and a quick caution flag.
• WBGT (Wet-Bulb Globe Temperature) adds wind and radiant energy to the mix. One handheld meter delivers an objective number you can log by hour, shift, or location.
• The ACGIH Threshold-Limit Values (TLVs) translate WBGT into safe exposure times for acclimatized workers; an Action Limit is provided for new or returning staff.
• Work/Rest schedules—simple tables backed by NIOSH—convert WBGT plus workload (light, moderate, heavy) into duty cycles. Example: heavy manual work at 103 °F WBGT earns 20 minutes work / 40 minutes rest each hour.

If impermeable suits or FR coveralls trap heat, adjust the readings upward; plastic is a greenhouse that amplifies the heat impact.

Phone apps from OSHA and NIOSH put the math in every superintendent’s pocket, pinging hydration reminders and flagging extreme-heat warnings based on GPS coordinates.

Why Construction and Outdoor Trades Take the Hardest Hit

A paving crew can stand over fresh 300-degree asphalt, under hot summer sun, wearing double-layer fabrics. A rebar gang ties steel that reflects midday rays onto faces and necks like a tanning mirror. Roofers, miners, utility trench workers, agriculture hands—each adds its own twist: confined trenches, missing shade, diesel exhaust, or adrenaline-charged production goals that disguise early symptoms.

Combine high radiant heat, heavy metabolic demand, limited airflow, and brand-new hires who celebrated the weekend with beer and little sleep, and you have a perfect storm for heat stress illness.

Here’s a grim statistic worth repeating: Three out of four heat-fatalities occur in a worker’s first week on a hot site, when the body has not yet adapted. That single fact should reshape every onboarding plan.

Controls You Can Use to Combat Heat Stress

Engineering Controls: Improve cross-ventilation; install high-volume, low-speed fans when ambient air is cooler than skin; set porta-coolers at break stations; wrap ovens and generators with radiant shields; insulate steam lines; erect temporary shade screens at pour decks. Even small tweaks can cut radiant heat measurably.

Administrative Controls: Begin every hot season with a formal acclimatization plan: 20 percent of full duty on day one, adding 20 percent each day until the worker reaches 100 percent. Reschedule the heaviest tasks to pre-noon; rotate arduous jobs to equalize metabolic load; enforce cool-down breaks. A designated heat-safety lead should record WBGT, adjust work/rest cycles, and carry authority to call time-out.

Personal Protective Equipment: Is crucial when all else fails but unreliable alone. Ice vests, cooling towels, vented hard-hat liners, moisture-wicking base layers, and lighter-weight clothing blends can drop skin temperature enough to lengthen safe work bouts. Test new gear with a pilot pair of workers before you outfit an entire crew, and remember ice packs quit after an hour; schedule time to rechill.

Building a Heat-Illness Prevention Program That Lives and Breathes

A dusty binder on a shelf never saved a worker. Your Heat Illness Prevention Program (HIPP) should be visible, dynamic, and practical.

Post the plan. Water-Rest-Shade charts and urine-color hydration posters belong at the porta-john, the gang box, and the trailer door.

Brief daily. A two-minute tailgate that covers forecast, current WBGT, shift workload, and any extra controls trains situational awareness faster than a once-a-year slide deck.

Supply hydration. Cool water every 300 feet and electrolyte mixes on heat-alert days tell crews you value kidneys over schedule.

Drill first aid. Crews who are aware of heat illness symptoms are able to treat heat illness faster and call for help sooner. Assign a buddy system.

Audit and correct. Log WBGT regularly, pair readings with crew lists, and review any incident for gaps in acclimatization, PPE, supervision, or engineering controls.

Stay legal. OSHA’s Heat-Hazard National Emphasis Program is already ticketing job sites when the heat index tops 80 °F. A federal heat standard is moving through rulemaking; states like California, Oregon, and Washington enforce even stricter rules.

Finish Strong—A Five-Step Field Checklist

1. Pull last summer’s incident logs and flag every heat-related entry.
2. Inventory equipment: WBGT meter, shade structures, coolers, PPE
3. Write or dust off your HIIPP and acclimatization schedule and hand it to every foreman.
4. Install hydration and first-aid posters where eyes linger—porta-johns, lunch trucks, tool rooms.
5. Run a tabletop drill: “It’s 106 °F WBGT at 2 p.m.; laborer collapses on deck—what next?”

The cost of prevention is measured in minutes and gallons; the cost of failure is measured in lives and lawsuits. Measure the heat, write the plan, train the people, and stand ready with water, rest, and shade. The sun is predictable. Let your prevention be just as relentless.

For more information, watch the FACS webinar on heat stress here. And for quick help developing your Heat Illness Prevention Program, call FACS at (888) 711-9998 or contact us online here.

The post Beating Heat Stress on the Jobsite: A Field-Tested Playbook appeared first on Forensic Analytical Consulting Services.

Here’s a surprising statistic: The National Institute for Occupational Safety and Health (NIOSH) reports that up to 90% of eye injuries at work could be prevented through proper protective eyewear.

Effective eye and face protection does more than keep your company and employees in regulatory compliance. Using the correct protective gear can protect vision, reduce lost workdays, lower healthcare costs, and maintain steady productivity. Most importantly, it helps make sure your employees stay safe on the job.

Understanding the Risks

Workers in various fields, from construction sites and manufacturing plants to laboratories and healthcare settings, face multiple eye and face hazards. Flying debris such as metal fragments, wood chips, and particles are a significant risk, particularly in manufacturing and construction. Chemical splashes, harmful ultraviolet (UV) and infrared radiation from welding or lasers, and biohazard exposure in medical settings, fabrication, and anywhere else they are used.

Despite readily available protective gear, injuries often occur due to inadequate awareness, improper PPE selection, or simply not wearing protection consistently. Workers may underestimate the danger of certain tasks or rely on inappropriate equipment, leading to preventable incidents.

Eye Safety Standards You Should Know

To address these risks, OSHA outlines clear regulations under standards 29 CFR 1910.133 (general industry) and 1926.102 (construction). Employers must not only provide eye protection but ensure it meets the stringent American National Standards Institute (ANSI) Z87.1 specifications.

