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Solving the Chemical Hazard Puzzle

Chemical exposures in construction are responsible for many more deaths than physical hazards. Yet chemical hazards do not get nearly as much attention – likely because the links are harder to prove and because they tend to kill much more slowly.

It’s been over 50 years since Dr. Irving Selikoff uncovered the deadly toll of asbestos exposures on construction and shipyard workers. Yet even today, thousands of workers die each year from past asbestos exposure. And the problem doesn’t stop there. Of the thousands of chemicals on the market today, many are known to be toxic and very few have mandated exposure limits.

OSHA’s permissible exposure limits (PELs) are over 40 years old and even OSHA says they are not protective enough. The agency has tried to update these limits, but the regulatory process is so lengthy and convoluted that little progress has been made.

Frustrated by the lack of progress, OSHA published a list of their exposure limits alongside recommended limits from NIOSH, the American Conference of Government Industrial Hygienists (ACGIH) and Cal-OSHA. The goal was to encourage companies to adopt the recommended limits, which are much more protective. The agency also created a website that shows contractors how to choose safer chemicals.

In the fall of 2014, OSHA issued a request for information (RFI) to officially ask for input on strategies to solve this regulatory puzzle. Over the last year, the LHSFNA chaired a safety and health committee as part of the North American Building Trades Unions (NABTU) to develop suggestions to find a way forward.

This fall, the NABTU submitted those comments, which recommend that OSHA examine the following solutions, any of which would be a great improvement on the current situation.

  • Focus on task-based exposure limits, which are more practical than PELs. The varying nature of construction means exposures change constantly, making PELs less useful since they measure average exposure over an eight-hour day. PELs are also problematic in construction because so few exposures are to single substances; most exposures are “mixed exposures.” An increased emphasis on task-based exposure limits addresses both of these issues.
  • Explore the concept of control banding, which sets limits for a class of chemicals. This method has proven successful in the British system, Control of Substances Hazardous to Health (COSHH). In the U.S., sheet metal workers are using a similar approach to address welding hazards, which can vary depending on the base metal, welding rod, type of welding, etc.
  • Model future regulation on the American National Standards Institute’s (ANSI) chemical hazard standard, ANSI/ASSE A10.49 Control of Chemical Health Hazards in Construction and Demolition Operations. Developed with significant LHSFNA input, this standard assesses hazards based on their toxicity and exposure potential, then uses these assessments to develop chemical hazard control plans.
  • Continue to develop comprehensive standards for chemicals where exposures are significant and risks are high. This could be achieved through a standing advisory committee such as the one used in California.

OSHA will review these and other comments over the coming year and decide on a course of action. Feedback from the NABTU will hopefully steer the agency in the right direction, toward a system that more effectively protects construction workers from exposures to hazardous chemicals.

[Scott Schneider is the LHSFNA’s Director of Occupational Safety and Health.]

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