The ANSI Z87.1 standard outlines critical performance criteria, including impact resistance, chemical protection, and UV radiation shielding. PPE marked with “Z87+” indicates high-impact resistance, essential for jobs involving flying objects. Labels such as D3 (liquid splash), D4/D5 (dust), U6 (UV protection), and W (welding filter shades) guide users in choosing appropriate gear for specific hazards. Compliance with these standards ensures reliable performance and protection in critical situations.

Choosing the Right PPE for Eye Protection

Selecting protective equipment isn’t as simple as grabbing any pair of safety glasses. Effective protection requires matching PPE specifically to the hazards of the task:

• Safety Glasses: Suitable for general impact hazards, must meet Z87.1 standards.
• Safety Goggles: Provide sealed protection from chemical splashes and dust. Look for ventilation types based on your exposure (direct, indirect, or non-vented).
• Face Shields: Offer extra protection from larger debris or chemical splashes but always require safety glasses or goggles underneath.
• Welding Helmets: Essential for protection against intense UV and IR radiation; ensure compliance with ANSI standards and proper shade selection.
• Specialty Eyewear: Laser protection, chemical-resistant, and prescription eyewear provide specialized safety where general eyewear might fall short.

Comfort and proper fit significantly influence compliance. Workers are far more likely to consistently wear comfortable PPE. Regularly involving workers in the selection process helps ensure the equipment meets their comfort and functional needs, thereby promoting consistent use.

Common Eye Protection Mistakes and How to Avoid Them

Employers and employees share responsibility for workplace safety. Common errors include using incorrect PPE for tasks, wearing damaged equipment, prematurely removing gear, or simply neglecting to wear it at all.

One frequent mistake is choosing inadequate PPE, such as opting for safety glasses when goggles or a face shield are required. Workers sometimes underestimate hazards, believing basic protection is sufficient, which can lead to serious injuries. Employers must conduct thorough hazard assessments and clearly communicate the specific PPE requirements for each task.

Damaged or worn-out PPE is another common issue. Scratched lenses, broken straps, or missing side shields drastically reduce protection and visibility. Regular inspections should be part of daily routines, with damaged PPE immediately replaced. Employees must be trained to recognize signs of wear and encouraged to report issues without hesitation.

Premature removal of protective gear is a significant risk. Workers may remove goggles or shields when they feel safe, even though hazards are still present. Employers should consistently reinforce that PPE must remain worn until employees are fully clear of all risks.

Another critical mistake is inadequate maintenance and storage of PPE. Dirty or improperly stored gear can impair visibility and reduce protection. Establish clear protocols for cleaning, maintaining, and storing PPE correctly. Easy access to well-maintained equipment encourages consistent and proper use.

Neglecting comprehensive training is also problematic. Employees must fully understand the proper use, fit, and limitations of their PPE. Regular training sessions reinforce safety protocols and provide opportunities to address concerns or misunderstandings.

Finally, poor enforcement and lack of leadership examples can undermine compliance. Managers and supervisors must visibly support and enforce PPE protocols consistently, setting the standard by correctly using their own equipment.

Emergency Preparedness and Workplace Safety

Even with precautions, accidents can happen, emphasizing the critical role of emergency equipment. ANSI Z358.1 standards guide the proper installation and use of eyewash stations and emergency showers, which should always be accessible “for quick drenching or flushing of the eyes and body.”

Proper training in emergency responses — such as immediately flushing chemical splashes for at least 15 minutes — can significantly reduce injury severity, preventing long-term vision impairment. Regular emergency drills and clearly marked equipment locations ensure rapid and effective responses during real incidents.

Building a Culture of Safety at Work

Safety awareness is a cultural commitment. Leadership must actively prioritize and demonstrate safe working behaviors. Regular inspections, ongoing training, and recognition programs encourage everyone to participate and reinforce safe practices.

Strong safety cultures don’t develop by chance. They require consistent commitment, clear communication, and collaborative effort between employers and workers. Encouraging employee feedback and active participation fosters an environment where safety becomes ingrained as a core value at your company.

Emerging Trends and Future Innovations

New PPE innovations continue to emerge, including ergonomic designs, advanced materials, and smart technology like augmented reality (AR-enabled) glasses and sensors that detect hazards in real-time. These innovations promise enhanced protection, comfort, and usability, driving greater compliance and safety.

However, adopting new technologies always requires thorough risk assessments to ensure they don’t exacerbate hazards instead of lessening the threat. Staying informed and adaptable helps organizations continually improve their safety strategies.

Eye and face protection is fundamentally about safeguarding health, livelihoods, and lives. With appropriate awareness, thorough hazard assessments, and proactive use of PPE, workplaces can significantly reduce the risk of preventable injuries. Every person on your team should be encouraged to work safely, shown how to work safely, and provided the equipment that can help them work safely.

For more information, see the FACS/Bullard presentation on eye and face protection or contact FACS directly at (888) 711-9998.

The post Workplace Safety: Protecting Eyes and Face from Injury appeared first on Forensic Analytical Consulting Services.

For many industries, from construction to manufacturing, these rules represent a significant shift in how indoor heat risks are regulated and managed.

This article will guide you through the essentials of the regulation: when it applies, what’s required, and practical steps to implement a compliant heat illness prevention program.

Are You Exempt From the Indoor Heat Regulation?

First, let’s make sure you’re in the right place. Understanding the new California indoor heat regulation does take time and effort — however, your operations may not be covered by it.

Here is a list of the exceptions to the new law:

• Teleworkers performing duties at a place of their choosing
• Incidental heat exposure (fewer than 15 minutes in any 60-minute period), except that working in vehicles without air conditioning and those working with shipping or intermodal containers while loading, unloading, or doing related work
• Emergency operations aimed at the protection of life or property
• Prisons, local detention facilities, or juvenile facilities
• Outdoor workplaces (although this is covered by Cal/OSHA’s outdoor heat regulation)

None of the exceptions mean that working in the heat doesn’t matter, only that there is a personal responsibility to protect oneself or there are already regulations in place that govern work where indoor heat may be a health concern.

When Does the Indoor Heat Regulation Apply?

The new indoor heat regulation for workplaces in California outlines specific situations that require you to safeguard employees working in elevated temperatures.

When are the requirements of the regulation triggered?

The regulation triggers at 82 degrees Fahrenheit (F) for workers wearing garments that restrict heat removal from their bodies (wearing work coveralls, gloves, or helmets, for example) and for workers working in a high radiant heat environment. If those conditions are not in existence, the trigger point is 87°F.

What is an “indoor space”?

Indoor space is defined as a space that is under a ceiling or overhead covering that restricts airflow and is enclosed along its entire perimeter by walls, doors, windows, dividers, or other physical barriers that restrict airflow (whether those barriers are open or closed). During building construction, a workplace becomes “indoor” once the barriers are in place. Note that the outdoor exception for shaded spaces does not apply indoors.

What Must You Do to Comply With the New Indoor Heat Regulation?

Once conditions trigger the new regulation, employers are required to do the following:

Employers must provide potable drinking water

• Employers must ensure that employees have no-cost access to potable, cool drinking water.
• Each worker should have at least one quart of water per hour available during their shift.
• Water must be placed near work areas and cool-down locations. Workers should not have to travel long distances to access it.
• While you don’t need to provide all the water at the start of the shift, it must be replenished regularly to meet the hourly requirement.

Employers must provide access to cool-down areas

• Provide access when indoor temperatures reach 82°F or higher, you are required to provide a designated cool-down area where employees can rest and recover.
• These areas must be shielded from radiant heat and maintained at temperatures below 82°F.
• Employees should be encouraged to use cool-down areas regularly, and any worker who requests a cool-down rest period should be allowed one.

Employers must monitor heat levels and record data

• Begin monitoring temperature and heat index when indoor temperatures reach 82°F. Additional measurements should be taken whenever temperatures are expected to rise by 10°F or more.
• Employers must record the measured temperature or heat index (whichever is higher) and retain those records for at least 12 months. Best practice is to integrate this documentation into your regular project files.
• Instruments used for measuring must be maintained per the manufacturer’s instructions.
• Instruments used must provide the same results as indicated by heat index charts from the National Weather Service for temperature at certain humidity levels.

The new indoor heat regulation for California also requires a written implementation plan and training for both workers and supervisors. You’ll find more about those in the content below.

Invest in Reliable Monitoring Tools

Measuring and tracking workplace conditions is critical for maintaining compliance with the new California indoor heat regulation and ensuring employee safety. Make sure the tools you use for monitoring are accurate and simple to use. Be sure to train management on their proper operation.

• Thermometers: Keep trustworthy thermometers on the worksite to monitor temperature.
• National Weather Service Heat Index Chart: Readily accessible online. Print and laminate for regular use. The chart provides the heat index at the temperature and humidity levels you have recorded.
• Wet Bulb Globe Thermometers: These devices measure temperature, humidity, air movement, and radiant heat. They are ideal monitoring instruments, especially in manufacturing or other enclosed spaces.
• Personal Heat Stress Monitors: These are worn by selected employees to provide information for that specific person.
• Heat Stress Apps: The American Industrial Hygiene Association’s heat stress app can help you assess conditions, review precautions, and access real-time heat index forecasts. The app also provides risk factors, training recommendations, and programmable hydration and rest reminders.

Remember: The regulation is triggered by either the current temperature or current heat index. At higher relative humidity levels, the heat index can be greater than 82 °F while the temperature is under 82 °F.

Control Measures for Managing Indoor Heat

Compliance with the indoor heat regulation requires a layered approach to managing heat exposure. By combining engineering, administrative, and personal protective measures, you can create a safer environment for your team while meeting regulatory standards.

Engineering Controls: Reducing Heat at the Source

The first line of defense against indoor heat is to reduce temperatures and maintain a safe environment using engineering controls. These measures focus on modifying the work environment itself:

Key factors to assess include:

• Temperature Control Systems: Install or maintain air conditioning units, fans, and ventilation systems to keep temperatures below 87°F — or below 82°F in areas where employees wear restrictive clothing or radiant heat is present in the work area.
• Radiant Heat Barriers: Use shielding materials or insulation to block heat from equipment, machinery, or sunlight.
• Humidity Reduction: Dehumidifiers or improved ventilation can lower humidity levels, making the work environment more comfortable and safer for employees.

Administrative Controls: Scheduling and Breaks

When engineering controls alone aren’t enough or aren’t feasible, administrative practices can further mitigate heat risks:

• Work-Rest Cycles: Adjust workloads and schedules to allow for regular rest breaks in cool-down areas.
• Staggered Shifts: Where possible, schedule physically demanding tasks during cooler parts of the day.
• Job Rotation: Rotate employees between high-heat tasks and less strenuous roles to prevent prolonged exposure.

Personal Protective Equipment (PPE): When Other Measures Still Aren’t Sufficient

In some cases, PPE can provide additional protection against heat-related risks:

• Cooling Vests and Wraps: Wearable items that help maintain lower body temperatures during extended work periods.
• Moisture-Wicking Clothing: Lightweight, breathable materials can aid sweat evaporation and heat dissipation.
• Specialized Headgear: Helmets with built-in cooling pads or ventilation improve comfort and safety.

While PPE can be a helpful supplement, it should never replace engineering or administrative controls. Instead, it serves as a last line of defense in situations where other measures cannot fully address the risks.

How Is Heat Illness Detected?

Heat illness can present itself in several ways, ranging from mild discomfort to severe medical emergencies. Train your team to recognize these symptoms and respond both quickly and appropriately.

• Heat Rash: Small red bumps or clusters, often on the neck, chest, groin, or underarms. Common in humid environments where sweat can’t evaporate.
• Heat Cramps: Painful muscle spasms caused by dehydration and salt loss. Often a warning sign of more serious heat stress.
• Heat Syncope: Fainting for a short duration, dizziness, and light-headedness can signal a developing problem.
• Heat Exhaustion: Symptoms include heavy sweating, dizziness, nausea, weakness, and a rapid pulse. Employees in this state need immediate cooling and hydration.
• Heat Stroke: The most serious form of heat illness. Symptoms include hot, dry skin, confusion, and loss of consciousness. Heat stroke requires emergency medical attention and is fatal in 50% of cases if untreated.

Emergency Procedures: Responding to Heat Illness

Even with the best prevention strategies, heat illness can occur. Having a clear and effective emergency response plan is not only a regulatory requirement but also a critical element in protecting your employees from severe outcomes.

You must have first aid supplies available, access to Eemergency Medical Services (EMS) , and a way to communicate with EMS and with your crew. Someone must be available to call 911 and provide clear directions to the site.

Make sure EMS access is not restricted at the site or that someone can meet the responders at the gate or barrier to provide entry. Remember that cellular phones are not reliable in some areas, meaning you must provide an alternate method for communications.

Immediate Actions for Heat Illness Symptoms

Recognizing heat illness early can prevent it from escalating. When symptoms do appear, take immediate action. Never leave the employee alone and do not send a worker home without offering medical assistance.

Here’s how to Prepare:

Heat Illness Prevention

Acclimatization: A Key Step in Prevention
New or returning workers are most at risk during their first 14 days on the job. The same applies to workers assigned to a new geographical area. Gradually introducing employees to high-heat environments is essential. Nearly 75 percent of illness fatalities occur during the first week of working in excessive heat environments.

• Follow the 20% rule. Start new workers at 20% of their full workload on day one, increasing by 20% each day as they acclimate.
• Sudden temperature increases can affect even seasoned employees. Keep a close eye on conditions and adjust workloads, as needed.
• Heat waves are defined as temperatures at least 10°F greater than the average high daily outdoor temperature for the preceding five days and are at least 80°F. Make sure to document your daily temperature recordings.

Encourage Team Awareness

One of the biggest dangers of heat illness is that workers may not recognize the symptoms themselves when they are affected.

Emphasize the importance of the following safeguards:

• Looking Out for One Another: Supervisors and coworkers should monitor each other for signs of heat stress.
• Reporting Symptoms Early: Employees must feel comfortable reporting any signs of heat illness without fear of repercussions.

By fostering a culture of awareness and prevention, you reduce risks and reinforce your commitment to safety. With these foundational steps, your team is better prepared to avoid the dangers of heat illness altogether.

Training and Compliance Programs for Heat Illness Prevention

Effective training is the cornerstone of compliance with California’s indoor heat regulation. Both employees and supervisors need to understand the risks, recognize symptoms, and know how to respond to heat-related illnesses. Developing a robust training program and a comprehensive heat illness prevention plan ensures everyone is prepared to stay safe and meet regulatory standards.

Employees must receive training on the following key topics:

• Environmental risks such as high temperatures and humidity
• Personal risks such as dehydration, inadequate acclimatization, and restrictive clothing
• The added burden of heat load from exertion, work clothing, and other factors
• Site-specific protocols for reporting symptoms and summoning medical help
• The importance of adequate water intake
• The importance of acclimatization
• Recognizing heat illness symptoms and first aid procedures
• Emphasis on never leaving a distressed employee alone and reporting any observed issues
• EMS procedures for the worksite

Supervisors must receive training on the following topics:

Supervisors require more detailed training to effectively oversee heat illness prevention and response efforts:

• Supervisors must understand every aspect of the training employees receive
• How to follow the requirements of the regulations and your stated procedures to ensure employees receive timely and appropriate medical attention
• Full knowledge of EMS procedures and clear communication during emergencies
• How to measure temperature, humidity, and heat index using approved tools or apps.
• Proper recordkeeping procedures, including what data to document and how long to retain it

Develop a Heat Illness Prevention Plan

You must have a written plan for establishing, implementing, and maintaining your health illness prevention program. It should be specific to your worksite and address all aspects of indoor heat management, including the following:

• How drinking water will be supplied, monitored, and replenished
• Cool-down area locations and maintenance procedures
• Guidelines for adjusting workloads and break times based on temperature conditions
• Steps for identifying and responding to heat illness
• How to summon medical help and guide EMS responders to the worksite
• How and when employees and supervisors will be trained
• A description of the feasible control measures you will implement as needed

Ongoing Compliance and Resources

Maintaining compliance isn’t a one-time effort. Make training and plan updates part of your regular safety routine:

• Provide annual updates or as regulations change
• Adapt your heat illness prevention plan as your worksite or operations evolve
• Utilize tools like the Cal/OSHA website and industry-specific guidance to stay informed

By understanding the new regulation, providing the necessary resources, and building a culture of safety awareness, you can reduce risks and help ensure your workers stay safe and productive

Contact FACS online: Ask FACS

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The updated standard mandates that employers provide detailed hazard communication programs, including labeling, safety data sheets, and employee training. These changes help ensure that everyone in the workplace has access to clear and accurate information about the chemicals they may encounter. This move towards a globally harmonized system not only enhances safety but also simplifies international trade by standardizing hazard classifications.

Implementing these updates requires the cooperation of all stakeholders, from employers to employees. Compliance with the updated OSHA standard involves integrating new labeling systems, conducting thorough training sessions, and maintaining up-to-date safety data sheets. Understanding your responsibilities under the new regulations is crucial for maintaining a safe working environment and avoiding potential violations.

Key Takeaways

• The updated standard includes the Globally Harmonized System for chemical classification.
• Employers must provide comprehensive hazard communication programs and training.
• Compliance ensures a safer workplace and aligns with international standards.

Overview of OSHA and the Hazard Communication Standard

The Occupational Safety and Health Administration (OSHA) plays a critical role in ensuring workplace safety, particularly through the implementation of the Hazard Communication Standard. This standard aims to protect workers from chemical hazards by requiring proper labeling, safety data sheets, and training.

The Role of OSHA in Workplace Safety

OSHA, an agency of the U.S. Department of Labor, is responsible for creating and enforcing rules to ensure safe and healthy working conditions. Established in 1970, OSHA’s mission includes reducing hazards, conducting inspections, and providing training to both workers and employers.

Key responsibilities include:

• Regulation development: OSHA creates standards to address various workplace hazards.
• Inspections: Regular inspections and investigations are conducted to ensure compliance.
• Educational programs: Offering resources and training to improve workplace safety.

OSHA’s efforts have significantly reduced workplace injuries and illnesses, contributing to a safer work environment for millions of workers.

Evolution of the Hazard Communication Standard

The Hazard Communication Standard (HCS), also known as HazCom, was developed to ensure information about chemical hazards is properly communicated to workers. Since its inception in 1983, the standard has undergone several revisions to enhance its effectiveness.

Key updates include:

• In 2012, OSHA aligned HCS with the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals.
• Label changes: Standardized labels and safety data sheets (SDS) were introduced.
• Classification criteria: New criteria for chemical classification improved hazard identification.

These updates aimed to make the HCS more effective in preventing chemical-related injuries and illnesses. You can explore more about these updates in detail through resources like OSHA National News Releases.

By keeping up with these changes, employers can ensure they are providing the necessary information and protection to their workers.

Understanding the Globally Harmonized System

The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals was developed to standardize chemical hazard communication worldwide. It aims to ensure that information about chemical hazards is consistent and understandable, regardless of where the chemicals are produced or used.

Globally Harmonized System of Classification and Labeling of Chemicals

The Globally Harmonized System of Classification and Labeling of Chemicals is a framework created by the United Nations to harmonize the criteria for classifying chemicals according to their health, physical, and environmental hazards.

The system utilizes standard pictograms, signal words, and hazard statements across all countries. This uniform approach makes it easier for workers and emergency responders to understand the risks associated with various chemicals, enhancing workplace safety.

Safety Data Sheets (SDS) are a critical part of GHS, providing detailed information on the properties, handling, storage, and emergency measures related to chemicals.

Impact of GHS on Hazard Communication

The implementation of GHS has significantly impacted hazard communication. Organizations must now adhere to consistent classification and labeling practices, regardless of the country. This helps reduce confusion and improves safety by providing clear hazard communication across borders.

Employers are required to update their hazard communication programs to align with GHS standards. This includes training employees on the new labels and Safety Data Sheets.

By following GHS guidelines, companies ensure compliance with international regulations, fostering a safer and more informed workplace.

For more information on GHS and its impact on hazard communication, you can refer to the detailed final rule on hazard communication.

Key Components of the Updated Hazard Communication Standard

The revised OSHA Hazard Communication Standard aims to improve safety by ensuring clear communication of chemical hazards through standardized classification, labeling, and documentation.

Hazard Classification Criteria

The updated standard introduces specific hazard classification criteria. You must classify chemicals based on their health and physical hazards. Criteria are detailed, covering various toxicities, skin corrosion, and environmental impacts. The intent is to unify classification methods globally, making it easier for you to understand the risks associated with chemicals you handle. Accurate classification ensures the right safety measures are taken, reducing workplace accidents and health issues.

Labeling Requirements

Labels must now follow a standardized format. Key elements include signal words, hazard statements, precautionary statements, and pictograms. For example, chemicals must include a “Danger” or “Warning” signal word to indicate their level of hazard. Hazard statements describe the nature and degree of hazard (e.g., “Causes severe skin burns”). Precautionary statements suggest safety measures like using protective equipment. Pictograms are graphical symbols that quickly convey hazard information at a glance, enhancing immediate understanding and reaction to risks.

Safety Data Sheets Format

Safety Data Sheets (SDS) must follow a specific 16-section format. These sections cover identification, hazard identification, composition, first-aid measures, fire-fighting measures, and more. This standardized format ensures comprehensive and consistent hazard communication. For example, Section 4 details first-aid measures, guiding you on what to do in case of exposure. Section 8 covers exposure controls and personal protection recommendations, ensuring you know the necessary precautions to take. The format is designed to provide all critical information needed for safe handling and emergency response.

Responsibilities of Stakeholders

Key stakeholders each have specific roles to play in ensuring compliance with the OSHA Updated Hazard Communication Standard. Chemical manufacturers and importers must properly classify chemicals and provide accurate safety data. Employers need to implement comprehensive communication programs, while workers are entitled to proper training and protective measures.

Chemical Manufacturers and Importers’ Obligations

Chemical manufacturers and importers have critical responsibilities. They must identify and classify hazards of the chemicals they produce or bring into the country. This includes preparing and updating Safety Data Sheets (SDS), which detail the properties, hazards, protective measures, and safety precautions for using the chemical.

Manufacturers must also label containers with required hazard information. The labels must include signal words, pictograms, hazard statements, and precautionary statements. It is essential that these labels are consistent and clearly communicate the risks.

Regular updates to both labels and SDS are necessary to reflect new information about hazards or protective measures. This ensures that all entities in the supply chain, from importers to end-users, possess the latest safety information.

Employers’ Duties

Employers have a duty to implement a written hazard communication program in the workplace. This program must include a list of hazardous chemicals present, along with detailed information on each chemical provided via SDS. Your responsibilities also include ensuring chemicals are labeled correctly.

Training is a fundamental requirement. You must provide effective training to your workers that covers the hazards of the chemicals they might encounter and safe handling practices. This training must occur at the time of initial assignment and whenever a new chemical hazard is introduced.

It’s also important to develop and maintain emergency procedures for actions to take in case of accidental exposure or spills. Employers must routinely review and update the hazard communication program to guarantee its continued effectiveness.

Workers’ Rights and Protections

Workers have the right to access information regarding hazardous chemicals in their workplace. This includes access to a physical or electronic copy of the SDS for each chemical, and clear, readable labels on all chemical containers.

Training is not just an obligation of employers but also a critical right for workers. You should receive proper education on how to handle hazardous chemicals safely, understand the labeling system, and know where to find the SDS. You have the right to report any unsafe conditions without fear of retaliation.

Workers must use any provided personal protective equipment (PPE) correctly as instructed and report any issues with the labeling or SDS to their employers immediately. Continuous engagement and communication between workers and employers play a crucial role in maintaining a safe workplace environment.

Hazard Communication Programs and Training

A well-implemented hazard communication program ensures workers are fully informed about potential chemical hazards in the workplace. Effective training, coupled with accessible hazard information, is crucial for employee safety.

Developing an Effective Hazard Communication Program

To create an effective hazard communication program, include clear labeling, Safety Data Sheets (SDS), and a comprehensive written plan.

Labeling: Use standardized labels on containers with the chemical name, hazard warnings, and manufacturer information.

Safety Data Sheets (SDS): Make SDS available for all hazardous chemicals, detailing hazard information, handling, and emergency measures.

Written Plan: Develop a written program outlining how hazard communication will be managed. This includes labeling, SDS management, and employee training protocols.

Regular audits and updates ensure compliance and address any emerging hazards.

Training Requirements for Employees

Training employees on hazard communication is mandatory and vital for their safety.

Core Topics: Training should include hazard identification, proper handling procedures, and emergency response measures.

Frequency: Conduct training during initial employment, when new chemicals are introduced, and periodically for reinforcement.

Materials and Methods: Use various materials such as videos, hands-on demonstrations, and written instructions.

Documentation: Maintain records of all training sessions, including dates, attendees, and covered materials.

Evaluation: Assess employees’ understanding of the training to ensure effectiveness and make necessary adjustments.

Special Considerations in Hazard Communication

When handling hazardous materials, certain factors demand special attention. These include the handling of trade secrets and the specific contexts in which certain chemicals are used.

Trade Secrets and Confidential Business Information

OSHA’s Hazard Communication Standard allows for the protection of trade secrets. If a chemical identity could reveal a trade secret, employers might withhold the exact name.

Employees and medical personnel may request the information if necessary for health and safety. OSHA’s amended rules provide a balance, granting trade secret protections while ensuring critical safety information is accessible during emergencies.

For instance, trade secrets can be protected without compromising necessary safety details. Disclosure requirements ensure workers know potential hazards from substances like flammable gasses, pyrophoric gasses, and other dangerous materials.

Chemicals in Specific Contexts

Certain chemicals require unique handling due to their hazardous nature. For instance, chemicals under pressure, aerosols, and explosives need specific measures.

For example, flammable gasses and desensitized explosives possess properties necessitating distinct hazard communication practices to prevent accidents.

Pyrophoric gasses may ignite spontaneously in air, requiring special labeling and usage guidelines. Proper documentation through Safety Data Sheets (SDS) is mandatory, with updated hazard information reflecting current standards.

These measures ensure workers are adequately informed about risks and safety procedures specific to these complex categories of chemicals.

Compliance Guidelines and Enforcement

Understanding how to comply with the OSHA Hazard Communication Standard (HCS) and the potential enforcement mechanisms is crucial for businesses to avoid penalties and ensure workplace safety. Enforcement includes fines for violations, while compliance guidelines help employers navigate regulations.

Inspections and Violations

OSHA conducts inspections to ensure adherence to the HCS. These inspections can be prompted by workplace incidents, employee complaints, or as part of routine checks. Federal agencies such as OSHA have the authority to impose fines and other penalties for HCS violations.

Common violations include failure to maintain proper hazard labels and omission of Safety Data Sheets (SDSs). State plans, such as Cal/OSHA, may have additional regulations and enforcement mechanisms beyond federal requirements. Non-compliance could lead to significant fines, recorded as violations in the Federal Register.

Guidance for Compliance

To comply with the HCS, employers must follow several key steps. First, ensure all chemicals in the workplace are labeled correctly according to OSHA standards. Second, maintain accurate and accessible SDSs for each chemical. Third, provide training for employees to recognize and understand hazardous materials.

Federal agencies, including OSHA, provide resources and training materials. Employers can refer to documents like the Hazard Communication Standard Final Rule for detailed guidance. It’s also essential to stay updated with any changes in regulations to avoid violations. Local or state-specific guidelines, such as those from Cal/OSHA, must also be considered to ensure comprehensive compliance.

Call FACS at (888) 711-9998 for additional information, or submit your information through our contact form and we’ll be in touch with you shortly.

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Mold in healthcare settings can pose significant health risks and liability issues. Along with an effective mold and moisture management program, consulting with an environmental health consultant to assist in evaluations will help achieve a safe environment for patients, staff, and visitors.

This article outlines key standards and guidelines, the fundamentals of mold biology, examples of health risks of mold, sampling methods, and risk management strategies.

Standards and Guidelines

Effective mold management in healthcare settings begins with understanding and adhering to established standards and guidelines. Key documents include, but are not limited to:

• APIC State-of-the-Art Report, FGI Guidelines for the Design and Construction of Hospitals and Health Care Facilities
• The Joint Commission Environment of Care Standards
• CDC Guidelines for Environmental Infection Control in Health-Care Facilities
• AIHA’s “Recognition, Evaluation, and Control of Indoor Mold” for essential insights into managing mold-related issues

Fundamental Principles of Mold Growth

Mold growth requires three essential elements: a viable mold spore, a food source, and moisture. Common food sources in healthcare settings include paper, gypsum, wood, fabric, leather, soil/plant matter, adhesives, food, and organic debris. Moisture sources can arise from plumbing failures, building envelope failures, sprinklers, runoff, rain, flooding, humidity, moisture, and steam.

Certain mold species, such as Aspergillus species, are of special concern in healthcare due to their infectious nature that may pose elevated health risks to susceptible patients.

Sampling Methods for Mold

As in all industrial hygiene, sampling strategies should always have a clearly defined purpose and objective. Random, undirected sampling is never recommended. Sampling methods vary based on the objective, whether it’s verifying the abatement of a hazard or assessing environmental conditions.

Species-level sampling is crucial in the healthcare environment, to demonstrate the presence or absence of infectious mold species. This can allow for the matching of environmental samples to patient biological samples during suspected healthcare acquired infections. Common collection methods include surface sampling, bulk sampling, and air sampling. The most common air sampling technique is the non-viable spore trap sample. However, when working in the healthcare environment, this common sampling and analytical strategy may not be sufficient in evaluating the environment. Therefore, to allow for species-level identification, sampling and analytical methods must include either viable (e.g., culture plates) or Polymerase Chain Reaction (PCR; DNA analysis). The table below compares the various sampling and analysis techniques.

Risk and Liability Management

Infection risks arise when mold spores are disturbed without effective controls, potentially reaching patients and causing serious health issues. Managing mold-related risks involves a thorough assessment and control of potential hazards. Historical cases have shown that patients have died from exposure to Aspergillus spores in hospitals, highlighting the critical need for effective risk management.

Litigation risks are also significant, as hospitals may face lawsuits even with controls in place. Therefore, it is essential to assess risk, implement control measures, and meticulously document the assessment and effectiveness of these controls. This documentation helps protect the healthcare facility in case of legal action and ensures compliance with industry standards and guidelines.

FACS Recommendations Concerning Mold in Healthcare Settings

Mold management in healthcare settings is a multifaceted challenge requiring adherence to established standards and guidelines, understanding the biology of mold growth, recognizing the health risks associated with mold exposure, and implementing effective sampling and risk management strategies.

FACS vast experience in serving the healthcare industry allows for FACS’ understanding of the complexity of the healthcare environment and sensitivity of its occupants. By selecting the right assessment strategy, maintaining thorough documentation, and partnering with an experienced environmental health consultant, healthcare facilities can mitigate the risks associated with mold and ensure a safe environment for patients, staff, and visitors. Understanding and addressing these elements are crucial for effective mold management and maintaining the overall health and safety of healthcare environments. For more information, call FACS: (888) 711-9998.

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Unfortunately, lead is also toxic to humans.

The Roman architect, Vitruvius, warned about the negative health effects of lead in the first century BCE. Mining with lead, working with lead, drinking water from lead pipes — Vitruvius said all are hazardous and that clay is much preferred for potable sources of water. It took hundreds of years before those warnings were taken seriously.

Lead Standards and Regulations in the USA

One of the earliest regulations in the United States was the Lead-Based Paint Poisoning Prevention Act of 1971. This act marked the beginning of federal efforts to address lead hazards, particularly in housing. It aimed to reduce lead poisoning in children by prohibiting the use of lead-based paint in residential structures that received federal funding.

The Environmental Protection Agency (EPA) took further steps by phasing out leaded gasoline starting in the mid-1970s, with a complete ban effective by 1996 that dramatically reduced airborne lead levels. Additionally, in 1978, the Consumer Product Safety Commission (CPSC) banned the use of lead-based paint, defined as paint containing 0.5% or 5,000 parts per million lead, in residential properties and on products intended for children, citing the toxicity of lead and the risk of lead poisoning.

These actions laid the groundwork for subsequent regulations and efforts to mitigate lead exposure and protect human beings. They reflected a growing awareness of lead’s health implications and a commitment to environmental and public health safety.

Is Lead Still a Health Hazard?

Lead is a naturally occurring element that has been linked to a range of serious health issues, from cognitive impairment and developmental delays in children to cardiovascular problems in adults. It is now understood that there is no safe level of lead exposure to lead for children. Regulatory agencies are tightening restrictions at every juncture on lead’s path from the mining phase to the disposal phase.

Given the abundance of evidence about lead’s toxicity, people are often surprised that lead is still used in various applications — including paint, batteries, shielding for radiation, and certain types of glass and ceramics. Residential paint can still contain up to 90 parts per million lead and “lead free” plumbing fixtures can contain small amounts of lead used to make brass. Efforts to minimize exposure reflect a balance between utilizing lead’s beneficial properties and mitigating its health risks.

The FACS webinar update on lead standards highlighted a staggering finding from a study conducted by Duke and Florida State University: As much as half of the US population born before 1996 may have had significant lead exposure, resulting in approximately 824 million lost IQ points. This underscores the critical need for rigorous standards and protections to mitigate lead exposure.

Changes to Lead Standards

Regulatory changes are not just bureaucratic whims but are informed by a deepening scientific consensus on the dangers of lead. Federal and state agencies are uniformly mobilizing to update and tighten lead-related regulations.

Among the most significant proposed changes are those by the EPA which aim to lower the clearance and hazard levels for lead on surfaces and redefine what constitutes lead-based paint.

The city of Oakland, for example, implemented rules mandating permits for projects disturbing paint in older homes and childcare facilities. This and other regulations highlight a localized response to a nationwide health concern.

The Occupational Lead Poisoning Prevention Program under the California Department of Public Health (CDPH) is in the process of updating Title 17 and will bring the federal renovation, repair, and painting rule into the standards of California law.

Information found in the FACS lead standard updates webinar outlines the trajectory of regulatory evolution, from recognizing lead as a hazard to implementing stricter measures aimed at reducing exposure. These changes underscore a commitment to public health, driven by a blend of scientific evidence and regulatory innovation.

What Should Employers Do to Meet Updated Lead Standards?

Cal/OSHA has updated their construction and general industry standards for lead, effective as of January 1, 2025. The sweeping updates to lead regulations present a complex challenge for employers, especially in the construction industry. These challenges are not merely administrative but involve a comprehensive overhaul of workplace practices to ensure the safety and health of employees.

Employers are tasked with instituting stringent hygiene practices, developing detailed lead compliance plans, and conducting regular medical surveillance, even for tasks that involve what was historically considered minimal lead exposure. The introduction of more accurate measurement analysis and the requirements for “trigger tasks” introduce additional layers of complexity and potential costs.

Furthermore, the nuanced nature of the new regulations demands a high level of vigilance from employers to stay compliant, particularly in understanding the categorization of tasks and the specific protective measures required for each level of exposure. Employers should not only adapt to these regulations but also proactively engage in training and data collection to preemptively address compliance requirements.

How Will the New Lead Standards Be Enforced?

The effectiveness of these regulatory updates hinges on robust enforcement mechanisms, and that raises concerns about compliance and oversight.

The uncertainty surrounding the enforcement of the new standard is palpable among employers, given the historical challenges associated with regulatory compliance in the construction sector. The potential for increased inspections and penalties for non-compliance add to the apprehension.

The webinar underscored the importance of employers gathering data and establishing a baseline for future assessments to navigate the uncertainties of enforcement. The anticipation of more stringent enforcement efforts by Cal/OSHA, possibly through the hiring of additional inspectors, reflects a broader commitment to safeguarding workplace health. This dual focus on compliance and enforcement embodies the evolving landscape of occupational safety amid the persistent challenge of lead exposure.

Occupational Lead Exposure and the Path Forward

The landscape of lead regulation is undergoing a pivotal transformation, driven by a confluence of scientific insight, public health advocacy, and regulatory focus. The updates to lead standards, while presenting formidable challenges for employers, underscore a collective endeavor to fortify worker safety and mitigate the health risks associated with lead exposure.

However, the journey does not end with the enactment of stricter regulations; it continues with diligent compliance, robust enforcement, and the unwavering commitment of all stakeholders to safeguard the well-being of workers and communities.

The lessons shared in the FACS lead standard updates webinar serve as both a blueprint and a call to action, emphasizing that the health impacts of lead exposure are preventable with informed, concerted efforts. Regulators are doing their part. It is incumbent upon employers to do theirs.

To speak with a FACS lead plan expert, call (888) 711-9998.

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Companies operating any mine (metal, non-metal or coal), quarries, sand, gravel, and other aggregate activities should know and apply the new requirements to remain in compliance with federal law.

Below is a summary of the major provisions in the final rule.

Key Changes under the New MSHA Silica Rule

Establishes a Uniform Permissible Exposure Limit and Action Level: The rule sets a uniform permissible exposure limit (PEL) for respirable crystalline silica at 50 micrograms per cubic meter of air (µg/m³) over an 8-hour time-weighted average shift (TWA). This aligns with the PEL required by the Occupational Safety and Health Administration (OSHA), which was published in March 2016.

Additionally, an action level (AL) of 25 µg/m³ calculated over an 8-hour TWA has also been established. The new PEL and AL apply to all three forms of respirable crystalline silica either alone or in any combination (i.e., quartz, cristobalite, and/or tridymite).

Requires Exposure Monitoring: Operators must commence sampling for any miner who is expected to be exposed to respirable crystalline silica. MSHA eliminated the use of objective or historical sample data to establish a baseline of silica exposure in the final rule. If initial samples are below the action level, additional sampling is still required within three months to confirm compliance.

Mine operators must also sample with equipment that is designed to conform to ISO 7708:1995(E) standard. Additionally, mine operators are required to use laboratories accredited to ISO/IEC 17025 to analyze samples for respirable crystalline silica using an analytical method specified by MSHA, OSHA or NIOSH.

Recordkeeping requirements: Records pertaining to sampling must be posted on mine bulletin boards and by electronic means (if applicable) for 31 days upon receipt. The records must include the sample date, occupations sampled, and concentrations of respirable crystalline silica found.

Additionally, all evaluations, sampling and corrective action records need to be stored for at least five years under the new rule.

Mandates Immediate Reporting and Corrective Action: Mine operators must immediately report any overexposure to RCS and take steps to reduce the concentration of respirable crystalline silica to below the PEL.

The mine operator must make approved respirators available to affected workers before the start of the next work shift and ensure the respirators are worn for the full shift or during the period of overexposure until miner exposures are at or below the PEL.

Corrective actions must be taken immediately to lower the concentration of RCS to at or below the PEL. If the sample exceeds the action level (AL), but is below the PEL, the operator can continue to operate, but must resample within three months. If the initial sample is below the AL the operator must sample again, at least seven days after and within three months to confirm compliance. This periodic sampling must continue until two successive samples demonstrate silica levels below the action level.

Requires Periodic Evaluations: Qualitative evaluations must be repeated at least every six months or whenever there is a change in production; processes; installation and maintenance of engineering controls; installation and maintenance of equipment; administrative controls; or geological conditions.

Engineering and Administrative Controls: Mine operators must implement feasible engineering controls as the primary method for controlling respirable crystalline silica. Administrative controls may be used as supplementary measures when necessary. The MSHA rule makes it clear compliance by engineering controls is preferred over administrative controls. Additionally, the final rule explicitly forbids the rotation of miners as an acceptable administrative control.

Respiratory Protection: The final rule incorporates the respirator standard of ASTM F3387-19 for all airborne contaminant standards. This standard applies to the selection, fit, use, and maintenance of approved respirators. Affected miners shall be provided with a suitable NIOSH-approved atmosphere-supplying respirator or NIOSH- approved air-purifying respirator equipped with particulate protection classified as 100 series under 42 CFR part 84 or particulate protection classified as High Efficiency ‘‘HE’’ under 42 CFR part 84. N95’s are no longer an option. Additionally, mine operators must have a written respiratory protection program in line with the standard.

The final rule does not allow the use of respiratory protection for compliance although it does acknowledge that respiratory protection protects miners from silica, therefore allowing the use of respiratory protection while engineering controls are developed and implemented if respiratory protection is necessary by the nature of the work.

Medical Surveillance Requirements: The final rule includes a provision for metal and non metal operators to provide regular medical examinations to all miners at no cost. The medical surveillance programs are designed to be similar to those already required for coal miners under the existing standard. The medical surveillance requirements are intended to improve early detection of respiratory illnesses, including diseases related to respirable crystalline silica.

The new requirements became effective on June 17, 2024. Coal mine operators must comply within 12 months of the publication date. Metal and Non-Metal operators have 24 months to comply, allowing them additional time to meet the new standards while addressing the urgent need to protect miners’ health.

This comprehensive update to the MSHA’s silica rule aims to significantly reduce the health risks associated with respirable crystalline silica exposure in the mining industry. In a press release announcing the rule, MSHA emphasized the hazards associated with the inhalation of respirable crystalline silica and concluded that the rule change will result in over 1,000 avoided deaths and almost 4,000 avoided cases of silica-related illnesses.

The respirable crystalline silica final rule is now in effect and operators can begin early sampling today. For help complying with the new regulations contact FACS by telephone at 888-711-9998 or use our contact form.

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